Brady Engvall
3714 Oyster Pl. E.
Aberdeen, WA.
98520

City of Westport
Fred Chapman-Public Works Director
506 N. Montesano Street
Westport, Washington
98595

RE: Shoreline Substantial Development Permit and Preliminary Plat for Cohasset Park

Dear Sir,

The Expanded Environmental Checklist for Cohasset Park Subdivision is deficient in addressing historic wet season flooding and ponding conditions associated with the project area and it's environs. It did not address cumulative impacts and is a good example of segmentation and piece-mealing of a development project. The Department of Ecology(DOE), Grays Harbor County (County) as well as Westport (City) have extensive knowledge of this issue including beach areas such as: the Long Beach Peninsula, Grayland, Westport and Ocean Shores. In fact Ocean Shores is experiencing serious contamination problems in waterways especially constructed to retain and discharge surface waters. Or put another way, "an engineered solution". The problem area is a low coastal swale, between two sand ridges, with very little down gradient. This precludes the expelling of heavy seasonal rainfall which results in seasonal ponding and lake like conditions. The Checklist shows little regard for this current situation and in fact glosses over these well understood historic coastwide conditions.

Also in the vacinity of this project there are a number of undeveloped plats that will assuredly add to elevated water tables as they are built out in the future.

We also have a situation where the City and County award Grade and Fill permits that are not monitored for compliance. This leads to unregulated development at its worst.

As expressed in the Draft South Coast Flood Hazard Management Plan the County drains an area from Schafer Road/SR 105 to the City where the City impounds the water within the City limits and an area north of Ocean Avenue (Washington State Park lands). As reported by a conversation with Westport Public Works Director, Fred Chapman, there is no surface water flow from the Westport ponding location to Grays Harbor through a ditch near Holand Center. This means we have a lake/ponding condition by definition and any additional runoff, from additional development and filling, will have negative impacts on an already impossible situation.

The present high water conditions are impacting City and County residents.

These impacts come in the form of service road flooding, high water around homes and flooded septic and drain field systems. The last item mentioned is a major concern. This is a public health and satety issue and precludes any other consideration.

Failed septic systems are against the law. Water, by its very nature, will distribute fecal colliform and its potential health hazards to all locations where it flows. I 'm not comfortable with the idea that contaminated surface water will not reach the estuary at a future date.

Especially if the Draft South Coastal Flood Hazard Management Plan is adopted as proposed.

Poor policy decisions, that are carried out on land, eventually manifest themselves in the waters of the estuary. Currently the GH estuary is on the EPA 303d list, which means - they do not meet historic beneficial uses for public waters, and Total Maximum Daily Load (TMDL) studies are concluded. TMDL's mean that if, in fact, it is shown that G.H. is polluted then regulatory land use decisions, to protect the estuary, are on the way. This is to make well a compromised water body that we as citizens all use and enjoy. I'm sure, we as a group would concur, keeping Grays Harbor healthy and its profound benefits to local citizens and State residents alike is a worthy goal.

At the very least the Cohasset Park proposed plat should undergo a full EIS (Environmental Impact Study) to define its cumulative impacts in a clear and thourgh manner. And at the same time the City and County (in a collaborative effort) move forward with a comprehensive drainage plan that meets the needs of the respective jurisdictions and citizens into the future. Thank you for the opportunity to comment on this SEPA process.

Sincerely,

Brady Engvall    Member of:  Chehalis River Council
                                  Friends of Grays Harbor (FOGH)
                                  Citizens For Responsible Development
cc: Washington State Department of Health
      GH County Department of Health
      DOE -Shorelines Division