October 8, 1999
Kathleen Kunz
NEPA Coordinator
U.S. Army Corps of Engineers
ATTN: CENWA-PM-PL-ER
P.O. Box 3755
Seattle, WA 98124-2255
Dear Ms. Kunz,
I attended the Corps of Engineer Environmental Impact Statement scoping meeting, September 29th at Rochester High School. I have a number of concerns about the flood project. This letter is an attempt to describe those concerns, the basis for the concerns and present some recommendations.
The plan(s) is concerned about the losses sustained by the residents in the project area. My heart really goes out to them. Many of them have experienced ever increasing flood damage, yet they individually did nothing to cause it.
The Corps of Engineers should be concerned about the health and safety of the floodplain residents who live downstream of the project area; our needs are being overlooked.
As the Corps works through the various processes and procedures it must consider the significant impact the final decision will have on the lives and safety of residents in the watershed.
The financial and hydrologic models are just that 'models'. The results have to work in a real world - a real world which has been managed and altered by human occupancy - and a real world which does not respond to rules of the model world or the theories behind the existing floodplain modifications. Rain will still seek to run downhill, rivers will always seek the shortest course to the ocean - and real flood water sees constructed solutions only as a temporary obstacle to be overcome.
Risk based economic analysis appears to be the bottom line for selection of alternatives. A large part of the financial concern seems to be associated with transportation delays associated with flooding along Interstate-5. As the alternatives are evaluated I will be interested to see how the proposed models evaluate the potential for loss of human life versus the benefits of no transportation delays.
Finally, here are two questions that need consideration:
Would the solution be the same if the entire floodplain was in Lewis County?
Would the solution be the same if the employees of the consultant, the Corps of Engineers, DOT, DOE, FEMA and USGS actually resided in the floodplain?
Sincerely,
Dave Palmer
7475 State Route 12
Oakville, WA 98568
Attachment: Concerns and recommendations
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1. Concern: Floodplain Fill
Residents downstream of the project area (defined as: the cities of Centralia and Chehalis and the urbanizing area immediately adjacent) feel that floodplain filling in the project area is a Significant Issue. The current authority which is dated in 1986, predates 13 years of extensive growth and filling in the Centralia - Chehalis floodplain. A decision made in 1986 based on project work completed before 1986, could not have anticipated the changes which have taken place.
Basis for Concern:
I offer as evidence the enclosed chart, Rainfall Comparisons. The chart shows total rainfall for a rain year. A rain year, for my purposes, begins in October and includes all precipitation through April of the next year. The big flood of 1996 is shown as rain year 1995. The data for this chart came from
(Select the following to go to:) http://www.ncdc.noaa.gov/pub/data/coop-precip/washington.txt - it is provisional and some months had no valid record - therefore the displayed values are understated.We've experienced two recent major floods in the Oakville area. January of 1990 and February of 1996. A review of the chart will show there have been many years in the past when the rainfall exceeded those two years - yet there wasn't the major flooding that took place in 1990 and 1996. Upstream impacts seem to be one of the contributing factors.
2. Concern: Focus of Study
The current study area (the cities of Centralia and Chehalis and the urbanizing area immediately adjacent) seems far too limited.
Basis for Concern:
As the rainfall chart shows, significant rainfall occurs outside of the study area. Unfortunately there are no other official rain gages in this part of the watershed, but the evidence seems to indicate that while there is a strong relationship between rainfall in Centralia and rainfall in Oakville - there are significantly different extremes between normal and peak readings in the Oakville area.
It is extremely troubling that there is no documented rainfall history for the area at, or above, the Skookumchuck dam.
There do not appear to be any stations that record rainfall for the Scatter Creek or Black river drainage.
How can operating limits for the Skookumchuck dam be proposed (in hopes of smoothing out the flow at Grand Mound) when critical rainfall levels are not known, and when they are known there is significant variance between existing recording stations?
3. Concern: Project Area Flooding versus Downstream Flooding
We are experiencing more frequent flooding downstream. Rainfalls which shouldn't cause flooding now are cause for concern. It seems that the upstream flows are now displaced from their floodplain and the downstream residents are paying the price. Lands which normally didn't flood, are now flooded and Highway 12 at the Thurston - Grays Harbor county line is frequently closed.
Basis for Concern
I offer as evidence of my concern two charts (1997-1998 Flood Season, and 1998-1999 Flood Season) which reflect gage levels for the Skookumchuck river (at Pearl Street), the Chehalis river at Centralia, the Chehalis river at Grand Mound, the Black river (close to Hwy 12 bridge), and the Chehalis river at Porter.
In 1997-1998 the Chehalis river at Centralia crested above flood stage 1 time. The Chehalis river at Grand Mound crested above flood stage 5 times. The Skookumchuck river never reached flood stage. The Black river crested once.
In 1998-1999 the Chehalis river at Centralia crested above flood stage 5 times. At Grand Mound the Chehalis river crested above flood stage 9 times. The Skookumchuck river crested above flood stage 1 time. The Black river crested above flood stage 9 times.
Any attempt to minimize the flood problem in the project area would seem to add to the flooding situation that already exists downstream. Attempting to smooth out the flow in the project area can only add to the flood waters that already impact the downstream area.
4. Concern: Structural Solutions
The entire solution seems to be based on structural approaches.
Basis for Concern:
I've already expressed my concern about filling in the floodplain. However nowhere in the plan is there any concerted discussion on new building standards or the abandonment of the floodplain. It does not appear that the Corps, or anyone, is seriously evaluating relocation of flood damaged properties or restoration of floodplain capacity. Each of the alternatives seems to focus on allowing full use of the floodplain, without restriction, and without a moratorium or change in permitting or building practices.
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The project area is certainly an area of industry, retail and residential importance. It is an area which has seen an explosion of growth and development, especially alongside the I-5 corridor. However the recent occupants of that floodplain built and moved there knowing that it was a floodplain - but they felt the risk was worth it. Now it is claimed that flood episodes take place in the project area too many times.
While I agree that upstream flooding does occur, and that the occupants of the flood area are impacted, I object to a solution which would seem to increase the impact on downstream residents. Moving project area flood waters downstream sooner will not help downstream residents.
Floodplain fill
I feel that the Corps of Engineers must reinvestigate the floodplain, document their findings, and determine, year by year, the cumulative impact of floodplain fill that has taken place - at least since the date work began on the current authority (Section 401(a) of the 1986 Flood Control Act (PL-99-662)) which appears to have been started before 20 June 1984. Therefore the investigation should go back perhaps to rain year 1981, when large rain events did not trigger major downstream flooding.
A hydraulic analysis should be performed year by year to determine the contributing factors which have led to the current flooding situation.
Study area boundaries and new studies
The current study area has to be expanded and treated as one inclusive and comprehensive unit. The entire area historical rainfall patterns need to be researched and analyzed. The proposed highway improvements (Interstate 5 and State Highway 12) need to be incorporated into the floodplain modeling and hydraulic analysis.
There are so many influences outside of the existing study area that in the name of human health and safety they cannot be ignored. I firmly believe that if the portions of Thurston County and Grays Harbor County that are the subject of this letter, were instead part of Lewis County, there would be a totally different solution.
Regulatory changes and relocation
It would seem that part of this extensive project should be the analysis of the benefits that could be accrued by regulatory change and relocation. If floodplain development continues at the current rate - what will the future costs be? If floodplain development is restricted what would the future benefits be? If existing structures between the 50 year and 100 year flood levels (or the 25 year and 50 year or any other combination) were relocated what would the future benefit be? What would these regulatory or relocation actions do to the total cost of the project and what would the downstream benefits be?
Stakeholder participation
I realize that the legislature in 1998 established a technical committee comprised of WSDOT, WaDOE, US Army Corps of Engineers, FEMA, USGS, affected counties and tribes to resolve the flooding issues. However this committee structure totally ignores the stakeholders in the watershed. U.S. Census data reports have proven that 52% of the watershed population lives outside of the incorporated areas - and they are not represented. If the technical committee, and the legislature are serious about resolving the flood issue then the residents have to have a voice in the decision making process.
Studies and research materia l
In addition to the well known reports published by county and state government, there are a number of other study sources available. For example:
Bibliography of Published Reports and Maps Related to Water Resources of Washington State as published by the U.S. Geological Survey and Washington State Agencies - Compiled by Luis A. Fuste, Hydrologist (Biologist)- Information Officer, U.S. Department of The Interior, Geological Survey, Water Resources Division, Washington District Office, 1201 Pacific Avenue, Suite 600, Tacoma, Washington 98402. Many of these reports predate computers and are not available through traditional sources.
Many of the residents of the watershed are 2nd and 3rd generation. Within their families exist written records of previous flood years. Hopefully the Corps seeks out this data.
WDNR has an extensive aerial photo library - dating back many years. These photos will document many years of landscape modification and can serve as a history lesson as the Corps analyzes alternatives.
Several of the communities have historical societies and/or museums. Within these organizations there is a lot of unpublished, and therefore commercially uncataloged, information. Certainly the Corps would benefit by requesting assistance from these groups as the Corps seeks information on flooding.
Bridges and culverts - Highway 12
A casual inspection of the Black river bridge over Highway 12 in Grays Harbor County shows an extensive amount of back fill under what appears to have been at one time a wider bridge expanse. There are other culverts on this road and county roads that demand attention. Were these at one time bridges? Have old floodways been filled with rip-rap, to save maintenance costs? Even the new culverts (just placed in September 1999) at the Moon Road and Highway 12 intersection have been partially filled with rip-rap. There are old flood channels along Highway 12 which are blocked by rip-rap, where they intersect Highway 12. The Corps must research the historical records from the various counties and the state to see what flow modifications have been done in the name of roadway improvements.
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