Public Works Trust Fund Board.

Letter to Washington State Public Works Trust Fund Board.

The following letter to the Trust Fund Board lays out the errors in the Carlsborg Waste Water Facility and Financial Plan Amendment for the Carlsborg Urban Growth Area with links to the FACTUAL numbers for the Carlsborg UGA population, housing units and the actual number of commercial properties.  I invite all who read this blog to please feel free to check my facts and please read or re-read my earlier post on Clallam County Code Enforcement, Creating Paper Water and How to Misrepresent a Rural Area as Urban.

Dear Cecilia Gardener,

I have received a copy of the Carlsborg Waste water Facility Plan Amendment – DRAFT 2014.  I once again have serious and grave concerns about the financial feasibility of the Carlsborg UGA Sewer Project. It appears that the Facilities Plan and the Financial Plan are fraught with errors, ASSUMPTIONS and PROJECTIONS stated as facts.  Upon closer scrutiny it is fictional and wish fullness not reality.

To begin, the number of  potential ERU (equivalent residential units) hookups is erroneous, the math does not show the reality of the Carlsborg UGA as follows…

Their statement: Page 8-4, An estimated 484 ERUs, 78 residential and 406 commercial,

are located within the Initial Connection Area. 
http://www.clallam.net/PublicWorks/documents/CWFDraft2.pdf

Reality: 2010 Census Carlsborg CDP (census designated place) http://www.census.gov/2010census/popmap/ipmtext.php?fl=53:5310075 , Population 995, 547 Residential Dwelling Units of which we know that 334 of them are in EXEMPT Mobile Home Parks leaving a total of 213 Residential Units for potential hookup.

Carlsborg UGA Economic Profile:  http://www.clallam.org/SiteAssets/resources/economic-development-reports/Carlsborg%20UGA%20Economic%20Profile%20September%202011.pdf  Pages 16-18 List Of  UGA Businesses.  There are 113 Businesses in the Carlsborg UGA not 406 as seen in this Financial Plan.

Additionally, allowing a waiver of hook up for those that have septic systems younger than 20 years old defeats to entire purpose of the sewer system in its initial construction phase and may lead property owners to defer hook up until the mandated time to do so. Example: If you have an approved onsite septic system installed this year 2014 you would not have to hook up to the sewer until your system is 20 years old or fails and is non-repairable.  These approved onsite septic systems cost can cost $30 - $50 thousand dollars and require regular testing and maintenance at owners expense and this plan offers no real adequate financial compensation for abandoning their own system for the sewer.

In addition to these errors I am concerned about the hookup fee waiver of $7,476.00 per ERU dropping the cost of hookup from $7,976.00 to $500.00 per ERU which includes businesses.  Concerning the “Get Connected” Loan Program” loans up to $3,000.00 at 3% interest for hookup costs of which the repayments would go to the county “General Fund” instead of being earmarked for O&M of the sewer system. “plan assumes that the repayments (about $70,000 per year) would go to the County WITHOUT being restricted to the Carlsborg system.” Pages 14-15 of the Plan Amendment Appendix H. http://www.clallam.net/PublicWorks/documents/CWFDraft2.pdf  This $500.00 “incentive” is not a factual accounting of the real cost of hookup and abatement of the old system as this plan fails to add the footnotes from the Clallam County Public Works Department 1-Assumes sewer main on the same side of the road as the property.  2-Add $2,000.00 if County Road must be crossed. 3-Based on ESTIMATES assembled by the CCAC (Carlsborg Community Advisory Council).  This plan also does not include the REAL cost of abatement of the old system, their estimate is $750.00 in total.  Actual is much higher as pumping costs alone are $350.00 - $375.00 which does not include excavating the tank, crushing the top, backfilling the empty tank and recovering the tank. 

One must read this entire Financial Plan to discover the real monthly costs.  They state $66.00 per month, if you take advantage of the “GET CONNECTED” loan program add $30.00 per month to the cost, if you are a private well owner an additional $12.00 to the monthly cost or the cost of metering your well and paying additional water use fees.  That would make the monthly fee $107.00 per month for those on a private well if they take the “LOAN” which would create an EXTRAORDINARY financial burden on those in the Carlsborg UGA with an Estimated median household income in 2012: $26,656 (it was $28,103 in 2000) Read more: http://www.city-data.com/city/Carlsborg-Washington.html#ixzz3Hg9sEoW3  Estimated per capita income in 2012: $16,758,  Median Average Age 60.3 years.  UNEMPLOYMENT IN 2013 9.0%

The arbitrary nature of the monthly fees of $66.00-$70.00 for those on PUD water and the increase to $78.00 minimum for those on private wells is discriminatory and appears punitive for having a private well as there is no way charge a fee to those on private wells without requiring them to spend additional money to install a meter, which is also not mentioned in the Financial Plan.

In light of these errors and other facts, I feel this plan is financially infeasible and should be withdrawn from loan approval and the entire plan scraped in favor of the LAMIRD alternative with owner financed cluster systems. The Carlsborg area should be down zoned to alleviate the burden on the water supply, aquifers and river.

Your consideration is appreciated,

Bryan Frazier