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Dear Commissioner Graham and Col. Rigsby:
We want to share with you our commitment to the residents of the Upper and Lower Chehalis Watersheds to produce a flood hazard reduction strategy that is effective, responsive, and consistent with the environmental standards established by the State Legislature and Federal Government. We share the belief that the residents, businesses, farms, facilities, wildlife, and ecosystems located in the Chehalis River flood plain have experienced unacceptable damage from floods over the last decade. We also understand that individuals who experienced flooding are impatient for a long-term and effective solution. To achieve this goal, it is important that we generate an effective, responsible, and legal resolution to escalating flood damage. This letter outlines our concerns about proceeding with the current project approach that may not meet federal and state requirements and, in the long run, may not prove effective for the entire watershed.
The purpose of environmental regulations is to evaluate the consequences of an action on the environmental, social, and economic elements of communities. There are a number of individuals and organizations that believe they have the correct approach to solving the flood problem, but many of these approaches' conflict with each other. Our efforts must be focused on achieving an outcome deemed beneficial to all.
The specific project outlined by your consultant in the Chehalis River Basin Flood Reduction Interim Report, December 1998 primarily focuses on flooding impacts within Lewis County. The propose project is a structural strategy for flood stage reduction, based on a model, which, if developed has the potential to change the hydrology of the entire upper and lower watersheds. We are concerned that the downstream impacts associated with the proposed channelization and flow manipulations on both the Skookumchuck and Chehalis Rivers have not been evaluated adequately and may have dramatic consequences to the residents of Thurston and Grays Harbor Counties along with those of the Chehalis and Quinault Indian Nations. The model must also recognize the challenges and opportunities presented when a flood hazard reduction strategy of this magnitude converges with the current salmon crisis in western Washington. Consequently, it is important that impacts of these project components be examined further before a decision can be made.
The responsibility vested with government officials to examine the consequences of actions developed from models is an important obligation we take very seriously. While the model provides a hypothetical solution for flood stage reduction, it remains an incomplete effort. The model's assumptions for upstream project actions on downstream hydrology must be verified. The investment in dollars of the project coupled with the potential adverse consequences to the population and environment downstream requires due diligence by exercised in decision making. In the urgency of the moment we must not forgo the analysis necessary to address the legitimate concerns of constituents outside your jurisdiction. There must be a thorough review and investigation of other non-structural alternatives which will contribute to the goal of flood damage reduction while avoiding further impact to the natural resources on the basin. Further, we must not miss the opportunity to contribute to the recovery of salmon stocks in the Chehalis Basin through floodplain enhancements. Expanding the goals of this flood damage reduction effort to include environmental restoration and enhancement would increase public and governmental support for the effort, and qualify it for a share of the federal, state and private funding opportunities which are being provided to save salmon.
Neighboring local governments, the Lewis County Flood Control Zone Citizen Advisory Committee and scientists from our staffs have all specified concerns to you about this project being advanced without alternative analysis being complete. This is a requirement of federal and state law that must be met. Moreover, comprehensive testing of the model, in addition to non-structural alternatives, will be an essential requirement of this project. Our agencies are committed too working with you to develop alternatives.
We strongly suggest the Lewis County implement the recommendations in its approved comprehensive flood hazard management plan as well as link its flood management decision making process to the Chehalis Watershed Basin Partnership group. This watershed partnership has received state funding to develop a basin-wide plan that addresses many objectives your are seeking. This is a forum we all support. Further, Lewis County should take a strong leadership role by adopting fill restrictions in the floodplain - one of the principal recommendations of the County's flood plan. The County's current regulations do not address loss of floodplain storage. Other basin communities such as Thurston County, have flood problems less severe than those of Lewis County, but have adopted standards that exceed federal requirements in order to avoid exacerbating flood problems. The Lewis county flood plan also recommends that the County create a mechanism to generate a source of stable, long-term funding to ensure that the County is able to equitably participate in funding any flood damage reduction projects. While the form of this district or special utility is a local decision, it is imperative that the County demonstrates its commitment to fully participate in funding any proposed solutions.
We believe that an aggressive strategy of floodplain preservation which considers watershed impacts will result in the protection of existing flood storage areas which are crucial to a long term reduction in flood hazard. This in turn will result in less new development being subjected to flood risks and will allow for the development of alternative approaches which make use of the preserved storage. Again, while we are committed to working with you to develop a solution that benefits all concerned, we cannot abdicate our responsibilities to protect the population and environment of downstream communities from the consequences of upstream project actions that are narrow in focus, and potentially harmful.
In conclusion, we believe it is necessary to review the full range of alternatives and impacts in an open dialogue with officials from all communities and tribal nations potentially affected by your project action. The watershed process currently underway in your community provides such a forum of opportunity. The commitment by all parties to resolve flood and environmental issues in the Chehalis basin is strong; the resolve to work out differences must be equally strong.
Please continue to work with Jerry Alb, chair of the Flood Hazard Reduction Technical Committee, to develop feasible alternatives to resolve the flooding issues in the Chehalis Basin. Jerry can be reached at 306-705-7480. | 
