Motion for Extension Until 800114 to File Brief Amicus Curiae Re Whether Indian Tribes Status Gives Sufficient Cause for Late Intervention.Nrc Does Not Object to Such Extension.Affidavit & Certificate of Svc Encl| ML19296C880 |
| Person / Time |
|---|
| Site: |
Skagit |
|---|
| Issue date: |
02/15/1980 |
|---|
| From: |
Oconnell C
INTERIOR, DEPT. OF |
|---|
| To: |
NRC COMMISSION (OCM) |
|---|
| References |
|---|
| NUDOCS 8002290016 |
| Download: ML19296C880 (4) |
|
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|---|
Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20082F7881983-11-23023 November 1983
Withdrawal of OL Application.Certificate of Svc Encl
ML20082F7771983-11-23023 November 1983
Motion for Order Approving Encl Withdrawal of Application & Terminating Proceeding
ML20080L9431983-09-28028 September 1983
Second Request for Addl Extension Until 840115 to Answer Intervenor Motion for Summary Disposition of Contention 1. Portland General Electric Co Expects to Decide on Plant Termination by End of 1983.Certificate of Svc Encl
ML20080G0731983-09-13013 September 1983
Request for Extension Until 831014 to Answer Intervenor Motion for Summary Disposition of Contention 1.Motion May Be Moot If Other Owners Concur W/Util Decision to Terminate Proceeding.Certificate of Svc Encl
ML20071Q7201983-06-0303 June 1983
Response Opposing Applicant 830525 Request for Extension Until 830930 to Answer Motion for Summary Disposition of Contention 1.No Good Cause Demonstrated.Certificate of Svc Encl
ML20071M0781983-05-25025 May 1983
Request for Extension Until 830930 to Answer NRDC Motion for Summary Disposition of Contention 1.Time Needed to Consider Implications of Final Northwest Conservation Electric Power Plan & Licensing Alternatives.Certificates of Svc Encl
ML20023C4571983-05-12012 May 1983
Memorandum of Points & Authorities Supporting Intervenor Motion for Summary Disposition Since Contention 1 No Longer Controversial Issue.Certificate of Svc Encl
ML20023C3741983-05-12012 May 1983
Statement of Matl Facts as to Which There Is No Genuine Issue Re Contention 1
ML20023C3691983-05-12012 May 1983
Motion for Summary Disposition of Contention 1 Re Calculation of Demand for Electrical Energy Negating Need for Plant.No Genuine Issue of Matl Fact Exists
ML20023C6971983-05-12012 May 1983
Affidavit of DB Goldstein Supporting NRDC Motion for Summary Disposition of Contention 1 Re Need for Power.Four Forecasts for Energy Needs Refute Need for Power Justification Developed by Util.Prof Qualifications Encl
ML20064N6681983-02-10010 February 1983
Motion to Suspend Health & Safety Prehearing Schedule Pending Adoption of Final Regional Energy Plan or Until Conclusion of Evidentiary Hearings on Need for Power. Applicant Appears Ready to Absorb Facility Costs
ML20071A6671983-02-10010 February 1983
Certifies Svc of Intervenor Motion to Suspend Safety & Health Schedule on 830210
ML20070T0661983-02-0404 February 1983
Motion for Order Suspending Health & Safety Prehearing Schedule,Pending Adoption of Final Regional Power Plan & Further Order of Aslb.Suspension Would Be in Best Interest of All Concerned.W/Certificate of Svc
ML20083N8101983-01-31031 January 1983
New Contentions Based on New Info in SER Suppl.Certificate of Svc Encl
ML20083N1991983-01-26026 January 1983
Notice of Appeal & Exceptions to ASLB 830118 Memorandum & Order.Memorandum & Order Fails to Recognize Yakima Indian Nation Sovereignty & Treaty Rights Which Are Supreme Law of Land.Affidavit of Svc Encl
ML20028F1831983-01-25025 January 1983
Notification of Intent to File New Contentions Based on New Info in SER Suppl.Certificate of Svc Encl
ML20028E9701983-01-19019 January 1983
Reply to NRC & Applicant Response to Natl Wildlife Federation/Or Environ Council,Columbia River Inter-Tribal Fish Commission & Coalition for Safe Power 821213 Motion to Clarify & Amend Certain Contentions.W/Certificate of Svc
ML20072A6731983-01-18018 January 1983
Motion for Extension of Time Until 830210 to File Answer to Natl Wildlife Federation/Or Environ Council 830105 Motion to Compel Discovery.Parties Attempting to Settle Matter by Informal Agreement.Certificate of Svc Encl
ML20028C9581983-01-0505 January 1983
Memorandum Supporting Natl Wildlife Federation/Or Environ Council 830105 Motion to Compel Discovery.Applicants Misinterpreted 10CFR2.740(b)(1) Relevancy Std.Discovery Requests Are Relevant.W/Certificate of Svc
ML20028C9501983-01-0505 January 1983
Motion to Compel Applicants to Respond in Full to Natl Wildlife Federation/Or Environ Council 821201 Interrogatories & Request for Production of Documents
ML20028C3221983-01-0303 January 1983
Suppl to DOE 821126 Limited Appearance Statement.Doe Position Is That Hanford Site Is Not Open,Unclaimed Land as Defined in 1855 Treaty W/Yakima Indian Nation,Article Iii. ASLB Is Wrong Forum for Resolving Issue
ML20070L5411982-12-27027 December 1982
Answer Opposing Yakima Indian Nation 821210 Motion for Reconsideration of ASLB 821029 Memorandum & Order Re Suppl to Petition to Intervene.Aslb Rejection of Contentions 7,8 & 9 Well Founded
ML20070L4901982-12-27027 December 1982
Affidavit of Mv Stimac Supporting Applicant Answer to Yakima Indian Nation Motion for Reconsideration.Describes Plant Site & Location of Casements.Certificate of Svc Encl
ML20079J6021982-12-23023 December 1982
Response Supporting Intervenor 821213 Motion to Clarify & Amend Contentions 7 & 8.Quantification of Environ Impacts Not Practicable Due to Subjective Nature.Certificate of Svc Encl
ML20023B3081982-12-20020 December 1982
Response to 821201 Discovery Requests.Certificate of Svc Encl
ML20079H3711982-12-13013 December 1982
Motion to Clarify & Amend Contentions 7 & 8.Contentions Should Be Reorganized to Facilitate Coordinated Evidentiary Presentations for Environ Matters ASLB Set Out as Contentions 4,7 & 8.Certificate of Svc Encl
ML20070D1181982-12-10010 December 1982
Affidavit of R Jim Supporting Yakima Indian Nation Brief on Admissibility of Nation Reworded Proposed Contention 10 & Motion for Reconsideration.Nation Has Right to Pasture Horses & Gather Roots Even Though Us Holds Title to Land
ML20070C9121982-12-10010 December 1982
Notice of Counsel New Law Firm Affiliation,As of 820901
ML20070C8181982-12-10010 December 1982
Motion for Reconsideration of ASLB 821029 Memorandum & Order Re Yakima Indian Nation Contentions 7,8 & 9.Nation Right to Enjoy Reservation Peacefully Given by 1855 Treaty Should Be Protected by ASLB
ML20070C7981982-12-10010 December 1982
Brief Supporting Admissibility of Yakima Indian Nation Reworded Proposed Contention 10.Attempt to Terminate Reserved Rights of Yakima Indian Nation Violates Fifth Amend.Land Cannot Be Taken by Inverse Condemnation
ML20070C7691982-12-10010 December 1982
Certifies Svc of Brief on Admissibility of Reworded Proposed Contention 10,motion for Reconsideration of ASLB 821029 Memorandum & Order,R Jim Affidavit & Notice of Counsel Law Firm Change on 821210
ML20028B9251982-12-0101 December 1982
Brief Re Admissibility of Yaking Indian Nation Proposed Contention 10.Clarification Needed on Procedural Rule of Commission & Scope of Contention.Certificate of Svc Encl
ML20028B8971982-12-0101 December 1982
Request for Production of Documents & Interrogatories,Per 10CFR2.740(b) & 10CFR2.741.Certificate of Svc Encl.Related Correspondence
ML20028B2631982-11-26026 November 1982
Limited Appearance Statement.Hanford Site Is Not Part of Yakima Indian Nation Reservation Established by 1855 Treaty. Indian Privilege of Hunting,Gathering Roots & Berries & Grazing Animals Does Not Extend to Hanford Site
ML20066K9761982-11-22022 November 1982
Motion to Alter Lead Party Designation Established for Contention 3 in ASLB 821102 Memorandum & Order.All Intervenors Concur That NRDC Should Be Designated Lead Party,Since NRDC Demonstrated Greatest Expertise on Issue
ML20066L0101982-11-22022 November 1982
Motion to Amend Accepted Contention 3.Proposed Amends Would Conform Contention 3 to Earlier Admitted NRDC Contention on Which Contention 3 Is Partially Based.Certificate of Svc Encl
ML20023A8301982-10-15015 October 1982
Response to 820910 First Set of Production Requests. Certificate of Svc Encl.Related Correspondence
ML20023A8141982-10-14014 October 1982
Response to Yakima Indian Nation 820930 Suppl to Petition to Intervene,Containing List of Contentions.Objects to Contentions 4-10.Certificate of Svc Encl
ML20027C1591982-10-0606 October 1982
Response to 820917 First Set of Interrogatories
ML20063P4011982-10-0606 October 1982
Response to Columbia River Inter-Tribal Fish Commission 820923 Notice of Appeal of ASLB 820903 Memorandum & Order Denying Intervention.Applicants Will Not Oppose Appeal in Order to Maintain Schedule for Proceeding
ML20071N3791982-10-0404 October 1982
Response to First Set of Interrogatories.Certificate of Svc Encl
ML20065H5481982-09-29029 September 1982
Applicant Response to Coalition for Safe Power 820910 First Set of Interrogatories.Certificate of Svc Encl.Related Correspondence
ML20065H5451982-09-29029 September 1982
Supplement to Petition to Intervene,Consisting of Contentions & Bases for Contentions
ML20065J1601982-09-28028 September 1982
Responds to Util 820917 First Set of Interrogatories. Certificate of Svc Encl.Related Correspondence
ML20069F9491982-09-23023 September 1982
Notice of Appeal of ASLB 820908 Memorandum & Order Denying 820505 Petition to Intervene.Supporting Brief Encl
ML20069F9541982-09-23023 September 1982
Memorandum Supporting Appeal of ASLB 820908 Memorandum & Order Denying 820505 Petition to Intervene or Alternatively, to Remand Petition to ASLB for Further Clarification on Question of Standing.Certificate of Svc & Exhibit Encl
ML20137F8001982-09-17017 September 1982
Amended Subagreement 2 Between State of Wa Energy Facility Site Evaluation Council & NRC Re Protocol for Conduct of Joint Hearings on Facility Project
ML20027B5661982-09-17017 September 1982
Response to First Set of Interrogatories.Certificate of Svc Encl
ML20027B5631982-09-17017 September 1982
First Set of Interrogatories
ML20027B5571982-09-15015 September 1982
Motion for Extension of Time Until 821004 to Respond to Applicant Interrogatories.Counsel Was Unavailable When Interrogatories Arrived. Certificate of Svc Encl
1983-09-28
[Table view]
Category:PLEADINGS
MONTHYEARML20082F7771983-11-23023 November 1983
Motion for Order Approving Encl Withdrawal of Application & Terminating Proceeding
ML20080L9431983-09-28028 September 1983
Second Request for Addl Extension Until 840115 to Answer Intervenor Motion for Summary Disposition of Contention 1. Portland General Electric Co Expects to Decide on Plant Termination by End of 1983.Certificate of Svc Encl
ML20080G0731983-09-13013 September 1983
Request for Extension Until 831014 to Answer Intervenor Motion for Summary Disposition of Contention 1.Motion May Be Moot If Other Owners Concur W/Util Decision to Terminate Proceeding.Certificate of Svc Encl
ML20071Q7201983-06-0303 June 1983
Response Opposing Applicant 830525 Request for Extension Until 830930 to Answer Motion for Summary Disposition of Contention 1.No Good Cause Demonstrated.Certificate of Svc Encl
ML20071M0781983-05-25025 May 1983
Request for Extension Until 830930 to Answer NRDC Motion for Summary Disposition of Contention 1.Time Needed to Consider Implications of Final Northwest Conservation Electric Power Plan & Licensing Alternatives.Certificates of Svc Encl
ML20023C4571983-05-12012 May 1983
Memorandum of Points & Authorities Supporting Intervenor Motion for Summary Disposition Since Contention 1 No Longer Controversial Issue.Certificate of Svc Encl
ML20023C3741983-05-12012 May 1983
Statement of Matl Facts as to Which There Is No Genuine Issue Re Contention 1
ML20023C3691983-05-12012 May 1983
Motion for Summary Disposition of Contention 1 Re Calculation of Demand for Electrical Energy Negating Need for Plant.No Genuine Issue of Matl Fact Exists
ML20064N6681983-02-10010 February 1983
Motion to Suspend Health & Safety Prehearing Schedule Pending Adoption of Final Regional Energy Plan or Until Conclusion of Evidentiary Hearings on Need for Power. Applicant Appears Ready to Absorb Facility Costs
ML20070T0661983-02-0404 February 1983
Motion for Order Suspending Health & Safety Prehearing Schedule,Pending Adoption of Final Regional Power Plan & Further Order of Aslb.Suspension Would Be in Best Interest of All Concerned.W/Certificate of Svc
ML20083N1991983-01-26026 January 1983
Notice of Appeal & Exceptions to ASLB 830118 Memorandum & Order.Memorandum & Order Fails to Recognize Yakima Indian Nation Sovereignty & Treaty Rights Which Are Supreme Law of Land.Affidavit of Svc Encl
ML20072A6731983-01-18018 January 1983
Motion for Extension of Time Until 830210 to File Answer to Natl Wildlife Federation/Or Environ Council 830105 Motion to Compel Discovery.Parties Attempting to Settle Matter by Informal Agreement.Certificate of Svc Encl
ML20028C9581983-01-0505 January 1983
Memorandum Supporting Natl Wildlife Federation/Or Environ Council 830105 Motion to Compel Discovery.Applicants Misinterpreted 10CFR2.740(b)(1) Relevancy Std.Discovery Requests Are Relevant.W/Certificate of Svc
ML20028C9501983-01-0505 January 1983
Motion to Compel Applicants to Respond in Full to Natl Wildlife Federation/Or Environ Council 821201 Interrogatories & Request for Production of Documents
ML20070L5411982-12-27027 December 1982
Answer Opposing Yakima Indian Nation 821210 Motion for Reconsideration of ASLB 821029 Memorandum & Order Re Suppl to Petition to Intervene.Aslb Rejection of Contentions 7,8 & 9 Well Founded
ML20066L0101982-11-22022 November 1982
Motion to Amend Accepted Contention 3.Proposed Amends Would Conform Contention 3 to Earlier Admitted NRDC Contention on Which Contention 3 Is Partially Based.Certificate of Svc Encl
ML20066K9761982-11-22022 November 1982
Motion to Alter Lead Party Designation Established for Contention 3 in ASLB 821102 Memorandum & Order.All Intervenors Concur That NRDC Should Be Designated Lead Party,Since NRDC Demonstrated Greatest Expertise on Issue
ML20063P4011982-10-0606 October 1982
Response to Columbia River Inter-Tribal Fish Commission 820923 Notice of Appeal of ASLB 820903 Memorandum & Order Denying Intervention.Applicants Will Not Oppose Appeal in Order to Maintain Schedule for Proceeding
ML20069F9541982-09-23023 September 1982
Memorandum Supporting Appeal of ASLB 820908 Memorandum & Order Denying 820505 Petition to Intervene or Alternatively, to Remand Petition to ASLB for Further Clarification on Question of Standing.Certificate of Svc & Exhibit Encl
ML20027B5571982-09-15015 September 1982
Motion for Extension of Time Until 821004 to Respond to Applicant Interrogatories.Counsel Was Unavailable When Interrogatories Arrived. Certificate of Svc Encl
ML20063M6211982-09-10010 September 1982
Motion for Extension of Time Until 820923 to File Responses to Applicant First Set of Interrogatories.Staff Will Be Absent from Ofc 820911-23.Certificate of Svc Encl.Related Correspondence
ML20063M2351982-09-0101 September 1982
Statement of Matl Fact as to Which There Is No Genuine Issue on Coalition for Safe Power Contention 26
ML20063M2291982-09-0101 September 1982
Motion for Summary Disposition of Coalition for Safe Power Contention 26.No Genuine Issue of Matl Fact Exists.Basis for Contention Was PSAR Section 3.10 Which Has Subsequently Been Amended.Related Correspondence
ML20063A5051982-08-19019 August 1982
Motion for Leave to Reply to Applicant 820730 Response Opposing Columbia River Inter-Tribal Fish Commission 820716 Motion for Admission of Second Suppl to Petition to Intervene.Question of Standing Raised.W/Certificate of Svc
ML20062D5201982-08-0505 August 1982
Response to Columbia River Inter-Tribal Fish Commission 820716 Motion for Admission of Second Suppl to Petition to Intervene.Good Cause Shown for Contention 4.Other Factors Favor Admission of Contention 5.W/Certificate of Svc
ML20058D5401982-07-21021 July 1982
Memorandum Supporting Appeal of ASLB 820706 Memorandum & Order.Contentions 3E & 5 Should Be Accepted as Litigatable Issues.Certificate of Svc Encl
ML20063H1141982-07-16016 July 1982
Motion for Admission of Second Suppl to Petition to Intervene
ML20053D0651982-05-27027 May 1982
Motion for Extension of Time Until 820611 to Answer Coalition for Safe Power 820527 Amended Contentions. Washington co-counsel Has Not Received Contention & Document Is Lengthy.Certificate of Svc Encl
ML20052D0561982-04-28028 April 1982
Response Opposing Deposition of MT Dana.Discovery Premature & Does Not Relate to Matters in Controversy.Reasonable Notice Not Given & Allowing Deposition Would Amount to Harassment.W/Certificate of Svc.Related Correspondence
ML20054E1511982-04-20020 April 1982
Motion for Extension of Time for Filing Addl Contentions Since Portions of PSAR & Amend 5 to Application for Site Certificate/Environ Rept Received on 820416,4 Days Before Contentions Due
ML20005B7061981-08-18018 August 1981
Motion,In Ltr Form,For Order That All Parties Fully Serve All Documents on Coalition for Safe Power & Forelaws on Board,Pending Renoticing & Rulings on Petitions to Intervene.Impractical to Gain Access to Documents at Lpdr
ML19332A8871980-09-11011 September 1980
Statement Suggesting That Full Commission Review of Orders & Opinions Below Not Necessary Due to Mootness.Aslb 800827 Order Indicates Proceeding Has Terminated
ML19321A6291980-07-16016 July 1980
Motion for Order Evidencing Current Status & Setting Schedule for Further Proceeding.Amend to Application Will Be Filed by 800930.Anticipated Schedule for Environ Rept & PSAR Amends May Be Filed on Same Date.W/Draft Order & Release
ML19323J2211980-06-0404 June 1980
Reply Withdrawing 800508 Motion to Dismiss Application. Applicant Response to Motion & Mecca Affidavit Provided Detailed Info Re Applicant 800414 Rept.Progress Rept Must Be Filed by 800601 by Applicant.Certificate of Svc Encl
ML19312E9291980-05-23023 May 1980
Reply in Opposition to Skagitonians Concerned About Nuclear Power 800508 Motion to Dismiss Application W/Prejudice Due to Lack of Diligent Pursuit.Applicants Are Engaged in Extensive Program to Locate Suitable Site
ML19310A2181980-05-0808 May 1980
Motion to Dismiss Application W/Prejudice.Applicants Took No Steps to Pursue Application Despite Opportunity Given at 800122 Conference to Address Pending Geology & Seismology Issues.Certificate of Svc Encl
ML19323A9731980-04-17017 April 1980
Pleading in Lieu of Brief Amicus Curiae Re Untimely Petition of Three Indian Tribes.Urges Admittance of Tribes as Full Parties Except for Fully Addressed Issues Where Serious Gaps in Existing Record Must Be Shown.Certificate of Svc Encl
ML19296D5061980-02-22022 February 1980
Response in Opposition to Doi 800215 Motion for Extension Until 800414 to File Brief Amicus Curiae.Motion Filed at Last Day of Permitted Period.Certificate of Svc Encl
ML19296C8801980-02-15015 February 1980
Motion for Extension Until 800114 to File Brief Amicus Curiae Re Whether Indian Tribes Status Gives Sufficient Cause for Late Intervention.Nrc Does Not Object to Such Extension.Affidavit & Certificate of Svc Encl
ML19296B1471980-02-0101 February 1980
Answer in Opposition to Skagitonians Against Nuclear Power 800122 Motion to Compel Responses to Interrogatories.Motion Untimely & Questions Re Seismic Profile Outside Scope of Proceedings.Certificate of Svc Encl
ML19260D5181980-01-21021 January 1980
Motion in Opposition to NRC 791102 Motion to Postpone Hearings on Geology & Seismology Issues.Proposed Evidence Twice Rejected as Inconclusive.Applicants Have Failed to Carry Burden of Proof Re Issues.W/Certificate of Svc
ML19262C3001980-01-18018 January 1980
Motion to Compel Applicant Answers to Skagitonians Concerned About Nuclear Power Interrogatories Re San Juan Islands Seismic Profiles.Interpretation of Atomic Energy Act Holds Applicant Liable for Matl False Statements
ML19257A3971979-12-12012 December 1979
Objection to Intervenor Skagitonians Concerned About Nuclear Power Interrogatories Re Seismic Profiles of San Juan Islands.Western Geophysical Seismic Profiles Not Discovered by Util Until 1979.No False Statements Made
ML19256F8401979-12-0505 December 1979
Reply to Skagitonians Concerned About Nuclear Power 791109 Proposed Findings on Financial Qualifications.Intervenor Adopted short-term View Rather than long-term Considerations Re Inflation Rates & Market Ratios.Certificate of Svc Encl
ML19211A1121979-11-30030 November 1979
Reply to Skagitonians Concerned About Nuclear Power 791112 Proposed Findings of Fact.Fes & Fes Final Suppl Addressed Environ Impacts & Whole Population Issues Indiscriminately Certificate of Svc Encl
ML19211A1071979-11-30030 November 1979
Reply to NRC 791005 Proposed Findings of Fact.Urges Board to Reject Recommendation 3 Contained in Finding 44,Pages 27-28. Condition Re Environ Evaluation Prior to Commencement of Const Activities Is Not Authorized by NEPA & NRC Rules
ML19211A0881979-11-30030 November 1979
Reply in Opposition to Intervenor Forelaws on Board/Citizens for Safe Power Findings of Fact Re Alternative Sites & Postulated Accidents.Certificate of Svc Encl
ML19262A7481979-11-20020 November 1979
Response in Opposition to Indian Tribes 791105 Supplemental Petition for ALAB-552 & ALAB-559 Review.Petitioner Failed to Raise Good Cause Re Alleged ASLB Misapplication of Late Intervention Factor.Certificate of Svc Encl
ML19291B8911979-11-0909 November 1979
Pleading Re Applicants' Financial Qualifications.Total Cost of Project Exceeds Applicants' Figures.Certificate of Svc Encl
ML19260B1681979-11-0808 November 1979
Response in Opposition to Skagitonions Concerned About Nuclear Power 791116 Motion to Direct Certification,Stay Proceedings & Review ASLB Actions.Detriment to Public Interest as Basis for Interlocutory Review Not Established
1983-09-28
[Table view] |
Text
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3 t@oc p 'Ej
@ g 3 UNITED STATES OF A! ERICA , e
!RICLEAR REGULATORY C0}ciISSION cy s IN THE MATTER OF PUGET SOUND POWER 6 ) DOCKET NOS.
LIGHT COMPANY , ET AL. , ) STN 50-522
) STN 50-523 SECRETARY OF THE INTERIOR MOTION FOR EXTENSION OF TIME TO FILE BRIEF AMICUS CURIAE By letter dated January 22, 1980, and Order, dated January 16, 1980, this Commission invited the Secretary of the Interior to file a brief amicus curiae addressing the question; Whether petitioner's [ Upper Skagit, Sauk-Suiattle, and Swinomish Tribes] status (Anerican Indian Tribes),
separate f rom or in conjunction with the particular other facts and circumstances of and surrounding this case, gives rise to sufficient cause to excuse the extraordinary tardiness of the filing of the Tribes' petition to intervene.
While the Secretary is anxious to express his views to this Conmission concerning that issue, nore pressing business necessitates a request for an extension of 60 days to file such a brief.
8000200
(.'
_2_
THEREFORE, the Secretary respectfully requests an extension to April 14, 1980, to file a brief amicus curiae.
Commission staff has no objection to such an extension.
Respec fully,
-),
,- C~ / C Charles E. O'Connell, Jr.
&n Attorney for the Secretary of the Interior February 15, 1980
. .w VERIFICATION (DISTRICT OF COLUMBIA) ss:
Charles E. O'Connell, Jr. , being first duly sworn, states that he is the attorney for the Secretary of the Interior; that he is authorized to execute the foregoing document; that he has read same and is familiar with the contents thereof; and that cil allegations and f acts conta!.ned therein are true and correct to the best of his knowledge, information, and belief.
Subscribed and sworn to before me this / day of [ IJ m Mfg, 1980.
- /
2daLn $dww ti6ta'ry Public
' /( -
/
My C - ission expires b J/ /9A3 - -
. As CERTIFICATE OF SERVICE I hereby certify that I have this day served the foregoing document upon each party listed below.
Russell W. Busch, Esq.
Evergreen Legal Service 5308 Ballard Ave. , N.W.
Seattle, WA 98127 Donald S. Means P.O. Box 277 q1; f ,.
La Conner, WA 98257 / /
/
^
O T.F. Thomsen, Esq. g , .9 Puget Sound Power & Light Co. fj 2
, Te ~ -[ [4 #
"dg 4 'Q 1900 Washington Building Seattle, WA 98273 t, t-g Q 'C.~ep'i-fSj f: ,
y s v. 'y 'g,>b jN' Skagitonians Against Nuclear Power
6fh V f
,c x'
Roger Leed, Esq.
1411 4th Avenue Building
\ 'I q.,1\
Suite 610 Seattle, WA 98101 Nuclear Regulatory Commission Of fice of Executive Legal Director Attn: Stewart A. Treby, Esq.
Washington, D.C. 20555 l .'
c.
Charles E. O'Connell, Jr}
, l5 h
/ D6te
.