This was originally posted to: Guemes Island Planning Advisory Committee

GIPAC Comments On Environmental Analysis Of Proposed New Ferry

April 30, 2018

To:  Skagit County Planning and Development Services
pdscomments@co.skagit.wa.us

Re:  Replacement Guemes Ferry Proposal

From: The Guemes Island Planning Advisory Committee (GIPAC)

Thank you for the opportunity to comment on the Guemes Ferry Replacement Environmental Assessment (EA). As you know, the ferry project is of great interest and importance to our community, and we need to make sure that County decision-makers have the most complete and accurate information and analyses possible to support their choice among the alternatives presented. 

Previously, GIPAC submitted comments on the scope of the EA, asking that key environmental concerns of the adopted Guemes Island Subarea Plan be given close consideration in the environmental review. In particular, we quoted the plan: “In addition to seeking cost?effective ferry service, the goal of these policies is based on the GMA premise that the extension of public services and facilities to Rural areas like Guemes Island will not induce growth or adversely affect rural resources or rural character.” (p. 78)

Having now reviewed the draft EA, we believe additional analysis is needed to address these key concerns of the Guemes Island Subarea Plan. We ask that these concerns, particularly the proposal’s potential to induce growth and negatively affect the island’s already limited water resources, be addressed more completely in the final report. But we also want to be clear: GIPAC’s intent is not to suggest that sizing of the ferry should be used as a tool to control growth on the island; we have and will continue to work with the County to implement regulatory changes needed to appropriately protect our water and rural character. But to the extent that additional growth may be stimulated by a larger new ferry, we want to make sure this impact is documented and considered.

Key questions and concerns regarding the EA:

The EA concludes that the proposal will not affect growth on the island, based on an analysis of when the current ferry went into operation, compared to the number of building permits each year thereafter. Specifically, the EA Exhibit 14 shows that building permits did not increase right away when the current ferry (with expanded capacity) went into service in 1980, and the report therefore concludes there will be no induced growth impact from the current ferry proposal.  But indirect impacts, by definition, are typically delayed in time. They do not always occur simultaneously with project construction, the way that direct impacts do. Therefore looking only at the years immediately after a larger ferry began operation in 1980 may not capture the full impact of ferry-induced growth.

Furthermore, the analysis does not take into full account the role of economic factors that could mask the effect of ferry capacity increases on growth. The sharp reduction in building permits at the start of the recession in 2008 certainly suggests that the primary factor influencing building permit activity may well be economic conditions. In the same vein, the sharp uptick in building permits which started in 1992 corresponds to a period of strong economic expansion in the U.S. Could the delayed impact of the new ferry introduced in 1980 also have played a role? Economic indicators must be factored into the analysis in order to isolate the possibility that there was additional impact from induced (delayed) growth.

In the big picture, we recognize that many factors come into play in determining growth on the island. There is a complex interplay among factors that, we acknowledge, may make it difficult to isolate and quantify ferry impacts. Nevertheless it’s important to try.

Again regarding Exhibit 14, we would appreciate clarification about how the “Number of Structures Built by Year 1960–2016” is calculated. Much of the growth now occurring on Guemes Island is in the form of existing homes being enlarged or replaced—so our question is whether these are taken into consideration, or are structures counted only as new buildings on vacant property? We would point out that the building cap proposed in the Guemes Island Subarea Plan relates to all new buildings and any expansion of 25 percent or more of existing homes. This should be the measure of building activity captured in the environmental assessment.

In assessing the potential for growth on the island, GIPAC suggests that the propulsion system for the new boat may be a bigger factor than the size of the boat in stimulating visitors to the island and encouraging building activity. A cutting-edge electric ferry will attract national attention, raising awareness of Guemes Island and attracting both day visitation and, because visitors will like what they see, interest in long-term residence. While the environmental benefits of the electric ferry should be fully documented in the EA, so should its potential impact in bringing more people to the island.

Shifting demographics on Guemes Island are a factor we suggest should be acknowledged in the EA, because they create a very sensitive situation with respect to ongoing and projected growth on the island. In 2006, the American Institute of Architects determined that 70 percent of all shoreline properties on Guemes were owned by people 65 years or older. (See Guemes Island SDAT, Creating a Sustainable Guemes, June 20-22, 2006 at tinyurl.com/GISDAT.) As a result of this demographic factor, we are already in the middle of a significant transfer of property ownership from one generation to the next, and acceleration of property sales. The EA should note that the island is in a state of flux regarding demographics, and ongoing changes in the socio-economic makeup of the island may result in increased building activity.

The EA does not attempt to identify the extent to which access to the island would improve under the proposal, contrary to considerable literature describing how to assess the indirect impacts of transportation projects. That analysis always starts with quantification of the improved access that a transportation project provides. In the case of a new highway, the analysis starts with quantification of reduced travel times to an area. The ferry project EA needs to provide this type of analysis, without which there is no basis for analyzing indirect impacts. How many cars are currently left behind at the dock, and how often? What is the average additional travel time these cars are subject to? How would these numbers change under the proposed ferry expansion and the alternatives? (Note that GIPAC recognizes, conversely, there could be significant economic benefits for contractors and other workers who lose time waiting in the ferry line when their planned ferry is full and they are left waiting at the dock.)

Given this (quantified) reduction in travel time to the island, what is the reasonably expected increase in the rate of housing growth on the island? This impact may not be “significant” but that does not mean that we can know with certainty that no impact will occur, or that there will be no difference in impacts between the three alternative boat sizes.  

The EA needs to provide a more thorough discussion of water problems on the island that have been caused by growth occurring to date.  In 1977, the federal Environmental Protection Agency designated all of Guemes Island a "sole source aquifer."  However, there is no mention in the EA of wells that have failed since the early 1990s due to seawater intrusion. There is mention of the County PUD-operated reverse osmosis plant on West Beach, but no analysis of what caused the community wells in the Potlatch Development (where the PUD is located) to be condemned by the State Department of Ecology. To be complete, the EA needs to mention well failures in the context of the island’s Sole Source Aquifer, and address the issue of how to prevent further growth-induced failures. The implication that measures currently in place to address seawater intrusion have “solved” the problem is not defensible. ??GIPAC continues to push for tighter restrictions on new wells and additional research to better delineate key aquifer recharge areas which need protection. On the flip side, the work that GIPAC is doing to encourage rainwater catchment systems as an alternative to wells could eventually enable growth that would otherwise be restricted due to aquifer limitations. 

We recognize that indirect impacts can be difficult to assess. Data may be missing, and numerical analyses may not always be feasible. Nevertheless, the EA is not complete unless it at least attempts to undertake this analysis. At a minimum, the EA needs to be revised to:

— Identify economic indicators that have affected growth over time, in order to help isolate any additional growth (indirect impacts) that may have been stimulated by the larger M/V Guemes ferry going into service as a replacement for the Almar ferry. 

— Provide quantification of how much the proposed larger ferry would improve access to the island. For example, what would be the average reduction in travel time for cars that would otherwise be left behind? 

— Acknowledge that some increase in the rate of growth may be induced by a 50% or 33% (reduced ferry size alternative) increase in ferry capacity and associated reductions in travel time, even if data and analysis limitations make it impossible to fully quantify.

— Provide additional documentation of the well failures that have occurred on the island and the potential for increased water problems due to increased water withdrawals associated with possible ferry-induced growth.

— Address the additional questions and considerations identified in Items 2-4 above.

Even if indirect impacts cannot be fully quantified or are deemed not significant, their potential still needs to be addressed. GIPAC asks for a more complete discussion of indirect impacts so that they can be taken into consideration by the decision makers responsible for determining the size and propulsion system for the new boat. 

Thank you for your serious consideration of these comments.

Guemes Island Planning Advisory Committee

Hal Rooks, Chair
Stephen Orsini
Michael Brown
Patty Rose
Allen Bush
Edith Walden
Nancy Fox
Gary Curtis, Emeritus