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HomeMy WebLinkAboutres2016-050WHATCOM COUNTY COUNCIL AGENDA BILL NO. 2016 309 - -8 CLEARANCES Initial Date Date Received in Council Office Agenda Date Assigned to: Ori inalor� Mann 12/7/2016 12/6/2016 Council Division Head: Dept. Head: Prosecutor: PurchasinR/BudRel: Executive: TITLE OF DOCUMENT. i Res. Send Letter to Legislature Request. Amend. To GMA for Water Availablility ATTACHMENTS: SEPA review required? ( ) Yes ( ) NO Should Clerk schedule a hearing ? ( ) Yes ( ) NO SEPA review completed? ( ) Yes ( ) NO Requested Date: SUMMARY STATEMENT OR LEGAL NOTICE LANGUAGE: (If this item is an ordinance or requires a public hearing, you must provide the language for use in the required public notice. Be specific and cite RCW or WCC as appropriate. Be clear in explaining the intent of the action.) Resolution sending a letter to the state legislature requesting amendments to the Growth Manangement Act clarifying that counties can rely on Department of Ecology guidance for determining legal water availability COMMITTEE ACTION: COUNCIL ACTION: 12/6/2016: Motion carried 7 -0 to approve a resolution sending a letter to the State legislature requesting amendments to the Growth Management Act clarifying that counties can rely on Department of Ecology guidance for determining legal water availability 't Res. 2016 -050 Related County Contract #: Related File Numbers: Ordinance or Resolution Number: Res. 2016 -050 Please Note: Once adopted and signed, ordinances and resolutions are available for viewing and printing on the County's website at. www.co.whatcom.wa.us /council. 1 2 3 4 5 6 7 8 9 10 11 12 13 1.4 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 PROPOSED BY: CONSENT INTRODUCTION DATE: DECEMBER 6, 2016 RESOLUTION NO. 201+6 -050 SENDING A LETTER TO THE STATE LEGISLATURE REQUESTING AMENDMENTS TO THE GROWTH MANAGEMENT ACT CLARIFYING THAT COUNTIES CAN RELY ON DEPARTMENT OF ECOLOGY GUIDANCE FOR DETERMINING LEGAL WATER AVAILABILITY WHEREAS, in 2012, a group of citizens and environmental groups, known as Hirst et al, challenged the Whatcom County Comprehensive Plan as it related to residential development and permit- exempt wells; and WHEREAS, in 2013, the Growth Management Hearings Board ruled in favor of Hirst et al; and WHEREAS, in 2013, Whatcom County appealed this ruling; and WHEREAS, in 2013, Whatcom County contracted with Van Ness Feldman LLP, who specialize in water rights, water law and the Growth Management Act (GMA); and WHEREAS, the State Department of Ecology, Washington Association of Realtors, and Washington Association of Counties, and other groups, sided with Whatcom County and filed Amicus briefs; and WHEREAS, in 2015, the State Appeals Court overturned the Growth Management Hearings Board; and WHEREAS, in 2015, Hirst et al appealed to the State Supreme Court; and WHEREAS, Whatcom County has spent hundreds of thousands of dollars in legal fees fighting Hirst et al; and WHEREAS, on October 6th, 2016 the Washington State Supreme Court issued its decision, now known as the Hirst ruling; and WHEREAS, in response to the Hirst ruling, with unanimous advice from our legal staff, contract attorneys, and the administration, which includes people from both major political parties, the Whatcom County Council issued an emergency moratorium on building permits for properties relying on permit- exempt wells; and WHEREAS, hundreds of property owners suddenly have been denied building permits for properties they have lawfully subdivided, platted, and even begun infrastructure improvements; and 1 2 3 4 S 6 7 8 9 10 11 12 13 14 WHEREAS, the Whatcom County Council believes that the Hirst decision is profoundly flawed, both in its legal reasoning and practical implications; and WHEREAS, with the Hirst Decision, the State Supreme Court has caused devastating financial and emotional hardship for the people of Whatcom County; and WHEREAS, residential water withdrawals from permit- exempt wells represents a tiny fraction of water consumption in Whatcom County; and WHEREAS, Washington State and the Department of Ecology have sole responsibility for determining water availability, closing a basin, or issuing or interpreting water rights; and WHEREAS, while the Hirst ruling impacts 29 counties planning under GMA, Whatcom County is the only defendant in this case and is therefore uniquely vulnerable and subject to immediate review for compliance and subsequent state sanctions, and WHEREAS, half of Whatcom County's budget comes from state or federal grants and programs, and WHEREAS, the Whatcom County Council recognizes the precious value of clean and copious potable water; and WHEREAS, The Whatcom County Council will continue to engage all stakeholders to collaborate on issues of water quality and water quantity; and WHEREAS, the Whatcom County Council recognizes the financial and environmental impacts created by conversion of resource lands to low- density, residential sprawl; and WHEREAS, denying citizens their right to use permit- exempt water withdrawals to provide for their homes and families is an inappropriate strategy for preventing sprawl; and WHEREAS, the employees of Whatcom County are working hard to respond to Hirst without jeopardizing the legal or financial standing of Whatcom County government; and WHEREAS, we believe that a narrowly- focused, non - partisan amendment to the GMA can resolve this egregious misinterpretation by the State Supreme Court; and WHEREAS, there have been productive meetings with the State Legislature, support from the Washington State Association of Counties and other groups, and meetings with local state legislators of both parties and of both chambers; and WHEREAS, the State Legislature alone has the power to remedy this grievous error imposed by the Supreme Court. 1 NOW, THEREFORE, BE IT RESOLVED that the Whatcom County Council will 2 send a letter, signed by the Council Chair on Council letterhead, to the State Legislature's Local 3 Government committee and Agriculture and Natural Resources committee requesting urgent 4 attention to this matter, and requesting a rapid, narrowly- focused, non - partisan amendment to 5 the Growth Management Act clarifying that Counties can rely on Department of Ecology 6 guidance for determining legal water availability and provide the Department of Ecology with 7 necessary resources to create legally defensible guidance, and restore the procedures in place 8 before the Hirst decision. 9 10 BE IT FURTHER RESOLVED that the letter will be substantially similar to the letter 11 sent to the legislature on December 1, 2016, by Washington State Association of Counties, 12 Building Industry Association of Washington, Washington Association of Realtors, Washington 13 Farm Bureau, and others. 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 BE IT FURTHER RESOLVED that the letter will also request the legislature to adopt legislation to enable the Seasonal Storage of Surplus Water to Mitigate Fully the Net Consumptive Impact of Permit Exempt Domestic Wells proposal submitted by Councilmember Browne (attached) and provide sufficient funding for the pilot program as requested. BE IT FINALLY RESOLVED that we believe this proposal will provide immediate relief for our residents. APPROVED this `'t" clay of December y 2016. ATTEt Dana bjrovwta -,Qa is,__Qe:r °'of tee Council A,1PPRVE'/q►4rrt�" Civil Deputy Prosecutor WHATCOM COUNTY COUNCIL TCOM O TY, ASHINGTON 14V-1 a B hanan, &uncil Chair CLERK OF THE COUNCIL Dana Brown- Davis, C.M.C. COUNTY COURTHOUSE 311 Grand Avenue, Suite #105 Bellingham, WA 98225 -4038 (360) 778 -5010 December 8, 2016 �c m I,- om U�l WHATCOM COUNTY COUNCIL RE: Washington Supreme Court Decision on GMA & Rural Water Supply Members of the Washington Legislature: COUNCILMEMBERS Barbara Brenner Rud Browne Barry Buchanan Todd Donovan Ken Mann Satpal Sidhu Carl Weimer Whatcom County adds its voice to Washington State Association of Counties, Building Industry Association of Washington, Washington Association of Realtors, Washington Farm Bureau, and others in strong and united opposition to the recent decision of the Washington Supreme Court, Whatcom County v. Hirst et al., No. 91475 -3. In this decision, the Court concluded that the Growth Management Act ( "GMA ") requires counties to regulate water supply for new development to a greater extent than required by both the Department of Ecology ( "Ecology's ") local instream flow regulations and the state's water code. The Court's conclusion that the GMA requires local governments to exceed specific state environmental statutes and regulations is wholly unsupported by the GMA, related statutes on water availability, and the history of the GMA and state's water code. Over the past decades, local governments and landowners have relied on Ecology's authority as our state's sole water resource agency. Just five years ago, in its Kittitas County v. Eastern Washington Growth Board decision, the Supreme Court ruled that local government regulation of land use and Ecology's regulation of water resources should be complementary and consistent. This decision tracked state GMA regulations providing that "if the department of ecology has adopted rules . . . , local regulations should be consistent with those rules. Such rules may include instream flow rules . . . " WAC 365 - 196- 825(3). (emphasis added). Further, the state's Water Resources Act, which provides the governing principles for Ecology's instream flow rules, states plainly that county governments "shall, whenever possible, carry out powers vested in them in manners which are consistent with the provisions of this chapter." RCW 90.54.090. (emphasis added) Now, the Supreme Court has elevated the general planning language of the GMA above the more specific provisions of state laws and regulations implemented by Ecology on water resources. The Supreme Court failed to note, let alone analyze, the various legal authorities that support consistency between local government land use permitting and Ecology's water resource authority. Further, the Court badly confused the difference in the state's water code between reviewing "impairment" of water rights (which only Ecology has the statutory authority and funding to do), to the review of "water adequacy" for building permits, which local governments do in reliance on Ecology's permits and regulations. The impacts of this decision will be devastating to rural landowners and counties throughout Washington State, many of which have adopted or are considering residential building permit moratoria solely because of the Supreme Court's decision. The economic losses to rural landowners could easily run into the hundreds of millions of dollars. Whatcom County requests a solution that is not very novel: that the Legislature establish that local government land use plans and permit decisions can rely on Ecology's regulation of water resources. We appreciate the candid comments of Ecology at the recent work session of the Senate Agriculture, Water, and Rural Economic Development Committee meeting that only ".. . 1% of the cumulative use of water in Washington State" is from domestic exempt wells. In Whatcom County, total domestic exempt well use accounted for only .7% of total water use in that county during the growing season. In Skagit County, where Ecology's ill- conceived 2001 Skagit Instream Flow Rule is being interpreted to establish a groundwater moratorium (though nothing of the sort was ever mentioned by Ecology upon adoption), domestic exempt well use also accounts for only .7% of total water use. In Central Puget Sound counties like King, Pierce, and Snohomish, areas that could be implicated by the Hirst decision, total domestic exempt well use accounts for 1 %, 3.6 %, and 6.3% of total growing season water use. See Ecology Publication No. 15 -11 -2016, Permit - Exempt Domestic Well Use in Washington State, Table 3, February 2015. Further, the Legislature should recognize that the instream flow levels adopted by Ecology will, by design, rarely be met by actual flows, regardless of the amount of water use from domestic wells. Ecology's adopted minimum instream flow for Nooksack River in late summer is 1,900 cubic feet per second (cfs). WAC 173 - 501 -030. This adopted flow level has not been met in any of the past five years, as actual flows in late August have ranged between 973 cfs and 1,570 cfs. All domestic exempt wells in Whatcom County (including those with delayed or no impacts to the Nooksack River) use 600,000 gallons of water per day. Ecology Publication No. 15 -11 -2016, Permit - Exempt Domestic Well Use in Washington State, Table 3, February 2015. Thus, total domestic well use in Whatcom County is only .93 cfs - compared to an Ecology minimum instream flow level of 1,900 cfs during the late summer season. The small amount of water used by domestic exempt wells and the immeasurable impacts of a single domestic well on instream flows does not mean that Ecology should not, or has not, addressed the issue where unique local circumstances exist. In recent years, the Legislature has spent millions of state dollars for water right acquisitions around the state to support Ecology instream flow rules that protect groundwater and instream flows. Recent Ecology rules in Spokane, Walla Walla, Clallam, Kittitas, and Jefferson Counties demonstrate a willingness by Ecology to seek to develop regulations that reflect local conditions. Beyond the rural domestic well issue, state, local, and ratepayer efforts have also achieved significant water use reductions through agricultural irrigation efficiencies and the state's municipal water use efficiency rule. Regulation of water resources by Ecology reflects the agency's statutory authority and expertise. The current level of chaos and uncertainty wrought by the Supreme Court's Hirst decision is simply untenable. Ultimately, the question is simple: Should counties and citizens be able to rely on the permits and regulations adopted by Ecology - our state's sole water resource agency? The answer is clearly yes, and anything short of that is a disservice to our state's counties and rural landowners. Sincerely, tBar y uchanan, Chair Wh com County Council Cc: Whatcom County Councilmembers Whatcom County Executive Governor Jay Inslee Growth Management Hearings Board Department of Ecology AB2016 -309B Seasonal storage of surplus water to mitigate fully the net consumptive impact of permit- exempt domestic wells Rud Browne Whatcom County Councilmember — At -Large RBrowne@co.whatcom.wa.us DRAFT 2016 -12 -02 Background A recent Washington State Supreme Court ruling has changed how counties review permit- exempt domestic wells for building permits under the Growth Management Act (GMA). In the Whatcom County vs. Hirst, Futurewise, et al. decision, the Supreme Court ruled that the county failed to comply with the GMA's requirements to protect water resources. The ruling requires the county to make an independent decision about legal water availability. The Court also said the county must ensure that new permit- exempt uses do not impair instream flows and senior wafter rights when making water availability determinations prior to granting new building permits. (for more detail see r ;v.:uCy. wa. ga�lprpgra mslwrinwrar'hi rst. htmi) Under the new rules a large number of rural parcels have been affected which is creating significant financial hardship for many county residents who had purchased property to live on or for other purposes such as funding their kids' college tuition or their retirement. Contrary to some opinions few if any, of those affected are experienced land speculators that could have been expected to anticipate the risk of loss caused by this situation. In response to the Supreme Court decision Whatcom County has been forced to enact an emergency moratorium prohibiting the filing, acceptance and processing of new applications for uses that rely on permit - exempt groundwater withdrawals for water supply in most of the county. The exception is applications that provide documentation that there is an adequate and legal water supply to serve the proposed use in the form of: 1. A water right from Ecology, or 2. A letter stating the ability to provide water from a municipal or public water purveyor not dependent on a permit- exempt well, with adequate water rights issued by Ecology, or 3. A rainwater catchment system approved by the Whatcom County Health Department. This document is presented as exploration of a fourth possible option, the seasonal storage of surplus water that is later used to fully mitigate the potential impact of domestic well use in a way that does not affect more senior water rights or instream flows. This water would come from one or more sources including: (a) winter withdrawal of ground water from an aquifer that is expected to be fully recharged before springtime, (b) stormwater runoff from driveways and other impervious surfaces, and (c) rainwater collection from roofs. Concept Whatcom County has an abundance of water, unfortunately while we have more than we need in winter we don't have enough in summer. The average gross daily domestic ground water consumption for residents is estimated to be 65 gallons per day or less. The best available science suggests that between 80% and 90% of rural ground water consumed for indoor domestic use is actually returned to the soil through the homes septic system. The recent ruling requires that any and all consumptive uses must be completely mitigated (drop for drop) and that the mitigation must occur at the time of use. Exhibit A provides an estimated average Gross consumption for a family of four of 260 gallons per day, Net consumption at 208 gallons per day which calculates that a Deficit of 52 gallons per day needs to be mitigated. This proposal demonstrates how homeowners could store surplus water during the winter and use it to fully mitigate their net consumptive use at other times of the year in a way that would comply with both the new court ruling and the physical constraints imposed by a physically finite water supply. The components of the solution (see Exhibit B): Permit- exempt well In areas where a public water supply is unavailable a permit- exempt well (A) would continue to be used to provide the primary potable water source for the home. Well water can normally be used as potable water source provided it meets bacteria and other containment standards. Whereas State health laws require that rainwater must be treated for bacteria in order to be a potable water source and trucked water may not be used at all as a primary potable water source. The first difference between this proposal and current practice is that unlike existing unmetered permit - exempt wells previously used to provide water in support of building permits new wells would have meters that measure consumption on a daily basis throughout the year. The second difference is that while normal net daily indoor domestic water consumption is quite small due to the majority of the water being returned to the ground through the septic system, this proposal acknowledges recognizes it is not zero and provide for full mitigation as required by recent court rulings by reducing the net consumptive use to zero. 2 Distribution from wel Water from the well would travel through two distribution lines: • The first line would provide potable water to the residence. This line would have a meter (B) that would collect data on the Gross amount of water being used for domestic use. • The second line would provide metered (C) water to the mitigation tank (D) and the optional outdoor garden tank (E). However water would only be allowed to pass to the storage tanks when the computer (F) determines that seasonally surplus water is available and it opens valve #1 (G) Re- infiltration of used water After water is used in the house most of it would pass into the septic tank as normal and ultimately the septic drain field (S). A third meter (H) would be placed on the pipe from the septic tank to the drain field to determine the Net amount of water being returned to the ground. The water "Deficit' amount (Gross — Net) that needs to be mitigated would then be calculated by the computer every 24 hours. (As water from the septic tank may have a small amount of residual solids the meter may need to be different than the other three, alternatively it may be possible to use a positive displacement pump to provide metering data.) Mitigation Once the computer (F) has calculated the daily water Deficit that needs to be mitigated it will open valve #2 (1) on the Mitigation tank (D) and will allow mitigation water to enter the septic drain field until the fourth meter (J) confirms that the Deficit amount has been sent to infiltrate back into the aquifer as mitigation. Alternatively if is determined that it would be preferable not to allow the mitigation water to mix with the normal septic drain field water supply a separate, smaller mitigation water infiltration field could be used somewhere else on the property. This preserves instream flows and avoids conflict with other senior water rights. The end result will be a net indoor domestic groundwater consumption of ZERO Mitigation water suoply Each home would have one or more Mitigation water tanks (D) with a collective capacity great enough to store enough water to mitigate their entire years estimated water Deficit (current estimates suggests this would be about 20% of their average daily Deficit for a nine month period however actual usage data from the pilot program may prove this to average 10% or less). The Mitigation water does not need to meet potable water standards therefore the Mitigation tank can be filled from one or more sources: 1. Stormwater collected from driveways and other impervious surfaces (M). An added benefit is that this water and the contaminates would be directed into the septic drainfield during the drier months rather than enter streams during the wetter months as it currently does (this may need to be limited to perhaps 1,000 sq. ft. per occupant to avoid creating a perverse incentive to increase impervious surface areas). 2. Rainwater from roofs (K) 3. Surplus winter ground water from the permit- exempt well (G) 4. Finally trucked water (in the unlikely event that the other three sources are inadequate) Garden water tank At the homeowners option each home could also have one or more Garden water tanks (L). The capacity would be determined by the homeowner. This water would normally be used to provide water for garden use. While the Garden tank could be connected via a one way valve to the Mitigation tank to allow the Garden water 3 to be used as a backup Mitigation water supply the Mitigation water would not be allowed to flow into the Garden tank to prevent the Mitigation tank being drained accidently. Homeowners Computer The Computer (F) would likely be a modified smart phone running a mobile application. The reasons for this are as follows: • Smartphones are robust low cost self- contained hardware platforms with inbuilt displays, keyboards, battery backup power and radios (Cellular, Wi -Fi and GPS). Even obsolete models could be used effectively. • Provides easy connectivity to a central computer via the homeowners Wi -Fi or the Cell carriers data network (low use cellular data connections typically cost $10 a month or less) • Intuitive, familiar user interface (everyone knows how to use a phone) • Application software can be updated easily by downloading it from the phone's "App Store" • Common, easy to understand programming environment will reduce development costs • Serial interface can be used to connect to the data bus /ports to read the meters and control the valves Computer software would be written to: • Receive information from the central computer as to what dates each season Storage water may be pumped to the Mitigation and Garden tanks • Send daily information on Gross Water usage, Net Water Usage and Mitigation Water used. • Provide the above information on the phones display for the phone owner to see • Email reports to the user as to consumption levels to help them in their personal conservation efforts. Central computer A central computer that is managed by either the Department of Ecology or the County would: • Tell the homeowners computer when water can be pumped for storage • Collect daily information from each device • Verify that the consumption and mitigation numbers make sense • Initiate alerts for improper events such as: • Homeowners system has gone offline • Out of authorization storage water line usage • Actual Mitigation water consumed is below calculated minimum amount (e.g. tank is dry) • Provide researchers with actual water use data such as: • Anonymously by user • By named basin • By aggregate System summa The total system as outlined above would require: • 1 Cell phone and charger • Interface box between Cell Phone, meters and valves 3 "clean" water meters (B, C & J) • 1 "dirty" water meter (H) • 2 valves 4 • 1 or more water tanks Piping Costs Initial rough estimates place the costs, in quantity as follows (these are still a work in progress): Description Qty Each Total Simple smartphone and charger 1 300 300 Interface box between Cell Phone, meters and valves 1 500 500 3 "clean" water meters (B, C & J) 3 110 330 1 "dirty" water meter (H) 1 150 150 2 valves 2 50 100 Control system Subtotal 1,380 5,000 Gallon Water tanks (installed) 2 7,500 15,000 Possible expansion /enhancement of drainfield if required (not costed but would be moderate) Prelimina estimate for a 4 person household $16,380 It needs to be acknowledged that this proposal would add extra expense above and beyond the cost of a installing just a well, however the cost of the well and mitigation system would likely still be less than the combined cost (water share, extension of service line to property and connection charges) for a homeowner to hook up to an existing private water system if available. 5 Legislative requirements The development and piloting of this proposal will likely take three or more seasons of active data collection in order to prove the concept and refine the computer models necessary to calculate exactly the annual start and end dates that surplus water is available. The best way to generate the data needed to build the models is through the active participation of landowners who are affected by the new rules. Therefore it is suggested that the Washington State Legislature amend the current statues to accept that landowners who agree to cooperate and participate in this pilot project will be deemed to have fully mitigated their net consumptive water use and may rely on a permit- exempt well as their primary domestic water source. If the pilot program results in effective solutions being developed the landowner would be expected to adopt them. If for some reason the solutions prove to be ineffective participating landowners would be grandfathered in under the rules in place prior to the moratorium. Initial Funding The impact created by the recent Supreme Court rulings is not limited to Whatcom County; it affects most undeveloped rural property across the state. Therefore logically the cost to develop and pilot this concept should be funded from state rather than county funds. As the residents of Whatcom County are the ones most immediately impacted it would seem reasonable that they should be the ones to be offered the first opportunity to participate in the pilot as a means to achieve compliance with the recent rulings. While further determination needs to be made as to the ideal size and length of the pilot program, given the urgent need to find a solution we should start by offering anyone building a house in Whatcom county over the next three years the opportunity to participate. The state would reimburse reasonably incurred costs for the necessary infrastructure to be incorporated within their building plans in exchange for the landowner agreeing to: (a) providing the data necessary to properly evaluate and refine the concept, and (b) to continue to use the final working system in perpetuity unless the state later determines the solution is unnecessary or ineffective. Conclusion While this proposal may be more complex than some others under consideration it respects and responds to the reality than we have finite water resources throughout the state which require that we mitigate seasonal overconsumption of water with actual water from other sources. A Exhibit A DRAFT Rud Browne - 2016 -11 -18 SEASONAL USE OF EXEMPT WELLS WATER BUDGET - Indoor use only. Outdoor use would be-additional GREEN BOXES ARE VARIABLES Step 1 Number of users (minimum 2): 4 Persons Gallons per day /person: (50g /person /day min, recommend 65)' (range 42 to 65 US Gallons) 65 US Gallons Gallons per day used: (users x gpd) 260 US Gallons Step 2 Estimated net percentage of water consumed (range 10% to 20 %) 20% Step 3 Days per year Exempt wells impacted by Senior Rights or In- Stream Flow rules Start date I -May End Date [ -Nov 184 Days Step 4 Calculate Net impact in Gallons per season Gross water use during restricted period in Gallons (average gallons per day consumed x days impacted) 47,840 US Gallons Net water use during restricted period in Gallons (gallons used x net percentage consumed) 9,568 US Gallons Size of seasonal storage tank required 9,568 US Gallons Step 5 Use of Exempt well Allow metered domestic use of exempt well year round an average daily rate not to exceed the storage systems capacity to mitigate In this example as the average daily usage rate would 260 US Gallons therefore the seasonal storage required would be 10,000 US Gallons The well, stormwater and rainwater can be used to fill the storage tank in mid winter when there is excess surface water (Rounded up) Approximate price per US Gallon to store water in a tank(s), (includes installation) S 1.50 USD Cost of sufficient tank capacity to store water (total storage x cost per Gallon) $ 15,000 USD Step 6 Metering proposal DEDUCT The gross amount of metered water pumped from the well per day to provide Potable water is: 260 US Gallons ADD back the amount of metered water leaving septic system for introduction to drain field each day is: 208 US Gallons ADD back the net water consumed is automatically calculated and released from storage into the drain field to mitigate: 52 US Gallons Total net impact on senior water rights such as seasonal irrigation rights (adjusted daily): Total negative impact on minimum instream flow levels (adjusted daily) _ W H m _I t W u w ° A W � a�n W E N W W Q w w �V C �f5a tf y.7 Oi w Q Cs� 4 .} a4� trS� m a 1� u � N V I m G cc 9qLyU h N M N N t r C LL C r 4D u w Y W N N u � C v � a c c. 16 N O ul Q1 m n � m o a E H m c®r w Z m r C� G 461 N � N •N a � C Q 3 w z O m 0 N UJ C 0 m a z r d 0