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Staciei'Hoskins
From: AI Scalf
Sent: Friday, April 29, 2005 2:06 PM
To: Stacie Hoskins
Subject: FW: SEPA for Marrowstone WSP Amendment & DOH approval requirements
fyi
AI
-----Original Message-----
From: Lorna Delaney
Sent: Friday, April 29, 2005 9:17 AM
To: AI Scalf; Leslie Locke
Subject: FW: SEPA for Marrowstone WSP Amendment & DOH approval requirements
Lorna Delaney, Human Resource Manager
Jefferson County
PO Box 1220
Port Townsend, WA 98386
Ph: 360-385-9133
From: Nancy Dorgan [mailto:ndorgan@waypt.com]
Sent: Thursday, April 28, 2005 10:41 AM
To: McCauley, James; Klocke, Karen
Cc: Lorna Delaney; Jefferson County PUD#l; jerrod,davis@doh,wa.gov
Subject: Re: SEPA for Marrowstone WSP Amendment & DOH approval requirements
Jim and Karen,
Whether the PUD chooses to conduct SEP A on its WSP amendment for the Marrowstone extension is quite a different question than
whether SEP A is a WAC requirement for state agency (DOH) approvals of major extensions and WSP amendments. I wasn't suggesting
that DOH would be the lead agency, but that the environmental review by the local lead agency would be a requirement for any
application for a WSP amendment approval by DOH.
Karen's explanation to me two years ago why DOH was now requiring SEPA for any amendments was based on Lilia Lopez's (AG) legal
counsel. The purpose was to prevent jurisdictions from deliberately leaving something out of a WSP, intending to to just put it into an
amendment later and be able to do so without mandatory environmental review. That old scenario would be repeating itself in Jefferson
County if DOH merely leaves it to local discretion whether to conduct SEPA on WSP amendments. Time will tell if the PUD here
conducts SEP A or does not, but that is irrelevant to my policy question to you. What should be my reasonable expectation of the
process?
Meanwhile, construction permits are being discussed for Marrowstone (see attached) prior to a proposed WSP revision. prior to
required environmenal review of that amendment. and prior to DOH approval of the WSP amendment for a Marrowstone extension.
What kind of reverse planning process is that?
So, have your regulations changed again regarding required SEPA for WSP amendment approvals? I would appreciate a direct answer
from DOH staff rather than being referred to an interpretation by PUD staff.
Thanks,
Nancy
----- Original Message -----
From: McCauley, James
To: 'Nancy Dorgan' ; Klocke, Karen
Cc: McCauley. James
5/5/2005
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s~nt: wedneSday,' April 27, 2005 8:381
Subjecf: RE: Marrowstone WSP Amendment & SEPA
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With.respect to your email, the Jefferson County PUD is the lead agency for SEPA for the Marrowstone project. I suggest
that you contact them directly.
From: Nancy Dorgan [mailto:ndorgan@waypt.com]
Sent: Monday, April 25, 20054:39 PM
To: Klocke, Karen
Cc: McCauley, James
Subject: Marrowstone WSP Amendment & SEPA
Karen,
Below is an email I received from you several years ago when the City of Port Townsend intended to expand its water service area
without amending its WSP and conducting SEP A for that amendment. You told me that DOH had changed its procedures regarding
those issues. A similar situation now exists for the PUD's proposed Marrowstone water system, which has not yet been approved by
DOH as part of the WSP.
You and Jim McCauley were copied in Jerrod's 4-19 email to me and I was puzzled to read that:
" 3. Yes, we will be taking another look at the capacity when the PUD submits the WSP Amendment for Marrowstone Island.
However, I am not sure if this Amendment would trigger SEP A Since the PUD is the lead agency, they will determine whether this
is necessary. We only receive SEP A comment letters if they are sent to us by individuals or organizations."
I wanted to follow-up with you about his statement. I looked up the relevant WAC, and it falls in a section regarding Dept. of DSHS
review. Construction of the Marrowstone system obviously would not be SEP A exempt:
(3) The approval of engineering reports or plans and specifications under WAC 248-54-
085 and 248-54-095, for all surface water source development, all water system storage
facilities greater than one-half million gallons, new transmission lines longer
than one thousand feet located in new rights of way and major extensions to existing
water distribution systems.
Jerrod stated that he wasn't sure if the WSP amendment would trigger SEP A Perhaps he just wasn't yet aware of the policy change at
DOH described in your message below. Or is there something I don't yet understand about the approval process? Would DOH
approve an amendment that came to them without SEP A documentation? The PUD has had a pre-app conference for construction of
the new waterlines and it looks like things might be moving ahead. Would DOH allow construction of the system prior to approval of
the WSP amendment? Would DOH require proof of prior (not pending) DOE approval of any new or transferred water rights? How
would I proceed if the PUD merely chose to ignore the SEP A review?
Thanks for your help.
Nancy
Original Message -----
From: "Klocke, Karen" <Karen.Klocke@DOH.WAGOV>
To: "'Nancy Dorgan'" <ndorgan@waypoint.com>
Cc: "Vazquez, Michele" <Michele.Vazquez@DOH.WAGOV>; "Davis, Jerrod" <1errod.Davis@DOH.WA.GOV>
Sent: Tuesday, January 21, 2003 5:43 PM
Subject: SEP A
> Recently you raised a question regarding SEP A review. You questioned
> whether or not a system submitting WSP amendments for systems of 1000 or
> more connections needed to go through the SEP A process.
>
> In the past, we (DOH) have not required SEP A review for an amendment.
>
> Lilia Lopez (our Assistant Attorney General) indicated that the requirement
> for SEP A review applies to 'approval' of plans should also apply to
> amendments of those plans. If this didn't apply, then someone could work
> around the SEP A process by not initially including something in the WSP and
> later putting it into an amendment.
>
>>From this date forward, we wil be requiring systemsjwitll J.QOQ. or more
> connections to submit SEPA documentation for both~nlt"tfiMnents.
5/512005 # ()
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>
> Thank'you for raising this question. If you have any other questions,
> please feel free to call or e-mail me.
>
> Karen J. Klocke
> Regional Planner
> WSDOH, Div. of Drinking Water
> Southwest Regional Office
> P.O.B.47823
> Olympia, W A 98504-7833
>
> (360) 664-2999
> FAX 360-664-8058
>
> ** The Department of Health works to protect and improve the health of
> people in Washington State**
>
>
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5/5/2005
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Jefferson County PUD#l Pre-Application Conference PRE05-00008
Marrowstone Island Water System project
DCD Conference Room: April 18, 2005 10:00 am
Attendees: Jim Parker, Bill Graham
Jim Pearson & Terry Duff, DPW; Linda Atkins of Env Health; Stacie Hoskins, DCD
DRD: Stacie Hoskins, Development Review (360) 379-4463
1. Various zoning designations: Rural Residential; Local Agriculture; Convenience Crossroad;
Parks, Preserves & Recreation
2. ESA's: UDC Section 3.6.4
Susceptible Aquifer Recharge Area (SUSC) and Special Aquifer Recharge Protection Area
(SARP A); Coastal, At Risk and High Risk Seawater Intrusion Protection Zone (SIPZ)
UDC Section 3.6.5;
LSHA 1,2 & 3, Erosion and Seismic hazard: UDC Section 3.6.7 Geotechnical report to
address stability of soils if working in those areas
Type 5 Streams: 50-foot buffer UDC Section 3.6.8;
Fish & Wildlife (Eagle) Send to WDPW UDC Section 3.6.8;
Wetlands: UDC Section 3.6.9;
Flood: Follow Flood Damage Prevention Ordinance as applicable Ordinance No 18-1120-95
Conservancy Shoreline designation UDC Section 5 (Additional shoreline designations may
apply - I need to see plans)
3. ESA's and buffers depicted on site plan; Wetland Delineation, geotechnical report
4. Unified Development Code available online at:
http://www.co.iefferson.wa.us/commdevelopmentludc/default.htm
· Minor Utility Developments are a C(a) use: Administrative Conditional use with
Type II process
· UDC Section 4.40 addresses Performance and Use-specific standards for Minor
Utility Developments
· UDC Section 6.12 addresses development standards for Utility Service Lines and
facilities
5. Fees: $2,767.00 plus additional notice boards
UDC Section 3, Table of Uses
Minor Utility Development in all zones is C(a) Use Base fee
Notice of application
Notice Boards: one per each ROW or as agreed
625.00
127.00
8.00 each
UDC Section 5, Shoreline Management Master Program: If any work proposed within
shoreline jurisdiction (200 feet of shoreline)
Utilities in a Conservancy Shoreline Designation is identified as a Conditional use.
Shoreline Substantial Development (Conditional Use) Base fee 1,439.00
Requires Notice of Application included above
Notice Boards included above
Notice of Hearing 127.00
PRE05-00008 JCPUD#l Marrowstone.doc
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6. Forms
· Master Permit Application
. JARPA
· Stormwater Plan
· Conditional Use Permit
. Provide a narrative describing how you meet the Shoreline Management Master
Program
i. Each of the 12 performance standards for Utilities
ii. Each of the five Conditional Use criteria.
PUBLIC WORKS: Jim Pearson (360) 385-9160
Stormwater: DOE Stormwater Management Manual for Western Washington
Roads: Submit Stormwater Management Plan,
Terry Duff (360) 385-9159
Utility permit applications
ENVIRONMENTAL HEALTH: Linda Atkins (360) 385-9444
Water: WSDOH
Other Agencies:
Washington State Department of Health
James McCauley, (360) 586-2510, ierod.davis@doh.wa.gov
Washington State Department of Fish & Wildlife
Jeff Davis. (360) 895-3965, davisipd@dfw.wa.gov
Shelly Ament, (360) 681-4276, amentkma@dfw.wa.gov
Washington State Department of Ecology
Jeffree Stewart
PO Box 47775
Olympia, W A 98504-7775
(360) 407-6521
JSTE461@ecy.wa.gov
US Army Corp of Engineers, APPLICATION REVIEW PROJECT MANAGER
U.S. Army Corps of Engineers
Seattle District Regulatory Branch
ATTN: Jessie Winkler
Post Office Box 3755
Seattle, W A 98124-3755
Telephone: (206) 764-5528
Fax: (206) 764-6602
iessica. g. winkler@nws02.usace.armv.mil
Washington State Department of Transportation
Dale Severson
PO Box 47440
Olympia, WA 98504-7440
(360) 357-2736
seversd@wsdot.wa.gov
PRE05-00008 JCPUD#[l-M:J![fOwstone.doc
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