PC422a_Arleen_Fisher_11-16-2018From:Arleen Fisher
To:Lori Barlow
Subject:Painted Hills Sub-2015-0001 / PRD-2015-0001 / FPD-2016-0007-Issuance 10/26/18
Date:Friday, November 16, 2018 4:46:56 PM
Attachments:NPIF section60_3.pdf
2012 Stormwater Management Program (PDF).pdf
2017-04-07_Disaster_Request_Letter.pdf
Photolog.pdf
Vicinity Maps and Photos 2013 Stormwater Grant Request.pdf
Painted Hills Golf Course 1948-50.doc
November 16, 2018
Please admit my prior comments, documents, images, and attachment on this proposed
development:
PC179 dated 09-20-2015, PC222 dated 10-05-2015, PC300 & PC316 dated 09-29-2017.
Add all the Flood Events from the City of Spokane Valley’s Painted Hills "other watershed
documents" website, especially the 1996 flooding for the record.
Painted Hills is an environmentally sensitive areas & critical areas: wildlife, wildlife
corridors, high rated Spokane-Rathdrum aquifer recharge area, floodplains, floodways,
stormwater issues, road flooding issues.
Adding fill to this site would create several upstream and downstream flooding problems
and create millions of dollars of property damage to homes. It would also create problems
in the area on 40th Avenue where the developer plans stormwater mitigation.
SEPA Checklist SVMC 21.20 Received by City of Spokane Valley on 08/20/2018.
Please review
A: Background #11 Gustin Property parcel number in NOT 45343.9052
B: Environmental Elements #3 Water
The projects engineer has specified that it is not fish bearing.
Other professional engineers have documented the fish in Chester Creek during other
projects. This area contains surface water, floodplains, floodways. A development directly
south of the Painted Hills golf course property have found fish in their
stormwater/floodwater mechanisms. They are not allowed to clean out the silt out of their
stormwater mechanisms due to the Fish, until the Washington DNR – verifies the find.
Stream designation F should remain in place until the Washington DNR has verified and a
proper Watershed Study is completed on all portions or Chester Creek, including Gustin
Ditch, and all Chester Creek Unnamed tributaries to assess where these fish come from.
When reviewing the Spokane County Flood Insurance Study information, you can see how
much area Chester Creek covers. Examples attached in various area’s and coming from
different mountains and higher elevations. I would not think that the DNR would allow fish to
be injected into wells, as they might be a protected bull trout species.
Per Spokane Regional Stormwater Manual 7.5.2
Setbacks
I did not see a “call out” in any of developer’s documentation for any other property
owners private wells and septic/drain fields. Several residents live in a very close proximity,
sometimes just across the street of the proposed development. With many planned
changes to stormwater drainage, roads, and cut and fill raising elevations, this should be arequirement. Every aspect of the Spokane Regional Stormwater Manual should be
followed for this developments scope.
Per FEMA, once your community adopts its floodway (of which this development has two
floodways on the site, plus two that come from HWY27, traveling west towards 40th Avenue
where the developer plans to transfer compensatory stormwater and floodwater), you must
fulfill requirements of 44 CFR 60.3(d). The key concern is that each project proposed in thefloodway must receive an encroachment review, i.e., an analysis to determine if the project
will increase flood heights. You may also want to require that this review determine if theproject will cause increased flooding downstream. Note that the regulations call for
preventing ANY increase in flood heights. This doesn’t mean you can allow a foot or a tenthof a foot – it means zero increase. If you do not limit the increase to zero, small increases in
flood heights from individual developments will cumulatively have significant impacts onflood stages and flood damages. Under NFIP minimum requirements, it is assumed that
there will be no cumulative effects since the permissible rise for any single encroachment iszero. Therefore, “no-rise” certification a documentation should be made to every single
homeowner in four square miles of this proposed development.
After altering a watercourse, the developer has created an artificial situation and must
assume responsibility for maintaining the capacity of the modified channel in the future.
Otherwise, flooding is likely to increase as the channel silts in, meanders or tries to go back
to its old location.
Restrictive Regulation of High-Risk Areas
May a government unit adopt tight regulations for high risk areas, such as floodways and
velocity zones and dunes, to implement a no adverse impact standard?
Courts have upheld very restrictive regulations for high risk areas even when there were
few
economic uses for the lands because of the potential nuisance impacts of activities in these
areas
and because of public trust and public ownership issues.
As an alternative to this highly sensitive area, I would recommend open spaces to meet
ecotourism, recreation, and other activities that do not harm the environment. The City of
Spokane Valley and Spokane County should seek assistance to purchase the property as a
critically environmental floodplain and compensatory flood basin as it’s in the WRIA 57
basin. Possibly do an inter-agency Watershed study and get long-term gage records for
Chester Creek. The last Water shed study proposal was done by the Spokane County is
1998. This could be joint effort between the City, County, State Agencies, and Federal
Agencies. Chester Creek and the associated tributaries produces to much water and
flooding events to ignore any longer. And putting fill and covering so much of the property
with hardscape will only exacerbate the problems.
Spokesman Review Article dated Aug 31, 1996 in Part:Citizens Panel Looks At Methods To Control Chester Creek Floods
Story By Brian Coddington
Lifetime Chester resident Sally Gerimonte remembers the spring of 1950, when what is
now Painted Hills Golf Course was completely under water.
Gerimonte, 61, also recalls spring runoff flooding the road leading to the original Chester
Elementary.“We used to have to walk through water to get to school,” she said.
This article was published after the County Golf Courses received FEMA disaster funds in
1996 for flood recovery to two golf courses. Whereas, Mr Senske states in the article who
owned the Painted Hills Golf Course at that time declined government assistance to replace
damage to the courses bridge.
Attachments:
Thank you for your time and consideration,
Arleen & David Fisher
6121 S Zuni Dr (Painted Hills 6th Addition)
Spokane, WA 99206