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\nKevin Cricchio, Senior Planer  \nSkagit County Planning and Development Services 1800 Continental Place  \nMount Vernon, WA 98273 [kcricchio@co.skagit.wa.us](kcricchio@co.skagit.wa.us)  \nRe: File No. PL16-0097 & PL16-0098; Concrete Nor’West Grip Road Gravel Mine  \nCentral Samish Valley Neighbors Project Permit Comments  \nDear Mr. Cricchio,  \nThese public comments are being submitted on behalf of Central Samish Valley Neighbors (“CSVN”) to address Special Use Permit application No. PL16-0097 and Forest Practice Conversion application no. PL16-0098, which propose to convert a forest into a 51-acre gravel mine anticipated to excavate 4.28 million cubic yards of gravel and sand and haul those materials with large gravel trucks and trailers on substandard, rural roads for the next quarter century. The project would clear 68 acres and excavate to within 10 feet of the water table, which is hydrologically connected to the Samish River and its associated wetlands. Eschewing the 300+-foot buffer required for industrial development next to such critical areas with steep slopes, the mine would observe just a 200-foot buffer. The mine and its undersized buffer would cut into an important wildlife corridor provided by one of the last remaining blocks of undeveloped land in the vicinity. Mine operations would impact a quiet, rural community and the school routes, cyclists, pedestrians, and commuters who rely on the roads. And the impacts are not limited to those that will occur in the future; a 2018 conversion of the 2 . 2-mile-long forest road into a gravel hauling road without review or approval has already caused unexamined impacts to the 36 wetlands and 25 streams and seeps along its route, including Swede Creek.  \nDue to these impacts, and as explained in detail below, the mine application does not demonstrate compliance with Skagit County’s special use permit criteria and thus cannot be approved without revision. Nor do the conditions set forth in the County’s Mitigated Determination of NonSignificance (“MDNS”) ameliorate the impacts – the impacts summarized above and detailed below would occur with those conditions in place. As discussed separately in CSVN’s appeal of that MDNS, the conditions do not address these impacts and, at least with respect to the 200-foot wetland buffer, exacerbate mine impacts by including conditions that violate County regulations. Consequently, the SUP application must be denied in its current  \nLORING ADVISING PLLC | PO Box 3356 | Friday Harbor, [WA 98250](WA 98250 | 360-622-8060 | kyle@loringadvising.com)[ |](WA 98250 | 360-622-8060 | kyle@loringadvising.com)[ 360-622-8060](WA 98250 | 360-622-8060 | kyle@loringadvising.com)[ |](WA 98250 | 360-622-8060 | kyle@loringadvising.com)[ kyle@loringadvising.com](WA 98250 | 360-622-8060 | kyle@loringadvising.com)  \n009443  \nform so that the applicant can revise the proposal to ensure that it meets SUP requirements to:  \n(1) not create undue noise for existing, surrounding dwelling units; (2) avoid causing potential adverse effects on the general public health, safety, and welfare; (3) not conflict with the health and safety of the community; (4) be served by adequate public facilities or services; and (5) maintain the character, landscape, and lifestyle of the rural area.  \nIn drafting this letter, we reviewed all of the publicly-available application materials, including the following:  \n(1) the March 7, 2016 fact sheet, special use narrative, and project description;  \n(2) subsequent special use narratives and revised project description;  \n(3) SEPA Checklist;  \n(4) fish and wildlife documents by Graham-Bunting Associates;  \n(5) the December 2021 NW Ecological Services’ Impact Assessment & Mitigation Plan (“NES Report”);  \n(6) the Hydrogeologic Site Assessment and December 16, 2021 Response to Skagit County Geologic Hazard Requirement from As","cbCaij63rxyAszNA","https://ap.wps.com/l/cbCaij63rxyAszNA","pdf",24245330,110,"English","# Background\n## Project Details and Work Completed to Date\n## Compliance With Special Use Permit Criteria\n## Review of Application Materials and Expert Exhibits\n## Requested Outcome and Required Revisions","[{\"question\":\"What permits and project are being commented on?\",\"answer\":\"The comments address Special Use Permit application PL16-0097 and Forest Practice Conversion application PL16-0098, proposing a 51-acre gravel mine in the Central Samish Valley.\"},{\"question\":\"Why does CSVN argue the applications should not be approved?\",\"answer\":\"The submission claims the mine would create significant impacts to wetlands, streams, wildlife corridors, and community road use, and that the SUP criteria are not met in the current proposal.\"},{\"question\":\"What does CSVN request the county to do?\",\"answer\":\"CSVN requests denial of the SUP application in its current form and requires the applicant to revise the proposal to ensure compliance with noise, public health and safety, adequate facilities, and preservation of rural character.\"}]","CSVN SUP Project Comments - PL16-0097 & PL16-0098 - gravel mine appeal and compliance request | PDF",277]