Has growth become more important than clean drinking water? Our government has a duty to protect us and especially our children, the elderly, and other vulnerable groups from exposure to polluted water sources. Clean water is finite and precious. We should not be reluctant to protect it.
The City of Edmonds is one of the few cities in Snohomish County not 100% reliant on Everett or Seattle for its drinking water. Edmonds/Woodway already has Deer Creek Springs and now the 228th Street Wellfield will be coming online to give residents in south Edmonds and Highway 99/Esperance areas clean, uncontaminated drinking water.
Edmonds’ city administration, staff and the Planning Board are currently deciding what the city should do to protect these two existing clean drinking water sources in Edmonds. One way to do that is to recognize and protect what are called “CARAs” (Critical Aquifer Recharge Areas). From the Edmonds Development Code (EDC) 23.60: “CARAs have prevailing geologic conditions associated with infiltration rates that create a high potential for contamination of ground water resources or contribute significantly to the replenishment of ground water.” Currently this code provision states that there are no CARA areas in Edmonds. Two CARAs in Edmonds have now been accurately computer mapped. In fact, states, cities and counties have a recognized legal duty to acknowledge and protect identified CARAs.
From the Edmonds Planning Board packet dated 7/26/23:
Critical aquifer recharge areas (CARA) are being established to protect public groundwater drinking supplies from potential contamination and to ensure adequate groundwater availability. The proposed code amendment would revise Chapter 23.60 EDC to regulate CARAs in the City of Edmonds, based on the identification of CARAs in proximity to aquifers utilized by the Olympic View Water and Sewer District (OVWSD).
These CARA protections are finally catching up with science by targeting the need to keep PFAS, or “forever chemicals,” out of our drinking water. Cities are being asked to be intentional with these new codes to prevent this toxic contamination of drinking water supplies, including limiting stormwater runoff. These “forever chemicals” are being considered as potentially cancer-causing and are linked as well to a decreased immune response, with babies, immunocompromised people and elderly at highest risk. The hard truth is that if we do things that allow pollutants to drip into these areas, it will pollute these clean water supplies.
Currently, there is no known contamination of these two drinking water aquifers here in Edmonds. We are lucky, but new threats are looming on the horizon.
At the July 26 meeting, one planning board member asked a very good question: How is it that these CARA areas are contaminant-free without any past CARA regulations? Staff answered that it was most likely due to these areas being zoned mostly single-family. Clearly, then, there is a relationship to this land being used less intensively and the amount of hazardous runoff being produced. It is vitally important that we protect these CARAs from huge increases in density.
The 2023 state-mandated housing bills, HB 1110 and HB 1337, both include doubling or quadrupling the impervious housing surfaces on a single-housed lot as well as forcing parking from private property garages onto our city streets. This would greatly increase the likelihood of contaminated runoff in the aquifer areas. This type of mandated upzoning density and restrictions on adding onsite parking requirements for vehicles should be exempted from these CARA areas.
Now that CARAs in Edmonds have been identified, the “Buildable Lands Report” should be adjusted to exempt them from population growth mandates such as those found in recent state housing bills. We advocate for the strictest possible protections for these areas.
A first step is for the Edmonds Planning Department staff to add language to our “CARA Code” that states CARAs in Edmonds should be exempt from HB 1337’s requirements for upzoning. Section 3 of that bill states that the act does not require cities to authorize construction of ADUs “where development is restricted under other laws, rules, or ordinances as a result of physical proximity to onsite…critical areas…”
You might be asking yourself, “what can I do?”
An effective way to make your voice heard is to email the Edmonds Citizens Planning Board, which will be holding a public hearing this Wednesday, Nov. 29 at 7 p.m. and making recommendations to the city council on the new CARA. Collective voices are compelling. Join your voice with other Edmonds residents and email your thoughts and ideas on protecting our CARAs to the planning board at: citizens-planning@edmondswa.gov.
— By Dr. Michelle Dotsch
Michelle Dotsch is president of the Alliance of Citizens for Edmonds (ACE) and has authored this on behalf of the board.
I think my three grown children are already planning a four plex for our property, but I agree that covering the lot with housing would likely increase contamination of soil, drinking water, and Puget Sound. The extra car trips, as we go from two older people who no longer drive much, to a “compound” of eight adults and three teens, will be a significant increase in PFAS, 6PPD, and other nasty stuff. Since street sweeping is presently the only vaguely effective method for reducing some vehicle contamination, allowing us to park six to ten cars on the street is also a problem. I like the idea of directing growth outside the drinking water protection areas, and adjusting our growth targets, at least for now. Perhaps we can build the “compound” after they figure out how to treat stormwater for all the nasty stuff.
Soon to be Councilmember Dotsch,
Thank you so much for this information. I saw the PB agenda, knew it was an important issue but didn’t have the detail that you have laid out here.
I plan to email Planning Board members, as you have suggested, and hope others do as well.
I disagree with Michelle Dotsch’s assertion that concern about PFAs should result in opposition to HB1110 & 1337 allowing duplexes, triplexes, and quadplexes on areas previously zoned single family units only within the CARAs.
The EPA identifies sources of PFAs as ‘proximity to industrial sites, airports, military bases, lands where biosolids containing PFAs have been applied, and other sites where PFAs have been produced or used…’
She interprets city staff’s statement about the absence of PFAs as ‘…likely due to these areas being zoned mostly single-family…’ as meaning ‘Clearly, then, there is a relationship to this land being used less intensively and the amount of hazardous runoff being produced…’ City staff made no statement about ‘land being used less intensively.’ A valid interpretation of staff’s statement is that being zoned single-family means that it is not zoned industrial, or used as an airport, military base or lands where PFAs have been produced or used.
If residences were a potential source of PFAs in drinking water from CARAs, then it follows that even with single family residences, some PFAs would have been found. But none have been found.
New duplexes, triplexes, and quadplexes as authorized by HB1110 and 1337 should not be restricted in the CARAs.
Are we assuming that these are currently just potential sources of safe drinking water or are they already sources of some of our drinking water? Is it possible that these two clean aquifers could reasonably be our main source, or one of our main sources of clean drinking water now and/or in the very near future? Could the city save some money by getting all, some, or most of our drinking water from these sources? Seems like we need many more facts relating to how to protect this resource in the best way possible. It also seems like the best way to limit nearby over density with it’s potential for pollution would be to make these actual city owned sources of our drinking water supply in order to fully justify their protection against external, forced upon us, up zoning legislation.
Thank you for the alert on this important issue Michelle. Protecting our drinking water is definitely a big deal and we should all pay attention to what is happening.
I assume that the water district was OK with existing land use and zoning in the CARA when the 228th Street well was drilled a few years ago. The mapping shows Hwy 99 upgradient in the 228th St CARA with used car lots, auto repair, various commercial uses and tens of thousands of cars daily.
I don’t see the basis for future CM Dotsch’s concerns about upzoned neighborhoods somehow making groundwater pollution risk worse in the 228th St. CARA than exist now or were/should have been predicted when the well was drilled.
Ideally the planning board should look at other ways of mitigating the impacts of the State top down upzoning, such as requiring decent setbacks and requiring on site parking until the City gets around to improving the storm drainage, sidewalks and roads. I’d also like to see the City give up on zero lot line development. But restricting residential development in the CARA does not make sense.
Great article Ms Dotsch. Thanks for sharing with us.
Does anyone know if Edmonds city water supply is currently being tested and monitored for PFA’s? If so, where can this data be found? Someone in this thread mentions that PFA’s have not been found – I would like to see a reference with recent testing results to confirm.