(Editor’s Note: In this Letter to the Editor Brian Frazier of Carlsborg asks some burning questions about the county’s plan to spend somewhere between $17 million and $45 million to build a sewer system few in the area want or need. Not only can he not get a realistic cost estimate, he cannot find scientific proof to back up the county’s premise that such a sewer system is needed. Couple this with the aspect of pumping raw sewage across two salmon rivers and paying the city of Sequim nearly $1 million per year for sewage treatment. His questions should cause taxpayers to pay more attention before this project gets to the point of no turning back. Finally, questions surrounding payment for this project are mired in controversy. Does it meet the criteria under the Opportunity Fund? Have all the cities in the county been queried as to their desire for expenditures from the Opportunity Fund, which is supposed to benefit the entire county? Thanks Brian for opening this important dialog.)
In 1990 with the passage of the Washington State Growth Management Act counties and cities were to begin Comprehensive Land Use Planning to reduce urban sprawl. Under RCW 36.70A.110 Comprehensive plans – Urban growth areas. Urban growth areas should be located first in areas already characterized by urban growth that have adequate existing public facilities and service capacities to serve such development, second in areas already characterized by urban growth that will be served adequately by a combination of both existing public facilities and services and any additional needed public facilities and services. Under RCW 36.70A.020 Planning Goals, the counties and cities were to: Encourage development in urban areas where adequate public facilities and services exist or can be provided in an efficient manner. Reduce sprawl. Reduce the inappropriate conversion of undeveloped land into low-density development. Retain open space and recreation. Protect the environment and enhance the state’s high quality of life, including air and water quality and the availability of water. Encourage the involvement of citizens in the planning process. Ensure that those public facilities and services necessary to support development shall be adequate to serve the development at the time the development is available for occupancy.
It was this same year that Clallam County claimed Carlsborg to be “characterized by urban growth” and chose to designate Carlsborg as an Urban Growth Area (UGA) under much protest by the citizens of Carlsborg.
Carlsborg did not fit the definition of “already characterized by urban growth” and did not have “existing” or “combination of public facilities and services” as defined under the GMA. One need only look at the aerial map to see that Carlsborg was not “urban” and that it did not comply with the GMA.
In spite of public dissent and after being told that we have a limited, over-appropriated water supply, Clallam County continued to push ahead with in-fill and piece-meal development in Carlsborg including new nitrate-reducing on- site septic systems, which are not allowed in a UGA. Thus, allowing development to disrupt the shallow aquifer south of Highway 101 and causing several wells to go dry north of Hwy. 101 and allowed development along the banks of Matriotti Creek, therefore failing to protect quality of life, water quality and availability. All in an effort to make Carlsborg fit their designation as “urban.”
Clallam County began a system wide sleeving of the irrigation ditches contrary to the 1983 USGS report by B. W. Drost http://pubs.usgs.gov/wri/1983/4094/report.pdf where he stated: “In the Sequim-Dungeness peninsula, Clallam County, Washington, leakage from irrigation ditches is the most important source of ground-water recharge. Possible future land-use changes could lead to termination of the irrigation system. This would result in lower heads throughout the ground-water system that could lead to well failures, increased pumping costs, seawater intrusion, and water-quality degradation.
As a result of the county not heeding the warning we have experienced lower levels in the top aquifer, wells have gone dry including my own 65 foot deep, well causing me do drill down to 110 feet to reach water and there has been some degradation in water quality due to the declining levels in the aquifers.
This degradation led the county to declare a public health hazard requiring the need for a sewer system in the Carlsborg UGA, citing the unproven report of “known to have failed or failing on-site septic systems” which bears no scientific support. This statement by the county lead to contentious debates at public meetings with the PUD, the Board of Commissioners and the Department of Community Development from 2008 and continuing to this day.
I asked for scientific proof of their statement of “known to have failed or failing on-site septic systems.” Here is the e-mail exchange.
Dear Carol, BOCC
I am requesting the following under The Public Disclosure Act:
All documents identifying the location of the purported known failing or failed on-site septic systems in the Carlsborg UGA, the agency reporting the failures including the results and testing method used in determining the failures and the proof of science. The test results and the agency providing the proof of science and scientific testing method used in determining the failed or failing systems contribution to the nitrate load in the ground water in the Carlsborg UGA.
“The Department of Community Development has reviewed our records and determined there are no records in our department to provide. Thank you. Cindy Swegle Clallam County Department of Community Development The Commissioners’ office is not in possession of any records responsive to your request. Trish Holden, CMC Clerk of the Board, Commissioners’ Office
Dear Mr. Frazier,
In response to your latest records request for documents identifying the location of the purported failing or failed onsite septic systems in the Carlsborg UGA, the District is not in possession of documents fitting that description. You may want to check with the County.
Carla Field Public Records
Officer Records Coordinator Clallam County PUD”
You can see by their responses that there is no scientific proof of their statement of “the known to be failing or failed on-site septic systems”.
On April 23, 2008 the Western Washington Growth Management Hearings Board determined that the County was noncompliant with the Growth Management Act. The Hearings Board Decision found that the County was not compliant with the provisions of the GMA for providing sewer service in the Carlsborg UGA and that the Carlsborg Capital Facilities Plan for police service does not comply with GMA.
On June 4, 2012 the order of non-compliance and invalidity was lifted for the Carlsborg UGA by the Growth Management Hearings Board. Clallam County had come up with a $17 million dollar sewer plan.
This sewer plan began a whole new series of questions and debates with the Board of County Commissioners (BOCC), Department of Community Development (DCD), PUD and County Public Works over the cost of the system and what it will cost the citizens of Carlsborg. We have been continually told by the BOCC, DCD, PUD and Public Works that “when we know the costs, you will know.” Well, we still don’t really know the total cost of the sewer system or the individual costs to the citizens. All we have are “assumptions, estimates, projections and approximations” from the Carlsborg Sewer Financial Plan by the FCS Group hired by the county and nothing more.