PC329_Tom_Clark_11-13-2018From:Brenda Clark
To:Lori Barlow
Subject:Painted Hills Planned Residential Development SUB-2015-0001/PRD-2015-0001/FPD-2016-0007
Date:Tuesday, November 13, 2018 4:23:27 PM
Dear Ms Barlow,
I previously expressed my concerns associated with the above referenced proposed
development in an e-mail to you on 9/26/2017. My concerns outlined in that letter are stillvalid and I am hopeful that they along with the items below will be addressed in the upcoming
EIS which has yet to be completed.
I have been made aware of a new plan to mitigate the concerns associated with the proposeddevelopment lying in the 100 year floodplain. It is my understanding that the developer is
intending to elevate the site to an elevation above the designated flood elevation by importingin excess of 300,000 cubic yards of fill. The fact that the developer is now contemplating such
a large expense and bazar plan to physically rebuild the plot of ground so that it is buildableverifies that the site is not a good candidate for residential development use. In it's natural state
it is best suited to be left as an open area contributing to storm water mitigation which protectsus, it's neighbors , from storm water damage and flooding. It seems obvious that the site
doesn't work for the planned development and forcing it to do so is a bad idea.
I want to bring to your attention two major problems with the proposed filling of the site andthe accompanying storm water mitigation scheme which I hope you will consider as you
review the upcoming EIS for the development.
First, the disturbance to the local area associated with such a large earthwork endeavor can't beoverstated. The constant truck traffic to and from the site in our residential neighborhood will
be devastating to the existing roads, will present traffic control issues, emergency accessissues, not to mention noise and dust pollution. Assuming a fill effort of 300,000 cubic yards ,
this will require a minimum of 15,000 truck round trips. Assuming they could dump a truckevery 3 minutes that is a 5000 hour endeavor or working 8 hours a day 5 days a week that
equates to over 2 months of constant hauling. Depending on the fill source ( I can't see whereone has been designated in the Land Disturbance Permit ) it could require as many as 20
trucks with trailers to accomplish the fill effort. Can you imagine the impact such enormoustruck traffic would have on our intersections? If this activity takes place during the school
session the problem compounds. The traffic issue alone is of major concern but that coupledwith the other impacts of the proposed filling of the site makes such an endeavor too much to
ask of our community and neighborhood. The damage to our roads and intersections alongwith our health and safety is too great of a cost to ask us to bear. The pending EIS needs to
address the fill operation in detail addressing these concerns.
Secondly, I am very concerned that by forcing the site to work for the developers personalgain will put the city of Spokane Valley as well as Spokane County in a position of great risk.
I continue to ask the question of who will maintain and operate the storm water mitigationsystem in the likely case that the proposed HOA is unable to do so? The widely discussed
legal case of Phillips -vs- King County clearly points to the permitting agency for the liabilityof the system should the HOA who originally owned and operated the system disband. Is the
liability worth the increase in tax base that the project would provide to the city? How wouldthe county be reimbursed should the development's system fail and adversely effect the
infrastructure up stream of the development? Worse yet , who would be responsible for theeffects of a failure to the private property upstream and adjacent to the site? Surely the county
will need to approve the plan as it is immediately adjacent to to the county/city boundary. I am asking that the pending EIS or other required documents address this potential
operational liability.
With the submission of his latest plan the developer is clearly trying to find a way tocircumvent the obvious best use of the referenced property. Any piece of property can be
reconfigured to suit a new use, but at what cost environmentally , socially, and economically. I'm not sure what is driving such a bazaar plan as the fill plan recently submitted but it is
clearly at too high of a cost to our community for the reasons outlined above and warrantscontinued scrutiny by all parties involved and effected by the proposal.
Thank-you for your time and continued efforts reviewing this ill-conceived development.
Sincerely
Tom Clark5214 South Cree Drive
Spokane, WA509-991-3088