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June 19, 2005
Jefferson County Department of Community Development
621 Sheridan Street
Port Townsend, WA 98368
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Attention: Stacie Hoskins, Project Planner
Re: MLA05-00276
Conserve Water First states its strong objection to issuance of all of the permits contained within
Master Land Use Application MLA05-00276: SDP05-00014 and ZON05-00027 for the,
Shorelines-Substantial Development and Conditional Use, and Administrative Conditional Use
Permit for Minor Utilities as well as for any other required permits related to Stormwater,
JARPA, or the Corps of Engineers. These permits are not consistent with the requirements of
the Shorelines Management Act, Shorelines Master Program, and the County's Unified
Development Code.
The June 8, 2005 published notice states that the proposal is exempt from review under SEPA.
We specifically challenge the use of this exemption considering the provisions of WAC 197-11-
800-(24)(b), WAC 197-11-756, and WAC 197-11-305. We express our strong disappointment
and disagreement with the County's acceptance of the PUD's application as complete without
continuing to require the Originally requested wetlands delineation of the project area and a
related environmental impact analysis.
There has been much discussion aboutthe use of 8" pipes to seek to avoid SEPA review for
this major system extension, but our concern about the diameter relates more to the value
engineering of the PUD staff's design and the adequacy of the 8" line to serve an expanding
system. The PUD was unable to provide Conserve Water First members with a copy of the
Engineering Report that had been submitted to DOH. The project design appears to have been
a moving target subject to unspecified revisions, and it is our opinion that the PUD application
aimed low, hoping for minimal. response from. reviewers, including the public, and relying
ultimately on engineers at the Department of Health for design responsibility.
I request that you send me any notice of any hearings and copies of any decisions regarding
this public notice Type III land use application.
Thank you for your consideration of our comments.
Sincerely,
Ray Harker
155 East Beach Road
Nordland WA 98358-9622
ray@mysterybay.org
Conserve Water First
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