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October 28, 2022
Federal Salary Council
U.S. Office of Personnel Management
Pay and Leave
1900 E.Street NW, Room 7H31
Washington, D.C. 20415-8200
SUBJECT NAVAL MAGAZINE INDIAN ISLAND, PORT HADLOCK,WASHINGTON, REQUEST INCLUSION INTO
SEATTLE-TACOMA LOCALITY PAY AREA
Dear Honorable Federal Salary Counsel Members:
We write you todayto present data supporting a case for special consideration in making a
Washington in the Seattle Tacoma localitypayschedule.
determination to include Jefferson County,
/
Previously two of the major criteria used to determine inclusion in an adjacent locality pay schedule for
GS federal employees on a county-by-county basis. One criteria was that a jurisdiction needed to meet
a threshold of 400 GS employees. Jefferson County has been well under this threshold of GS employees
in the past and unlikely to change significantly in the future.
A second criteria is called the Employment Interchange Rate—The Employment Interchange Rate is a
measure of workers commuting between an existing locality pay area (in this case,the Seattle/Tacoma
locality) and the proposed area of application (Jefferson County, Washington).The rate is calculated by
including all workers in assessed locations, not just federal employees. The threshold rate was 7.5%.
The proposed change to 20%employee interchange rate is expected to be implemented.
Jefferson County would have become eligible for inclusion in the Seattle/Tacoma pay schedule with the
removal of the 400 GS employee requirement, were it not for the simultaneous increase in the
employment interchange threshold from 7.5%to 20%. Jefferson County's exchange rate is currently
16.5%, which is more than double the previous threshold and only 3.5%under the proposed threshold.
Jefferson County stands apart from any other jurisdiction in several significant ways. One is the
demographic makeup of county population and the other is the geographic location and isolation of
Jefferson County.
Jefferson County has the highest percentage of citizens over the age of 65 years in the state of
Washington at 39.2%with a median age of 59.5 years as of 2020, according to the WA State Office of
Financial Management. Jefferson County's age demographics affect the number of working age citizens,
which necessarily negatively effects the number of commuters in and out of the county for employment.
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Jefferson County's 2020 population is
32,997. West county(in green) has a
Jefferson County,WA Zip Codes
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- population of 6,261 with the rest of the
Ya.„ population in eastern Jefferson County.
Sank lounry
1 Th Jefferson County is located on the Olympic
Peninsula within western Washington and
i'$.,..rv, is divided by the Olympic Mountains into an
' ( eastern and western area with no vehicle
, ___ access from one end of the county to the
other without passing into either Clallam or
(".\ ' ' Grays Harbor counties.The western area is
#' __. :,__,______..J bordered by the Pacific Ocean coastline and
the eastern area is bordered by the marine
waters of the Strait of Juan de Fuca and the
Puget Sound.
Due to the geographic location, options for Jefferson County interchange are very limited. There are
numerous factors and challenges which discourage from interchange. Jefferson County only has only
three Highways (SR20, US101 and SR104)all are 2 lane Highways that leave the county and one is a ferry
to Whidbey Island (SR20)that allow access to other Counties.
Moreover,to access each of these adjoining counties SR104 over the Hood Canal Bridge is the only
viable roadway link to Kitsap County,
Ili,S...caanx., vwr+a,s.a West US 101 is the only link to Grays
.. ^Y's.rM -
Harbor County to the west and south,
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Strait »- "4 East US 101 is the only link to Mason
a ,: ^ g County to the south,and SR20 by
.� �^ ii ferry is the only link to Whidbey
« ..'° Fmk, ,� `4�``•, a _,, t ( Island (Island County)to the east.
_" ' olrmpr National Park ,,,,,,,° Unlike other jurisdictions that may
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have multiple surface streets and
Pacific + wr'.,, �„
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Ocean -'"'" "'' "1.. other routes between jurisdictions,
., "''� . `al m. ; these are literally the only roads that
` } are available to commuters.
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,,d„ Each of these routes have unique
. 0 1 vulnerabilities that affect their
1 reliability for employment
"�+� m s interchange (i.e.,commuting).
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The vast majority of commuters
utilize the transit route (Highway 104) across the Hood Canal floating bridge for eastern Jefferson
County which is the most heavily populated region. There are approximately 19,000 vehicles that cross
the Hood Canal Bridge on average per day. The factors which make it difficult for workers to commute
along this route include the following:The Bridge is a floating bridge (not a fixed span or suspension
bridge) across the marine transport waters of the Hood Canal. The route is prone to frequent
unscheduled closures. There are a total of 400 average bridge closures per year with little to no advance
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• warning, with an average wait time of 45—60 minutes per bridge closure event. The average backup of
vehicle traffic caused by these closures depends on the time of day and season but the vehicle lines in
both Kitsap County and Jefferson County on Highway 104 can exceed 6-8 miles long in both directions.
Marine traffic has the right of way and bridge operators must open the bridge within an hour of being
notified. The vast majority of these closures are the result of large vessel (e.g., Navy submarines,
sailboats,commercial vessels, etc.). These Crossings at the Hood Canal are accomplished by opening the
middle of the floating bridge by retracting a mechanical span.
Other unexpected closures are due to winds above 40 mph sustained for at least 15 minutes and
extreme tidal currents—these conditions force the bridge to close for vehicle traffic (i.e.,the mid span is
opened)to relieve structural pressure from the wave energy which could damage the anchor cables that
hold the bridge in place and also for the safety of the vehicles,which can be impacted by the waves
cresting onto the bridge deck. Environmental closures have no timeline for reopening to vehicle traffic.
Additional closures are the result of ongoing maintenance required to keep the bridge structurally
sound. For the protection of the pontoons, concrete, metal decking, and trestle sections from harsh
saltwater conditions. One upcoming maintenance event per Washington State Department of
Transportation is the Hood Canal Bridge—Center Lock Rehabilitation. As early as May 2023 travelers
can expect up to four total weekend closures of the SR 104 Hood Canal Bridge,from 11 p.m. Friday to 4
a.m. Monday. Bridge crews will also require additional series of nighttime intermittent closures to all
travelers.
Residents of the Olympic Peninsula and surrounding areas still remember when the west half of the
Hood Canal Bridge sank in 1979,to re-open several long years later, in 1982. In 2003,the project for
replacing the east half of the Hood Canal Bridge was started. The project affected bridge traffic for
many years,with a full closure in the spring/summer of 2009 and continued closures for testing and
further work.
A lesser used route for Jefferson County is the Washington State operated car ferry between Port
Townsend and Whidbey Island at Coupeville. While this ferry route used to be able to rely on two
ferries in the summer to handle vacation and commuter traffic, currently and for quite a few years,this
route typically only runs one boat,the M/V Salish. This ferry is a smaller class vessel that will carry 64
vehicles and 748 passengers. Compared this to vessels used on the Seattle/Bainbridge and
Edmonds/Kingston crossings in Kitsap County that typically have room for 202 cars and 2499 passengers.
Consequently,on the Port Townsend/Coupeville run, reservations are requ-ired in advance to purchase
tickets and to board the M/V Salish ferry. The ferry also poses numerous challenges to daily commuters
as it frequently shuts down due to low tides, not allowing sufficient water depths for the vessel's draft at
the ferry landing docks, high winds resulting in unsafe sea state conditions, heavy fog which severely
limit visibility, mechanical failure, and the ferry dock landings which have mechanical ramps and timber
pilings.
Additionally, during the height of the tourist season in Spring/Summer of each year the traffic volumes
utilizing the ferry increase significantly and it can be difficult for commuters to make a reservation on a
daily basis. In order to reach the east side of Puget Sound (i.e.,the Seattle side)from Whidbey Island it
requires a lengthy drive from the Keystone ferry landing to the Deception Pass bridge or another ferry
crossing from Clinton (Whidbey side)to Mukilteo (Seattle side). Finally,the ticket prices due to inflation
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and fuel costs have substantially increased over the past several years making it more expensive to
commute to and from Jefferson County using this ferry route.
The final route (and least utilized)that can be used by the population workers for Jefferson County is
West Highway 101 which follows the western shoreline of Hood Canal. This is a very narrow 2 lane and
winding road that has no lighting and can be very treacherous during the winter when snow and ice is
frequently present on the road surface as this route goes over a mountain pass on the edge of the
Olympic Mountains. The Walker Mountain pass can be difficult during winter and the entire route along
the Hood Canal shoreline areas is prone to rockslides and mud slides, which can result in road closures
in excess of 1-2 days. The distance to Kitsap County from Jefferson County along this route is the
longest route to and from Kitsap or Pierce County and takes additional 2.5 hours of commuting time one
direction—
This lengthy travel time is compounded by the significant increase in traffic volumes during the peak
tourist season from spring through fall each year. On a final note, housing along this route is almost
non-existent due to the lack of buildable land in the narrow strip between the Hood Canal shoreline and
the steep edges of the Olympic Mountains which dominate this roadside landscape. As a result of these
issues,this is not a desirable or acceptable transit route for workers interchange to Jefferson County.
Clearly,the Hood Canal Bridge is the only viable commuting route from Jefferson County for the
majority of employees working out of the county or coming into the county to work.
In conclusion,these are many of the impediments, challenges, and issues affecting the three alternative
routes that can be utilized by workers for the Employment Interchange Rate for Jefferson County of
16.5%. For the reasons previously stated it is not easy or always feasible for most employees or
employers working in Jefferson County easily commute out of county, nor is it easy or always feasible
for employees to commute into the county due to the difficulties of getting to work in a timely and
dependable manner.
We believe we have presented data supporting a case for special consideration of the unique
circumstances affecting Jefferson County—primarily our older, retired demographic (the oldest in
Washington State) and our particular transportation vulnerabilities and constraints that both affect our
Employment Interchange Rate. Jefferson County respectfully requests from the to include Jefferson
County, Washington in the Seattle/Tacoma locality pay schedule.
Sincerely,
Brian D. Hicks
Chief Information Officer
Naval Magazine Indian Island
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