Oct. 15, 1999
Mr. Fred Chapman,
Lewis County Building Official
360 N. Market Blvd.
Chehalis, Wa. 98532
Fax: 740-1245
Re: Placement of Stockpile of fill dirt on Hamilton property, West of Rush Rd. and East of Newaukum River.
Dear Sir;
I hope by this time you have had a chance to view the flood video we gave you on the 13th., of the Feb. 1996 flooding of the Hamilton and Tri-Mt. property and the Rush Rd. vacinity of Exit 72 off I-5.
In our conversation of Oct. 14, 1999, you stated, Jerry Graham had let it slip that he had buried a bus in this frequently flooded area, will anything be done to dig it up and remove it from the property? Have you learned any more on the Mobil home Mr. Graham placed on the river bank of the Newaukum River? Both of these issues are very concerning to the fish and wildlife habitat in this frequently flooded area.
With the county looking to federally fund an $80,000,000. flood reduction project which includes excavation of 3 million cubic yards of earth from the flood plain, allowing fills and stockpiles of fill to be put into the floodplain and frequently flooded areas makes no common sense.
Floodplain Management, Executive Order 11988 of 1977
Summary: Directs all Federal agencies to avoid, if possible, development and other activities in the 100-year base floodplain. Where the base floodplain cannot be avoided, special considerations and studies for new facilities and structures are needed. Design and siting are to be based on scientific engineering, and architectural studies; consideration of human life, natural processes, and cultural resources; and the planned lifespan of the project. Federal agencies are required to:
Reduce the risk of flood loss Minimize the impact of floods on human safety, health, and welfare Restore and preserve the natural and beneficial values served by floodplains in carrying out agency responsibility Implementing guidelines: 40 CFR 6030
The Tri-Mt. fill project, across the road from the proposed Hamilton fill project; On page #9 of the Tri-Mt. Hyd. Assessment, the report states,
Filling in the floodplain will only have an impact on downstream properties as the amount of stored floodwater upstream is reduced. A loss of this small volume of storage is insignificant when compared to the total floodplain storage area and any effect is dissipated within a short distance downstream of the fill. (3) (4) (5) (6)In this study they fail to do scientific studies on the other fills that are involved in cumulative displacement of this flood plain.
The study does not take into account, five (5) fills that have gone into or are permitted for the area of this floodplain.
Two fills, (6) unregulated, and uncalculated have been placed in the same floodplain to the west of Rush Rd.
Three other fills are either in, or permitted in the storage area to the East. None of these are calculated in the proposal.
The Technical Analysis To Evaluate Impacts Of Fill, prepared by Northwest Hydraulic Consultants Sept. 1997, does not calculate the impact of these fills for cumulative displacement. Page five (5) of this study says, for the February 1996 flow conditions, the water level will increase 0.5 to 0.9 ft., which is within the standard FEMA regulatory floodway 1.0 ft. allowable rise. The report says, with the proposed fill the water level could be raised 10.8 inches, this leaves us with 1.2 inches before hitting the FEMA threshold of 12 inches, to accommodate the cumulative volume of the other five (5) fills in this floodplain.
One Hamilton fill, on the west side of Rush Rd. contains over 20,000 cu. yds.,(7) and was not used in the calculations for cumulative water rise in the floodplain. (6) This additional fill would push the projected rise well over the FEMA allowable rise. Which designates this area a floodway and therefore pursuant to LC Code15.35 Item (b) page 9. Filling in the floodplain will only have an impact on downstream properties as the amount of stored floodwater is reduced. For the record, We are the impacted downstream properties! Lewis County has done no cumulative floodplain study of the entire floodplain to stay within FEMA regulations.
This stockpile, and the fill which has already been placed on this property, will block, change the course and divert floodwaters of the Newaukum River and cause increased flood damage to private and public property.
As Lewis County is involved in and receives millions of dollars each year from FEMA, The State of Washington, NIMF, for fish and wildlife habitat and restoration, flood reduction and flood damage. Allowing the fill and placement of obstructions in known frequently flooded areas which will divert floodwaters, cause flood storage to be lost, and alteration of natural floodplains, is in direct opposition to the policies to protect human life, safety and property of the citizens of Lewis County, and degradation of fish and wildlife habitats we are trying to preserve.
As we are going into flood season, we hope you will wisely use all information available to you to make an educated decision on the very important mater.
Written Response Requested
Sincerely,
Dan Smith & Tammy Baker
575 Newaukum Vly. Rd.
Chehalis, Wa. 98532
cc.
SWAT
BOCC
LCFZAC
CRC
FEMA
WSEMD
WSDOT
WSDOE
WSF&W
GMA
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