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Home My WebLink Aboutres2003-059R77ATCOM COUNTY COUNCIL AGENDA BILL NO. 2003 -324 CLEARANCES lnshlml Date Date Receivedin Council Obese Agenda Date Asti nedro: Originator: Man W. Aanmt ADS Finance 9 -/2 V�/ � 0 E SEP 16 2003 VHATCOM COUNTY COUNCIL 3 Assessor DiviDivision Head; Sybda Goodwin Auditm IZg3 9 -23 -03 Public Works & Capital Projects Committee / Council : Dept. Hal Hart Head 4" Executive Paul Chudek Hearing Examiner Prosecuor: Karen Frakes Jail COUNCIL ACTION TAKEN: 2003 -324 9/23/03: Approved 6 -0, Roy absent, Res. #2003 -059 Juvenile PurchasPogrcRudger. Parks Planning Ha! Hart Fvecudve: Pere Kennon SUB ✓LC /: Besohtnon approving the Birch Bay Water and Sewer District Comprehensive Water System Plan. ATTACIIMEA'IS.- (1) Proposed Resolution (2) Staff Report Note: The Birch Bay Water and Sewer District Comprehensive Water System Plan is on de at the Council Office SEPA review required? ( x ) Yes ( ) NO SEPA review completed? ( x ) Yes is ) NO Should Clerk schedule a hearing? ( ) Yes ( x ) NO Requested Date: SUMMARYSTATEMENT: RCW5ZI6.010(b) indicates that the County legislative authority must approve, conditionally approve or reject a comprehensive water system plans The request is to approve the Birch Bay Water and Sewer District Comprehensive Water System Plan. Distribution Request indicate dance who should receive a copy after Council action. Lit neeuJlc names to the right . ADS fr d/ldes Management ADS Finance ADS Human Resources ADS! f Services Assessor Auditm Cooperative Ertensum District Coon Executive Health Paul Chudek Hearing Examiner Jail COUNCIL ACTION TAKEN: 2003 -324 9/23/03: Approved 6 -0, Roy absent, Res. #2003 -059 Juvenile Parks Planning Ha! Hart Prosecutor Treasurer Related File Numbers: I (this item): RM= :ff Zoo . 1:2 Planning Division\ Water and Sewcd Water System vlans \Birch Bay Water System Plan \Agenda Bill.doc Birch Bay Water System Plan, 9112103 Sponsored by: Consent Proposed by: Planning & Develo men, Services Introduction date: 920 03 RESOLUTION NO, 2003 -059 APPROVING BIRCH BAY WATER AND SEWER DISTRICT COMPREHENSIVE WATER SYSTEM PLAN WHEREAS, State law (RCW 57.16.010(6)) requires the County Council to approve, conditionally approve, or reject comprehensive water system plans; and WHEREAS, Birch Bay Water and Sewer District submitted a Comprehensive Water System Plan for approval on April 16, 2003; and WHEREAS, Birch Bay Water and Sewer District requested that the deadline for County review under RCW 57.16.0 10 be extended; and WHEREAS, a determination of non - significance was issued pursuant to the State Environmental Policy Act; and WHEREAS, the Whatcom County Division of Engineering approved the Birch Bay Water and Sewer District Comprehensive Water System Plan; and WHEREAS, the Whatcom County Health Department approved the Birch Bay Water and Sewer District Comprehensive Water System Plan; and WHEREAS, the State Department of Health approved the Birch Bay Water and Sewer District Comprehensive Water System Plan; and WHEREAS, under the provisions of state law, the Whatcom County Comprehensive Plan, and County-wide Planning Policies, water service in rural areas must be at rural levels and should not be used as a basis for rezoning property; and WHEREAS, the County Council reviewed the Birch Bay Water and Sewer District Comprehensive Plan for compliance with the approval criteria set forth in RCW 57.16.010(6)) and RCW 57.02.040 and finds that the plan satisfies these criteria, subject to certain conditions; NOW, THEREFORE, BE IT RESOLVED that the County Council hereby approves the Birch Bay Water and Sewer District Comprehensive Water System Plan dated April 2003, subject to the following conditions: 1. Water to areas designated Rural under the Whatcom County Comprehensive Plan shall be provided at rural service levels. 2. Provision of water to areas designated Rural under the Whatcom County Comprehensive Plan shall not serve as the basis for rezoning properties. 3. Approval of the portion of Birch Bay Water and Sewer District's Comprehensive Water System Plan in section 8, T40N, R1E, W.M., where there is a new overlap with Bell Bay Jackson Water Association's service area, is contingent upon resolution of the overlap. APPROVED this 23 day of September , 2003. ATTEST WHATCOM COUNTY COUNCIL WHATCOM COUNTY, W INGTON , Dana Brown- avis, Cle e Council Dan McShane, Council Chair_ APPROVED AS TO FORM: i "vil Deputy Prosecutor Birch Bay Water & Sewer District PDS Staff Report Commehensive Water System Plan Sept. 12, 2003 WHATCOM COUNTY PLANNING & DEVELOPMENT SERVICES STAFF REPORT I. BACKGROUND INFORMATION Subject: Water System Plan Approval Applicant: Birch Bay Water and Sewer District Summary of Request: County Council approval of the Birch Bay Water and Sewer District Comprehensive Water System Plan as required by RCW 57.16.010(6). SEPA: The Birch Bay Water and Sewer District issued a Determination of Non - Significance on March 19, 2003. County Division of Engineering Approval: May 2, 2003. County Health Department Approval: August 19, 2003 State Department of Health Approval: August 29, 2003 Primary Water Source: The City of Blaine (which obtains water from wells) Existing Services (2000): 6,048 residential customer equivalents (RCS's) County Council Timeframe: The Birch Bay Water and Sewer District Comprehensive Water System Plan was submitted for approval on April 16, 2003. Pursuant to RCW 57.16.010(6), County Council approval, conditional approval or rejection of water system plans is to occur within 90 days of submission of the plan. However, Birch Bay Water & Sewer District requested an extension of the deadline to September 24, 2003. H. ANALYSIS OF THE PROPOSED AMENDMENT The factors that are to be considered in evaluating a proposed water system plan are set forth in RCW 57.16.010(6) and RCW 57.02.040(3). These factors are addressed below. (A) Whether the proposed action in the area under consideration is in compliance with the development program that is outlined in the county comprehensive plan, or city or town comprehensive plan where appropriate, and its supporting documents. Property in the Birch Bay Water and Sewer District's water service area is designated by the Whatcom County Comprehensive Plan as: (1) Birch Bay Urban Growth Area, (2) Blaine Urban 1 Birch Bay Water & Sewer District PDS Staff Report Comprehensive Water System Plan Sept. 12, 2003 Growth Area, and (3) Rural. The following zoning districts implement these three Comprehensive Plan designations: Birch Bay Urban Growth Area Comprehensive Plan Designation • Urban Residential four dwellings /acre zoning • Urban Residential Medium Density six dwellings /acre zoning • Resort Commercial zoning ✓ General Commercial zoning ✓ Neighborhood Commercial zoning Blaine Urban Growth Area Comprehensive Plan designation • Urban Residential four dwellings /acre zoning • Rural one dwelling/ten acre zoning Rural Comprehensive Plan designation • Rural one dwelling /five acre zoning • Rural one dwelling /ten acre zoning Staff has reviewed the Birch Bay Water and Sewer District's Comprehensive Water System Plan and finds that it is generally consistent with the land use policies of the Whatcom County Comprehensive Plan. Whatcom County Comprehensive Plan Policy 2R -2 states that "... Water lines shall not be extended to serve urban levels of development outside a Short Term Planning Area.. "The County's Comprehensive Plan divides urban growth areas into short term planning areas and long term planning areas. Short term planning areas are intended for urban development in the near term, whereas long term planning areas are intended for eventual urban development in a longer time frame. The proposed water plan anticipates water line improvements in areas that are designated as long term planning areas (outside of current short term planning areas). The proposed Birch Bay Community Plan would eliminate the short term/long term distinction, so this issue may become moot within the Birch Bay urban growth area. However, even if the short/long term distinction is retained, it is assumed that at least some of the long term planning areas would transition into short term planning areas within the 20 -year planning period. Additionally, it is prudent to plan ahead for future water service to all portions of the Urban Growth Area over the 20 -year planning period. Therefore, the fact that the water plan anticipates improvements in the long term planning areas appears to be appropriate. However, future County Council action to either eliminate the long term/short term distinction or to convert long term planning areas to short term planning areas will be required before the District could provide urban levels of service in these areas. Birch Bay Water & Sewer District PDS Staff Report Comprehensive Water System Plan Sept. 12, 2003 The Water System Plan projects a Birch Bay Water & Sewer District population of 9,597 people in 2021 (Water System Plan, p. 2 -10). There is not an adopted population projection for Birch Bay in the existing Whatcom County Comprehensive Plan. The proposed Birch Bay Community Plan projects the population of Birch Bay at 9,619 in 2022. The Planning Commission adopted a lower projection of 7,116 for the Birch Bay UGA. In any event, the County Council has not yet adopted population projections for Birch Bay. Therefore, staff does not find any inconsistencies between the Water System Plan and adopted County policy at this time. (B) Whether the proposed action in the area under consideration is in compliance with the basin -wide water and /or sewage plan as approved by the State Department of Ecology and the State Department of Health (formerly Social and Health Services). In an e-mail of July 11, 2003, the State Department of Health (DOH) indicated that the Coordinated Waster System Plan (CWSP) constitutes the "basin- wide" water plan. The DOH approved the Birch Bay Water & Sewer District Water System Plan on August 29, 2003 and stated that "... This water system plan is consistent with ... the Whatcom County Coordinated Water System Plan." It should be noted that the Birch Bay Water & Sewer District is modifying its service area boundaries, in part to reduce overlaps with Bell -Bay Jackson Water Association and other purveyors. However, GIS analysis reveals that a small area of new overlap with Bell -Bay Jackson would be created by the service area boundary revision. Section 4.1.4 of the CWSP does not allow the creation of new overlaps. Therefore, approval of the Water System Plan should be contingent upon resolution of the overlap (staff understands that Birch Bay and Bell -Bay Jackson are working to resolve this situation). (C) Whether the proposed action is in compliance with the policies expressed in the county plan for water and /or sewage facilities. Chapter 5 of the Whatcom County Comprehensive Plan contains the following policies relating to water service in the area: Policy 5Q -1: Work with the PUD, Birch Bay Water and Sewer District, Blaine, Ferndale, Ecology, and other jurisdictions as appropriate, to ensure adequate water supplies to the Urban Growth Area and designated industrial areas in northwest Whatcom County... Policy 5Q -2: Ensure provision of urban levels of water service to urban growth within areas designated for urban growth. The Birch Bay Water & Sewer District's water service area includes most of the Birch Bay UGA (it appears that other purveyors intend to serve the portions of the Birch Bay UGA that are not within the Birch Bay Water & Sewer District's service area). Birch Bay Water & Sewer Birch Bay Water & Sewer District PDS Staff Report Comprehensive Water System Plan Sept. 12, 2003 District's service area also includes portions of the Blaine UGA. The District recently signed a new contract to purchase water from the City of Blaine. The contract has a duration of 30 years (with extensions possible) and will provide the District up to 2.11 million gallons of water per day, which is the forecasted maximum daily demand for 2020 (Water System Plan, pp. ES -1 & 3 -17). The District is also pursuing additional water sources, which including obtaining water from PUD No. 1 and new wells (Water System Plan, pp. 1 -6 & 3 -18). The District currently provides wholesales water to PUD No. 1 for sale to the BP Cherry Point Refinery (Water System Plan, p. 4-5), thereby helping meet the water needs of industry in the northwest County. (D) The comprehensive water system plan shall not provide for the extension or location of facilities that are inconsistent with the requirements of RCW 36.70A.110. RCW 36.70A. 110 contains the urban growth area provisions of the Growth Management Act (GMA). RCW 36.70A. 110(4) indicates: In general, cities are the units of local government most appropriate to provide urban governmental services. In general, it is not appropriate that urban governmental services be extended to or expanded in rural areas except in those limited circumstances shown to be necessary to protect basic public health and safety and the environment and when such services are financially supportable at rural densities and do not permit urban development. This section of the GMA raises two issues: ❑ Birch Bay Water and Sewer District plans to serve areas within Blaine's Urban Growth Area. ❑ Birch Bay Water and Sewer District plans to serve areas designated Rural under the County Comprehensive Plan. The first issue raised by the GMA is Birch Bay Water and Sewer District's service within Blaine's Urban Growth Area. The Birch Bay Water and Sewer District water plan includes several areas that are within Blaine's Urban Growth Area: ➢ The property generally located between Lincoln Rd. and Drayton Harbor. ➢ The property generally located between California Creek and Portal Way. ➢ The property generally located in the Semiahmoo Dr. area. Birch Bay Water & Sewer District PDS Staff Report Comprehensive Water System Plan Sept. 12 2003 Whatcom County Comprehensive Plan Policy 2Z -2 is to: Work with Birch Bay Water and Sewer District and the City of Blaine to resolve the issue of jurisdiction north of Lincoln Road and east of the Semiahmoo development. As a starting premise, assume the area between Lincoln Road and Drayton Harbor to ultimately be part of Blaine but with water and sewer service from the district. Staff is not aware of any formal process underway to address Policy 2Z -2. However, Birch Bay Water & Sewer District declared the above properties within the Blaine UGA as part of its service area when the Coordinated Water System Plan (CWSP) was adopted in 2000. The City of Blaine subsequently declared their water service area under the CWSP, which did not (and under the CWSP could not) overlap with Birch Bay Water & Sewer District's service area. The City of Blaine Comprehensive Plan's future water service area map, which indicates that Blaine anticipates serving its urban growth area. However, Blaine's Comprehensive Plan also states that: ... Portions of the future water service area are currently served by the Birch Bay Water and Sewer District. As these areas annex into the City Limits, the City will work with the Birch Bay Water and Sewer District to assume service to these areas or enter into a contract with the District to continue serving these areas... (p. 6 -2). The City of Blaine's Community Development Director stated, in an e-mail message of September 11, 2003, that: The City of Blaine is not opposed to the Birch Bay Water and Sewer District providing service within the Blaine UGA. However, please note that the City Comprehensive Plan requires master development plan review and annexation before it will support urban development in the UGA. Until such time the City will continue to coordinate with Whatcom County to ensure that the UGA remains at rural densities. Most of the area within the Blaine UGA that is within Birch Bay Water & Sewer District's water service area is zoned Urban Residential four units per acre (UR4) under the County's zoning code. The UR4 zoning allows development at four dwellings/acre when the property is within the short term planning area, is served by public water and sewer, and has stormwater facilities. Otherwise, the density is one dwelling unit per five acres. Most of the area between Lincoln Rd. and Drayton Harbor has been designated as a "provisional" short term planning area under Ordinance 2001 -069 (this ordinance expires later this year if plans and financing for sewer are not in place). The area between California Creek & Portal Way and the Semiahmoo Dr. area are designated as short term planning areas. The General Manager for the Birch Bay Water & Sewer District indicated in a phone conversation of September 11, 2003 that, while some of these areas have water service, they currently do not have sewer service. Therefore, at the present time, they could only develop at densities of one dwelling /five acres. However, Whatcom County zoning applies in these areas and it does not appear that there are any provisions in the interlocal agreement with Blaine that would keep these areas at rural densities if all the conditions of the 5 Birch Bay Water & Sewer District PDS Staff Report Comprehensive Water System Plan Sept. 12, 2003 Whatcom County Zoning Ordinance were met in the future. In fact, section 6A of the Interlocal agreement between Whatcom County and Blaine states that current zoning will apply within the urban growth area until annexation. The second issue raised by the GMA is service within the rural area. Whatcom County comprehensive Plan Policy 2DD -4 is to "Discourage urban levels of water and sewer service extensions to serve development outside of Urban Growth Areas ... unless there are serious public health or environmental concerns." Whatcom County Comprehensive Plan Policy 5P -3 is to "Discourage extension of urban levels of water service to areas not designated as urban growth areas.. " Additionally, County Wide Planning Policy F -7 states: "The availability of pipeline capacity required to meet local needs and/or supply shall not be used to justify development counter to the county -wide land development pattern and shall not be considered in conversions of agricultural land, forestry, and rural areas." It should be noted that there are a number of water purveyors, including cities and water districts, that serve in rural areas of the County. However, state law, County -wide Planning Policies, and the County Comprehensive Plan, when read together, indicate that this service must be at rural levels and should not be used to justify future rezones to more intense land uses. III. RECOMMENDATION Based upon the above analysis, staff recommends that the County Council approve the proposed Birch Bay Water and Sewer District's Comprehensive Water System Plan, subject to the following conditions: 1. Water to areas designated Rural under the Whatcom County Comprehensive Plan shall be provided at rural service levels. 2. Provision of water to areas designated Rural under the Whatcom County Comprehensive Plan shall not serve as the basis for rezoning properties. 3. Approval of the portion of Birch Bay Water and Sewer District's Comprehensive Water System Plan in section 8, T40N, R1E, W.M., where there is a new overlap with Bell Bay Jackson Water Association's service area, is contingent upon resolution of the overlap. IV. EXHIBITS 1. Whatcom County Division of Engineering Letter of 5/2/03 2. Whatcom County Department Letter of 8/19/03 3. Washington State Dept. of Health Letter of 8/29/03 4. City of Blaine E -mail Letter of 9/11/03 WHATCOM COUNTY ?ptcom coc2 PUBLIC WORKS DEPARTMENT s JEFFREY M. MONSEN, P.E. 3 Director k t 95Mrrvctc Rodney Langer, P.E. Project Manager CHS Engineers, Inc. 12507 Bel -Red road Suite 101 Bellevue, WA 98005 -2500 DIVISION OF ENGINEERING Joseph P. Rutan, P.E. - Assistant Director 5280 Northwest Drive, Suite C Bellingham, WA 98226 May 2, 2003 Subject: Review and Approval of Birch Bay Water and Sewer District Comprehensive Water Plan Dear Mr. Langer In accordance with RCW 57.16.010(6), we have reviewed and do hereby approve of the Birch Bay water and sewer comprehensive plan dated April, 2003. Note that any work performed within County right-of-way requires a revocable encroachment permit from our Engineering Division office. Whatcom County would like to see disturbances kept to a minimum for County road surfaces. With that in mind, we encourage that any new water lines and appurtenances be placed outside the existing pavement for any improved County roads, where possible. Additionally, should the Birch Bay Water and Sewer District have future plans to service any properties, you should make arrangements to accommodate those properties as the road facilities are installed at the time. In that way, the public road would not be excavated and patched. We look forward to coordinating all necessary work with you; Gene Altman is our contact for any work within County rights-of-way. Please do not hesitate to contact Gene or myself in the future with any concerns car questions. Sinc Toe Rutan, P.E. County Road Engineer cc: Rodney Langer, CHS Gene Altman Matt Aamot Phone: (360) 676-6730 County: (360) 380-8110 FAX (360) 676-6558 �pOM CO HEALTH E COUNTY REGINA rector NT HEALTH )DEPARTMENT 3 i OheROr P.O. Box 935 GREG STERN, M.D. Bellingham, WA 98227 -0935 �q Or Health Officer 'SNINOS AN 2 0 2003 August 19, 2003 1DMWIStMTION 13696766720 1 ' 3w.une 11 1 COMMDNIC u DISWE REPORTING LINE Roger Brown (3W)73&25(3 Birch Bay Water and Sewer District Hi1AUTTF 1NUDS 7096 Point Whitehorn Road HEUTHwENUUs 360„3 8 2522 Blaine, Washington 98230 -9675 CoNbAMICmu msE 1M W)73&2508 Dear Mr. Brown: 1301 73675)0 DE WOPMENTu m5TBR1TIES Whatcom County Health Department staff reviewed the Birch Bay Water °6))6'660" and Sewer District Comprehensive Water System Plan to determine if the DmRONMDrtu HW,„ 301626622) plan as submitted complies with RCW 57.16.010. Based on that review, 1 Whatcom County Health Department gives their approval to the plan as M.IERNAVCH "° submitted. (3W) 64] -2329 MENEAL H`"°N 30/06029 If possible, we suggest that you add Whatcom County Environmental 1 HIV,STD Health to your emergency contacts list contained in Table 6.1. You can 130162"593 call (360) 676 -6724 to report an emergency. If you need to contact us SUBSTANCE MDSE between 4:30 PM and 8:30 AM you would call the same number. Our 130) 676 29 after hours message gives the caller directions for reaching an on -call staff WM RECORDS member. 0016766720 WIC If you have any questions please contact me. 00)73x2505 COLNW ME Il Sinc rely, — 3601384 1528 1/ Paul Chudek, R.S. Environmental Health Supervisor cc: Clerk of the Whatcom County Council Whatcom County Engineering Ahatcom County Planning & Development Washington State Department of Health, Northwest Regional Office 509 Girard Street 1500 North State Street 1000 North Forest Street FAX (360) 676 -7646 FAX (360)676 -6729 FAX (360) 738 -2490 s � STATE OF WASHINGTON DEPARTMENT OF HEALTH 1043572nd Ave. S. , Suite 200, K17 -12• Kent, Washington 98031 -2358 August 29, 2003 i ROGER BROWN, GENERAL MANAGER SEP 2003 BIRCH BAY WATER AND SEWER DISTRICT 7096 POINT WHITEHORN RD's BIRCH BAY WA 98230 -9675 L_. Subject: Birch Bay Water and Sewer District, ID #95904 Whatcom County Water System Plan - APPROVAL Submittal # 03 -0413 Dear Mr. Brown: The Birch Bay Water and Sewer District water system plan, received in this office on April 17, 2003 has been reviewed and in accordance with the provisions of WAC 246- 290 -100, is hereby APPROVED. Approval of this plan is granted through August 29, 2009 unless the Department requests an update or plan amendment pursuant to WAC 246- 290 - 100(9). Approval of this plan is valid as it relates to current standards outlined in WAC 246 -290, revised April 1999. Future revisions in the rules may be more stringent and require facility modification or corrective action. Approval of the update of this water system plan is required on or before August 29, 2009. This approval does not provide any guarantee and should not be considered to provide any guarantee concerning legal use of water or subsequent water rights decisions by the Department of Ecology. This plan demonstrates how the Birch Bay Water and Sewer District will maintain financial viability. This water system plan is consistent with the Public Water System Coordination Act (70.116 RCW) and the Whatcom County Coordinated Water System Plan. Standard Construction Specifications for distribution main extensions have been approved as part of this water system plan. With this approval and consistent with WAC 246 - 290 - 125(2) the Birch Bay Water and Sewer District may elect to proceed with the installation of distribution main extensions provided: That the Birch Bay Water and Sewer District maintains on file completed construction completion reports (a copy of which is attached) in accordance with WAC 246- 290 -125 (2) and WAC 246 -290- 120 (5) and makes it available for review upon request by the department. 5 QW27 0 Birch Bay Water and Sewer District August 29, 2003 Page 2 The following elements have also been approved as a part of the water system plan: • A proposed update to your Cross Connection Control Program in accordance with WAC 246- 290 -490 • A Wellhead Protection Plan in accordance with WAC 246 - 290-135 • A Water Quality Monitoring element including a Coliform Monitoring Program in accordance with WAC 246- 290 -300 Questions concerning water rights should be directed to the Department of Ecology. Regulations establishing a schedule for fees for review of planning, engineering and construction documents have been adopted (WAC 246- 290 -990). Please note that we have included an invoice in the amount of $3363.00 for the review of the Water System Plan and $93.00 for review of the Water Conservation plan. This fee covers our cost for review of the initial submittal, plus the review of one revised document. Please remit your complete payment in the form of a check or money order within thirty days of the date of this letter to: DOH, Revenue Section, P.O. Box 1099, Olympia, WA 98507 -1099. DOH recognizes the significant effort and resource commitment involved in the preparation of your WSP document. Thank you for your cooperation. If you have any questions or wish to check our records, please feel free to contact either of us at the numbers listed below. Sincerely, John T iele a , PE Regional En ' ee'r (253) 395 -6761 art: Construction Completion Report i a a gue� Regional Planner (253) 395 -6771 cc: Matt Aamot, Whatcom County Planning & Development Services Paul Chudek, Whatcom County Health Department Diane Pottinger, CHS Engineers, Inc. Matt Aamot- Birch Bay Service in UGA From: 'Terry Galvin" <TGalvin @cityofblaine.com> To: <maamot @co.whatcom.wa.us> Date: 9/11/03 4:12PM Subject: Birch Bay Service in UGA The City of Blaine is not opposed to the Birch Bay Water and Sewer District providing service within the Blaine UGA. However, please note that the City Comprehensive Plan requires master development plan review and annexation before it will support urban development in the UGA. Until such time the City will continue to coordinate with Whatcom County to ensure that the UGA remains at rural densities. CC: 'Steve Banham" <SBANHAM @cityofblaine.com >, "Gary Tomsic" <GTomsic @cityofblaine.com >, <schugtsos @nas.com> Page 1