Below the jump is a 'Petition For Review (PFR) to the Growth Management Hearings Board concerning the ramifications and processes of the Alaskan Way Viaduct.
The jurisdiction of this PFR extends the envelope of practice before the board, consistent with the law and appropriate to the circumstances. These circumstances include the alleged victimization of the petitioner by King County, its Courts and officers (public and private) and the State of Washington as an inappropriate growth management practice. As such, State Courts massive jurisdictional problems over the matters at hand.
Please note that petitioners academic, civic, and professional experience in these subjects is substantial, likely in a preponderance of measures exceeding that of Board members in depth and seniority. Board members Paegler and Earling have direct familiarity with this history and petitioner in fact ‘trained’ them in some regards during the professional emergence of Growth Management.
Lastly please note that there are substantive and procedural matters regarding this case that must remain confidential to the Board and Respondents.
BEFORE THE CENTRAL GROWTH MANAGEMENT HEARINGS BOARD
STATE OF WASHINGTON
Douglas L. Tooley,
Petitioner, Case No. ________________
v.
Christine Gregoire, Governor of Washington State
Richard Conlin, Seattle Council President
Mike McGinn, Seattle Mayor, PETITION FOR REVIEW
Respondents.
I. PETITIONER
Douglas L. Tooley
766 Alpine Forest Drive
Bayfield, CO 81122
doug@motleytools.com (preferred contact)
970 672 0052
II. THE CHALLENGED ACTION
Alaskan Way Viaduct Replacement SEIS-Final
Appears Challenge filed in Advance of Publication
III. DETAILED STATEMENT OF THE ISSUES
1. Does the Alaskan Way Viaduct Replacement Plan amount to, or require an amendment of, the Comprehensive Plans of the City of Seattle and King County or any sub-area?
2. Do the modifications to standard project procedure rise to the level of Growth Management Act significance?
3. Did the State and City adoption of the Alaskan Way Final EIS fail to comply with the requirements of RCW 36.70A.020 because of court interference, obstruction, harassment, and bullying with citizen participation?
4. To what degree did the State and City adoption of the Alaskan Way Final EIS abuse the requirements of RCW 36.70A.090 regarding innovation in developing new legal practices of citizen interference, obstruction, harassment and bullying?
5. Does the coordination required by 36.70A.100 amount to civil or criminal conspiracy in this project and related actions?
6. Pursuant to 36.70A.103 has the State of Washington been involved or led this conspiracy in legal practice?
7. Do these legal practices invalidate the Comprehensive Plans of Seattle and King County as well as any resultant contracts, pursuant to 36.70A.140?
IV. STANDING
Participation Standing based on comments published 2/15/2011 at Motleytools.com/Blog and sent via certified mail on 2/19/2011, #7008 1830 0002 7822 5496
V. ESTIMATED TIME REQUIRED FOR HEARING ON THE MERITS
Unknown
VI. RELIEF SOUGHT
Petitioner requests that the Board rule the challenged action to be noncompliant
with the GMA and remand the challenged action to the jurisdiction to take the necessary legislative actions for it to be compliant with the GMA.
The Petitioner has read the Petition for Review and believe the contents to be true.
Dated this 22nd day of February, 2011.
___________________________________
Douglas L. Tooley
