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
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
