Methow Valley Citizens' Council
Scaling down the Resort
Index to MVCC's campaign to avert a destination resort in the Methow Valley, Washington
Declaration of George Wooten, Jr.
BEFORE THE OKANOGAN COUNTY COMMISSIONERS IN THE PUBLIC HEARING ON THE EIS ADDENDUM FOR THE ARROWLEAF PLANNED DESTINATION RESORT DECLARATION OF George F. Wooten, Jr. I, George Wooten, Jr., based on my background, qualifications, and experience as a scientific professional, declare as follows: 1. I have training and experience relevant to water quality analysis, from my experience in the following areas: a. I am a biochemist, with three years of graduate school research, teaching, and education at the Pharmacy School, University of Maryland at Baltimore, where conducted research on the biodegradation and transport of pesticides from agricultural sites. I have five years of laboratory technical experience in the pulp and paper industry as a senior lab technician. b. I am familiar with wetlands, wetland ecology, wetland delineation, and legal procedures for wetlands dredge and fill permits. I have completed the Interagency Wetland Delineation Training Course, Darrington, Washington, 1993, by US Army Corps of Engineers, US Environmental Protection Agency and USDA Forest Service. I have experience delineating wetlands from my work with the Forest Service timber program for Winthrop and Twisp Districts, and consultation with the US Army Corps of Engineers and other private firms. I teach wetlands ecology in Okanogan County with the Trust for Habitat Conservation. c. I am experienced in aerial photo interpretation and land classification methods using ground-truthing, remote sensing and statistical analysis. I have taken Basic Photointerpretation Training, Seattle, Washington, 1989, by Nationwide Forestry Applications Program. I have training and expertise in interpretation of aerial photography through five years of field work and mapping for the North Cascades Grizzly Bear Ecosystem Mapping Project; as the photointerpretor for the protection of critical habitat for spotted owls, lynx and sensitive plants for the Methow Ranger District of the US Forest Service; and as the photointerpretor for two Methow Valley watersheds in the Eastside Forest Ecosystem Health Assessment with Richard Everett. d. I have extensive experience with field botany and ecology in ten years of agency work on the Okanogan National Forest. I am a botanist and a Contracting Officer Representative Level I for botanical surveys on the Okanogan National Forest. I was responsible for insuring compliance of botany contractors working on surveys for Threatened, Endangered and Sensitive (TES) plants on the Okanogan National Forest. e. Attached hereto is my curriculum vitae (Wooten Exhibit A). 2. I have read and am familiar with all the relevant parts of the EIS Addendum for the Arrowleaf Planned Destination Resort, as well as with pertinent documents related to MVCC's appeal of the Arrowleaf FEIS to Superior Court in Chelan County, including the DEIS, the FEIS, MVCC's appeal, and the rebuttal statements from the developer's consultants. 1. The Addendum does not consider a large enough affected environment to judge what impacts will occur to the wildlife and plants on and adjacent to the site. On p. II-2, Affected Environment, the Addendum states that, "...all precipitation generally infiltrates into the ground and eventually recharges the underlying aquifer. As a result, there is no direct surface water runoff pathway to the Methow River or Early Winters Creek from the site, except during snowmelt when the ground is frozen or during extremely intense thunderstorm events when precipitation intensity exceeds the soil permeability." This conflicts with the EIS comment by Department of Ecology (Rebecca Inman, FEIS Letter 5, Comment 22), who commented that , "As previously mentioned, one ditch apparently drains into a wetlands. During spring runoff, and during rain-on-snow events the water will apparently sheet flow or infiltrate the close-cropped golf course. ...The tee for golf course Hole 3 is proposed to be located on the terrace south of and above the small ephemeral channel at the base of the slope that connects Wetland A with Wetland B." The EIS depicts this area as a "Type 5 Water Ephemeral Channel" (Existing Conditions Map B, Figure 2B). The Appendix H, in the EIS, maps the channel as being a wetland on August 7, 1994, long after snowmelt, but only a few months before the snows begin. The presence of a wetland here this late in the year indicates that significant water recharge occurs continuously. Plot P in the "Ephemeral Channel" is listed as being a wetland formed by an "old berm"; if so, then it is technically a diversion restricting the spring from spreading over a much larger wetland area. Therefore the Addendum should analyze water quality based on a realistic model that takes into account significant horizontal pesticide transport during the spring, summer and fall. 2. The effects of summer thunderstorms have not been adequately quantified. The Methow Valley has frequent summer thunderstorms, and they often produce sheet flow, which would transport pesticides from the resort into the ground water. The Addendum doesn't depict what would have happened this year, 1998, when daily temperatures were hot in early spring, and the golf course superintendent would have been irrigating and applying chemicals to the golf course in early May. The Methow Valley then had a sudden, very rainy period - which put a lot of water through the soil profile, that would have delivered nitrates and pesticides into the Methow River. Neither the Addendum nor the EIS accurately described the increase in nitrates and pesticides, and likely exceedance of 1 milligram per liter threshold criteria, that would have resulted from a thunderstorm carrying Class A effluent into a Class AA river. 3. The Addendum and EIS acknowledge, "The irrigation lake would be within the 100-year floodplain and thus could be inundated during severe floods." On Appendix D, p. 1-4 of the DEIS, Appendix 1, the waste water treatment facility would treat an additional 125,000 gallons of day at Class A standards, which would be used to irrigate the golf course. Class A water would contain suspended particulates and coliforms which would not be transported through the groundwater, but would migrate during overland flow events. Neither the Addendum nor the EIS accurately described the increase in nitrates and pesticides that would result from a thunderstorm carrying Class A effluent into a Class AA river. 4. Neither the Addendum nor the EIS answered the questions of James Tracy, Special Counsel to the Planning Department, speaking before the County Commissioners hearing on the adequacy of the EIS, on August 20, 1996, who stated, "We also have in this proposal an equestrian center. Which in itself raises some questions regarding the handling of surface water runoff from the equestrian center. " Mr. Tracy's questions about the runoff from the Arrowleaf PDR have not been analyzed in the Addendum. This additional source of nitrogen and coliform runoff have not been discussed yet in the Commissioner's findings, the EIS, or the Addendum. 5. Neither the EIS nor the Addendum considers the impacts to water quality and quantity from the sewage outflow from adjacent land owners. James Tracy, Special Counsel for the Okanogan County Planning Department, stated at the Commissioner's Hearing on the Adequacy of the Arrowleaf EIS, August, 20, 1996. "...the sewage facilities on Arrowleaf are designed to serve only Arrowleaf residents." The Methow river shore across the river from the Arrowleaf PDR is already densely subdivided. Additional subdivision and development will increase on these parcels, yet the analysis of the contributions of coliforms, pesticides and runoff was not available in the Addendum for the Commissioners to amend their decision. If thresholds for AA Water quality are exceeded, a repeat of the past issuance of a building moratorium to protect water resources in the area, known as Subunit A, could occur again. 6. Herbicide and fertilization application calculations also do not account for herbicide application elsewhere on the property. There will be many other areas where the proposed resort would have (and already has) major weed problems. Given the amount of ground disturbance that the resort will produce, it will be necessary to control weeds on at least 600 - 1000 acres. This would greatly increase the total amount of herbicide applied to the site, over what was projected for the golf course alone. 7. The economic and environmental costs associated with flooding of the proposed golf course in the 100-year Methow River floodplain has not been acknowledged. Flood damage from the Hangman Valley Golf Course in Spokane, Washington, in a similar climate and setting as the Arrowleaf PDR, will cost taxpayers nearly $1 million, according to reporter Dan Hansen of The Spokesman-Review, on April 1, 1998. Under the headline, "Hangman golf course fix to cost $1 million", the news article explained, "Money for the work would come from a 20-year bond repaid through golf fees. But golfers may get a break: The state has recommended that the Federal Emergency Management Agency pay $680,000 of the cost, since engineers predict it will prevent future flood damage. `It's still taxpayer money, even if it does come from the federal government,' McCaslin said." 8. The Addendum claims that the Arrowleaf PDR would use IPM on the golf course, yet it in Table 5, Maximum Potential Use, is given as 243 pounds of chemical herbicides (over 100 pounds 2-4D), 258 pounds of chemical insecticides, 2,184 pounds of chemical fungicides, and 39.4 pounds of chemical growth regulators. The Addendum presents no details about how these pesticide quantities are going to be monitored and regulated. In actuality, it would be up to the discretion of the golf course attendant to use what he/she wished, with no state reporting requirements necessary. The application of a ton of fungicide every year to sandy soils adjacent to a AA river would be detrimental to the water quality, and would impair health and quality of the Methow River, which currently has one of the highest water quality standards in the western US. The fungicides released would seriously damage mycorrhizal associates of native cottonwood communities that currently hold the banks in place. This would lead to loss of root strength and bank stability, replacement of strong perennial native root communities with grasses and annuals, and eventually to an increased risk of flood damage. 9. The Addendum specifies neither the amount, nor chemical composition, of so- called "inert ingredients", that would be used in conjunction with pesticide use on the golf course and residences. "Inert" does not mean "inactive", but includes compounds diesel fuel, benzene and xylene, which can be more toxic than chemicals listed on the label. Soaps and surfactants used to multiply the effects of pesticides are considered "inert", yet they have been implicated in adverse estrogenic (hormone mimicking) effects, which can harm reproductive systems of many organisms and lead to cancer in some cases. The Declaration of George Wooten, in the MVCC appeal to Superior Court, included a reference documenting that surfactants in different commercial preparations of glyphosate result in 400-fold greater toxicity to sockeye salmon fry (Monroe, David H., 1988, Ecotoxicity of surfactants used in vegetation management. Environmental Consultants Northwest, Stanwood, Washington - Wooten Exhibit F in Superior Court). Unfortunately, such "inert ingredients" are considered trade secrets by the industry, which keeps the full extent of their use hidden from public consideration. "Inert ingredients" can make up over 98% of a pesticide formulation. Without knowing what "inert ingredients" will be used on the Arrowleaf PDR, neither the Addendum nor the EIS have made it possible to make an informed decision about whether the resort will harm the environment. Neither the Addendum nor the EIS have addressed the toxicity resulting from the leaching and breakdown of chemicals are bound loosely to surface materials, but which are released during precipitation events. 10. Many herbicides and pesticides break down into compounds that are toxic to non-target organisms (including humans). Many breakdown products have estrogenic (hormone mimicking) effects, which can harm reproductive systems of many organisms and lead to cancer in some cases. Almost all of these breakdown products will move into the groundwater sooner or later. If they haven't moved into the groundwater during the growing season - they will move down there during the spring snow melt, when the largest quantity of water flows through the soil profile in the Mazama area. The currently pristine AA waters of the Methow River will become polluted. 11. The Addendum does not describe the adverse impacts of incidental take of Threatened and Endangered species as required in the Endangered Species Act, as a result of pesticide transport into the food supply of Methow steelhead, which spawn along the Arrowleaf parcel, other fish species proposed for listing (bull trout and Methow Spring Chinook), bald eagles, spotted owls, grizzly bear and gray wolf, all of which have been observed near the resort. The addendum specifies no control measures for vertebrates or rodents, such as pocket gophers, which are common in Methow Valley. The use of rodenticides would increase the likelihood of adverse secondary effects to gray wolves, bald eagles and spotted owls using the site. 12. MVCC'S written appeal, page 10 (Section C #2) states, "The EIS fails to address the impact of the PDR on threatened and endangered species." Bull trout, Chinook salmon and steelhead were all petitioned for listing as endangered at the time of the appeal, and as pointed out by Lynda Hoffman, Letter 8 in response to the DEIS and in her 4.28.97 deposition, "steelhead are now listed as endangered". The "type 5 ephemeral channel, identified as wetland "P", in the EIS Appendix H, connects with wetlands labeled on the EIS maps as A1, A2, A3, A4, A5, B1, B2, B3, B4, C, D, and P, and forms a continuous, wetland habitat with anadromous fish redds at the outlet on the Methow River. Wetlands contiguous with endangered species are classified as Category One Wetlands in Washington state, and receive minimum 200 foot buffers, in addition to the added buffer strip required for the channel wetlands. It would be nearly impossible to obtain a dredge and fill permit for this project if this were known, not to mention the unlikeliness of National Marine Fisheries approval to allow damage to Threatened and Endangered Methow fish stocks, therefore it appears that the EIS as planned is an attempt to conceal the true extent of endangered species habitats and wetlands on their property. The Addendum does not address these significant impacts to water quality, either. 13. The Addendum fails to address any of the issues raised by the MVCC appeal and the declarations of George Wooten and Joseph Dana Visalli, about the effects of pesticide transport on amphibians. The latter points out that while no amphibian surveys were conducted and some of the species assumed in the EIS and DEIS to reside in the area have never been located in the county, the development will "benefit amphibians." This is an unsubstantiated and inaccurate statement, which has already been contradicted in the reference cited by George Wooten in his declaration to Superior Court, that herbicide application is implicated as one of the causes in the global decline of amphibian populations (Blaustein and Wake, 1995, The puzzle of declining amphibian populations. Scientific American, April, 1995, pp. 52-57). If the Addendum had presented findings to the contrary, it would have been possible to debate the relative impacts to amphibians, but as written, neither the Addendum nor the EIS have given sufficient evidence that amphibians in general, and spotted frogs in particular, will benefit from the resort. In fact, the spotted frog in recent years is nearly extirpated from its former range throughout western washington, and remains secure only in still undeveloped habitats east of the Cascades. 14. The Addendum does not address what will happen to harlequin ducks. Neither the EIS nor the addendum describes the adverse impacts on harlequin ducks feeding on insects killed by pesticides. The FEIS claimed that the harlequin nesting period would "coincide with the period of limited trail use on the PDR site." (page 6 of Kenneth Raedeke's rebuttal to the MVCC appeal). The county brief points out that "wildlife breeding and nesting occurs from May to mid-June." Dana Visalli's declaration cited data indicating that harlequins actually nest within the time span of May 15 to July 1. May and June are the height of the wildflower bloom in the upper valley and would clearly be a time of heavy trail, irrigation and golf course use. As indicated in Visalli's declaration, "harlequins will be vulnerable to disturbance from the considerable activity at the proposed development in June." 15. Neither the EIS nor the addendum describes the adverse impacts of pesticide transport on amphibians and songbirds that would result from drift of aerosols used to kill insects. As the county brief reiterates, the EIS indicates that the development will impact bird species, "that feed on insects, those that are least tolerant of human disturbance, those that nest on the ground or in cavities, and those that are adapted to larger patches or blocks of forest". (County Brief page 42 lines 17-19). This list would include most of the birds species that currently use the site. The summary assessment of impacts to songbirds given in the EIS are that the development "will contribute to the viability of bird populations in the region." This was contradicted by the EIS's assumptions of impact just enumerated. The Declaration of George Wooten, in the MVCC appeal to Superior Court, included the reference documenting the resort's effects on songbirds (Lyle Friesen, Paul Eagles and R.J. Mackay, effects of residential development on forest-dwelling Neotropical migrant songbirds, Conservation Biology, Volume 9, pp. 1408-1414 - Wooten Exhibit G in Superior Court), which concluded, "Many bird species are in local or regional decline because of habitat loss or degradation . . . we found that the number of houses surrounding a forest severely undermined its suitability for Neotropical migrants. Neotropical migrants consistently decreased in diversity and abundance as the level of adjacent development increased, regardless of forest size." Diazinon, a widely used landscape maintenance and golf course pesticide, and similar in structure and action to other nerve-gas type insecticides proposed in the Addendum, is documented by the EPA to have caused over 50 bird kills involving up to 1000 birds in every region of the country. EPA, citing "a disturbing, and sometimes shocking, record of bird mortalities", canceled diazinon's registration on golf courses, but still allows the chemical for other turf and lawn uses, such as would be common on the proposed PDR (Catherine Cox, 1992, Diazinon. Journal of Pesticide Reform, Volume 12, p. 30-35 - Wooten Exhibit C submitted to Superior Court). One investigator has detected the presence of 2,4-D and diazinon in pond water, and found that wet ponds were not effective in removing these more soluble and mobile compounds (Bannerman, R. 1994. Unpublished data on diazinon concentrations and toxicity in stormwater ponds. Bureau of Water Management. Wisconsin DNR. Madison, WI.). This suggests that even with maximum vertical mixing assumed by the EIS and Addendum, soluble and mobile pesticides will still be transported through porous soils into the Methow River's wildlife and human inhabitants. I declare under penalty of perjury of the laws of the State of Washington that the foregoing is true and correct. Executed at Winthrop, Washington this 25th day of June, 1998. __________________________________ George Wooten, Jr.
Index to MVCC's campaign to avert a destination resort in the Methow Valley, Washington
