[Vision2020] Comment Period for Stateline Development Expires Thursday

[Mark Solomon]

Here are the comments I submitted on behalf of the Palouse Water 
Conservation Network. Must just be a coincidence that I sent the same 
to all PBAC members yesterday  and today those concerns are being 
voiced by a PBAC rep. for the City of Pullman.

Mark Solomon
**********
Mark Bordsen
Whitman County Planner
PO Box 430
Colfax, WA 99111-0430

February 15, 2006

Dear Mr. Bordsen,

Please accept the following as our comments on the M-DNS and 
environmental checklist for the shopping center development proposed 
by the Hawkins Companies for the Pullman-Moscow Corridor.

Issue: Hawkins Companies estimates in their application they will 
need 40 acre foot per year to supply water to the development. Their 
number underestimates their water use by 68.5%.

Based on actual consumptive amounts by type of use from the City of Santa Fe
(www.santafenm.gov/planning-land-use/development-law/water%20use%20in%20santa%20fe.pdf 
)
and building sizes as presented on the applicant's website, it 
appears that the applicant has only estimated water consumption for 
the big big boxes (80,000 sq ft and over). Using a total of big big 
box square footage of 630,000 sq ft x.6 acre foot/10,000 sq ft 
yields 37.8 acre foot/yr compared to the 40 acre foot in the 
application.

However there is an additional 170,625 sq ft of small big boxes 
(>80,000) listed on the plan in nine separate buildings. Assuming as 
is normal in this type of development that up to half of those 
buildings may be restaurants and again utilizing Santa Fe actual 
consumption averages of 5.9 acre foot/ restaurant/yr  x 4 
restaurants= 23.6 acre foot.

The remaining small big boxes (@ 100,000 sq ft) at .6 acre foot/yr = 
6 acre foot/yr.

Sum:	37.8 acre foot/yr for big big boxes
	23.6 ac ft/yr for restaurants
	6.0 ac ft/yr for small big boxes
	67.4 ac ft/yr

325,851 gallons/acre foot x 67.4 acre foot = 21,962,357 gallons per 
year consumed PLUS fire needs not included in the application but 
I've heard the number 1 million gallons in a tank for fire use 
bandied about.

Landscaping irrigation is NOT included in consumptive uses estimated 
above and may not be a factor if the developer applies treated 
wastewater (application includes on site WWTP) but could be an issue 
as I am assuming the health department may have an issue with 
landscape irrigation coming out of simple treatment pond/sewage 
lagoons as envisioned in the application. The developer estimates 
8-12% of the developed area will be landscaped --110 acres developed 
x 12% = 13.2 acres landscaped). No accounting is given as to the 
water needed for landscape maintenance or its source although the 
plat map indicates an "irrigation pond".

So, we'll ignore landscape irrigation (for now), add in the fire 
reservoir and round the number to 23 million gallons/yr. For 
comparison, that is 2.8% of the water used by the entire City of 
Moscow in 2005.

Issue: Developer says the source of water will be groundwater. 
Application does not state which aquifer: Wanapum or Grande Ronde?

Review of well logs on neighboring properties indicates the Wanapum 
is still wet in the area of the development (it dries out just to the 
west 1/2 mile). Moscow currently pumps @30% of its water from the 
Wanapum or @ 245 mgy. Moscow Wanapum well static water levels fell @ 
5' in the past year closely following historical trends of decline 
when pumped at the current rate. If the developers well pumped from 
the Wanapum, it would be an increase of 9.4% in the volume withdrawn 
with a likely increase in the rate of decline in Moscow wells. A 
similar comparison to the Grande Ronde/Moscow pumping yields a 4% 
increase in Grande Ronde pumping. Moscow's main GR well, Well#9 
located less than one mile from the proposed development, fell 1.1 
foot last year continuing its historical downward trend.

Issue: New water rights are just about impossible to acquire in WA 
until the WRIA process is complete and the queue of applications 
already submitted is processed. Estimates from DOE staff indicate a 
five-ten year backlog of applications currently exists. Water rights 
can be attained by transfer of an existing right within the same 
water sourcing area.

The developer will eventually have to identify existing water rights 
he has acquired and proposes to transfer. The application is silent 
on the matter. Are the rights to be transferred in the Wanapum or the 
Grande Ronde? Where are they located and how will they impact the 
environment. How will development of new water sources to serve the 
proposed development affect the environment?

Proposed Action: The SEPA checklist should be returned to the 
applicant and not be accepted for review until such time as the 
applicant can more fully respond to the question of groundwater needs 
and sources as outlined above allowing the County to make the 
informed decision required by SEPA.

Sincerely,


Mark Solomon
Palouse Water Conservation Network





At 2:56 PM -0800 2/15/06, Area Man wrote:
>If you have any public comment regarding the shopping center development
>just across the state line in Whitman County, the 14-day public comment
>period expires at 4 p.m. Thursday. Public comments can be submitted in
>person to the Whitman County Planning Department, Att: Mark Bordsen, at
>the Public Service Building, 310 N. Main St., Colfax, or by mail to P.O.
>Box 430, Colfax, WA 99111. Written comments must be signed. Comments
>will not be accepted by e-mail.
>
>Once the comment period expires, Whitman County Planning Director Mark
>Bordsen will evaluate the comments and issue a final determination on
>the environmental checklist. Members of the public then will have 10
>days to appeal the final determination.
>
>This was gleaned from the following article in today's (Feb 15) Daily
>News:
>--------------------------------------------
>Cities question effect of corridor growth; Pullman, Moscow to submit
>opinions on highway shopping center
>
>By Michelle Dupler, Daily News staff writer
>
>A proposed shopping center development in the Pullman-Moscow Highway
>corridor is bringing to a head long-standing questions about the effects
>of growth on water resources on the Palouse.
>
>The Hawkins Companies submitted an application to Whitman County in
>January to build a shopping complex along the highway just west of the
>Idaho state line. At 714,000 square feet, the development would be seven
>times as large as the Wheatland Mall in Pullman and about twice the size
>of the Palouse Mall in Moscow, Planning Director Pete Dickinson said.
>
>The Pullman City Council focused on the proposed development at its
>Tuesday night meeting after it learned of the county's Feb. 1
>preliminary approval of the developer's State Environmental Policy Act
>checklist.
>
>The cities of Pullman and Moscow intend to submit comments about the
>water source for the development and its submitted stormwater drainage
>design. The cities also are concerned about how public services such as
>police and fire might be affected, since they might respond outside of
>their jurisdictions in emergencies.
>
>Neither city has any official role in the SEPA process or any power to
>make a decision about the project. However, like any member of the
>public, the cities can comment on the project and ask the county to
>address questions about the environmental issues.
>
>A key question is whether the developers will draw water from the
>shallow Wanapum aquifer or the deeper Grand Ronde aquifer. The developer
>plans to use on-site wells as a water source, rather than extending
>public utilities either from Pullman or Moscow, Whitman County Engineer
>Mark Storey said in a telephone interview today.
>
>Moscow Mayor Nancy Chaney confirmed today the developer has not
>approached Moscow about providing water or sewer service.
>
>The water should come from the Wanapum aquifer to minimize impacts on
>the two cities' water supplies, Pullman Public Works Director Mark
>Workman said at Tuesday's council meeting. The city of Pullman draws its
>entire water supply from the Grand Ronde aquifer. Moscow gets about 70
>percent of its water from the Grand Ronde and 30 percent from the
>Wanapum, Workman said.
>
>The Wanapum aquifer is recharged from surface water, Larry Kirkland said
>in a telephone interview today. Kirkland is the technical advisor and
>hydrologist for the Palouse Basin Aquifer Committee, a coalition formed
>to monitor water issues on the Palouse.
>
>The Grand Ronde gets some recharge, but the mechanism is unclear,
>Kirkland said.
>
>There may be some misunderstanding about how the proposed shopping
>center will use water, Storey said.
>
>"Part of the issue is people assuming the applicant is looking for a new
>water right," Storey said. "New water rights have not been released in
>Whitman County in years and years."
>
>The Hawkins Companies plans to transfer an existing water right to the
>shopping center, Storey said. But they have not said which aquifer that
>water right might come from. If they transfer a water right from the
>Wanapum aquifer, that water right would continue to be pumped from the
>Wanapum. The same is true for a water right from the Grand Ronde, Storey
>said.
>
>The developer could not be reached for comment.
>
>Workman also raised questions about the developer's design for
>stormwater drainage, suggesting the swales outlined in the environmental
>checklist will be ineffective because water does not percolate down
>through the soils on the Palouse. Instead, water sits in the ground or
>runs off into streams. That would be Paradise Creek in the case of this
>development.
>
>The county is addressing stormwater drainage with the Hawkins Companies,
>asking it to submit a design in line with the standards contained in the
>Eastern Washington Storm Water Manual. This manual, recently published
>by the Washington State Department of Ecology, demands a stricter
>standard, Storey said.
>
>Also, the developer will incorporate detention ponds into its stormwater
>system, allowing water to slowly be released into the natural drainage.
>Storey plans to consult with Workman about the developer's stormwater
>design as the project moves forward. "We want to make this match what
>the city of Pullman is doing as closely as possible," he said.
>
>A 14-day public comment period expires at 4 p.m. Thursday. Public
>comments can be submitted in person to the Whitman County Planning
>Department, Att: Mark Bordsen, at the Public Service Building, 310 N.
>Main St., Colfax, or by mail to P.O. Box 430, Colfax, WA 99111. Written
>comments must be signed. Comments will not be accepted by e-mail.
>
>Once the comment period expires, Whitman County Planning Director Mark
>Bordsen will evaluate the comments and issue a final determination on
>the environmental checklist. Members of the public then will have 10
>days to appeal the final determination.
>
>The council also:
>- elected Councilman Bill Paul as Mayor Pro Tempore and Councilman
>Francis Benjamin as alternate Mayor Pro Tempore;
>- adopted a resolution declaring the city's intent to limit traffic on
>Pine Street between East Main Street and Northeast Olsen Street to make
>way for the Pine Street Mall as part of the Downtown Riverwalk project;
>- accepted a donation of about $4,000 from Verizon Northwest to fund
>public access to the Internet at the Neill Public Library.
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