Letter from Andrea L. Weiser Opposing Quarry Mine in Marblemount

Letter from Andrea L. Weiser Opposing Quarry Mine in Marblemount

Andrea L. Weiser, MA, a professional archaeologist and a twenty-year resident of Marblemount has written a thorough assessment of the proposed quarry mine near Marblemount. Here it is:

To: Skagit County Planning Office

Thank you for the opportunity to comment. I have reviewed the project proposal and
supporting documents for expansion of the Kiewet infrastructure for rock quarrying
and mining in Marblemount 59252 Rockport-Cascade Road, Skagit County, within a
portion of Section 24, Township 35 North, Range 10 East, Skagit County, WA
(Parcels P45543, P45541, P45548, P45552, P45550, P45548, P128574, &
P120304). The associated permits are PL19-0032 and PL19-0033, PL19-0046, and
BP 19-0070.

I am deeply concerned with this proposal because even without a fuller understanding
of overall reach or longevity of impacts (i.e., through an EIS), this is clearly an
inappropriate location for such dramatic direct and indirect impacts to the health of
people, animals and fish, health of the natural environment, and the overall aesthetics
and quality of life for all those who live in or travel to this project vicinity.
This proposal is in a location within close proximity to a wild and scenic river in one of
the largest annual migration areas for bald eagles in the country in a river system
where federal, state and tribal agencies, and non-profit groups work in coordination
and have spent millions of dollars to enhance and protect and educate the public
about salmon and wildlife habitats and environmental health. This project is located at
the gateway to U.S. National Park and U.S. National Forest wild and wilderness areas
where visitors from all over the world come to enjoy the scenery and recreation
opportunities in a rural, remote, mountainous non-industrial setting. Several things
about the proposed project are diametrically opposed to these values and would
undermine the progress that has been made over the last several decades to
promote recovery from resource exploitation and extraction and cooperation and
collaboration between groups toward a common goal.

This quarry expansion project is counter to the mission of the Recreation and
Conservation Office (RCO) which, is a small state agency that manages millions of
dollars in grant programs each year to “create outdoor recreation opportunities,
protect the best of the state’s wildlife habitat and farmland, and help return salmon
from near extinction(www.RCO.wa.gov).” The habitat and recreation opportunities in
the Skagit River system is a key part of their programs. They collaborate with partners
and tribal communities annually with a focus toward restoration. The project proposal
and potential effects of the quarry project in this location is the direct opposite of RCO
mission and the organizations it supports: i.e., Recreation and Conservation Funding
Board (RCFB);Salmon Recovery Funding Board (SRFB); Invasive Species Council
Governor’s Salmon Recovery Office; Habitat and Recreation Lands Coordinating
Group.”

People visit and live in Marblemount because of the low population density, abundant
fish and wildlife, clarity of the air and water and beauty of the landscape. Not only
would the proposed project disturb the peaceful beauty of the landscape, it would
leave a lasting visible scar on the geography and a series of invisible scars that may
take decades to recognize or understand.

The studies that are submitted with the project proposal so far only serve to highlight
the great gaps in understanding of the lasting and overall impacts of such a proposal.
Yet comparison to other areas of and projects of similar scope and scale make it clear
that the costs and risks to the surrounding community and environment would be far
greater than the benefit.

Noise

Perhaps the most obvious immediate and lasting negative impact over the broadest
reach would be sound. From my home in Marblemount, I can already hear a
chainsaw from over a mile away and rocky ridges reflect that sound like a speaker to
the rest of the community. It’s difficult for me to fathom the noise and vibration impact
of blasting for constructing over a mile-long stretch of road, chainsaw and heavy
equipment noise for timber harvest of 2.7 million board feet over 90 acres and the
truck traffic to transport all that timber. Removal of 3.8 cubic meters of quarry rock
and transporting it could involve up to 250 truck trips per day, at three minute
intervals, six days per week for 12-hour days. Add to this level of noise disturbance a
rock crushing operation, oversized trucks carrying rock pieces large enough to use for
jetties, and gas and diesel re-supply trucks large enough to fill and refill storage tanks
for 13,000 gallons of diesel fuel and 1,500 gallons of gasoline. There is no way to
adequately mitigate for this sustained level of sound and traffic for the people living
directly downslope or across the road from these proposed operations such as the
residential homes along Rockport-Cascade Road. And the noise would be projected by
the rock faces being demolished and would carry across the valley, across the river
and be heard by people specifically in Marblemount for the quiet camping and
recreating experiences. Tourism is an important part of the economy and the National
Park Service and Forest Service have built their programs to support it.

Environmental Health & Water Quality 

Transport, storage, and resupply of diesel and gas leave the area at risk for spillage
of toxic materials which can cause local soil contamination and far reaching
contamination through water transport. The proposed work is on a rocky site in an
area that receives an average rainfall of roughly 70-80 inches per year. This is a
setup for slope runoff conditions compounded by the proposed timber harvest that
would put fish-bearing streams and the Skagit River system at risk for contamination.

Traffic

Traffic increases from the transportation of timber, rock, gravel, and diesel and gas
would cause a huge negative impact to the surrounding community(ies) for traffic
safety and road maintenance due to the heavy loads. Currently the Rockport-Cascade
Road is a favored route for bicyclists, motorcyclists, runners and fishermen in addition
to the local commuter traffic you might expect in a rural community. It is a quiet road
with not much traffic and a narrow shoulder. This dramatic shift in usage would cause
a safety hazard for anyone wanting to run or ride a bike and the large and oversized
trucks used to transport extracted materials would cause bottleneck areas for
motorists and increase hazards such as flying gravel or debris from truck wheels.

Environmental Considerations

Though the SEPA checklist and Biological Assessment touches on several of my
other concerns, the scope of study so far has been either inadequate to address them
or already made it clear to me that this proposed project is not suitable for the location
it is proposed within.

Comprehensive Plan and State Constitution

The proposed activities to expand the rock quarry infrastructure and operation are in
direct opposition to the Skagit County Comprehensive Plan. Relevant sections
regarding property rights include, and I quote:

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. Planning,
land use regulations and zoning protect individual and community rights in the following
ways:
· by avoiding nuisances through ensuring against incompatible neighboring land
uses;
· by balancing public and private responsibilities that may have conflicting interests;
· by providing predictability that enhances the value of private property;
· by protecting and conserving the natural resources that provide us with clean air
and water;
· by protecting our heritage by preserving both natural and man-made resources,
and scenic and cultural areas that generate civic pride;
· by assuring that each generation has responsibilities as a trustee of the
environment for future generations;
· by attaining the widest range of land uses without degradation, risk to health or
safety, or other undesirable and unintended consequences; and
· by recognizing that each person has a fundamental and inalienable right to a
healthful environment and that each person has a responsibility to contribute to the
protection and enhancement of the environment;
· by recognizing existing non-conforming land uses and the development rights
associated with them.

Cultural Resources

A more expansive and intensive study is needed to establish how many cultural
resources lie within the project footprint and how those and other known cultural
resources outside of the footprint would be affected by the proposed activities. Due
diligence for search/discovery of cultural resources has not been met nor is it
adequate to address long-term indirect effects of the project. The project came to my
attention because I’m a local resident of Marblemount and would feel, hear, and see
the dramatic effects of such a project. I also have particular expertise relevant to
reviewing the cultural resources investigation for the project as a professional
archaeologist recognized by the Department of Archaeology and Historic
Preservation (DAHP) and the Secretary of Interior for my professional qualifications,
which include a Masters degree in archaeology and over 25 years of experience,
most of that in the surrounding area in Washington. I have reviewed dozens of such
reports in Washington in recent years across several counties and conducted many
archaeological investigations myself so I am well aware of the guidelines set forth by
the DAHP as well as best management practices and common styles of investigation
that are conducted in the region. For an area of medium to high probability for
archaeological discovery such as this, a low level interval of investigation would be 5
shovel tests per acre which would equate to 600 shovel probes for this 150-acre
project. Archaeological survey is typically tailored to the topography and conditions in
a project area and the research design should show an appropriate coverage of the
area to meet due diligence. In an area like this that includes a lot of rocky terrain, the
number of shovel probes would be reduced but the amount of pedestrian survey
transects would be increased due to the potential for rock art, rock shelters, toolstone
outcrops, cairns and other features that may be related to hunting, ceremony or other
activities.

Another consideration is that level of effort should match the scope of proposed
disturbance of a project. The Cultural Resources Report submitted for this project is
grossly inadequate to meet the scope of the proposed project. A survey conducted in
two partial days by three people and only 9 shovel tests to cover a 150-acre project
area, much of which would be demolished by rock extraction and road building if the
project moves forward, is an inappropriately small level of investigation. I question
why the archaeologists did not continue their survey to cover a greater area or find
additional areas within the 150 acres for more intensive investigation. It is not clear
from their report how much of he area they actually surveyed. Since the scope of the
project is to remove most of the rock within the project footprint, the scope of impact
is much greater than the scope an archaeological survey could achieve in two days of
work.

Further, the authors mention nearby archaeological sites as general context but fail to
make a connection between the area of the proposed project and nearby cultural
resources deeply important to the Sauk-Suiattle, Swinomish, and Upper Skagit
Tribes. Distance in mileage is not the best measure of the connectivity of a landscape
and river system to cultural importance in the precontact period. Nearby villages
contain archaeological evidence showing thousands of years of use, and human
remains in other nearby locations represent two types of cultural resources that are
important to consider and serve to heighten the probability of finding archaeological
sites in the surrounding terrain. Broad “home base” areas that indigenous people
accessed for different activities surrounded villages (perhaps several miles accessible
on foot and even greater distances easily accessible by canoe). Ethnographic
documents suggest a high probability for spiritual/ceremonial practices in places like
highpoint rock promontories close to villages such as the proposed project area.
Other precontact (prehistoric) types of activities that could be expected within the
project include hunting, camping, plant collecting, acquiring stone suitable for making
tools and for special ceremonies. Rock shelters, culturally-modified trees and
significant trails are also possible within the project footprint. Ridge tops and ridge
saddles are some of the highest probability landforms for finding archaeological sites
as is demonstrated by hundreds of archaeological sites recorded and studied
throughout the North Cascades. This project includes a ridge crest with close
proximity and access to the Skagit River, and nearby villages could have easily been
accessed by trail and then a short canoe ride.

These cultural areas are important to the tribes as evidence of their history and some
for modern-day visitation to these places. It appears that the authors of the cultural
resources survey did review archaeological and ethnographic expectations, but didn’t
design their strategy of investigation to adequately search for them.

Sincerely,
Andrea L. Weiser

Skagit County Planners can expect another letter from Andrea before the May 13th deadline. Please join Andrea in expressing your perspective on this very concerning development.

We are in an extended public comment period. We encourage you to submit your written comments opposing the quarry permit by Monday, May 13, 2019, at 4:30 p.m. Remember to include your name and mailing address. Thank you for helping us speak out for the well-being of our Skagit River Valley.

Written comments can be sent to:

Skagit County
Planning and Development ;Services
1800 Continental Place
Mount Vernon, WA 98273

The permits are
PL19-0032 and PL19 -0033, 0046, 0046
BP 19-0070

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