Carlsborg Sewer-Project Math Stinks by Brian Frazier

How many people live in Carlsborg?

After reading 6 or so documents including the Financial Plan from Clallam County concerning the Carlsborg Sewer Project, I have come to realize that the county commissioners, Department of Community Development and the County Public Works Department have no idea how many people actually live in the “Carlsborg UGA.”


According to the June 20 2014 “Facilities Plan Amendment,” there were 856 people living in the “Carlsborg UGA” in 2013 — up from 842 in 2010. Using these figures based on “estimates” from the Office of Financial Management (OFM) result in a positive population change of 1.63% over the three year period,  or 0.55% growth per year. (See

Table E-1 page E-1, Table 2-2 Page 2-8, Chapter 1 Page 1-1, and Table 6 Page 12)


The actual, real population figures for the Carlsborg UGA are available from the OFM and the US Census.  According to the 2010 Census, 995 people were living in the Carlsborg Census Designated Place (CDP ) ; the 2000 census showed 855 — for a positive growth of 14.07% or 1.40% per year. 


Population decreasing

The 2013 Carlsborg CDP population is 908, according to the OFM.  That’s an 8.74% population decrease, or 29 people per year from 2010-2013, a 2.91% per year decline — but the county never talks about that even when asked point blank.


Why has the county and their “consultants” persisted on cutting and pasting erroneous figures from one document to the other since 2007 remains a mystery — especially when the accurate figures are available?


Actual residences and commercial businesses

You won’t see the county discussing housing units or the number of actual residences or commercial businesses in the Carlsborg UGA either; they only talk about “Equivalent Residential Units” (ERUs) not the number of physical structures.  Why, you may ask?



A numbers game

Because the number of ERUs is larger than the number of physical structures. The county states there are 406 commercial ERUs in the Carlsborg UGA, but there are only 62 physical commercial connections to be made.  Each commercial connection would then be assessed 7 ERUs (406 / 62 = 7).  See where this is going? 


They would then multiply the connection charge of $7,640 by 7 to get the total connection cost of $53,480.00.  Then do the same for the monthly user fee –$70 times 7 — for total user fee of $490.00 per month.  Follow me so far?


The county states they will waive all but $500 of the connection charge, but that’s still $3,500, plus any other plumbing cost like side sewer lines and abatement of a septic system that could add as much as another $8,500 GOTCHA! added to individual bills.


The number of residential ERUs  is simply the number of actual physical homes.  In Carlsborg there are 547 homes, of which 334 in mobile home parks are exempt by law, which leaves only 213 residences, plus the 62 commercial connections, for a total of 275 connections in the entire Carlsborg UGA — not 484 as stated in the February 2014 Carlsborg Sewer Financial Plan:


Why low-ball water use numbers? 


One ERU is equivalent to 125 gallons of water consumed per day, a low figure, considering that the Clallam County PUD says it should be 178 gallons per day.  This low ball figure frees the county to charge more if you consume more water.  This is a setup — the same one used by Mason County for its Belfair sewer system that’s now a wreck and running in the red.


Bad news from Belfair


Check out these articles:


Belfair sewer heading for the red

County weighs rate increase, subsidy

Mason County might need to nearly triple sewer rates for Belfair customers to avoid putting the Belfair Waste water Utility in the red.

“It’s a mess, and I don’t have the answer,” said Brian Matthews, Public Works and Utilities Director, calling the sewer utility “a turd.”


Port, business owners balk at sewer costs

 “A growing number of concerned citizens say that the Belfair sewer project could flush out residents, small businesses and non-profits in Belfair.”  “. . .connection fees are estimated at $3,000 per Equivalent Residential Unit (ERU), on top of another $6,000 to $7,000 to construct a side sewer into the system, and about $96 per month per ERU for sewer service.”

“Belfair Maytag Laundry had been tentatively allocated 22 ERUs, which means that it would cost the business $66,000 to connect and more than $2,000 per month in sewer rates.”

“The county had been estimating one ERU at a value of about 150 gallons per day, which many business owners felt was skewed too low allowing the county to charge for more ERUs per business.”


Clallam County going for broke – for Carlsborg

Gett the picture?  Clallam County has lost sight of the Carlsborg Sewer Project and is going for broke — at the expense of the Carlsborg residents.  


  1. Michael Gentry

    Thanks for finally making this understandable. The overarching conclusion I take from this is that we should never ask a bureaucracy to do simple math. This is quite a commentary of the level of competence we have come to accept in our elected officials and department managers and staff. Perhaps we should demand some testing take place? Yes, let’s post the math class grades of all future staff applicants and commissioners!

    1. Bryan Frazier

      I really hope this helps clear things up about Carlsborg. I feel the need to get the entire county involved in fighting this sewer plan because the county is using county taxpayer funds to pay for it. $513,000 annually just to pay back the $10 million state public works trust fund loan from the Opportunity Fund. They have also dipped into the Real Estate Excise Tax Fund (REET2) and are subsidizing the connection costs and monthly fees for 3 years with county funds not to mention the “get connected” loans of up to $3,000 for plumbing costs (side sewer lines and abatement of your on-site septic system). In the words of the Mason County Public Works Director, “this thing is a turd.” 275 total available connections in Carlsborg are not going to be able to pay for $1,063,921-$1,125,297 for the first 2 years of operation & maintenance and according to their “Carlsborg Sewer Financial Plan 3-21-2014 the system will be ($94,496.00) in the red in 2015. If we build it they may come just won’t work here. Clallam County Going For Broke.

  2. Nadia Seymour

    Interesting article. It leaves me with many more questions than it supplies answers to.

    One was what is the actual definition of “Equivalent Residential Units” (ERUs)”. The article presents this seemingly foundational basis for the figures of the Carlsborg project as a choice, as a way of manipulating numbers used to create an intentionally false conclusion. But, looking at the website of the Washington Dept of Health, (
    we see it is the accepted unit of measurement public water systems used when they are being designed. Are there other methods used by engineers and the public entities that design public water systems that are proven to be more accurate?

    I also did look at the article provided about the Mason county example, supposedly showing that this use of ERUs was a flaw in planning. But what I read was that the Belfair sewer was designed with an expectation of a level of growth that did not materialize, and therefore the administrators are looking to raise rates on the fewer number of hook ups in order to cover costs. This seems to be another victim of the 2008 recession. The article concludes with one official noting Was Dept. of Transportation is widening Route 3 through Belfair, and hoped that would lead to new businesses hooking up.

    Your article concludes with “Clallam County has lost sight of the Carlsborg Sewer Project and are GOING FOR BROKE at the expense of the Carlsborg residents. ” This makes me wonder : Why? You pretty clearly try to make the case that the County is intentionally using manipulated numbers, and are “going for broke”. Please do elaborate on why you think it is desirable for the County to do this. Why is the County trying to build a project you infer they know is wrong and bad, and that they know they will have to answer for? How is doing this benefiting anybody?

    People do have good reason to question what passes for leadership in Clallam County and Port Angeles in particular, but that does not mean everyone in local government is brain dead stupid, and malevolent.

    1. Bryan Frazier

      What is an Equivalent Residential Unit (ERU)

      An ERU is a unit of measure used to equate non-residential or multi-family residential water usage to a specific number of single-family residences.

      For example, if a system has sufficient physical capacity to serve 100 ERU’s, then that system would have sufficient capability to meet the projected needs of 100 full-time single-family residences. That same system would also be able to serve any combination of commercial, industrial, and residential customers provided the quantity of water used is equivalent to the projected needs o f 100 full-time single-family homes (100 ERU’s).
      What isn’t mentioned here is that this also allows the utility to charge you more should you use more than the designated ERU. I have stated that Clallam County PUD has said that the ERU for Carlsborg should be 178 gallons per day (gpd), not 125 gpd. As was mentioned in Belfair the low ERU of 150gpd was challenged as too low and then lowered to 135gpd which only made matters worse especially for businesses. Nadia, which sounds more ominous, 62 commercial connections or 406 commercial ERUs and what would this statement lead you to believe? It could lead a person to believe that there are more commercial connections than there actually are.

    2. Bryan Frazier

      County planners and their consultants use these ERUs for system design purposes based on current level of service and “assumption” and “projections” of “future potential growth” which may not materialize as happened in Belfair and Mason County, which has led to the extraordinary financial burden placed on so few residents and businesses and why their systems and the County are now in a financial crisis.
      The people of Mason County simply cannot afford a system that was based on a false notion or “assumption” of potential growth. According to the Office of Financial Management (OFM) Carlsborg has lost population over their 5 year study 2009-2013 not gained population.
      As you read the Mason County articles just replace Belfair with Carlsborg, the arguments are the same in every respect and Clallam County used the same “FCS consultants” as Mason County did.
      Widening the highways does not guarantee new connections and the cost of user fees and connection per ERU in and of themselves may prevent new connections from ever happening. The if we build it they may come is the major “flaw” in planning for both Mason and Clallam County.
      The one resource Mason County has that Carlsborg doesn’t is water and there has been discussions about eventually having to pipe water from Port Angeles through Carlsborg to Sequim to “mitigate” the water consumption in Carlsborg, but at what additional cost and to whom?
      As to your question of “why”? The only logical conclusion I can think of is money. As to who would benefit? Definitely not the citizens or the businesses of Carlsborg, only the developer, realtor and large land owners in the area and only if and it’s a big if the growth materializes which doesn’t appear to be happening and the realtors are getting nervous.
      By the “vision drawing” for Carlsborg being a “walkable destination” that looks more like Knott’s Berry Farm with it’s log flume ride, Locomotive Round House, trolly cars and horse drawn carriage rides it looks more like the County wants a Theme Park than a residential community.
      Clallam County like Mason County refuses to listen to the citizens and heed the warnings offered to them by examples like Belfair, Rustlewood, Lynch Cove, Allyn, Beards Cove and others. I do not “infer” that the County knows this is bad and wrong for Carlsborg, I state is clearly and plainly Clallam County just doesn’t care about it’s citizens or what this will cost all of them, including you. This sewer plan is a bad bet and the county is so far in and nobody in county government has the good sense to back out, they are “going for broke” to complete their “vision”.
      They may not be “brain dead”, “stupid” or “malevolent” but they are not and have not been honest about the costs of this vision and plan for Carlsborg, they dismiss the public input and commentary and that’s the real worry.

    3. Bryan Frazier


      Notice the wording here from the Carlsborg Sewer Financial Plan, they intermingle the words “structure” and “ERUs” as if they have the same meaning.

      “Existing structures within range of initial sewer lines: estimate 484 ERUs, of which 78 are residential and 406 are commercial.”
      Now take the number of commercial ERUs divided by the actual number of commercial PUD connection and you get 7 ERUs per connection multiplied by the connection charge per ERU of $7,640.00 equals $53,480.00 per commercial connection. How do I know how many commercial connections there are? I asked the PUD, see their e-mail response below.

      Bryan, please see below for the data you requested regarding residential and commercial customers in the UGA, and their water consumption.

      Number of Accounts and total water billed 1/14 through 11/14, Carlsborg UGA

      Account Billing
      Type/Class Usage
      TOTAL 1317560.00 CU FT
      COUNT 62

      TOTAL 751986.00 CU FT
      COUNT 99

      TOTAL 2069546.00 CU FT
      COUNT 161

      Thank you,


      Carla Field
      Records Coordinator/Public Records Officer
      PUD #1 of Clallam County
      Port Angeles, WA 98362


  3. HerbS

    Thank you Brian,
    As you know I have been fighting this as well.

    The behind the scene political pressuring was abysmal and hoq our East End commissioner Jim McEntire and Paul Martin used pressure to push this through the advisory board in Carlsborg was disturbing to say the least.
    In my own post, I will add to your own points about the ‘population’ of Carlsborg and how they will be targeted. Neither the designer or Paul Martin could really address that the ‘nitrate’ concerns might not even be lessened as the highest population density live in Mobil Home Parks and their old and FAILING systems cannot be made to hook up.
    To be blunt, the polluters that caused the State to intercede and pressure Carlsborg are free and clear. It is the rest who will pay through the nose.

    Finally the way it was pushed through because of the retirement of the Sequim Public Works manager just reeks of collusion. Sequim City council however is finding that reek to be a financial bed of roses.

    The minor environments caveat of PUMPING SEWAGE over the Dungeness was totally poo-pawed by the designer and Paul Martin.

    Too late now. Its a done deal!

    1. Bryan Frazier

      First I’ll say thank you for your fight for Carlsborg.
      I have to disagree with you about the Mobile Home Parks though.
      First their systems are in good repair and functioning as designed alleviating the need to be “forced” to connect per state law and we could still have a “nitrate” problem even if they did connect because the county still does not have an identifiable, definitive source of the “nitrate” problem just their canard about the “known to have failed or failing on-site septic systems.”
      Second, we did not have a “nitrate” problem prior to sleeving the ditches, in-fill and piecemeal development that the county allowed to occur since 1990 in their attempt to make Carlsborg appear more “urban” than it’s actual rural nature, just look at the 1990 aerial photo.
      Third, the state did not intercede because of the Mobile Home Parks, it interceded to control “urban sprawl” and contain it within the existing city boundaries.
      Fourth, the Carlsborg Citizens Advisory Council was hand picked by the Board of County Commissioners as a group of their own little bobble headed rubber stampers, no “pushing” was involved other than to push out public comment and objections, that’s the disturbing part and that continues to this day.
      I have yet to see definitive proof that James Town S’Klallam Tribe has signed off on the poo transfer across the Dungeness River.
      Fifth, Since there would be no outfall for a Carlsborg Sewer Treatment Facility the reclaimed “class A” water would be directly injected into the ground or sit in percolation ponds to leach back into our aquifers. It is said that Class A reclaimed water is fit for human contact but not for drinking, bathing or swimming. Why? Because it’s potentially toxic. Pharmaceuticals and Personal Care Products as Pollutants (PPCPs) refers, in general, to any product used by individuals for personal health or cosmetic reasons or used by agribusiness to enhance growth or health of livestock. PPCPs comprise a diverse collection of thousands of chemical substances, including prescription and over-the-counter therapeutic drugs, veterinary drugs, fragrances, lotions, and cosmetics. Sewage systems are not equipped for PPCP removal. PPCPs in the environment are frequently found in aquatic environments because PPCPs dissolve easily and don’t evaporate at normal temperature and pressures. Practices such as the use of sewage sludge (“biosolids”) and reclaimed water for irrigation brings PPCPs into contact with the soil.
      Seeing that the flow from Carlsborg is North North Easterly it all would end up in the River and our drinking water.
      The county needs to just back off this bad sewer plan and down size Carlsborg to it’s former RURAL designation before they completely ruin the water and the environment. If we don’t have the water to flush, then why build it?

    2. Bryan Frazier

      As I have mentioned before the MOBILE HOME PARKS are NOT the problem or the issue in Carlsborg. Their septic systems are in good working order and functioning as designed, they are not the “worst polluters”.
      To continue to say these things is right up there with the county and their “known to be failing or failed on-site septic systems” in which your statement and theirs are without scientific proof. Their systems are pumped and inspected regularly as required by law.

      Out of 547 residential units U. S. Census 2010 334 are in mobile home parks and are exempt from connection by state law RCW 35.67.370

      That leaves ONLY 213 residential units available for connection plus the 62 commercial connections you only have 275 total connections available in the ENTIRE CARLSBORG UGA not 1000 as you have stated. All the rest of the connections the county talks about are ghosts, they are nothing more than hopeful speculations based on “ASSUMPTIONS, PROJECTIONS and ESTIMATES” of POTENTIAL growth and nothing more.
      According to the 5 year ACS study by the U. S. Census Bureau 2009-2013 Carlsborg has lost population at a rate of 1.75% per year or 8.74% over 5 years. So much for “projected growth” from the county.
      If this turd is built, Clallam County like Mason County will go broke over it and so will the businesses and residents of Carlsborg.

      Check out my blog site where I have done the math for you complete with links for verification of my numbers.

      I have ALL the Financial and Planning documents in hand along with meeting minutes from the Department of Community Development, Public Works, BOCC and others.

      1. Bryan Frazier

        Herb your missing the point here. We don’t need the sewer, we don’t want the sewer and we definitely don’t want reclaimed water in our aquifers. Class A+ reclaimed water contains PPCPs (Pharmaceuticals and Personal Care Products as Pollutants) as well as antibiotic resistant SUPERBUGS (bacteria and viruses) which are not removed during treatment.

        Watch this video WASTE WATER from Flagstaff AZ. As I have stated before “there is NO scientific proof that the on-site septic systems are the problem.” I have the e-mails responses from Clallam County that support my statement. I also have 25 years worth of documentation to go along with it. No sewer and down zoning is the ONLY proper way to protect the water supply and the finances of the Carlsborg citizens.

  4. Bryan Frazier

    Determining the value of an ERU is not the average use during the 6 winter months of the year as Clallam County has done for the Carlsborg Sewer it should be done as follows: the actual quantity of water represented by an ERU when determining how many ERU’s it can service is related to the water used by the average single family home on the worst day of the year. This is called the Maximum Day Demand (MDD), typically expressed in gallons per peak day of the year per ERU (gpd/ERU).

    It is important to remember that the highest demand day of the year dictates the value of an ERU that a water system must use in its system planning and design. Just saying.


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