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May 5, 2009 TO: Bobak Talebi, Island County Planning Dept. FROM: Joan Schrammeck and Allison Warner, on behalf of
Camano Action for a Rural Environment (C.A.R.E.),
PO Box 1742, Stanwood, WA 98282 RE: Public Comment on 026/09 SPR and 090/09 ZCI (TR Camano’s Anchor Bay) Background: In the summer and fall of 2008, the Board of Island County Commissioners voted unanimously to adopt an "interim official control" ordinance composed of temporary regulations regarding commercial development at three non-residential rural areas of intensive development -- RAIDS -- along SR 532 on Camano Island. The interim control could last for six months while the County pulled together a committee of Camano residents to gather public input and work with the then-Island County Planning Director Jeff Tate and County Planner Bobak Talebi on a plan for what Camano people want for the few properties that are zoned for commercial development along the 532 Gateway. At the time this process began the affected properties were zoned Rural Village (RV). The idea was to create a new Camano Gateway Zone. David Platter of TR Camano was invited to participate and he did so, along with 10-12 other residents. I believe all of the business and property owners along 532 were invited to participate. At the end of the process there was near unanimous agreement that gas stations and convenience stores were not suitable and would not enhance the 532 Gateway to Camano, primarily because of the negative impact that left turns would have on traffic flow by causing accidents and/or necessitating new signal lights. Planning Dept Director Jeff Tate strongly recommended no gas stations or convenience stores based on traffic concerns. The Gateway group sent their recommendation to the Island County Planning Commission which overturned the staff/community recommendation and altered the proposed new Gateway Zone to add back in gas stations and convenience stores. The two recommendations are pending before the Board of Island County Commissioners which has not yet reached a decision (public hearing is scheduled for Tues, May 19). In the meantime, TR Camano submitted 026/09 for Site Plan Review and 090/09 for Zoning Code Interpretation. C.A.R.E strongly opposes this proposed site plan application and zoning code interpretation for the following reasons. 1) THWARTING PUBLIC PROCESS: Approving this site plan would completely subvert the community process that was initiated by the (previous) Board of Island County Commissioners in summer 2008 and welcomed by Camano residents. It is tyranny by a minority, in this case a minority of one, a person who participated in a community process and was outnumbered.
CARE applauds the Board of Island County Commissioners for an inclusive public process to chart the future of the Gateway. Now we wish to have Camano resident’s vision take hold. 2) SEVERE NEGATIVE IMPACT ON TRAFFIC: Allowing this site plan composed of a gas station and convenience store would have a dramatic and severely negative impact on all Camano residents who travel 532 in peak hours (6-9 am and 2-7 pm), including most if not all C.A.R.E. members. Even with a light and a turn lane, people turning left could cause severe accidents and untold dollars worth of damage. Slow downs created by a new traffic signal at Good Road would dramatically slow progress of traffic onto and off of Camano Island. The added signal could add 10 to 15 minutes or longer to people’s commute. The 532 corridor is already jam-packed with cars during peak hours. The slow-down of the flow of traffic is a significant issue that must be addressed in the SEPA process. We do not feel that the transportation concurrency adequately addresses the traffic issues on SR 532, with backups already occurring regularly on SR 532. The County does addresses the concurrency for Good Road, however, the issue on SR 532 falls into a loophole through lack of coordination with Washington State Department of Transportation (WSDOT), leaving the traffic issues on SR 532 unaddressed. TR Camano has not yet obtained a permit from WSDOT for access or for the intersection improvements. The land use permit should not be issued without the State road improvements being authorized by WSDOT. 3) PUBLIC SAID NO TO GAS STATIONS/CONVENIENCE STORES: In the process of rejecting the staff/community recommendation to not allow gas stations/convenience stores, the Planning Commission held a public hearing which was attended by approximately 50 people. When the attendees were asked if they wanted gas stations/convenience stores, approximately 80-90% of the attendees said “NO.” At a subsequent meeting when the Planning Commission made their decision to recommend inclusion of gas stations/convenience stores, they commented that they had never received so many letters and emails on any issue as they had on this one, with the implication being that Camano residents pro-actively contacted the Planning Commission writing against gas stations/convenience stores being allowed in the new Camano Gateway Zone. 4) SEPTIC NOT YET APPROVED – TR Camano is required to show proof of approval from the State of Washington that the targeted drainfield can accept septic flow from the specific uses and gallons per day resulting from the proposed development. This proposal must not be allowed to move forward until TR Camano submits evidence that the State Dept of Health has approved the specific use and additional gallons to be added to the drainfield at Terry’s Corner. An application has not yet been made to the WA DOH for this approval .
At this time, Mamdouh El-Aarag, the person at WA DOH who is responsible for LOSSes in Island County, knows nothing about TR Camano’s plans to develop their land north of 532. Furthermore, Mamdouh el-Aarag knows nothing about TR Camano’s revised site plan adding 4 buildings with 24 housing units in that were approved by Island County. Before approving either Anchor Bay, or changes to Bay View Park, Island County must require that TR Camano obtain State DOH approval on the septic volume and uses. At this time TR Camano’s septic permit for the earlier phase of Bay View Park has expired (in Mamdouh’s words it is considered “null and void.”
In coordinating with WA DOH on approval of the LOSS drainfield, Island County must revisit the issue of export of water from the Juniper Beach aquifer to the offsite drainfield via the septic line. Since salt water intrusion is an issue in this watershed, re-infiltration of water drawn from this aquifer within the watershed is a significant issue for SEPA, and should be an aspect of the Salt Water Intrusion analysis. The cumulative effects of various phases of this project must also be addressed, in that the resulting 5 million gallons of water per year exported from this aquifer represents a doubling of the current use. Given that the Juniper Beach residential community was excluded from being considered a RAID based on the issue of extreme salt water intrusion risk (in 1998 when the comprehensive plan), Island County must coordinate with WA DOH on this issue, rather than just defer to their permit process. (see attached emails from Mamdouh El-Aarag to Island County DOH and to Joan Schrammeck) 5) PROOF OF WATER SUPPLY MISSING – There is absolutely no proof in the application that Juniper Beach Water District or any water district will provide water for this development. TR Camano’s application is incomplete without documentation of an agreement on the source of water. (see attached email from Erica Peterson at State Dept of Health) C.A.R.E. is extremely frustrated that we are witnessing a third land use proposal pending when the approval of water by WA DOH for any of the three remains incomplete and unfinished. 6) TRANSPORTATION CONCURRENCY INCOMPLETE / SIGNAL LIGHT BURDEN MUST BE PAID BY THE APPLICANT - The Transportation Concurrency Certificate states that the addition of traffic due to this development will require the installation of a traffic signal at Good Rd and 532 which must be paid for in full by the applicant TR Camano, although this is not completely clear from reading the Certificate. Island County must make it clear to the public via these documents that TR Camano bears the full financial responsibility for the cost of the new signal light’s design plan, purchase and installation.
Furthermore, it must be pointed out that the transportation concurrency does not consider the negative impact that vehicles will have on existing traffic while turning in and out of the gas station/convenience store at peak hours, even with the addition of a signal light will have on existing traffic. The signal and the turning vehicles will have a dramatic negative impact all other vehicles using 532. Almost no one will benefit from a light being installed there. In fact, Camano residents will be injured by the addition of a signal light, due to slower moving traffic, longer commutes, creation of greater air pollution from idling cars and the burning of additional gasoline in those cars, all of which cost us more money and create health issues from additional car exhaust added to our environment. 7) NEGATIVE IMPACT ON EXISTING CAMANO ISLAND BUSINESSES – Camano Island currently has three small gas-convenience store businesses (Elger Bay Store/Gas, IGA Plaza Texaco and Huntington’s Market). One or more of these longtime locally-owned businesses could easily collapse if another gas station/store opens on Camano. There is absolutely no community need for another gas station. There currently exist three (3) gas station convenience stores in Stanwood approximately 1 mile east of TR Camano’s property. We believe new development should be required to conduct some type of economic feasibility and impact study before moving forward. We do not want new development to negatively impact existing businesses, and we don’t want more empty buildings for which no tenants can be found. 8) ACCESS TO 532 MUST BE RECONSIDERED – In their application TR Camano claims that they have “grandfathered” access to public roads. Upon talking to the WSDOT, it is clear that the Spare Room’s existing access does not apply to an entirely new development and wholly revamped use of the lot. Given that TR Camano has not disclosed appropriately the requirements in answering questions in the SEPA documentation, C.A.R.E feels the County should not have considered the application complete. TR Camano needs to proceed in the permit process in good faith rather than claiming rights it clearly doesn’t have. 9) NO MORE EYESORES – It seems TR Camano applies for land use permits and then does not complete its projects. Currently TR Camano’s property on the south side of 532 is an eyesore of overturned soils, weeds, and parking lot lamps. We Camano Islanders request that TR Camano not be allowed to begin this project until every last detail is final and approved. We want no more eyesores. 10) WETLANDS? Island County adopted a new process for finding and classifying wetlands. The property owner is responsible for looking for wetlands and bringing them to the County’s attention. TR Camano simply wrote “no wetlands on site” on their application. Since there are no boxes checked “no” it is clear that TR Camano did not actually evaluate their parcel by going through the checklist of things that would indicate a wetland. This is unacceptable. Island County must inspect the site for presence of wetlands as other wetlands are known in the vicinity. 11) COMMERCIAL SEPTIC IN A RESIDENTIAL AREA IS IMPROPER – We reiterate our view that it is improper for a commercial venture to be allowed to deposit septic in an offsite drainfield in a distant residential neighborhood. The State of Washington should never have approved the septic design because state law requires offsite septic drainfields to be “nearby.” Respectfully submitted, Joan Schrammeck and Allison Warner for C.A.R.E.
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