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Schipanski, Rich <rschipanski@eaest.com>
Friday, October 23,201510:49 AM
David W. Johnson; Dan Baskins (poulsbowashington@yahoo.com); Vicki Orrico; Hollinger,
Kristy
RE: WAC 197-11425
Thanks David.
Look forward to discussing Final SEIS format on Monday
Rich
From : David W. Joh nson [ma ilto : djohnson @co.jefferson.wa. us]
Sent: Friday, October 23,201510:43 AM
To: Dan Baskins (poulsbowashington@yahoo.com); Vicki Orrico; Schipanski, Rich; Hollinger, Kristy
Cc: David W. Johnson
Subject: FW: WAC 197-lL-425
FYI from Annie with Ecology on the 150 page text limit.
From: Szvetecz, An n ie ( ECY) [ma i lto :ASZV46 1 @ ECY.WA.GOV]
Sent: Friday, October 23,207510:34 AM
To: David W. Johnson <diohnson @co. iefferson.wa.us>
Subject: RE: WAC L97-L7-425
Hello David,
Well, the page limit is a challenge, and I agree that it probably has never been challenged because it may be
fairly easy to re-format the text such that pages beyond 150 are included in "appendices and background
material." The rule indicates that these sections are not included in the page limit.
However, more is not always better regardless of how this requirement has been enforced. Consultants may
have incentive to create bigger documents than necessary, so consideration of concise style for readability is
important along with being comprehensive.
AnnieSzvetecz-SEPAPolicvLead-DepartmentofEcology-affde.szvetecz@ecy.wa.gov
From: David W. Johnson Imailto:d iohnson @co. iefferson.wa.us]
Sent: Thursday, October 22,2OL510:06 AM
To: Szvetecz, Annie (ECY)
Cc: David W. Johnson
Subject: W AC L97 -LL-425
Annie,
l'm working on a SEIS and trying to make sure we comply with 197-11. t97-1.1-425 Style and Size, states that an EIS
"shall not exceed one hundred fifty pages." Our consultant claims they have never written an EIS under 150 pages and
have never been challenged on that. My experience also indicates that this particular requirement is ignored. Do you
know or are aware of any court precedence that would make this requirement irrelevant, or should be we concerned
that the SEIS text should not exceed 150 pages?
1