Realtors offer constructive suggestions for changes on WRIA 18 Plan
Feb. 3, 2005
Following is the Review of Specific Recommendations for changes to the proposed WRIA 18 Watershed Management Plan (Realtors' suggestions are in bold):
Sequim Association of REALTORS®
WRIA 18 Planning Unit Special Meeting
February 2, 2005
6:30-9:00pm Sequim High School Cafeteria
Clallam County REALTORS and interested parties:
In response to your diligent advocacy efforts, the Board of Clallam County Commissioners have directed the WRIA planning unit members to re-convene for two special meetings to review, discuss and evaluate concerns raised in public testimony regarding specific issues in the Watershed Management Plan. The Board determined the Planning Unit needed to be aware of the level of concern held by community members and should address those concerns. How these meetings will affect the Plan or the Plan adoption process is unclear, however it is important these meetings be substantive and contribute toward identifying specific amendments to the Plan.
Collectively, our efforts have been to seek solutions. In the spirit of collaborative policy making, I hope you will make every effort to attend these meetings to help re-assert our our recommendations to certain proposals in the plan.
It may be the Planning Unit’s intention is to make more specific the generalized nature of some recommendations in Phase 4 of the planning process. During Phase 4, an implementation plan will be developed. According to state law, the implementation plan does NOT have to be legislatively approved or open for public hearing. Therefore, this Phase is our last chance to have input into the Plan.
Our primary desire is to see the vast list of recommendations categorized under groundwater quantity prioritized. Prioritization should be guided by an overall policy that seeks to encourage voluntary conservation efforts, study further the groundwater model and increase efforts to fully characterize the aquifers and the effects of groundwater withdrawal on surface water.
WRIA 18 Watershed Management Plan Recommendations – Selected
Allow groundwater withdrawals from deeper aquifers in continuity
with surface water if impacts on stream flow are mitigated. (Recommendation
A-1 at page 3.1-8)
Encourage all new water supply wells, including exempt wells, to
be drilled to the second aquifer or lower in the Dungeness Planning
Area/East WRIA 18. (Recommendation A-3 at page 3.1-8)
New exempt wells should be drilled only where public water service
is unavailable. Unavailable means not within a reasonable timeframe,
in not cost effective, or is not feasible. If new development lies
within a reasonable distance from the boundaries of the service area
of a public water system, that public water system should have been
contacted and requested to provide service prior to land use approval.
(Recommendation C-2 at page 3.1-9)
Implementation of this recommendation also depends heavily on the desire and capability of public water systems to expand their service outside existing service areas. This recommendation should have been informed by a review of each public water systems’ future business plans and capability to fund the capital improvements necessary for such expansion.
Clallam County should approve building permits served by exempt wells
only if public water service is unavailable.
Where new development is proposed and Group A public water service
is unavailable as described in described in Recommendation C-2 above,
formation of a water system is encouraged, and Ecology should consider
issuing a water right for those systems. (Recommendation C-5
at page 3.1-9)
Consolidation of exempt wells to public water rights and service
from existing Group A systems is encouraged. (Recommendation
C-7 at page 3.1-10)
(Because this portion of the Plan is not organized into specific recommendations, we treat it differently for the purposes of this document)
Again, we emphasize the importance of having this agreement finalized and incorporated in the Plan BEFORE the Plan is adopted. If not, the following information should be identified in the Plan to ensure Department of Ecology’s rule on In-stream Flows for streams in the Elwha-Dungeness Watershed are guided to the fullest extent, by the Plan. Should this information not be incorporated in the Plan, the Department of Ecology will revert to their recently released Guidance Document for In-Stream Flow Rule-making. The legislative intent of the Watershed Management Act is for water management to be locally driven. By identifying this information in the Plan, we assure all water management activities are guided locally:
1. The anticipated future demand for exempt well use in the
As written, the Plan obligates the County to take certain actions. On Page 3.1-12 in reference to the goals of the Intergovernmental Agreement the Plan says:
Regulatory Controls: The County will pursue (emphasis added) legally-enforceable regulatory controls aimed at: (1) limiting the number of new exempt wells in favor of larger systems, (2)regulating the location, minimum depth and density of wells, and (3) reducing the withdrawal rate allowed from exempt wells. Elements of public water system plans, growth management plans, GMA and zoning ordinances, and building ordinances related to water development, use and delivery will be consistent with and support implementation of watershed plan elements.
Once the Watershed Plan is adopted, these obligations become binding on Clallam County in accordance with RCW 90.82.130(3)(b). Especially troubling is the hierarchy created in land use planning where the Watershed Plan guides the Comprehensive Plan, zoning ordinances, and building ordinances. This language should be deleted from the Plan.
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