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--></style><title>Re: [Vision2020] Comment Period for Stateline
Development</title></head><body>
<div>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.</div>
<div><br></div>
<div>Mark Solomon</div>
<div>**********</div>
<div>Mark Bordsen</div>
<div>Whitman County Planner</div>
<div>PO Box 430</div>
<div>Colfax, WA 99111-0430</div>
<div><br></div>
<div>February 15, 2006</div>
<div><br></div>
<div>Dear Mr. Bordsen,</div>
<div><br></div>
<div>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.</div>
<div><br></div>
<div><b>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%</b>.</div>
<div><br></div>
<div>Based on actual consumptive amounts by type of use from the City
of Santa Fe</div>
<div><tt><font
color="#000000"
>(www.santafenm.gov/planning-land-use/development-law/water%20use%20i<span
></span>n%20santa%20fe.pdf )</font></tt></div>
<div>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.</div>
<div><br></div>
<div>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.</div>
<div><br></div>
<div>The remaining small big boxes (@ 100,000 sq ft) at .6 acre
foot/yr = 6 acre foot/yr.</div>
<div><br></div>
<div>Sum:<x-tab> </x-tab>37.8 acre foot/yr for big
big boxes</div>
<div><x-tab> </x-tab>23.6 ac
ft/yr for restaurants</div>
<div><x-tab> </x-tab><u>6.0
ac ft/yr for small big boxe</u>s</div>
<div><x-tab> </x-tab>67.4 ac
ft/yr</div>
<div><br></div>
<div>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.</div>
<div><br></div>
<div>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".</div>
<div><br></div>
<div>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.</div>
<div><br></div>
<div><b>Issue: Developer says the source of water will be groundwater.
Application does not state which aquifer: Wanapum or Grande
Ronde?</b></div>
<div><br></div>
<div>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.</div>
<div><b><br></b></div>
<div><b>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.</b></div>
<div><br></div>
<div>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?</div>
<div><br></div>
<div><b>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.</b></div>
<div><br></div>
<div>Sincerely,</div>
<div><br></div>
<div><br></div>
<div>Mark Solomon</div>
<div>Palouse Water Conservation Network</div>
<div><br></div>
<div><br></div>
<div><br></div>
<div><br></div>
<div><br></div>
<div>At 2:56 PM -0800 2/15/06, Area Man wrote:</div>
<blockquote type="cite" cite>If you have any public comment regarding
the shopping center development<br>
just across the state line in Whitman County, the 14-day public
comment<br>
period expires at 4 p.m. Thursday. Public comments can be submitted
in<br>
person to the Whitman County Planning Department, Att: Mark Bordsen,
at<br>
the Public Service Building, 310 N. Main St., Colfax, or by mail to
P.O.<br>
Box 430, Colfax, WA 99111. Written comments must be signed.
Comments<br>
will not be accepted by e-mail.<br>
<br>
Once the comment period expires, Whitman County Planning Director
Mark<br>
Bordsen will evaluate the comments and issue a final determination
on<br>
the environmental checklist. Members of the public then will have
10<br>
days to appeal the final determination.<br>
<br>
This was gleaned from the following article in today's (Feb 15)
Daily<br>
News:<br>
--------------------------------------------<br>
Cities question effect of corridor growth; Pullman, Moscow to
submit<br>
opinions on highway shopping center<br>
<br>
By Michelle Dupler, Daily News staff writer<br>
<br>
A proposed shopping center development in the Pullman-Moscow
Highway<br>
corridor is bringing to a head long-standing questions about the
effects<br>
of growth on water resources on the Palouse.<br>
<br>
The Hawkins Companies submitted an application to Whitman County
in<br>
January to build a shopping complex along the highway just west of
the<br>
Idaho state line. At 714,000 square feet, the development would be
seven<br>
times as large as the Wheatland Mall in Pullman and about twice the
size<br>
of the Palouse Mall in Moscow, Planning Director Pete Dickinson
said.<br>
<br>
The Pullman City Council focused on the proposed development at
its<br>
Tuesday night meeting after it learned of the county's Feb. 1<br>
preliminary approval of the developer's State Environmental Policy
Act<br>
checklist.<br>
<br>
The cities of Pullman and Moscow intend to submit comments about
the<br>
water source for the development and its submitted stormwater
drainage<br>
design. The cities also are concerned about how public services such
as<br>
police and fire might be affected, since they might respond outside
of<br>
their jurisdictions in emergencies.<br>
<br>
Neither city has any official role in the SEPA process or any power
to<br>
make a decision about the project. However, like any member of the<br>
public, the cities can comment on the project and ask the county
to<br>
address questions about the environmental issues.<br>
<br>
A key question is whether the developers will draw water from the<br>
shallow Wanapum aquifer or the deeper Grand Ronde aquifer. The
developer<br>
plans to use on-site wells as a water source, rather than
extending<br>
public utilities either from Pullman or Moscow, Whitman County
Engineer<br>
Mark Storey said in a telephone interview today.<br>
<br>
Moscow Mayor Nancy Chaney confirmed today the developer has not<br>
approached Moscow about providing water or sewer service.<br>
<br>
The water should come from the Wanapum aquifer to minimize impacts
on<br>
the two cities' water supplies, Pullman Public Works Director Mark<br>
Workman said at Tuesday's council meeting. The city of Pullman draws
its<br>
entire water supply from the Grand Ronde aquifer. Moscow gets about
70<br>
percent of its water from the Grand Ronde and 30 percent from the<br>
Wanapum, Workman said.<br>
<br>
The Wanapum aquifer is recharged from surface water, Larry Kirkland
said<br>
in a telephone interview today. Kirkland is the technical advisor
and<br>
hydrologist for the Palouse Basin Aquifer Committee, a coalition
formed</blockquote>
<blockquote type="cite" cite>to monitor water issues on the
Palouse.<br>
<br>
The Grand Ronde gets some recharge, but the mechanism is unclear,<br>
Kirkland said.<br>
<br>
There may be some misunderstanding about how the proposed shopping<br>
center will use water, Storey said.<br>
<br>
"Part of the issue is people assuming the applicant is looking
for a new<br>
water right," Storey said. "New water rights have not been
released in<br>
Whitman County in years and years."<br>
<br>
The Hawkins Companies plans to transfer an existing water right to
the<br>
shopping center, Storey said. But they have not said which aquifer
that<br>
water right might come from. If they transfer a water right from
the<br>
Wanapum aquifer, that water right would continue to be pumped from
the<br>
Wanapum. The same is true for a water right from the Grand Ronde,
Storey<br>
said.<br>
<br>
The developer could not be reached for comment.<br>
<br>
Workman also raised questions about the developer's design for<br>
stormwater drainage, suggesting the swales outlined in the
environmental<br>
checklist will be ineffective because water does not percolate
down<br>
through the soils on the Palouse. Instead, water sits in the ground
or<br>
runs off into streams. That would be Paradise Creek in the case of
this<br>
development.<br>
<br>
The county is addressing stormwater drainage with the Hawkins
Companies,<br>
asking it to submit a design in line with the standards contained in
the<br>
Eastern Washington Storm Water Manual. This manual, recently
published<br>
by the Washington State Department of Ecology, demands a stricter<br>
standard, Storey said.<br>
<br>
Also, the developer will incorporate detention ponds into its
stormwater<br>
system, allowing water to slowly be released into the natural
drainage.<br>
Storey plans to consult with Workman about the developer's
stormwater<br>
design as the project moves forward. "We want to make this match
what<br>
the city of Pullman is doing as closely as possible," he
said.<br>
<br>
A 14-day public comment period expires at 4 p.m. Thursday. Public<br>
comments can be submitted in person to the Whitman County Planning<br>
Department, Att: Mark Bordsen, at the Public Service Building, 310
N.<br>
Main St., Colfax, or by mail to P.O. Box 430, Colfax, WA 99111.
Written<br>
comments must be signed. Comments will not be accepted by e-mail.<br>
<br>
Once the comment period expires, Whitman County Planning Director
Mark<br>
Bordsen will evaluate the comments and issue a final determination
on<br>
the environmental checklist. Members of the public then will have
10<br>
days to appeal the final determination.<br>
<br>
The council also:<br>
- elected Councilman Bill Paul as Mayor Pro Tempore and Councilman<br>
Francis Benjamin as alternate Mayor Pro Tempore;<br>
- adopted a resolution declaring the city's intent to limit traffic
on<br>
Pine Street between East Main Street and Northeast Olsen Street to
make<br>
way for the Pine Street Mall as part of the Downtown Riverwalk
project;<br>
- accepted a donation of about $4,000 from Verizon Northwest to
fund<br>
public access to the Internet at the Neill Public
Library.</blockquote>
<div><br></div>
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