2022-07-26_PlanningCommission_ChehalisBreen_TestimonyJuly 25, 2022
To: Lewis County Planned Growth Committee Subject: Chehalis Embarks on Process to Increase Urban Growth Area
My wife (Dalene) and I (Paul) own a working Certified Organic family farm that is very near to the acreage you are in discussion about for UGA expansion. The traffic, noise, garbage, and litter would
all increase on Kirkland Road. Another issue of importance is the high amount of additional pollution
that would be added to the Newaukum River. The Newaukum in recent years has become cleaner and is supporting more fish. A housing development would jeopardize the hard fought gains this river has made.
Housing developments won’t hesitate to use inorganic herbicides (Roundup), fertilizers, and pesticides,
all of which find their way into the waterways, which are detrimental to not only the fish, but all wildlife. Another huge concern is the amount of added traffic that will clog an already extremely stressed
interchange at I-5, exit 72. This interchange is currently at maximum capacity and cannot handle any
more traffic. Both the Chehalis-Breen UGA expansion and the Chehalis-Westlund-Enbody expansion would make a large impact on the traffic problems that already exist at this exit. For these reasons and more we are against both of the Chehalis UGA expansion plans.
Paul and Dalene Olson 282 Kirkland Rd.
Chehalis, WA 98532
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July 26, 2022
Dear Lewis County Planning Commission, c/o Mindy Brooks
Please accept this written testimony regarding the City of Chehalis proposal to expand the
Chehalis-Breen UGA to include a 109.8 acre parcel, bound on the north by Hamilton Road and
east by Interstate 5.
My name is Mary Verner, a resident of unincorporated Lewis County. My street address is 423
Newaukum Valley Road, Parcel No. 018056002002, Sec 22 Twnshp 13N Range 02W PTW2
NW4LT2 3324395, 29.7 acres, Use Code- Agriculture. My small family farm is one parcel over to
the west of the proposed UGA expansion. My neighbors to the north and east abut directly up
to the southwest boundary line of the proposed UGA expansion area.
Please accept these comments in opposition to the Chehalis-Breen UGA expansion,
incorporating my recommendations for the City to undertake further analysis, and my request
to extend the public comment period.
The City of Chehalis proposes a significant conversion of land use
As I understand the proposal, the City supports the request of the estate of Virginia Breen to
convert an old 110-acre family farm on the Newaukum River into a high-density multi-family
residential development. The parcel has historically been agricultural, located within Lewis
County Rural Development District RDD-20, 1 unit per 20 acres. If the city’s UGA expansion is
granted, the old Breen farm will be built out to 12 units per 1 acre, for a total of 456 new
residential units on 38 acres of the farm, the remaining 72 acres being in the floodplain.
Under GMA regulations, counties should locate urban growth first in areas already
characterized by urban growth. The area surrounding this parcel is not urban in character, and
should not become urban through piecemeal expansion of city limits and high-density
development.
To the west and southwest of this parcel, other parcels like mine are currently zoned 1 unit per
20 acres or Agricultural Resource Lands. The City correctly states that the specific parcel to be
annexed is currently zoned for rural residential and no resource land conversion is analyzed.
Despite this technicality, the likely practical effect of the proposed high-density development
on this parcel will be creeping rezoning proposals moving further along the I-5 corridor to
encompass the rest of the lower Newaukum River valley.
This is not a good location for build-out of high-density multi-family housing
The city’s goal with this UGA expansion is well-intended – to accommodate projected
population increases with additional affordable multi-family housing. However, cramming 456
affordable housing units onto 38 acres -- boxed in by I-5, Hamilton Road, existing commercial
development, and a river that frequently floods – is not a good solution to the housing
problem.
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Although the City says that future zoning will not create an island of land use that is not similar
to that surrounding it, the proposal would result in a high-density multi-family residential
development on 38 acres of farm land adjacent to a heavily-traveled I-5 frontage road. Adjacent
properties on Hamilton Road are built out with tractor, trailer and logging supply businesses
where large vehicles and equipment connect between two I-5 access points at the LaBree Road
and Rush Road interchanges. Future multi-family housing at this location might or might not be
affordable, but it also may not be livable for residents packed close together beside incessant
traffic, noise, lights, and activity, adjacent to a frequently-flooded area.
Traffic infrastructure in the area is failing and cannot accommodate the proposed new uses
The City’s proposal provides only cursory analysis of transportation issues. Vehicle counts are
deferred until development begins, but it is reasonable to expect that traffic will increase
significantly when 456 new residential units are added to local surface roads. I ask the County
to require more detailed transportation analysis before approving the proposed UGA
expansion.
• What are the traffic control plans at the new development’s intersections with Hamilton
Rd S and Hamilton Rd N?
• There are no sidewalks or bicycle lanes or bus routes along either of the Hamilton
Roads. Does the city plan to require developers to provide safe passage from the new
high-density residential development to the commercial attractions at the Rush Road
interchange?
• What are the proposed emergency ingress/egress points from the 456-unit residential
development? The upper end of Hamilton Rd S is not a feasible option; it is narrow, cuts
90 degrees in a 15 mph turn, and is underwater whenever the river floods. This leaves
only Hamilton Rd N, the busy I-5 frontage road, to provide one way access in and out of
a densely-populated housing development.
There is already an urgent need to implement traffic flow and safety improvements at the
dangerous I-5 Rush Road Exit. As new businesses have been added to the Exit 72 area, very
little has been done to address the corresponding increases in traffic. Both sides of the freeway
are in constant snarls of heavy trucks, passenger vehicles, and a few bold pedestrians. Passage
through the failing intersections creates multiple risks of collisions from all directions.
Meaningful investments in traffic controls are urgently needed just to try to rectify the unsafe
conditions that already exist, even without increasing the volume of vehicles and pedestrians
by allowing a new high-density residential development.
Going up Rush Road from the heavily congested Exit 72 area toward Napavine, the first turn to
the north is onto Newaukum Valley Road, a rural residential county road where I live. Already,
Napavine’s growth along Rush Road and Sommerville Road is leading to increased spillover and
bypass traffic, as drivers cut through Newaukum Valley Road to avoid traffic jams around the I-5
interchange. Traffic controls are already needed on Newaukum Valley Road, even without
traffic increases that will inevitably result from nearby high-density residential development.
The City’s proposal indicates Lewis County will be responsible for road repair until such time as
the site is annexed. As a Lewis County taxpayer, I would like to see additional transportation
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impacts analysis and capital infrastructure plans sooner, instead of allowing the UGA to expand
and make the situation worse.
Flooding and critical areas
The city’s proposed UGA expansion disregards the community’s experiences with devastating
flooding of the Newaukum and Chehalis Rivers. Flooding throughout the lower Newaukum
valley is a serious concern and should not be treated as an insignificant factor when considering
whether it’s wise to build dense housing on a parcel that is transected by the Newaukum River.
As you know, the entire Chehalis Basin, including the stretch of the lower Newaukum River that
passes through the proposed UGA expansion area, is the subject of significant public and
private investment to reduce the impacts of flooding. As a landowner and taxpayer, I have a
vested stake in those efforts and oppose developments that are inconsistent with those
investments.
My next door neighbor’s pasture directly abuts the proposed UGA expansion parcel. Every year,
my neighbor’s pasture is flooded. The foundations of my neighbors’ homes are being washed
out from below as the river changes course during each rainy season. Recently, the county had
to install large pilings on the river bank to halt erosion that threatens to undermine Newaukum
Valley Road when the river roars through the area at flood stage. The back of my 25-acre
pasture almost abuts the proposed UGA expansion parcel. Every year, my pasture is flooded,
with flood crests topping my fences and strong currents overwhelming my culverts. The land for
miles around is frequently flooded - along Rice Road to Stan Hedwall Park, along Rogers Road
and Shorey Road by the Veterans and RR museums, to the Newaukum River’s confluence with
the Chehalis.
The 110 acre parcel proposed for high-density residential development is not immune from the
natural forces of water, especially since the Newaukum River runs right through it. The City
acknowledges that 72 acres of the 110 acre parcel are within the flood zone. By designating 38
acres to be outside the 100 year flood plain, the City technically avoids expanding the UGA into
known critical areas. But as a practical matter, the river will flood wherever it wants to go and it
will not recognize an imaginary boundary around the 72 acres that fall within a formal
floodplain designation. It seems unwise to site 456 new residential units within the meander
zones of a river that is already causing devastating and recurring flood damage to properties
that already exist.
In its proposal, the City gives little attention to critical area concerns by pointing to the UGA and
WAC 365-196-310 provisions that allow UGA expansions into a floodplain when rights to the
development of the land have been permanently extinguished, use of the land is limited, and
development will not decrease flood storage, increase stormwater runoff, discharge pollutants
to fresh waters, or increase hazards to people and property. The City says is will require a
conservation easement and compliance with critical area development restrictions in the
future. But the proposal lacks analysis of best available science to protect critical area functions
and values. How will the river, streams, and groundwater be protected from stormwater runoff
from the new high-density development? How will fish and wildlife corridors be kept intact?
How will landowners be protected from hazards of unstable river banks? Additional analysis is
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needed now, before the land use changes are approved, before problems are compounded and
become too difficult and costly to fix.
This proposal will have a negative effect on neighboring property rights
I have serious concerns about the detrimental impacts of this proposal, and I expect some of
my neighbors will also have concerns if they understand what will happen to our property
values if this proposal is approved.
The direction of future growth should be toward compatible land uses. High-density residential
growth on this parcel is not compatible with surrounding low-density commercial, rural
residential and natural resource land uses. The area is already feeling the deteriorating effects
of increasing noise and light pollution and a decreasing sense of safety. If the City is allowed to
convert this historic farm parcel from rural to urban, the inevitable result will be gradual de-
designation of other nearby forest and agricultural lands to make way for even more mixed-use
high-density urban development.
If the Chehalis UGA is expanded and the old Breen farm is built out as intended, there will be
permanent changes to the character of other properties along the lower Newaukum River
valley. The UGA expansion proposal does not indicate how nearby natural resource lands will
be preserved and protected.
At this time, my neighbors and I enjoy rural lifestyles in unincorporated Lewis County. But the
UGA expansion map depicts a gradual squeeze being applied on us as Napavine builds out its
city limits from the south and west, and Chehalis expands from the north and east.
Urbanization of our rural lands is taking place without adequate planning and investment in
traffic controls, and without sufficient consideration of environmental and quality of life
impacts. Incremental urban conversion is not healthy for the surrounding community and will
reduce the rural land base, adversely affecting families and businesses that rely upon
agricultural and forest lands. Piecemeal expansions of urban growth areas should be avoided
and site-specific proposals like the Chehalis-Breen proposal should be deferred until they are
accompanied by full area-wide analyses of impacts.
I urge Lewis County to step in and protect the property rights of others in the vicinity. Please do
not allow piecemeal UGA expansions to erode the long-term agricultural and commercial values
of other properties to meet the City’s need to accommodate future population growth. I am
asking the County to protect family farms and to not allow conversion of valuable rural land to
urban housing.
My property rights and contractual commitments are put at risk by this proposal
I bought my farm in 2017 with full intention to maintain the land as it has been farmed by four
generations of Gleason family members before me. I have kept the land in agricultural
production - harvesting hay, fruits, and vegetables; pasturing beef cows, goats, and layer hens,
maintaining a clean water supply. I am investing in the property as a farm in an agricultural
area, not as a speculative real estate purchase to be subdivided for dense urban development.
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Based on the zoning and known conditions when I purchased my farm, I have made
commitments that depend upon a rural agricultural land area, including:
• A long-term lease to a rancher to demonstrate rotational-grazing practices for pasture
rehabilitation
• A long-term lease to a restoration ecologist to protect riparian and forest plantings
along the two creeks that run across my property to the Newaukum River
• A long-term NRCS farm plan, and a partnership with the Lewis County Conservation
District for riparian and forest restoration using native species as part of a carbon offset
project
• A preservation easement in return for a Washington State Historic Preservation grant to
stabilize my three-story barn that is listed on the Historic Barn Registry due to its
agricultural significance and location in a rural agricultural setting.
The proposed UGA expansion will lead to land uses in the area that are not compatible with my
investments in my agricultural property. Nearby urbanization will negatively affect my property
values and put my existing long-term contractual commitments at risk.
Please extend comment period
On July 17, 2022, I received a Notice of Public Hearing by mail, and right away sent an email to
the Lewis County Community Development Office requesting paper copies of all documents
related to this proposed UGA expansion. I received in response an email with digital
attachments and an offer to mail hard copies. In the interest of time, I took time vacation leave
on Friday July 22 to personally visit the Community Development Office for assistance
interpreting the map associated with the City’s proposal.
The turnaround time for comments has been very short, and I have had a limited amount of
time to research and better understand this proposal and its impacts on my property rights and
our rural agricultural area. My comments are based on initial impressions and I have many
questions. I respectfully ask you to consider extending the comment period so that I and other
nearby property owners can better understand both the proposal and the review process that
will result in this important decision.
At a minimum, please notify me at each step of the SEPA review process. Also, please notify me
when the County Commission schedules a hearing on amendments to the comprehensive plan
if the city proceeds with its Chehalis-Breen UGA expansion proposal.
Respectfully submitted,
Mary B. Verner
423 Newaukum Valley Rd
Chehalis, WA 98532
509-994-7206, mary@maryverner.com