By Andrea L. Weiser
To: Skagit County Planning Office
Planning and Development Services
1800 Continental Place
Mount Vernon, WA 98273
Re: Proposed Quarry in Marblemount, WA (PL19-0032 and PL19-0033, PL19-0046, and BP 19-0070)
To Whom it may Concern:
This project is incompatible with the Comprehensive Plan and would destroy the local economy and the future direction the vast majority of residents want to see.
Our future is restoration, outdoor education, and recreation not extraction, remediation, and mitigation for damage already done.
I appreciate how much work the Skagit County Planning Office has already invested to review the large volume of public comment associated with the notice of development at 59252 Rockport-Cascade Road in Marblemount. East Skagit County is the kind of location that industrial developers search for, thinking it might be an easy place to receive a permit because no one besides the planning office is paying attention. Low population density is not a measure that should be used against us. We care about where we live and we hope you do to. This project is incompatible with the Comprehensive Plan and would destroy the local economy and the future direction the vast majority of residents want to see. Our future is restoration, outdoor education, and recreation not extraction, remediation, and mitigation for damage already done.
If you can’t see clear to denying this permit outright, please require an Environmental Impact Statement so we can all see in great detail why the effects of this project could never be mitigated. I don’t want Marblemount to become the next Superfund site.
My life changed the moment I learned about Kiewit’s proposed mining quarry on Rockport-Cascade Road in east Skagit County. The massive proposal would blow up Big Bear Mountain into jetty rock and gravel, turn it to profit, and take it and the profit out of Skagit County over a small county road next to the Skagit River. The project site is across the Skagit River from Marblemount about a mile from my house—an idyllic setting in the woods, where I can hear from the sound of an engine a block away whether it’s my neighbor coming or the UPS truck.
After further investigation I realized I was wrong about something—not all of the rock would be hauled away. A volume of waste rock equal to 200-foot tall pile of contaminated spoils across 28-acres of the work site would not be marketable as jetty stone and would be stockpiled on site for an indeterminate amount of time.
Kiewit Corporation was sued for 5 million dollars for violating the Clean Water Act because employees had been diverting toxic waste into the San Joaquin River for three years before being caught.
I am not easily ruffled, but I became incredulous as I read deeper into the permit documents and learned the shocking magnitude and complexity of planned activities for the next 100 years with relatively scant discussion of near term and cumulative effects. Then I looked up the company proposing it. I found that Kiewit Corporation was sued for 5 million dollars for violating the Clean Water Act because employees had been diverting toxic waste into the San Joaquin River for three years before being caught. This says to me that instead of complying with environmental law in the first place, this company is willing to break it and just pay the fine. Then I looked up Kiewit’s net worth – $8.7 Billion. I felt sick.
The proposed activities would affect not just the environment, the peace, and viewscape, it would shatter our local economy and daily lives, and our children’s daily lives, and lives of their children and their children’s children. Those of us who recognized what was at stake began reading the detailed project proposal and permitting documents – over 1,000 pages, yet all these pages lacked the answer to a key question – what could possibly make this right?
Other questions were easier to answer such as, is there an Environmental Impact Statement (EIS)? No. Should one be required? Yes.
Would it create new jobs? No.
Would it create new jobs? No. Kiewit has said the 25 jobs expected to work the quarry would be drawn from existing union employees. The more I have read through the Operations Plan, the more I realize these aren’t just trucks and heavy equipment, these are monstrosities and special training and expertise is needed to use them. What Kiewit has proposed is to turn a quiet neighborhood into a full-scale industrial operation to extract a resource. In the process they would leave a shell-shocked community not receiving any kind of economic benefit.
Climate change is not called out in the permit documents but it should be for a number of reasons. For one, the need for jetty rock and riprap is expected by the US Army Corps of Engineers (USACE) to be on the rise as water levels rise. This makes reasonable sense. Waters will rise as the climate changes and environmental controls (like jetty rock) will be needed to protect infrastructure. True. But destroying another environment and community is not a way to solve that problem. This project is proposed in an area that is not a suitable source for that rock for the many reasons I have already commented on and will enumerate in this letter. Further, there are already other suitable sources of rock that fill those needs which are permitted for use as well as engineered blocks already being used successfully in saltwater jetties and in the Skagit River in Rockport adjacent to Cascadian Farm.
As you read through my comments, add your own reminder at the end of each section – what about cumulative effects? What is the context of climate change added to the future of other changes over the next 100 years? How do our choices now influence it?
Property Rights and Values
If permitted, the industrial operation to log, build a road, create a staging area, blast, stockpile, crush rock, truck and perform maintenance on large heavy equipment day and night, would be heard and seen in great detail by local residents, fisherman, rafters, eagle-watchers and family vacationers and yes, real estate brokers. However, I have my doubts that the property taxes would be adjusted to reflect a concurrent nose dive in property values.
Treaty Tribes have already expressed their opposition…
Treaty Tribes have already expressed their opposition to the project due to the baldly apparent effects this proposal would have on the cultural and natural resources which are deeply important to them.
Threatened, Endangered and Listed Species
On an adjacent property to the quarry proposal, Seattle City Light identifies animal habitat conservation as a priority. Key species such as peregrine falcons, eagles, fishers, lynx, red fox, wolves, and marbled murrelets adjacent to or on the Kiewit property have been observed by wildlife biologists and homeowners. Some of these species are being tracked by the Washington Department of Fish and Wildlife (WDFW) and US Forest Service. Mature trees in the proposed development area show potential for spotted owl habitat yet potential effects to such habitat is not even considered in the quarry proposal or the SEPA checklist, nor has a spotted owl survey been conducted.
Kiewit’s development plans are also at cross purposes to Skagit County’s own Comprehensive Plan regarding land use, civic pride, heritage and private property values
The project site is on a rocky ridge top above the federally-designated wild and scenic Skagit River and a short distance upstream of the wild and scenic Illabot Creek. The project contains regulated “critical areas” due to landslide, erosion, and seismic activity as defined in Skagit County Code SCC 14.24.410. Kiewit’s development plans are also at cross purposes to Skagit County’s own Comprehensive Plan regarding land use, civic pride, heritage and private property values:
“Skagit County in exercising its land use regulatory authority to protect the public health, safety and general welfare (Article XI Section 11 of the State Constitution), must respect private property rights by not exceeding the constitutional limits on its authority.”
Skagit County and the Skagit River System Cooperative (SRSC) just received the American Public Works Association’s project of the year award for restoration on Illabot Creek—an accolade to be proud of. Permitting the quarry would begin a backwards trajectory.
The quarry proposal would blast an 1,100-ft tall promontory out of existence. Roughly 30 homes are adjacent to or in near proximity of the quarry site and hundreds more are within earshot of the types of activities Kiewit proposes.
The quarry proposal would blast an 1,100-ft tall promontory out of existence. Roughly 30 homes are adjacent to or in near proximity of the quarry site and hundreds more are within earshot of the types of activities Kiewit proposes. Risk of contaminating the Skagit River ecosystem is high. From the blasting alone, dust from asbestos-bearing rock (Shuksan green schist contains actinolite) would become airborne as well as adhere to the spoils piles and large jetty rock being removed from the site and driven over a County Road (Rockport Cascade Road), two state highways adjacent to the Skagit River (SR-530 and SR-20) across a bridge over the Skagit River, and to a federal interstate (I-5). Nowhere in the project proposal or environmental documents is there any mention of controlling spread of asbestos particulate that could put human and animal health at risk and threaten water quality and fish.
Let the upper Skagit River continue to be the gem of the watershed that creates balance with development…
Permitting an industrialized set of activities, incompatible with local land use, would allow reversal of all the good work Skagit Fisheries Enhancement Group, Washington State Recreation and Conservation Office, tribes, agencies and dedicated consultants to promote the restoration, stabilization, and improvement of fish habitat in the face of already increasing pressures and climate change. Let the upper Skagit River continue to be the gem of the watershed that creates balance with development elsewhere in the County and the State.
…the risk is high for excess liquid ammonium nitrate fuel oil (ANFO), or other blasting chemicals, to fill in underground spaces.
Blasting residue and other chemical residue, such as diesel, gasoline, and lubricants –especially oil-based products adhere to rock. I learned from a blasting specialist that not only would fuel oil residue be a concern, but the lubricants used for maintaining the drilling equipment would be a concern. Further, due to the potential for gaps and cracks in the rock below the surface (such as this group of rocks is known to have), the risk is high for excess liquid ammonium nitrate fuel oil (ANFO), or other blasting chemicals, to fill in underground spaces. This heightens the likelihood of uncontrolled blasts and excess fly rock that could put blasting crews, operators and equipment on site at risk. This presents additional potential hazards not covered in the blasting plan.
Jetty rock removed from the site with these residues is a concern for airborne and waterborne spread of contamination all along the transport route.
Jetty rock removed from the site with these residues is a concern for airborne and waterborne spread of contamination all along the transport route. According to the Detailed project description, total full buildout would be 9.6 million cubic yards of rock material (page 7). According to an industry standard, 10-20% is a reasonable estimate for how much of the total volume could be suitable jetty rock. So what happens to the other 80-90% of spoils? I don’t see any evaluation of the stockpiles at all in the project documents. By using volume metrics in the proposal the amount of waste rock would compare to a 200 foot tall hill over the 28 acres identified for stockpiling. Anyone wanting to extract rock from it would need to implement engineering on the pile just to make it safe to draw material from. The stockpile area would be dusty and open to the elements and could put water quality at risk repeatedly over the course of the operation and beyond. Clearly, the cumulative effects of this have not been considered and Cunningham Crushing would pay the price.
What are the implications for road culverts and a Clean Water Act Section 404 permit?
The heavy rainfall in Marblemount is often overlooked but it is critical to consider. In a single rainy year, we have recorded 120 inches of rain in a rain gauge just 3 miles north of Marblemount and annual, sometimes bi-annual floods are common. With an industrial operation I would also expect a stormwater runoff plan and environmental controls for hazardous waste, yet I have not seen any of this in the project description or supporting documents. There is no mention of it in the blasting plan either. What are the implications for road culverts and a Clean Water Act Section 404 permit?
Project Operations and Potential Effects
The project description and supporting documents left me with more questions and concerns than answers. Based on the Detailed Operations Plan and Restoration Plan and comparing to similar operations at the near-depleted Beaver Lake Quarry in Mount Vernon, a jigsaw puzzle of information began to come together so I could envision what this operation would look like.
• Trailering in and staging heavy equipment, including trucks so big they would have to be brought in disassembled. Excavators so large they require a 14-rung ladder to get into them
• Blasting up to 6 times per day and slope grading on a slope prone to landslides and perched above more than 30 nearby homes.
• Construction of over a mile of access road to be used for logging and future mining operations through an area with no current approved use for mining (i.e., outside of the Mineral Resources Overlay)
• Chainsaw and heavy equipment noise for timber harvest of 2.7 million board feet across 90 acres. Truck traffic to transport all that timber (i.e, 80-ft long diesel trucks that could haul loads up to 80,000 lbs)
• Removal of 9.6 million cubic yards of rock using massive on site trucks for hauling stone, fuel and heavy equipment, such as the quarry haul trucks with gross weight of 256,000 pounds each.
• Truck traffic from 6 am to 6 pm, six days per week with equipment maintenance outside of the stated hours from 6 pm to midnight and occasional nightshifts. Yet no mention of how lights used for night time work and security lights would affect the night sky or how the sound of maneuvering trucks with back up alarms (one of the most grating sounds in existence) would affect the night time soundscape.
• 260 truck trips per day, i.e., averaging one truck every three minutes and up to 75 of these trips could be oversized trucks for jetty stone hauling, across 24 miles of narrow county road (Rockport Cascade Road) closely bordering the Skagit River and not built for those load weights or or traffic frequency. From Rockport Cascade Road to SR-530 then over the Skagit River bridge in Rockport. A narrow bridge not adequate for those loads or frequency. From there to a tight turn onto SR-20 to head west enroute through Sedro-Woolley to I-5. It’s difficult to get my head around these numbers. Even 260 logging trucks per day would be a huge impact to other motorists.
• The trucks used for hauling jetty stone would be oversized (with trailers including 7-8 axles) carrying jetty rock weighing up to 105,000 lbs. Stones exceeding 28 tons each would require special hauling equipment and oversize/overweight permits. (see Kiewit’s Operations Proposal, page 6). Yet no mention of how to get big trucks, with 7-8 axles, around the several traffic circles in Sedro-Woolley or where the trucks would go once they reach I-5. These vehicles would greatly affect traffic congestion for any route and yet it is not discussed in the traffic impact analysis. This leaves many more questions about road maintenance, road safety, increased congestion, and the carbon footprint associated with long haul transport.
This is a community where the annual Skagit River Eagle Festival happens each January on a river that hosts the highest migratory eagle population in the lower 48 states.
Local Economy, Eagle Festival, & Wilderness
How could such a plan be considered feasible by any stretch of the imagination? This locale is surrounded by homes specifically chosen for their quiet natural setting, in a gateway community to the North Cascades mountains and protected federal lands including wild and scenic rivers and federally designated wilderness in the Mount Baker-Snoqualmie National Forest and North Cascades National Park. This is a community where the annual Skagit River Eagle Festival happens each January on a river that hosts the highest migratory eagle population in the lower 48 states. The stretch of river where the quarry is proposed always has the highest counts. Last year, according to the US Forest Service, 111 eagles were sighted on one day along the river reach between between Marblemount and Rockport. In the summer, visitor numbers to and through this area explode due to the access to some of the best hiking, climbing, backpacking, camping, boating, fishing, motorcycling and biking in the state.
The traffic analysis does not account for tourist traffic.
Road Safety & Child Safety
The traffic analysis does not account for tourist traffic. With SR-20 closed from fall to spring, tourist traffic (except for January due to Eagle Festival), scales back considerably. A traffic assessment on a stormy nasty day in December (as Kiewit measured it) is no comparison to the summer traffic volumes. Try counting vehicles on Rockport-Cascade Road, SR-530 and SR-20 over 4th of July weekend, then add 260 trucks to each day.
The Rockport Cascade Road is a route listed on the Skagit County Bike Map as a way to “discover the Skagit Valley.” What bicyclists would discover instead is quarry town. The Rockport Cascade Road is also a bus route for the Concrete School District. Buses take the same route twice a day, fall to summer, that Kiewit has proposed for quarry trucks between Marblemount and Concrete. No one wants to see children at greater risk for accidents or slow downs. The kids on this route already ride the bus for over two and a half hours each day. None of this is called out in the permitting documents.
Concerns I have expressed in this letter are just a fraction of the gaps in critical information throughout the permit materials. The large volume of truck traffic proposed would affect road safety and traffic congestion throughout Skagit County and beyond, yet this is not reflected in the applicant’s permitting materials.
No massive quarry in Marblemount.
Clearly, this permit proposal is inadequate and yet it paints a clear picture. I hope you agree that the lack of context for cumulative effects, and the blatant disregard for regulatory considerations, environmental and community health, safety, and vibrancy of the local community and economy makes the choice clear. No massive quarry in Marblemount.
Andrea L. Weiser6 comments