This is the second part of the G.R.I.T. response to the draft SEPA issued June 21, 2001 by DNR. (Our first and partial response was submitted in our July 16, 2001 letter to Doug Sutherland.)

We are prefacing our comments by stating that some of the worst disasters in history have been caused by a confluence of unlikely occurrences at a particular moment which combine to result in the worst possible scenario. Due to sensitivities in both the natural and man-made features located within and adjacent to the proposed Powerhouse Site, there exists a recipe for potential disaster.

While there are numerous issues related to the threat to ESA-listed animals, mostly notably fish species located within this environment, the possibility exists for severe consequences to another species living in and near the area: Human Beings.

For instance, the nature of the mining activity may significantly undercut the geologically-sensitive area east of the critical slopes along the Sultan River and above the Jackson Powerhouse. In the event of a significant earthquake, which is increasingly being predicted to be more of a surety than a possibility, the Culmback Dam located at the southern end of Spada Lake designed to withstand a 7.5-magnitude quake (which is also the Water Supply for Everett, Sultan and many other communities) would be destroyed. Water from the lake, traveling west and southward via the Sultan River, would impact and probably destroy the Jackson Powerhouse. Debris from the dam and powerhouse might well result in adding to the potency of the earthquake and combine with previously-mined geological integrity. This would effectively bring the entire hillside down onto the city of Sultan and beyond, similar to the Johnstown Flood.

In the event of an earthquake large enough to either seriously crack or destroy the Culmback Dam, one might well say the collateral damage would be severe enough to destroy the town of Sultan regardless of geologic structure integrity issues from the mining [source: Everett Herald, Marcy 4, 2001, "Who'd go first in the Big One?"]. But in a 7.5-magnitude-or-below quake, the dam could be damaged just enough to weaken it to the point of releasing enough water to flood the Sultan to severe enough levels to undercut what remains of the geological structure of the mined areas.

There is an additional overall situation to consider related to potential man-made catastrophes: The constraints put into place for earth-moving, blasting, excavation and other human activities, are only as reliable as the person operating the machinery. The safety and welfare of hundreds, perhaps thousands, of human beings will be dependent upon one thing: The man or woman in the cab of the heavy machinery. And the outcome is that no matter what guarantees for safety or financial assurances are placed into whatever future contract is ultimately issued to a successful bidder, any resulting restitution for losses to the taxpayers and citizens of Sultan will be slight, and will be following an extended, protracted and emotionally disastrous legal battle for justice.

At the very heart of the proposed gravel extraction area exists moderate to serious impacts to the Sultan Basin's water resources. These are detailed in Robinson & Noble, Inc.'s report, Hydrogeologic Characterization Off-site Alternative North of Sultan, prepared as part of the compendium for the Granite Falls' EIS study as Alternative #3 and dated June, 1997, (Appendix I - Section 2)

Pages 3 and 4 of this study indicate that Winter's Creek travels directly through the gravel extraction area and is a major source of recharge and discharge for the Sultan Basin Hydrologic boundary line. This line delineates the general area of flow of water in the area, which runs from the northeast in a generally southwesterly direction.

This boundary enters the DNR proposed area at the approximate northwest area of Haywire Ridge, located at the approximate two or three o'clock position (using Haywire ridge as the clock's center). After flowing through the low permeability characteristics of this hard rock area, it flows generally southwestward to the more permeable infiltration gravel extraction area and "becomes" Winters Creek. The study states:

Further on the report states, "Care must be taken to control the fate of imported water and intercepted water to assure that recharge is neither diminished…or enhanced to the point of causing failure problems along the hillsides…if surface flow is allowed to leave an open-faced mine, turbidity could reach the Sultan river and potentially cause environmental damage."

Among other things, this hydrologic-geological configuration acts as a natural clarifier of the water for the ESA species contained in Winters Creek.

Another problematic factor is that the aquifer and water table in this area is both shallow and unpredictable, and a vital contributing function to the overall and prevailing hydrology in the area:

In layman's terms, the geological and hydrologic structure of the area is a vital focal point for the area's aquifer for human beings, plants and countless other living organisms "downstream" from the area. And, while DNR and CSR would love to use this gravel for their own purposes, human beings and other creatures need it, too. No amount of "mitigation" or "restoration" can reestablish its delicate ecological balance.

In conclusion to this portion of the SEPA discussion, it's our opinion that DNR's review of these issues was cursory, at best. Even though several studies were available for review by DNR personnel (including the one mentioned above), the conclusion given in a brief one-page April 19, 2001 memo to Bob Suda from Noel Wolff on this subject ended with the following "watered-down" statement relative to Winters Creek: "Ultimately, it will have to be decided how best to deal with the streamflow that crosses the Pipeline Road from east to west and currently percolates into the underlying gravels." This is a minimalist statement, considering the vital importance played by this body of water.

Taken as a conclusion, however, the above statement does support our position that the SEPA fails to address significant issues in a cumulative and site-global manner.

The study also discusses the various sources for water to wash the gravel, chief of which are purchasing water from the cities of Sultan or Everett. Because Sultan has historically experienced insufficiencies in its water supply, this could become a significant hardship on our community resources.

Although we did not have time to thoroughly address these issues, they are addressed in part in the study referenced above, a copy of which DNR has available for review. Additionally, I would like to add the following statement from the aforementioned memo by Noel Wolff regarding this issue which states the following:

The escarpment to which Mr. Wolff is referring, of course, is the Sultan River, which is ESA habitat and "home" to the Jackson hydroelectric power plant.

We would like to have addressed each item in the SEPA document point-by-point, but unfortunately ran out of time.

Thank you for the opportunity to comment on the SEPA.

Sincerely,

Loretta Storm, Co-Founder

G.R.I.T.