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HomeMy WebLinkAboutLog229 '. .. , OJ -' May 16, 2006 RECJ3J Jefferson County Hearing Examiner Department of Community Development 521 Sheridan Street Port Townsend, WA 98368 JtHt~~~\t~~'\\'1 m:~ Subject: Jefferson County Public Utility District's Application for a Shoreline Substantial Development Permit Required for the Marrowstone Island Public Water System I am providing the following information in relation to MLA05-00276, SDP05-00014 in the recognition that the determination of this hearing will have significant impact on the outcome of the Public Utility District's effort to bring a public water system to Marrowstone Island. This is an essential step in the multi-year process of resolving the issue of access to potable water for those residents whose wells have either become contaminated through seawater intrusion or no longer provide water at all. Because this project includes placing water pipelines within two hundred feet of the ordinary high water mark (OHWM), a Shoreline Substantial Development Permit is required. Today's public hearing is part of that process, and I appreciate this opportunity to provide added information for your consideration. The utility pipelines proposed in the application will be placed within long-established rights of way that include roadways and ditches of many decades standing, which have been repeatedly upgraded and maintained. Any significant adverse environmental impacts related to these have already taken place, and the government entities now responsible for the rights of way are using current best management practices to significantly reduce impacts of work accomplished to maintain the roadways and ditches, and to mitigate for past impacts and practices. Nothing I have learned about the project under consideration leads me to believe that the project will introduce long-term adverse impacts to the ecosystems of Marrowstone Island, its shorelines, or other near-shore environments. Any short-term impacts related to trenching, placement and covering of the necessary pipeline sections are transient in nature, and are far outweighed by the public benefit of at long last providing Marrowstone Island's residents reasonable access to a safe supply of the potable water they deserve as a basic human right. Recently a concern over the potential presence of contaminants in the soils that will be disturbed during the installation of the pipelines was raised. The correspondent was fearful that pollutants long buried or already at the surface could be blown off dirt piles or transported in runoff to critical aquatic habitats. In response, I would like to note that the ditches alongside the island's roads are maintained by state and county work crews on a routine basis, and have been for decades. The vast majority of potential contaminants are removed from the roadsides LOG ITEM # I"LC( . Pag'3._-L---otL l 1 1 through this routine maintenance, and their presence in runoff would have already been noted, were it significant. As I understand the process, installation of the pipeline will include the digging of trenches, into which the pipe will be laid and then covered. The short time that the excavated material will be out of the ground will not allow for significant dust formation or runoff potential. Controls to prevent such problems can be written into the contracts for the project. The outfall from ditches at the southeast end of Marrowstone Island enters the bay a very short distance from one of the island's commercial shellfish beds. The state tests the water in that location on a frequent basis as part of its responsibility to assure the safety of shellfish that will be sold in stores. In many decades of testing, the state hasn't found significant levels contaminants of the type the correspondent fears would be exposed should the proposed public water system project be allowed to proceed. This has been the case, even when storm events taking place in the days immediately following ditch maintenance resulted in significant amounts of roadside runoff entering the bay. For your consideration, I've included a copy of the Washington State Department of Health Office of Food Safety and Shellfish Program's Sanitary Survey of Kilisut Harbor. It contains a comprehensive shoreline survey, including those areas of concern for this permit consideration. On page 2 of the executive summary for the survey, the author states that stormwater entering Kilisut Harbor from stormwater conveyances (the ditches and culverts) is not a significant pollution source. In conversation with the report's author at the beginning of May, 2006, I learned that he doesn't believe that the pipeline construction on Marrowstone Island would cause additional pollutants to enter the marine ecosystem. He said that the most significant pollution source of concern in the harbor actually comes from transient boats mooring in Mystery Bay during the summer months. Other than the harvest prohibited zone at the north end of Indian Island, the only portion of Kilisut Harbor rated "Conditionally Approved" instead of "Approved" is the area around the moorage and docks at Mystery Bay State Park. To supplement the survey, I've included copies of the most recent Annual Growing Area Review for Kilisut Harbor and Mystery Bay. Each report includes water quality sample result summaries from December, 2000 through November, 2005. No new pollution sources have been identified in either area, and the ditches along the highway in the shoreline areas covered by this permit application have been cleaned several times. According to the Jefferson County Comprehensive Plan, our government has an obligation to ensure a sustainable and safe water supply, and allow development along shorelines that is compatible with the protection of natural processes, conditions, and functions of the shoreline environment. The plan encourages the use of community water systems, and county policy supports the formation of a public water system on Marrowstone Island as a long-term solution for water quality degradation caused by seawater intrusion. Additionally, the project is supported by all three members of the 24th District's legislative team. In making a determination for this Shoreline Substantial Development Permit we are balancing the potential transient environmental impacts in the designated shoreline zones with the foreseeable public benefits of allowing the proposed project to proceed. LO~ ITEM # ~~1A Pag'3 . _1.-._ ot J;;:: One criticaliy important public benefit of the public water system is the significant improvement in fire protection resources the system will provide to the entire island. The current practice of bringing water in tankers from the mainland to fight a significant fire is inadequate if a fire ever gets away from responders. This is particularly true in dryer years, such as those we have recently experienced. The environmental consequences of a large-scale wildfire on shoreline and other ecosystems would be far, far greater than the transient effects of installing the pipelines. A fully functional public water system will dramatically decrease the risk of such fires ever taking place on Marrowstone Island. Because residents will still be using septic systems to treat their wastewater, the use of water from the public water system will effectively introduce a new groundwater source via residential drainfields. Groundwater recharge through a drainfield ranges between 50% of water withdrawn from a water source (Washington Department of Ecology, as credited for on-site septic systems in Water Resource Inventory Area (WRAI) 5 instream flow rule) and 87% (according to the \NRIA 17 Stage I technical assessment, using a 1993 USGS study by Solly, et al. on page 17-8). Reducing groundwater withdrawals on the island, and adding a new water source for recharge through septic systems, we can anticipate a reduction in the scope of the seawater intrusion problem over time. Using the current levels of intrusion, and the locations of the affected areas as a baseline, this assumption could be rigorously tested once the public water system is in place. A detailed research project could provide an added public benefit through data that can be used in other regions where seawater intrusion provides significant public health challenges. Although this hearing is for consideration of the Shoreline Substantial Development Permit, we need to also remember to balance the potential transient environmental impacts of the project with the long-standing needs of the people who no longer have potable water available to them through their wells. Here you are weighing the potential short-term impacts to shoreline ecosystems on one side of the scale, and on the other, the long-term economic and health impacts for those who don't have reasonable access to the drinkable water that fulfils one of the most basic human needs we share. When your home has a bad well, you no longer have the option of selling your property for its rightful value. When you have to haul your water, your quality of life and health undergo a wide range of adverse and serious impacts, from the time required to obtain water and the cumulative effects of the many forms of emotional stress related to no longer having a usable well to the lifting injuries resulting from having to transport water to your home. The process of bringing a publiC water system to Marrowstone Island has already been long and exhaustive for many reasons. It has been contentious, and has created tensions and divisions in a community where we would neither expect nor wish such stresses to be found. It's time to move forward, to bring a safe water supply to every resident of the island who opts to hook up to the public service, and time to restore that sense of community that brought the island's residents to Marrowstone in the first place. It's a process that will not cause significant harm to the island's shorelines or other ecosystems, and it needs to be done to meet the basic human needs of all those whose wells no longer provide the potable water they require for health and safety. LOG ITEM # ?~~~ Pag~._Lot, .. , t Because i grew up rural, my upbringing may represent values of days gone by. i certainly hope not. I was taught that whenever I learned that one of my neighbors had a problem, I was supposed to do whatever I could to help solve that problem. I was taught that I was never to fail to do what I could to support and work toward the best possible solution, and more importantly, that I was never to bring harm to my neighbor or allow a harmful situation to continue. I hope we can all remember those simple lessons, and apply them in our lives, wherever we may be. Thank you very much for your time today, and for your kind consideration of my ~~~/ Norman J. Macleod Jefferson County resident ,~...---.,~-y, ,'/,,#' '''-" /Attachmentst /' 1. wast)i~gton Department of Health Office of Food Safety and Shellfish ," pro,irams - Sanitary Survey of Kilisut Harbor . I L' 2. ~shington Department of Health Office of Food Safety and Shellfish programs - Kilisut Harbor 2005 Annual Growing Area Review 3( Washington Department of Health Office of Food Safety and Shellfish / \' Programs - Mystery Bay 2005 Annual Growing Area Review ~ '~Z -~ Sf:::-. '-- / VJ~ ~~\ LOG ITEM # 7 "2-1. ..~ pag~._~""vj'..s.",~- ~. SANITARY SURVEY OF KILISUT HARBOR iv1A Y, 2001 WASHINGTON STATE DEPARTMENT OF HEALTH OFFICE OF SHELLFISH PROGRAMS # LO~ !l~M f: pag'3._~()t~ >f- \'J t:>(.c: ') e-e l b1 :t::1:ew- 7- (l Po I+W'. >{,~