Grays Harbor Audubon Society
November 20, 1998
Energy Facility Site Evaluation Council
PO Box 43172
Olympia, WA 98504-3172
Dear Council Members:
Thank you for this extended comment period on the transfer of the Satsop Nuclear Site to Grays Harbor County. We support the effort to take an abandoned state project in a rural area and use it to provide local jobs. I understand some progress has been made related to the protection of the 1,200 acres of mitigation lands, yet several concerns remain and are of high priority.
We have heard that Grays Harbor County and the SRP have agreed to sign a Wildlife Mitigation Plan with WDFW. I am concerned that the public has had no opportunity to review this agreement. In comparison, the current owner of the site, the Supply System, created a mitigation plan following a public comment period and has full responsibility to ensure that the current mitigation plan is followed, with oversight from your council. When a task needs to be completed related to this plan, the Supply System carries it out or hires the right people to do it. I have heard that Grays Harbor County is agreeing to pay WDFW only $2,500 per year to monitor the mitigation lands. Management of 1200 acres of wildlife habitat will require staff, budget, expertise and experience that local county government does not have and $2,500 will not provide. What organization ensures that industrial uses of the site will not intrude in the mitigation area, which are now zoned industrial? When our state's new salmon protection regulations are released, what resources are available to evaluate this effect on the wildlife mitigation area and management plan, and modify if necessary? With the Supply System providing the county fifteen million dollars for this transfer, the interest earned could provide some mitigation management funds without harming the County's economic plan.
Another issue of concern is the length of the agreement to maintain the mitigation lands. Somehow local officials believe that the 1,200 acre mitigation lands only have to be set-aside until the year 2040. What kind of mitigation is this? The taxpayers of the entire state paid for the site and are still paying. I do not believe that they think they are paying for mitigation of all that development only until 2040, unless the developed portion is to be restored to original condition in the year 2040. The original plan was based on s nuclear reactor site, which is very contained, requires a small staff to support, and very well regulated and overseen. Now the site has changed from county zoning of “general development” to “industrial development”, many cars and people will be working there, and uses could be heavy industry. In this light, the mitigation plan must remain in effect forever to compensate for the NEW use of the site. How can anyone possibly think that in the year 2040 we will have made up for all the environmental damage to the site with yet unknown uses? It should also be noted that nothing so far prevents the Grays Harbor County from selling any of these lands if they choose. This possible action was expressed by a County and PUD official when asked what would happen if the site wasn't “business successful” and taxes weren't available to offset that. As he put it “the lands are assets which may have to be sold”.
As you are aware, Grays Harbor County has begun a process to rezone part of the Satsop site. Rather than do a boundary line adjustment and rezone only the 478 developed acres, they are about to rezone 878 acres. This worries me. We hear over and over that most of the mitigation lands are on steep, unstable slopes and that no development could occur there. How many structures have we seen on the evening news sliding off of hillsides? Rezoning doesn't necessarily mean usage, but it also doesn't prevent it. In a county with limited staff to enforce regulations, what prevents it? Stranger things have happened.
An EFSEC Council Member has suggested that a conservation easement be placed on the mitigation lands. This is a wonderful idea and one I believe is a good balance for all parties concerned. Conservation easements are held by a third party land trust that ensures the property is protected in perpetuity for its intended purpose. I strongly encourage EFSEC to require a conservation easement on the mitigation land for purposes of wildlife protection forever, along with a payment of $200,000 for this purpose.
As we understand it when Satsop was to be a nuclear facility a water draw of 80 cubic feet per second was allowed from the Chehalis River. This was never a good idea, especially with continued water withdrawals being granted upstream of this site. When the legislature in 1996 passed the law giving the Satsop site to Grays Harbor County they included the possibility of a water draw of 20 cubic feet per second. What wasn't accounted for at that time was the drastic salmon situation we have today, and water availability in rivers and streams is a critical component of salmon recovery. Unless the County can show a requirement for additional water resources other then the well at the Satsop site, and ensure there is no-negative effect on aquatic wildlife, water rights to the Chehalis should be eliminated.
Thank you for this opportunity to comment.
Sincerely,
CC: Governor Gary Locke
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