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From: Scott Bender [scott@benderllc.com]
Sent: Thursday, March 03, 2011 4:22 PM
To: David W. Johnson, VMorrisCS@aol.com
Cc: Garth M@statesmancorporation.corn ; tmcdonald@cascadialaw.com; Craig Peck
Subject: RE: Black Point comments
Attachments: Porto 3-3-11 Comment responce.pdf
Hi David,
I prepared the attached memo responding to Susan's comments. Please let me know if you have
additional questions. Thanks, Scott
From: David W. Johnson[ma iIto: dwjohnson@co.jefferson.wa.us]
Sent: Wednesday, February 23, 2011 7:42 AM
To: VMorrisCS@aol.com; scoff@benderllc.com
Subject: FW: Black Point comments
2"' round of comments from Susan Porto,
From: Susan Porto
Sent: Tuesday, February 22, 20114:35 PM
To: David W. Johnson
Subject: Black Point comments
MEMORANDUM
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To: Garth Mann, Tom McDonald, David Wayne I',MB I S4
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CC: Vicki Morris, Craig Peck
Date: March 3, 2011
RE: RESPONSE TO CLARRIFICASTION COMMENTS BY MS. SUSAN
PORTO, JEFFERSON COUNTY PUBLIC HEALTH
On February 23, 2011 we received a request for clarification from Ms. Susan Porto of the
Jefferson County Department of Health in an email from David Wayne Johnson. The
clarification comments were a follow up to our December 10, 2010 comment response memo
to Ms. Porto's comments on the Neighborhood Water Supply Program and Pleasant Harbor
Monitoring Program. To maintain context, I provide the original comment responses, Ms.
Porto's comments, and our response as follows:
Pleasant Harbor Golf and Marina Neighborhood Water Supply Program
1. Monitoring Plan
c) Water quality samples were collected during pumping of the American
Campground well during the pumping test, and from MW -2. The analysis reports
are provided in the SDEIS and are available upon request.
Susan Porto February 2011 Comment: Your statements in this regard were "The
existing well has supplied water at similar to proposed rates with no adverse impacts
(chlorides = zero)." I don't understand how a pump test can be equated to "similar
rates" that are proposed by this project.
Scott Bender Response: The pumping test was performed at a rate of 65 gpm. The
resort demand estimate was 110 gpm or about 55 gpm for each of the wells (an
additional well will be constructed for the resort). Based on our calculations, the
drawdown during the pumping test was probably similar to that of long-term pumping
of the well during resort operations. The sample results demonstrate that there is high
quality water available under the expected drawdown conditions in the well. The
monitoring program will be performed to evaluate the effects, if any, of long-term
pumping.
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Memorandum to Mr. Garth Mann, Tom McDonald, David Wayne Johnson
March 3, 2011
Page 2
4. As noted in pages 16 through 18 of our December 2008 report, the hydraulics of
the resort will be such that there will be more groundwater recharge to the aquifer
during operation of the resort than presently occurs. This is largely a function of
collecting water from the roof tops and roadways and infiltrating it before the
water can evaporate be consumed by vegetation. Infiltration galleries will be
constructed beneath the golf course fairways that will be used to infiltrate excess
stormwater. These galleries will be placed around the resort to enhance aquifer
recharge. Attached is a preliminary facility map in which we have set aside
recharge areas as infiltration galleries.
Susan Porto February 2011 Comment: My concern is whether you have planned
adequately for drought years and the limitations of recharge.
Scott Bender Response: We believe we have adequately considered and planned
for drought years. First, the water balance calculations indicate that the resort
development will increase the amount of groundwater recharge to the aquifer by
96 ac -ft per year. That number was based on a high domestic consumption rate
required for permitting; demand will decrease based on the actual water use
design and projections of 75 gallons per day or less per unit. Since recharge to
the aquifer will increase, this will provide a natural buffer for drought years. The
Black Point aquifer is quite large when considering the amount of proposed
withdrawals, and there will not be a significant lowering of water levels due to
pumping should the natural recharge rate decrease. In addition, the storage pond
proposed within the Golf Course/Resort will have a holding capacity of two years
of irrigation water. Therefore, even if no guests use the resort (as Class A water
will fill the storage pond); there will be two years of irrigation water available.
We do not believe there is a significant `limitation' to recharge; the groundwater
monitoring data appears to be fairly responsive to precipitation events.
Two comments from the water right Report of Examination follow:
Water balances for the area indicate that estimated groundwater recharge on the Black Point Peninsula (2,330
aflyr) is significantly higher than the annual allocation associated with the water right (254 af/yr). 'therefore,
water availability is considered highly likely both at the scale of the production well and the aquifer system.
Water is available for appropriation. The aquifer in which the Pleasant Harbor wells are completed is reasonably
transmissive and capable of supporting the additional withdrawals requested. Use of the proposed new
production wells will be contingent on the applicant demonstrating that they are properly constructed and
adequately tested. The quantity appropriated reflects the amount needed to meet the needs of the applicant's
intended use. Water is therefore judged to be available for appropriation under existing Ecology regulations.
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Memorandum to Mr. Garth Mann, Tom McDonald, David Wayne Johnson
March 3, 2011
Page 3
Pleasant Harbor Golf and Marina Groundwater Monitoring Plan
1. Offsite wells will be identified as the project completes the permit stage.
Susan Porto February 2011 Comment: I don't believe you answered my concerns
here. To reiterate a portion of my comment from 3/26/10, "...and a recorded notice
to title be executed to allow agency and Resort access for the purpose of
implementing the plan."
Scott Bender Response: Pleasant Harbor has committed to making its best efforts to
monitor two or more offsite wells, and I believe at least two nearby residents have
expressed some interest in this. From my own perspective, I believe most people
would resist having an outside agency being placed on title for access; but I do
believe that there are local residents who would actively participate in the monitoring
program. There are many cases in the State where residents voluntarily participate in
these programs; Pleasant Harbor has committed to pursue this.
5. Groundwater monitoring at the site has shown stable groundwater levels even in
very low water years such as 2006 and 2008. Surface water storage will be
sufficient to supply more than one year of irrigation supply; however, the long-
term precipitation data do not provide any indication that the surface water
storage will not be replenished even in a dry winter.
Susan Porto February 2011 Comment: Doesn't it seem like that [water level] stability
is a function of the fact that the well had very little use during those years?
Scott Bender Response: We believe that the water levels will be stable regardless of
pumping, for three reasons: 1) the aquifer is very pervious, and therefore the amount
of drawdown that will occur will be quite small; 2) the aquifer is large, particularly
with respect to current and proposed withdrawals; and, 3) the proposed withdrawal
rates are relatively low compared to the recharge environment, particularly once the
resort is developed. Since there will not be a large drawdown cone due to pumping,
there will not be a wide -spread effect on groundwater levels.
Thank you, Susan, for your comments. Please feel free to contact me further if you
need clarification or have additional comments.
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