Kings Ridge Comment Letters

Subject:  Go East Landfill/Bakerview Proposal

Comments on the Mitigated Determination of Non-Significance (MDNS) for the Go East Landfill/Bakerview development should be submitted to Snohomish County before September 13, 2017.

Address comments to:

Paul MacCready, Principal Planner

Snohomish County Planning and Development Services

3000 Rockefeller Avenue, M/S 604

Everett, WA 98201

Or via email to:  paul.maccready@snoco.org

Put RE: Bakerview, PFN: 10-101204 SD

Following are some thoughts you may choose to include in your letter.  It is best to use your own words.  Be sure to include some sort of statement about the necessity of an Environmental Impact Statement (EIS).

I/we disagree with the County’s recent SEPA threshold decision of MDNS for the Go East Landfill/Bakerview project.  From the beginning, this project has had complexities that warrant thorough analysis and consideration of design alternatives that would present lower risk and far fewer impacts to human health and the environment.  An Environmental Impact Statement should be prepared.  Problems with this project that still have not been resolved include the following:

·       Inadequate site characterization, in particular not identifying all the areas where waste has been deposited.

·       Insufficient analysis of existing groundwater quality and potential impacts to groundwater.  The proposed groundwater monitoring system is inadequate.

·       Insufficient attention to the problems of steep slopes and creating new steep cut slopes immediately adjacent to residential properties.  This could lead to landslides, as some nearby homeowners have experienced firsthand, failure of the landfill cover during an earthquake, blocking of the stream that exits the site and causing downstream damage to culverts and roadways, exposure of buried waste, and a very expensive repair project.

·       Lack of clarity in the landfill closure plan regarding the handling of waste that will be excavated, then reburied or sorted and stored for use or disposal offsite.

·       Creation of stormwater ponds on top of the landfill cover, not fencing the ponds, and creating a public hazard with steep slopes rising directly above the stormwater ponds.

·       Providing only one entrance to a new residential development, when County design standards require two access points where over 250 vehicle trips per day are anticipated.  108^th St SE below 39^th Ave SE is already well over this threshold.  The proposed development would exceed this level by over six times, with the addition of approximately 950 daily vehicle trips.  This is an issue for current traffic levels on 108^th St. SE, but more importantly this is a huge concern in the event of fire or earthquake.

·       Truck traffic up and down 108^th St. SE and on 35^th Ave. SE during construction will create a mess at the 108^th St and 35^th Ave intersection, right beside the fire station; will damage the pavement on 108^th St SE, which was not designed to carry this level of truck traffic; and will create a huge noise impact for all the residents along these two streets, lasting for months.

·       The stormwater management system is inadequate, and there will be damage to the two streams receiving stormwater from the site.

·       Landfill gas from the closed landfill is a huge concern, especially because new houses in the Bakerview development may be as close as 8-15 feet from the edge of the landfill itself, and the landfill gas management and monitoring systems are inadequate.  Landfill gas acts as an asphyxiant and is also explosive above a certain concentration.

·       All the trees will be removed from 10 acres on the landfill property, creating a huge exposure potential as contaminated dirt and dust become airborne and affect nearby residents.  The risk of asbestos-containing material also becoming airborne is significant, and there is no zero-risk level for asbestos.  This is especially concerning because there are young children living in homes that are immediately adjacent to the landfill, and there are many others in the neighborhood who already have compromised respiratory systems.

·       Construction noise will be unbearable for those residents adjacent to the landfill, with multiple pieces of large construction equipment operating simultaneously.  Noise levels will exceed safe levels, and levels stated in Snohomish County Code. Proposed noise mitigation is inadequate.

·       The lots in the proposed Bakerview development are less than one-third the size of those in Kings Ridge and The Point.  This means the backyards of some existing homes will soon be adjacent to the backyards of THREE other houses, without any sort of mitigating vegetative screen, and completely destroying any sense of privacy.  This proposed lot size is entirely inconsistent with the adjacent neighborhoods and will affect property values negatively.  Preserving a buffer of existing mature trees would be a simple and effective way to at least screen the existing homes from the ugly bare earth of the new development, screen some of the fugitive dust, possibly reduce some of the construction noise, and separate the crowded new development from the existing, far less dense, adjoining neighborhoods.

·       To allow liability for the landfill and responsibility for post-closure care to be passed to a future homeowners’ association is unconscionable.  There is no guarantee of a viable future homeowner’s association.  And the level of technical expertise required to perform groundwater and surface water monitoring, maintain a landfill gas monitoring and management system, maintain stormwater ponds on top of a landfill cover, do regular inspections for erosion over the entire landfill cover, accomplish repairs where erosion has caused damage, and so on, are not activities a homeowners’ association should be expected to carry out or even hire contractors to do.  What happens is there is a catastrophic failure of the landfill cover?

·       The landfill closure plan does not provide an adequate plan for preventing erosion of the landfill cover, for seeding it, watering it while the vegetation gets established, mowing it, or for maintain the drains that cross the cover.

·       The Snohomish Health District (SHD) did not do a good job of overseeing the landfill when it was operating in the 1970s and 1980s.  SHD failed to require closure of the landfill when it should have been done after the landfill ceased operation in 1983.  Now, SHD has twice approved landfill closure plans for this site that were grossly inadequate. This third approval appears to be equally flawed.  Even more troubling is that the Health District still does not have a single engineer on staff who is actually qualified to review and approve such a plan, especially for a project that has as many added complexities as this one does.  Even if a more robust plan than this one eventually gets approved, we have no confidence that SHD can oversee construction of this project and ensure that it will be done in a manner that fully protects the health and well-being of residents living near the landfill property.

·       PACE Engineering, co-owner of the Go East property and the primary author of the landfill closure plan, has no prior experience in designing a landfill closure.  Their inexperience plus SHD’s lack of technical expertise and SHD’s failure to hire an engineering firm at the outset to review the landfill closure plan, has led to an awkward sequence of repeated plan revisions and reviews over the last seven years.  And the closure plan is still grossly inadequate.  SHD did not even bother to attend most of the hearing in 2015.  Moreover, SHD and the project applicant have ignored nearly all of the Department of Ecology’s comments on the closure plan.  Ecology’s comments were produced by an experienced landfill engineer and an experienced hydrogeologist.

·       An Environmental Impact Statement (EIS) is critically important for this combined landfill closure and residential development project.  Even after seven years of review, the project has not one or two, but MANY substantial flaws.  An MDNS is a flagrant dismissal of the many technical issues that were exposed and described by environmental experts during the MDNS appeal hearing two years ago, and most of which still have not been addressed.  An EIS would require the applicant to come up with design alternatives that would actually reduce the probable significant adverse impacts identified in the project.

·       Issuing a second MDNS for this project is a mistake and an affront to us who have spent a great deal of money and time attempting to point out to the County and SHD what is wrong with this project. It is time for the County and SHD to do their job to protect existing County residents, and not to pander to developers who bully them and demand approval of an ill-conceived, poorly designed proposal.