HomeMy WebLinkAboutLog074
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June 19, 2005
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Stacie Hoskins
Jefferson County Department of Community Development
621 Sheridan Street
Port Townsend, WA 98368
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Re: MLA05-00276/Comments
Dear Ms. Hoskins:
Please schedule further inquiry into the proposed Marrowstone Island water project!!!
We own two of the original hand dug wells on Marrowstone Island, likely dug before 1930.
These wells have produced cold, neutral pH, good tasting hard water for generations and
continue to do so today. A filter and a $150 Clear Wave electrostatic water conditioner keep
our water pipes and fixtures free of lime scale. Since moving out to Marrowstone from Port
Townsend in 1986 and since acquiring the second well in 2004, we have been careful to
respect our wells in many ways.
We do not want these and our neighbor's good wells degraded by soil and pollutant
disturbance during a construction project or by planned increased use of existing wells for
jrri~tion after unlimited pipeline water became available or by increased septic impacts a la
Hood Canal, increased water runoff, or other foreseeable impacts on Marrowstone Island
groundwater. There ARE good alternatives to a pipeline, including rainwater catchment as is
starting on Marrowstone and widely in use in the San Juan Islands.
But most important, the proposed water project is not just a simple proposal for pipe laid in
ditches. We believe the water proposed for Marrowstone Island is being stolen from the
Chimacum Creek Basin and pumped out-of-basin contrary to DOE's draft Instream-Flow
WAC.
The water for the system currently flows across Indian Island and then under Kilisut Harbor
to Fort Flagler State Park-in a leaky pipe that wastes precious water that should be
supporting SALMON HABITAT across Port Townsend Bay. That leaky pipe is old and
needs replacing.
However, the PUD's piecemeal phasing of its permit applications for the overall
Marrowstone system has kept that pipe-replacement project out of public review at this time,
contrary to the SEP A requirement to review known aspects and impacts of a proposal in a
cumulative. not sequential manner.
The PUD Commission ignored promises in its SEP A Checklist for their revised Water
System Plan to conduct future SEP A review for all capital projects, even those that were
classified in the WAC's as SEP A-exempt, such as an extension using 8 inch pipe. The PUD
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refused its role as SEP A lead agency, but that does not exempt the County from following
its own SEP A rules for MLAOS-00276.
Unfortunately, the County has followed the PUD's example and determined the project to
be SEPA-exempt. We most strongly object to that determination.
There are wetlands along and within the construction route--ditches included-and they
should be mapped as your department had originally requested, and any construction-related
environmental impacts analyzed for mitigation. Thank you for your recent clarification that
even though the application has been deemed complete, you can still request additional
information. Since you have already made that request to the PUD for wetland delineation
and impacts analysis, we think that having that information would be important to
determining whether or not SEP A should be conducted.
Disturbing and displacing soil in dry or waterlogged ditches full of runoff adjacent to or
leading to critical areas is not an activity that should be exempt from SEP A, especially given
the nasty pollutants associated with roadways where the construction will occur and where
contaminants will surely be dislodged into the environment.
Our properties are located on Flagler Road in a narrow strip between Flagler Road and Scow
Bay. There is evidence of springs and very wet land adjacent to the ditch and to Flagler
Road. We have used no pesticides, fertilizers or detergents other than 24 hour biodegradable
soaps since moving here. We have an electric lawn mower. We have cleaned up old roofing
materials, tires, crockery, bedsprings, and all manner of car parts from the beach in an effort
to restore the beach to a more pristine state. The proposal to disrupt ditches and install a
water pipeline to bring outside, probably chlorinated water onto this Island in mass
quantities and to encourage degrading of existing good wells is appalling.
After the state took over maintenance of Flagler Road in the early 1990's, we were dismayed
that WSDOT began spraying of Flagler Road, versus the County's former no spray policy.
We protested, quickly completed the required forms, and each year along with many of our
neighbors installed NO SPRAY signs along the roadside. Still, how much of what
compounds from this time or earlier wound up in our ditches along Flagler Road and might
better be left undisturbed?
What are the possible impacts to our shellfish beds, wetlands. springs. and our existing wells
from the proposed soil and water disturbance of this construction project? It's the County's
job to find out, and the County so far has stated that it will not conduct SEP A to find the
answers. That is inadequate review contrary to SEP A and County Code. and we urge you to
reconsider your determination.
Also, we do not think the PUD' s Water Service Area for Marrowstone was correcdy
approved by the Department of Health. DOH had rejected the Quimper System service area
map that had been approved on April 21, 2004 by the Water Utilities Coordinating
Committee (WUCC). On July 28, 2004 DOH Planner Karen Klocke sent a letter to WUCC
Chair Dan Tittemess, which stated:
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"The June 8, 2004, letter requests that we review the revised service
area maps. The service area maps lack sufficient detail. The
boundaries on the individual system maps need to show, at a
minimum, the names of the streets and state whether or not both sides
of the streets will be serviced. Please revise the service area maps and
include them with the CWSP update."
This correspondence should be available in the WUCC files at DCD. The CWSP has
obviously not yet been updated, and it has been more than a year since the WUCC has even
met since their April 2004 approval of the first set of maps that went to DOH on June 8,
2004. The WUCC could not possibly have approved the maps that the PUD sent to DOH
sometime last summer.
In an email to Nancy Dorgan dated June 3, 2005, Karen Klocke stated:
''When Jefferson pun updated their WSP, they (pun) submitted
improved maps that they received from the WUCC."
My conclusion is that the PUD inappropriately sent DOH revised maps that had not been
approved by the WUCC as requested by Karen Klocke, and Nancy Dorgan has asked DOH
how they intend to resolve this very serious process error.
In the meantime, pipeline construction permits are being applied for based on a service area
map that was not locally approved by the WUCC but approved by DOH under the
assumption that it had been. We ask you to confirm the legitimacy of the fundamental basis
for this permit. We ask Jefferson County Planning not to facilitate faulty process by allowing
yet another shortcut to construction.
Thank you for your consideration of our comments.
(J:J#~
Glenda Hultman
5331 Flagler Road
Nordland, WA 98358
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