Chehalis Basin Partnership Water Quality Committee
Grays Harbor Forestry Building
Montesano, Washington
June 12, 2008
9:30 a.m.
Meeting Summary
MEMBERS PRESENT: |
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Terry Willis, Citizen, Grays Harbor |
Randy Lehr, Grays Harbor College |
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Teri Franklin, Citizen, Grays Harbor |
Danielle Gardea, Puget Sound Meeting Services |
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Lee Napier, Grays Harbor County |
Don Loft, Graduate, The Evergreen State College |
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Dave Rountry, Department of Ecology |
Samuel Iwenofu, Quinault Indian Nation |
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Ron Schillinger, City of Montesano |
Janel Spaulding, Staff, Grays Harbor College |
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Patrick Wiltzius, City of Chehalis |
Nancy Allison, Washington Coast of Sustainable Salmon Partnership |
Chair Terry Willis called the Chehalis Basin Partnership (CBP) Water Quality Committee (WQC) meeting to order at 9:30 a.m.
Dave Rountry requested adding a follow up discussion on the actions pursued by the committee following the May meeting pertaining to the Partnership’s response to Randy Lehr’s water quality monitoring results and any comments by the Partnership on the two letters requested by the WQC.
Ms. Willis reported the Partnership requested sending a letter to the Quinault Indian Nation formally requesting the tribe’s information on water quality testing to add to the Partnership’s water quality monitoring efforts. The tribe volunteered to provide the information if the Partnership formally requests the information.
The second letter is addressed to organizations and agencies that did not respond to the request to provide information on efforts related to the Total Maximum Daily Load (TMDL) Detailed Implementation Plan (DIP) for inclusion of the information within the DIP. Lee Napier said the letter hasn’t been mailed. She is working with Janel Spaulding and Dave Rountry on the mailing of the letter. The Partnership approved mailing the letters.
Mr. Lehr reported on his presentation of the water quality monitoring program to the Partnership at its May meeting. The Partnership appeared to be satisfied with the direction the program is taking and expressed interest in obtaining access to the data. Software is available to enable easier readability of the data. The software is downloaded free of charge. Several people inquired about the source of the software.
Approval of May 8, 2008 Minutes
A correction to the minutes of May 8, 2008 on page three was requested to delete the paragraph stating, “Mr. Rountry disagreed with Mr. Jarzynka’s comment. The committee should act now.”
The minutes of May 8, 2008 were approved as amended.
Grays Harbor Draft Critical Areas Ordinance
Ms. Willis reported the Draft Critical Areas Ordinance (CAO) was released by Grays Harbor County for public review and comment approximately 70 days ago. She advised members on the opportunity to write comments and offer suggestions on the draft ordinance. Public comments are due by June 30, 2008. The draft will be revised based on comments received and released for a final public review and comment period. The committee has agreed to review and provide comments on the draft ordinance. The comments will be forwarded to the Partnership for its approval.
Ms. Napier introduced Janel Spaulding, Watershed Facilitator. There have been discussions with Mr. Lehr on Ms. Spaulding’s work plan, which will include a division of work between the committees. Currently, Ms. Spaulding will support the Citizens Advisory Committee and the WQC. Ms. Napier said she will continue supporting the Steering Technical Committee, CBP, and Habitat Work Group.
Members and attendees provided self-introductions and shared information about their background and education.
Nancy Allison arrived at 9:40 a.m.
Mr. Lehr said he is leaving Grays Harbor College to assume another position in the Midwest. He described the transitional program related to his departure and ongoing efforts of the Partnership’s work and activities. His new position is in the management of fisheries and water resources in the Midwest area where he was raised. He will be leaving the college in July.
Ms. Napier commented on the regional group, which just formed as the Washington Coast Sustainable Salmon Partnership. Ms. Allison started as the Executive Director on May 12, 2008.
Ms. Napier reported Chad Stussy is leaving the Department of Fish and Wildlife to accept a teaching position at North Thurston Public Schools District.
Ms. Spaulding volunteered to track member comments and feedback on the draft CAO.
Samuel Iwenofu arrived at 9:52 a.m.
Ron Schillinger indicated he has not had the opportunity to review the draft CAO. However, the draft document was introduced during the Grays Harbor County Economic Development Council meeting. The document was characterized as having some potential severe, negative impacts. He proposed submitting comments on the CAO similar to how he submitted comments to the Chehalis Flood Authority concerning the irresponsibility of not considering land use and its affect on flooding. He noted irresponsible development was allowed to occur along I-5 with fill to raise structures. He asked the committee’s consideration for sending comments separately on the CAO in addition to the comments the committee will forward.
Ms. Napier said she’s received feedback from the EDC meeting that the Director of the EDC compared the document to being identical to the guidance document issued under the Growth Management Act (GMA). She noted the document is not identical to the guidance document. The comment was not an accurate representation.
Mr. Schillinger said there is a reason Grays Harbor County has not elected to become subject to the restrictions of the GMA. For smaller cities, such as Montesano, it’s likely been very beneficial that the City hasn’t had to deal with the kinds of issues that other smaller cities have contended with under the GMA.
Teri Franklin reported she has been reviewing the interim CAO for Grays Harbor. For years, many people have indicated Grays Harbor does not impose buffers on wetlands. That belief is untrue. According to the interim CAO, 100-foot buffers are required from the annual high water line of any wetland in Grays Harbor County. She referred to the requirements in the interim GAO from 1992 under Appendix F under E Wetlands.
Ms. Franklin shared information on her potential filing of a lawsuit against Weyerhaeuser and Grays Harbor County on the Powers Creek property. Currently, both organizations are negotiating with her on some replantings.
Members began the review of the draft CAO. Mr. Lehr advised that he will send his comments electronically to members and to Ms. Spaulding.
Ms. Franklin objected to the first paragraph on page 2 specifically referring to the violation of citizen constitutional rights. Mr. Wiltzius pointed out that the provision reminds the reader that there are certain constitutional rights and if a property owner is not careful, some of the restrictions can infringe upon those rights. He conveyed acceptance with retaining the language.
Ms. Franklin referred to (3) on page 5 stating, “Grays Harbor shall make such field investigations, as are necessary, to determine if the criteria for a special study exception are satisfied.” She suggested that since Grays Harbor County does not employ environmental scientists, any evaluation should be conducted by the Department of Ecology (DOE) or a professional who has the expertise. Currently, that type of expertise does not exist within the county’s planning department. Mr. Wiltzius suggested revising the sentence so as not to preclude the county’s ability if the county should employ environmental professionals. He suggested adding, “qualified field investigators.” Ms. Willis noted the goal is to retain the option for local control. Ms. Franklin explained that since her involvement with the Wildcat Creek project, the county has indicated that no wetlands existed on the property. She said she was raised in the area and played in the wetlands and was aware of the existence of wetlands. The county sent a company from Longview, which indicated no wetlands were detected. Ms. Franklin said she took pictures of the wetlands after the logging activity and provided the pictures to DOE. DOE visited the site and acknowledged the existence of wetlands, which continues to be ignored by the county. The same thing occurred in McCleary’s recharge area. In the last 10 years, she said she’s had much experience with things the county has tried to overlook.
Mr. Lehr commented that there is a regional debate he is becoming aware of about whether a wetland should be considered a wetland dependent upon the class of the wetland. DOE has designated a range of wetland classes that speaks to the function, distribution, rarity, and size of wetlands. Some consulting companies use different measuring points and discount some wetlands as a non-wetland. There is a range of how a wetland is interpreted and often two people viewing the same wetland may not necessarily have the same opinion. Mr. Lehr said DOE considers soil type, size, vegetation, and hydrology when typing wetlands.
Ms. Willis pointed out that the provision pertains only to special study exceptions and is not specific only to wetlands. The provision could apply to an aquifer study for example. Ms. Franklin emphasized the county does not have the expertise for exceptions. The county needs a person with a better background to grant exceptions.
Ms. Willis suggested adding “aquaculture” as another activity to item b on page 8.
Ms. Franklin suggested the last sentence on page 10 is improperly stated and suggested revising the last sentence to read, “...to and surrounded by lots with existing structures constructed above the base flood level, provided …”
Ms. Willis said the provision on page 12 pertaining to “the cost of flood insurance will be commensurate with increase risk” should be deleted from the CAO because flood insurance is not required for everyone and it is not an issue of oversight by the CAO.
Ms. Willis suggested removing, “E. Procedural determinations made by the planning and building director shall be entitled to substantial weight” under Appeals on page 12.
Ms. Franklin questioned the location of critical protection area maps and inventories as referenced on page 12 of the draft. Mr. Lehr said the reference to maps is the Department of Natural Resources (DNR) land use maps. The language should also reflect that the maps are subject to change because of ongoing stream remapping activity. Ms. Napier reported on the proposal through the current grant round of the Salmon Recovery Funding Board (SRFB) to look at remapping basin-wide. The proponent is seeking guidance on what area of the basin to focus remapping activities. One area that has been suggested is the Wildcat Creek in Grays Harbor.
Discussion followed on the appeal process for maps. Mr. Lehr described the process for appealing information and how the information is substantiated.
Ms. Franklin suggested revising item C on page 13 to state, “Signs shall be installed at an interval of one for
every 50-feet as measured along the outer edge of the critical protection area or buffer and shall be maintained by the property owner in perpetuity, unless otherwise approved by Grays Harbor County.”
Ms. Willis referred to the wording on signs as outlined on page 14 and commented on the requirement to place signs in flooded areas. She questioned the practicality of the provision and cited some of her concerns. Mr. Schillinger said the provision places the burden on the property owner. Generally, there are some concerns about the issue of signage. Mr. Rountry asked about the purpose of the signage. Ms. Willis said the signs pertain to addressing the location of protected areas, such as during construction activities where the protected area is marked for protection. In that respect, it makes sense to mark off the area. During a project, it would be appropriate to place signs. However, she questioned the need to install signs to protect wetlands, fish and wildlife habitat, conservation area, geological hazards areas, or aquifer recharge areas.
Members asked how aquifer recharge areas are identified. Ms. Napier said the issue is under debate. Aquifer recharge areas are defined in the Washington Administrative Code (WAC). She noted that for the Grays Harbor CAO there are no critical aquifer recharge areas. However, in the McCleary area, portions of the McCleary watershed aquifer will be designated as a critical aquifer recharge area. The issue mainly pertains to potable sources of water and the areas surrounding potable water and what recharges the drinking water source. In the current CAO, critical aquifer recharge is defined as the watershed and Group A and Group B water systems and its adjacent 100-foot protection area. Grays Harbor is basing the designation on three hydrogeologists who have indicated it is the critical aquifer area for McCleary.
Ms. Spaulding asked about the responsible part for delineating a wetland or aquifer recharge area. Ms. Napier replied that it’s generally based on best available science (BAS) and generalized maps.
Ms. Willis commented on the development of the document through a cut and paste from other jurisdictions’ CAOs. Generally, there is nothing problematic with that process as long as the requirements are applicable to the county. The criticism of the document is that some of the provisions do not apply to the county.
Members reviewed the section pertaining to mitigation and reviewed the descending order of mitigation preferences. Mr. Schillinger said the goal is to achieve no overall net loss of environmental values or functions. Mr. Lehr said the language appears contradictory, as there can be no mitigation without a net loss. Generally, if mitigation concerns wetlands, there is a cumulative net loss as a result of mitigation. Mr. Wiltzius said there must be over time, a loss and gain of wetlands because of climate change.
Mr. Schillinger cited an example of mitigation for some soccer fields in the City of Montesano, which resulted in no net gain of wetlands because the mitigation was completed in an area where there were already existing wetlands.
Members discussed impervious surface and stormwater management. Members exchanged information on how wetlands are defined. Mr. Wiltzius said it should be appropriate to restore wetlands in an area that may already be designated. There should be some common sense applied to those types of circumstances. Ms. Willis said she’s unsure language should be included about restoring wetlands because of previous efforts in mitigating wetlands in areas that are not conducive for wetlands. She suggested the committee’s comments should evolve around the “no net loss” factor and whether it’s possible to undertake effective mitigation. She suggested the language should first include the goal followed by the various mitigation efforts.
Mr. Rountry referred to Ms. Franklin’s previous comments and said it appears there is a theme that has been identified as a need for application or reliance on a professional with the ability to apply BAS. It appears there is a pretty strong theme and the committee’s comments could identify a number of sections, paragraphs, and pages where that should be recommended. It is the intent of the CAO for BAS to be utilized. There is much disagreement that the CAO does use BAS, but in acknowledging that it’s the intent of the CAO, a comment could be conveyed around that theme and a recommendation or expectation that all the steps will be in place to utilize the expertise.
Discuss Roles and Responsibilities Regarding TMDL Implementation
Mr. Rountry reported that at the last meeting, there was a discussion about the roles and responsibilities of the committee compared to DOE as an entity as well as each individual’s role for the organizations represented in the context of implementing the TMDL. The issue has been raised at other meetings as well. He asked members for input on the committee’s role and their respective agency’s role in implementing the TMDL compared to the role of DOE or the Southwest Region Water Quality Program goals.
Mr. Wiltzius said he believes the DOE should develop the DIP, which he believes the agency did with the committee’s input. That is the purpose of the committee, for input with the various stakeholders around the table representing their needs. After development of the DIP, if DOE needs help and desires additional comments or review by the committee, the committee could assist. As far as implementing activities, Mr. Wiltzius said he doesn’t envision the committee undertaking DIP activities other than for those individuals who need to pursue activities as mandated by DOE. The purpose of the committee is to provide a thorough review by a diverse group of members.
Mr. Schillinger agreed. He appreciates the policy discussions that occur during committee meetings. The committee has no significant funding or staffing resources. DOE is a state agency, which has the legal requirement to pursue activities. DOE also has the funding and staff resources to pursue activities. He agreed with Mr. Wiltzius’ observations as the committee acting as a sounding board for priorities that will be achieved by all stakeholders.
Mr. Wiltzius agreed the committee can help promote the success of DOE’s DIP by acting as the sounding board. The success of the DIP without the input of stakeholders is less likely. Hopefully, the committee identified during the process, some issues that helped DOE formulate the DIP.
Ms. Willis said because of the committee’s input in the development of the DIP, there were changes and corrections as to the responsible organizations. Included in the language was the caveat of “when funding is available.” Each organization attested to undertake activities as their portion of the DIP, but only if funding is available.
Mr. Rountry said another activity that has been discussed is conducting sampling and the use of data. There is currently a very strong sampling program in place. He said he’s unsure if everyone is in agreement about the respective roles in both sampling and applying the information. He asked about the use of the sampling data. Mr. Wiltzius said the committee has assisted in moving the sampling program forward through the Partnership and the college. Grants were secured from DOE. The City of Chehalis also contributed some funds. That is a goal or step that the committee has helped promote. As far as using the data, it’s still too early as data collection is still underway. There is much information available because of the efforts of the college. There is a huge database, which is also available on the web.
Ms. Willis said the committee is still mulling over the issue of addressing who, what, and when issues and responsibility. Mr. Wiltzius said it’s up to DOE, as the driver of the TMDL process, to determine where they want to target next. The committee can provide input.
Mr. Lehr said he believe Mr. Rountry’s questions pertaining to the TMDL Program is whether DOE is meeting its obligation to monitor water quality by funding the monitoring program or whether it is viewed as a separate entity and that DOE should undertake separate follow-up monitoring. Mr. Rountry said DOE has a responsibility and a financial commitment to effectiveness monitoring. In the various levels of water quality monitoring plans that were initially developed by consultants and other entities and with the more refined and current sampling plan developed by the Partnership and the college, the objectives of the sampling conducted on behalf of the Partnership by the college and the tribes is more comprehensive, in fact, to help identify sources and to provide some general information on patterns or trends. That information can be compared to the ultimate regulatory goal of achievement of water quality standards. Mr. Lehr said he senses an approaching impasse in way management is conducted and perceived, and that most agencies, despite having more funds than local entities to address environmental problems are recognizing that it’s not enough and that there is insufficient local knowledge to effectively address the nuances of small scale management. Consequently, for most agencies in the U.S., it’s been mandated to promote community-based management of some sort by determining ways to empower citizens and local entities to conduct the management with input and feedback from DOE and WDFW. He noted there is often back and forth communication and assumptions between local jurisdictions and state agencies in terms of funding issues, inadequate resources, and other issues resulting in gaps with each believing it’s the other entity’s job. This leads to misunderstandings and well as questions during the committee’s conversations on how monitoring or implementation should be occurring. He said he suspects DOE supports the idea of a cooperative water quality monitoring program, which empowers the people in the area to be in direct contact in the management of the resource. However, DOE may also be considering that it might also be fulfilling its mandate of promoting community-based management while at the same time, the committee looks at the data as a separate project from something the DOE is doing. If it can assist the DOE then it’s beneficial, but DOE is ultimately responsible for TMDL implementation.
Ms. Willis questioned why DOE wouldn’t want to use the information especially since the effort was funded by DOE. The testing program included another step of ensuring the testing protocols met DOE’s requirements.
Mr. Wiltzius said Mr. Rountry is a standing member of the committee, and as a member and during the development of the monitoring sites; it’s likely the committee would have approved moving some of the sites to help facilitate DOE’s goals. However, without that direction from DOE, the committee selected the monitoring sites based on the best information the committee had. He suggested more input may be needed from DOE if the agency wants to see something different. Ms. Willis questioned whether that is the issue or if it concerns whether the data can be incorporated within the DIP. Mr. Rountry said he has been a little concerned about what he has been hearing in terms of DOE not doing enough to drive implementation and specifically that DOE should be doing its own monitoring. Mr. Rountry said he has been trying to understand the concerns by the committee. For instance, there have been comments such as, “DOE wants a monitoring site here because it’s a 303(d) listed site and it’s the department’s responsibility to monitor that as the department listed it and should keep on top of it, and well as ensuring that there is some corrective action there to restore it to water quality standards.” Mr. Rountry said he has been wondering about it on a philosophical level. It appears the direction of the Partnership, the committee, and the water quality monitoring program is terrific because it’s an approach that works. It’s possible it might not work in other communities because without the initiative and the passion of the Partnership and the college to ensure it was implemented, it’s likely that it wouldn’t be successful. It works here because those commitments are in place. Fortunately, there is an understanding for a need for it at the funding/financial management level to release the funds as well. However, most importantly, and on a philosophical level, this is an approach that respects the interests of the planning group, the Watershed Plan, and the TMDL DIP. People in the watershed want to know what is going on and want to stay on top of current conditions of water quality and supply in order to maintain identified beneficial uses and to take leadership and responsibility locally for using the information to direct future decisions, make changes or improvements, and prioritize efforts. The monitoring program provides for all those things and helps implement the interests of the people and the plan. Based on the feedback by the committee, Mr. Rountry said he is heartened and relieved because it appears the committee’s beliefs as well as his are on track in how the agency and the committee should work together. He said he is also pleased with the Partnership’s action to send the letter to the five entities requesting more information on implementation activities. That speaks to how the issue is of importance to the Partnership. Those entities submitted those activities in support of the TMDL DIP. The activities were not developed by DOE for comment by the entities. Each entity was involved in the development of the information and their expectations on what they could and should do. He said he is happy to see follow through by the Partnership and the Water Quality Committee to encourage entities to continue moving forward.
Mr. Lehr asked whether Mr. Rountry is asking whether the committee feels DOE is doing what it should be doing in relation to the TMDL DIP. Mr. Rountry affirmed that is the question.
Ms. Willis said she agreed but added that she believes when the hotspot was discovered on the Satsop, the conversation with DOE became somewhat eschewed where it became more the responsibility of the Water Quality Committee to narrow the hotspot down and almost engage in an enforcement mode. There is reluctance by many of the groups in terms of enforcement because it’s outside their authority. That role rests with DOE. She said she wants to ensure that the committee doesn’t agree with everything because if conservation districts and other groups are pushed into that scenario in the process of undertaking water quality monitoring, the districts and groups will push back because that is not what they do. Districts will pursue the programs and help landowners, but they are not in the enforcement mode of narrowing things down and pointing fingers. Mr. Rountry offered to follow up with Ms. Willis later on the issue.
Mr. Rountry departed from the meeting.
Ms. Willis said she addressed the last point because there have been other conversations among members that DOE does have an enforcement hat and that other agencies and entities do not want that activity forced upon them.
Transitional Program and Discussion Related to Randy Lehr’s Departure
Mr. Lehr briefed members on the transition of the Water Quality Monitoring Program and other activities after his departure. No changes are envisioned within the program other than in terms of staff resources. For the last year and half he and Don Loft have been working on the program and analysis. Currently, Mr. Loft is moving into a masters program and using funds from the monitoring effort to support his student-directed research at the graduate level. The college will continue collecting more samples through July 2009. Mr. Loft has developed database tools and analysis techniques for the automated database, which will provide updated versions of data. As the project continues to move forward, not only will there be more products related to water quality and analysis, Mr. Loft will be in position to continue moving the effort forward.
Mr. Lehr addressed questions pertaining to the ongoing program and his replacement. Mr. Lehr advised that over the course of the college establishing community partnerships, the college is convinced the approach of having faculty involved in community planning projects is beneficial for the college in many ways. His replacement will be teaching classes directed at fisheries and aquaculture as well as representing the college at local planning meetings and involved in local planning efforts.
Nancy Allison asked whether those duties and responsibilities will be codified within the job description. Mr. Lehr affirmed that it is included in the job description. He noted he is also part of the hiring process for his replacement. Over the last four years, the college has embraced the efforts as a good model for the college. The college is interested in continuing to maintain those efforts and the relationships. He noted when he was first hired community outreach wasn’t a major component of his position. The position has evolved over time as the partnerships have developed. Another position will be filled for similar responsibilities but from a forestry perspective. Once the hiring process is completed, the college will include:
· GIS position focused ½ time on GIS Clearinghouse & ½ time on GIS classes.
· Faculty member ½ time teaching fisheries and aquaculture classes and ½ time as program administration interfacing with the Partnership and the various planning entities.
· Faculty member ½ time teaching forestry and ½ time participating in forest management community work on a watershed management sustainability effort.
· Ms. Spaulding’s position assisting in efforts involved in watershed management.
· Mr. Loft will interface in continuing the data analysis and presentation of water quality data as its generated.
Mr. Schillinger conveyed how sorely missed Mr. Lehr will be.
Mr. Lehr said he is leaving the area the first week in July.
Next Meeting Topics
Ms. Napier reported she is unable to attend the July meeting.
Mr. Lehr suggested adding a discussion with Mr. Loft on efforts he is currently working on in terms of water quality monitoring and areas with consistent water quality violations to identify specific areas of land that might be contributing to water quality issues. He commented on the availability of land use landcover information overlaid on the basin. Ms. Napier asked whether healthy areas will be monitored as well. Mr. Loft said the information is displayed in a contrast to show the areas that are doing well as well as the areas that are not doing so well.
Ms. Napier reported there is another round of Centennial Clean Water grants. She suggested initiating a call for proposals or perhaps consider sponsoring a project. Mr. Wiltzius reported the grants have been significantly reduced. Ms. Napier offered that the committee may want to have a discussion on funding sources to continue the Water Quality Monitoring Program.
Grays Harbor Draft Critical Areas Ordinance – continued
Mr. Lehr referred to provisions addressing variances and said he believes the provision does not evaluate the cost of the variance either economically or environmentally. That would be a potential consideration for evaluating how variances are granted and where they are granted.
Ms. Franklin referred to section 18.06.095 Critical Protection Area Development Standards for Geologically
Hazardous Areas, and suggested the language should also include references to DNR’s soils and steep slopes resource map. Salmonscape is another source that is not mentioned. She suggested using all the available resources.
Mr. Lehr commented on the location of the data and the server where the information resides and suggested it would be acceptable to use the Clearinghouse data for any of the planning entities to inform their decision-making. However, from the legal perspective, the source should be the location of the primary data.
Ms. Napier commented that each adopted the Chehalis Basin Watershed Plan. In the spirit of partnership and cooperation there should be some reference or connection between land use and the watershed planning efforts.
Ms. Franklin commented on the inadequate forms of delineation that often occurs by consultants and others, which often is not based on good science. She suggested the information should be deferred to DOE or engineers who have the experience. Ms. Willis responded to the suggestion and noted such requests would likely bog down the work program of state agencies. The issue is utilizing available resources without burdening the process.
Ms. Franklin commented on the lengthy permitting process and her understanding of why permitting can be so time intensive and laborious. Members agreed the issue is important but the question is how to include information addressing the concerns in the draft CAO in terms of a functional provision.
Ms. Franklin suggested revising section j on page 16 to state, “(j) Hydroseeding or other erosion control methods as required in temporary erosion control plans, shall be utilized and maintained.”
Ms. Franklin referred to the provision on page 17 stating, “(II) The buffer may be reduced when an applicant
demonstrates to Grays Harbor County, pursuant to a special engineered study, that the reduction will adequately protect both the proposed development and the critical protection area.” She asked about language to ensure oversight responsibility if the exception doesn’t adequately provide the protection.
Ms. Willis asked members to send additional comments to Ms. Spaulding. Ms. Spaulding will draft a letter to the Partnership.
Ms. Napier reported the next Partnership meeting is on June 27, 2008. Comments should be sent to Ms. Spaulding by June 17, 2008.
With there being no further business, Ms. Willis adjourned the meeting at 12:00 p.m.
Prepared by: Valerie Gow, Recording Secretary/President
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