The following comments are made in relation to the SEPA document provided to DPER for their garages project. This is presented to show the inadequacy of the PacRac provided material.
para. A.7-“light industrial buildings” were not allowed in the master plan ordinance, only racing associated buildings. There should be a requirement that DPER approves any and all tenants that will occupy the garages.
para. A.8-A Critical Aquifer Recharge and a Noise Mitigation reports should be added to this list. [Jason, in the meeting, stated that the project will meet all the state and county Class 2 CAR requirements.]
para. A.10-Are there no reports/approvals required for the Washington State “Project of Statewide Significance” designation? Have the requirements been met for RCW 43.42.060 para. (2) thru (4) as referenced in RCW 43.42 as required in RCW 43.157.030 (specified in KCC/Phillips letter dated Feb. 2014 to Brian Bolander, Dir., WA DoC)? If not, this IUP should be disapproved as it was allowed under false pretenses.
para. A.11-Is there no permit required when the existing septic system for the sales building is to have a significant increase in effluent to process? Where is the septic tank and drain-field currently located? Where is the reserve drain field area?
para. B.1.e-Why no mention of the active audio/visual recording system for noise mitigation? This system needs to be described in some detail before project SEPA approval. [Jason, in the meeting, stated there will be a system similar to the Portland raceway’s internet accessible system, plus a video security system that will be used to enforce tenant noise rules.]
para. B.2.a-This response for diesel emissions and dust are wholly inadequate as the prevailing westerly winds will carry that dust, smoke and odor into the nearby residential neighborhood. These emissions over a period of multiple years will have a harmful effect on their health. In addiction there should be mitigation of free car washes for each of the neighbors vehicles every month as well as a couple of window washings for their homes per year.
[Jason, in the meeting, stated the excavated material is to be trucked to the south Pierce County area. So how does this reduce the travel distance of the trucked materials and thus the emissions generated?]
para. B.2.c-See a. above. Washing of SE 304th St. for the dropped and tracked off site gravel/mud should be required as well as the to and along the on-ramps to SR 18. (see KCC 21A22.070).
There should be some way to compensate all of us that will have dinged windshields and paint from the pebbles/rocks flung or dropped off the gravel transport tires and trailers. All our car insurance premiums are higher and/or we are paying out of our pockets for the damage inflicted by these hauling activities.
In addition kitchen/grease smoke from the restaurant needs to be zero as this is not a commercial zoned area where this kind of pollution would be expected.
If the excavated material is being trucked to the south Pierce County area, how does this reduce the travel distance of the trucked materials?
para. B.3.b.1)-“35.6 acre-feet per year” is less than a foot of rain per year on this 40 acre site. This isn’t Sequim nor Moses Lake, so try again on these figures. Will these low inflow figures affect the size of the stormwater filtration system and soil absorption rates?
We receive 4 to 5 feet of rain per year in this area. Since most of our rain falls during the cooler months when minimal evaporation occurs to reduce the total.
para. B.3.b.2)-This is the first we have heard that there is to be a restaurant within this project. Where is it located? How many square feet? Are there any exhaust vents polluting the neighborhoods? Any exterior seating with a PA system entertaining the neighborhood at all hours? Or for that matter any loud, amplified music indoors? Will this restaurant have an alcohol license? [Jason, at the meeting, stated the eating facility is intended to only be an occasional luncheon area within one of the garages. However there is concern this could grow into a full blown restaurant, open all day/night.]
para. B.3.c.1) & 2)-What does “treated for water quality” mean? How clean is it? Will this later treatment filter out heavy metals, asbestos, oils, organics, plastic/epozy residues, etc.
Previously, PR had said all sewage and industrial wastes were to be collected and hauled off-site for treatment. This would be the preferred method where the sandy soil will allow septic tank effluent to seep into Soosette and Soos Creeks above the salmon hatchery. Earlier PR stated there would be testing of Soosette and Soos Creeks for organic and non-organic contaminates prior to and periodically following project completion. This should be a requirement to protect the Soos Creek Salmon Hatchery.
IUP Sec. 2.H.3.-Develop and implement a water quality monitoring plan to assure that copper, other metals, hydrocarbons and other contaminants are not elevated in ground and surface waters on-site and in Big Soos and Soosette creeks;
4. Conduct flow monitoring in Big Soos and Soosette creeks before, during and after construction to ensure that normal or preexisting flows are being maintained.
5. Conduct biotic monitoring in Big Soos and Soosette creeks before, during and after construction;
para. B.3.d-How is the storm water to be “treated”?
para. B.4.b-Where and how many trees are to be removed?
[Jason, in the meeting, stated the eastern buffer would be increased from 25 to 50 feet at the request of a neighbor on SE 148th St.]
para. B.5.a.-All the “examples” except possibly beaver are located in the steep slope areas of the property within and along the southern and western edges around Soos and Soosette Creeks as well as possibly the northern border.
para. B.5.b.-Pileated woodpeckers and eagles are known to live in the wooded areas.
para. B.6.c-Is “waste oil” burning even allowed? The products of combusting this type of material are known to contain various carcinogens so should not be allowed next to a residential neighborhood. Waste oil products should be disposed of off-site to a recycler.
[Jason, in the meeting, stated waste oil burning would be deleted.]
para. B.7.a.-Will there be limits on the stored amount of explosive materials such as gasoline, nitromethane, cleaning agents, lithium, etc. to reduce the safety hazard to the neighborhoods? With all the flammables and ignition sources co-located in these garages, it is not if but when there is will be a fire/explosion. Just how far away is the nearest manned fire station?
para. B.7.a.3)-This project is supposed to house industries that are working with advanced materials and their development. Each tenant should be required to list all hazardous materials (composition and quantity) they intend to have on their site and that list should be approved by the local fire department, WA DOE, etc. prior to storing at their site.
para. B.7.a.4)-This answer is unacceptable. This project with all the flammables and ignition sources co-located in these garages, it is not if but when there is will be a fire/explosion. If safety is not a requirement for the garage personnel, it should still be to protect the residential neighbors. A manned fire station close to PR should be required, and if the district can’t afford to keep it manned then PR should be required to subsidize the fire district so the neighbors safety is at least as good as before the garages existed.
para. B.7.a.5)-Who will enforce these “tenant rules”? Can the neighbors trust PR’s management to do this job effectively? The Fire Dept. and DPER should be required to oversee this task.
para. B.7.b.2)-The CUP requires quiet days because the raceway property was zoned and located within a residential zoned area. The “grading” and “gravel processing and extraction” activities as well as the garage manufacturing activities will result in a significant increase in noise levels and hours of excessive noise. This is unacceptable as it makes the neighborhood’s surrounding the raceway unlivable and unhealthy. Noise created by impacts of metal on metal (ie by “hammering, pneumatic tools” in the garages forever, and by rock being loaded into truck trailers, gravel processors, backup beepers, etc) running all day for years during the “grading” process is significantly different than a neighbor doing similar activity for an hour or two every month or so. The current home owners had no expectation that they were to be subjected to industrial noise levels for 12 or more hours a day, every day of the week. The statement that “Most operation noise is not expected to generate measurable emissions at off-site noise-receiving locations.” is totally unbelievable, and should be understood as totally false since the range of impact noise will be in the thousands of yards distance. No mitigation can prevent impact type noise from disrupting normal around home activities, but funds to enhance sound deadening (ie as done around airports) in everyone’s home would be a good place to start. It is also well known that impact noise does not register on the noise measuring techniques and apparatus noted in KC noise limit codes.
According to this proposal what quiet time will the neighbors lose during (4-5 years) and after this project is built (assuming the CUP were enforced):
1. Quiet Mondays and Tuesdays
2. One quiet weekend day per month during the summer months
3. Quiet before 9:00 AM all year
4. Quiet after sundown or 5:30 PM which ever is earlier during all non-summer months and on Thursdays and Sundays year around.
The environment that close neighbors will be subjected to will prevent sleep for second and third shift workers, babies, young children and anyone wishing to take a nap. Any attempts to enjoy their property outdoors will be impossible even on days there is no racing, testing or high performance training scheduled.
I see only minimal mitigation specified for the neighbors and none that will reduce impact noise.
I see no mention of the CUP time restrictions. Why not? These time restrictions were specified because the raceway is located within residential zoning. These time restrictions should be required since this industrial noise is to be inserted next to a rural/residential neighborhood.
[Jason, in the meeting, stated that the CUP noise restrictions would be continued with enforcement by the noise monitoring system and tenant rules.]
One form of required mitigation could be the reduction in the source noise from racing vehicles (cars, karts and motorcycles) by the use of legal mufflers. Many race tracks are adding this type of restriction to alleviate some of the noise associated with this activity.
And “oh by the way” the full development of the raceway is expected to follow this garages project.
para. B.8.e.-In addition the zoning is restricted by it’s Conditional Use Permit.
para. B.8.h.-The whole site is designated as a Critical Aquifer Recharge Zone which has restrictions under KC and Washington state codes.
[Jason, in the meeting, stated that the project will be developed under all the Critical Area state and county regulations.]
para. B.8.L.- The insufficiency of the specified mitigation proposed is noted above.
para. B.10.c.-The thin line of forested area currently along SE 148th Ave. allows sunlight thru during the afternoon and evening hours which will be eliminated with the garages at the southern end of project.
[Jason, in the meeting, stated the eastern buffer would be increased from 25 to 50 feet at the request of a neighbor on SE 148th St.]
para. B.13.a.-There are several sites that meet this criteria: Neely Mansion (listed on the National Register of Historic Places), Soos Creek Salmon Hatchery, Green Valley Road Heritage Corridor (one of nine in King Co.) and Soos Creek Botanical Gardens.
para. B.13.d.-I see no compensation to the neighbors for their loss of clean air. They will get years of diesel smoke, CO/CO2 and dust, not to mention increased noise levels/hours. The heritage sites are impacted by high noise levels preventing them having ceremonies/activities that bring in improvement and operating funds. A yearly monetary donation could be mitigation solution.
para. B.14.a-SE 148th is a county road. I believe you should replace it with SE 144th. But since you mentioned SE 148th, you should repave it as it has become a secondary access to the raceway thru the Emergency Access gate for truck and motorhome traffic.
para. B.14.c.-Currently during the major August drag racing events parking and camping along SE 148th is occurring even in the presence of PR hired, off-duty police and they did nothing to prevent this activity. The CUP states this off site parking will be prevented by PR.
para. B.14.d.-Note comment to B.14.a.
para. B.14.f.-It is interesting that the expressed primary reason this IUP was approved by the KC Council was because it was to be a “Project of Statewide Significance”, however none of the space is designated for that purpose. Sounds like “bait and switch” to me. Since this IUP project would not be allowed by KC code because it is a piecemeal of the overall project of the previous ordinance and now doesn’t meet the requirements for a PSS, the permit should be rejected until some assurance as to there being several high tech tenants of “Statewide Significance” signed leases.
para. B.14.h.-Note the comment (para. B.2.c) on fugitive gravel gracing our roads but eventually finding our windshields and vehicle paint.
para. B.15.a.-Note comments for para. 7. above.
para. B.16.b.-Jason, in the meeting, mentioned that a 12 inch water main will be built from some point well north of his property line. This doesn’t sound like just “some upgrades” that he states here. Also he mentioned that with the kitchen waste water that there would be a separate tankage for that material which is also not mentioned in the SEPA.
What is the estimated cost of this project? Note the requirements A.10 above. ($50 million minimum)
How many permanent employees will this project have? Note the requirements A.10 above. (a minimum of 100 full time jobs)
Additionally it does not appear that the permit SEPA meets the specific requirements of KC code 21A.55.105, para. U. thru CC.