May 13, 2008

Kirk Johnson, Senior Planner
Skagit County Planning Department
1800 Continental Place
Mount Vernon, WA 98273

RE: Guemes Ferry Service Environmental Assessment

Dear Mr. Johnson:

This is a letter of comment pertaining to the Environmental Assessment document (EA) for the Guemes Island ferry extended service schedule. I believe there are several areas of potential malfeasance in the way that the County manipulated information to show that the extended service to Guemes resulted in a "Determinafion of Non-Significance" on the environment. These concerns were fully revealed to the County by the Guemes Island Ferry Conmlittee (GIFC) in response to the County's original EA Plan (GIFC letter dated 2/l/08 -page 3).

Issue I - The County failed to follow the Skagit County Comprehensive Plan (SCCP) (Transportation Element - Draft 2/10/06 & Final 10/10/07 - sections 8A-5.2 & 8A-5.3 respectively), which guides the county in methods for meeting increasing ferry traffic
demand. On page 29 of the EA report, the county extracted language on the methodology to meet increasing ferry use demand from the Guemes Island Ferry Capital Facilities Plan 2006-2020 (FCFP) labeled 9A-8.2. The SCCP 8A-5.3 posted on the County web site includes a fourth and final way to meet increasing ferry demand "(d) adding additional runs outside the current schedule". Contrary to the sequential process provided in SCCP 8A-5.3, on July 1, 2006, the County introduced both an extended service and a fixed schedule to meet increased ferry use demand rather than following the SCCP. The EA has failed to include proven ferry schedule alternatives which would increase ferry capacity by 35% within the previous operating hours as a way to meet increased demand as recommended by the GIFC. This omission has led to pages of posturing in the EA which are of little use except to support the County's position.

Issue Il - Ferry vehicular traffic growth between 1990 and 2004 has been misrepresented in a way to justify a need for expanded ferry service. The EA, Table 3.lon page 14, purports to use vehicular ridership data from the FCFP. The traffic data shifted upward by 23% between 1990 and 1991, distorting the county's baseline. Past requests by the GIFC to correct this error have received no response. Additionally, between 1999 and 2000 the source of ridership data changed from ticket sales to Coast Guard count. The ridership in the FCFP for 2004 is 101,975 vehicles, not the 124,574 used in the EA report. The EA incorrectly states there is a vehicular ridership increase of 74% (5.3% per year) from 1990 to 2004 when it actually increased by 14.8% between 1991 and 2004 or 1.14% per year. Using the correct rate of increase for vehicular ferry ridership will result in a significant change in any planning strategy or argument for increased service.

Issue III - Due to the large number of single family residences (SFR) on Guemes that are second homes, short term growrth caused by extended service will likely come from conversion of these residences to primary SFR. This concept was not even considered in the EA. The EA heavily relies on SFR data summarized in the FCFP to estimate growth rates. Some of the data is highly suspect. For instance, why is there no consistency in the SFR growth data between the FCFP report for 2001-2015 (page 25) and the report for 2006-2020 (page 18)? Why does the data for SFR in the FCFP (page 18) and EA (page 24) not add properly? I recently interviewed Earl Cahail who lived on Guemes until he left for college in 1939. He recounted and we compiled a list of SFR that totaled 97 at that time. This is quite different than the 14 SFR shown in the FCFP for 1940.

The falsification and manipulation of ridership data, the misuse of the SCCP to meet increased ferry demand, and ineffective assembly of residential growth data for Guemes shows the unprofessional way that the county tries to justify its position.

I am requesting that the County re-write the EA with the above issues taken into account.

Sincerely,

Carl M. Cady
Resident, Guemes Island

6185 SECTION AVE - ANACORTES, WA - 98221
PHONE: 360 299 0595 - FAX: SAME

Attachments: SCCP-transportation (page 19) 8A-5.2 8A-5.3; GIFC letter 2/l/08 page 3; FCFP pages 18, 19, 38 & 44-1 FCFP 2001-15 page 25

CC: Skagit County Commissioners, Friends of Guemes Island,
Judge Allendorefer-Superior Court Snohomish County