2006-387N-Minutes for Meeting December 20,2005 Recorded 4/7/2006File Number: CU-05-20
Applicant: Thornburgh Resort Company, LLC
Subject: Application for a Conditional Use Permit for a Destination Resort Conceptual
Master Plan approval (1,980 acres) in the Exclusive Farm Use (EFU-TRB) zone
Thornburgh Resorts MOIST be required to mitigate the full amount of water consumed by
their irrigation consumption. Their mitigation requirements are not fulfilled.
Thornburgh Resort Company has stated that they plan to use modern water conservation
methods to manage their irrigation on the resorts. Exhibit B-26, the Hydrology-Water
Supply Feasibility Evaluation, describes their Conservation Plan on page 26. Their
intention is to "Monitor the efficiencies of golf course and other irrigation needs
matching vegetation, soil and climate conditions to optimize water uses."
The Conservation Plan states that "A water conservation plan is intended for the Project
to produce a resort community that makes efficient and cost effective use of water. The
goal of the water conservation plan is to optimize water system efficiencies in irrigation
and domestic uses, educate the users on the benefits of water conservation, and optimal
landscaping that is conducive to water conservation. Employing these conservation
methods effectively will maximize the value of the Project, minimize investment in
developing water sources and distribution needs and improve the economic viability of
the Project." Plans include: "Installation of water meters on all source facilities,
"Service lines for domestic uses and Project irrigation uses", "Encourage drought
resistant or low irrigation landscaping on residential lots" and "Wastewater disposal
planning that utilizes beneficial use of reclaimed water".
On pages 33, 34 and 35 of the Application Summary, Thornburgh adds their intention to
employ various measures to minimize seepage losses, pipe irrigation water, avoid over
application and reuse wastewater and effluent in drip irrigation systems.
Audubon International has created guidelines for developers to access their
Environmental Planning Department expertise at the inception of a project. The goal is to
develop communities that integrate an ecosystem approach to siting, design, construction
and management. I have attached descriptions of their Signature Programs, as well as
articles on Environmental approaches to developments, "Saving Money, Saving
Resources" and case studies of participants who balance development and environmental
protection. I strongly suggest that the Thornburgh planners adopt these guidelines in
order to clarify what a Conservation Plan actually entails.
According to John Anderson, superintendent of The Club at Pronghorn, and the national
award winner of the 2004 Golf Digest Environmental Leaders in Golf Award, current
golf course watering practices promote careful monitoring of irrigation application in
order to water according to the particular turf grass needs. Water is applied into the root
zones and no deeper. The goal is to conserve water by applying only what the plants will
consume, between '/s inch to a few inches of water, by monitoring each emitter on the
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course. Over watering creates rapid growth, under watering results in wilt and disease.
So, the goal of a well managed irrigation program results in almost 100 % water
consumption. Pronghorn was recognized for their efficient use of Level 4 treated effluent
from the city of Bend to irrigate their golf courses and the surrounding landscaping.
On page 24, Table V, Exhibit B-26, the total annualized volume of water use for the 3
proposed golf courses is 1,081 Acre Feet, or 352,244,931 gallons per year. Miscellaneous
irrigation demands arel95 acre feet, or 63,540,945 gallons per year. Using conservation
watering methods, spray emitters would be regulated to providing no more than what the
turf needs for various areas of the golf courses. Irrigation of the surrounding landscaping
and in the commercial areas would be delivered by drip systems, thereby providing direct
water feeds into the individual plant root zones. This would supply only as much water as
the plants need to live.
On page 23, it states that "Mitigation is required for the amount of groundwater
withdrawal that is consumed." As modern golf course and landscape irrigation practices
do not apply water deeper than a few inches, the amount of water mitigated for golf
course use cannot be equated as quasi-municipal consumption of 40 or even farm
irrigation consumption of 70%, but must be mitigated at full consumption, which would
be 1, 276 acre feet, or 415,785,876 gallons per year.
Exhibit 18, B-14 & 15, Sanitary Sewer Collection and Disposal, describes the intended
dispersal of effluent collected within the resort onto the grounds on page 8. On pages 9
and 10 they state that they may choose to store treated effluence in a tank or pond and
apply it to the ground via sprinklers, or they may discharge into an underground dispersal
field or into a drip irrigation system or through above ground irrigation or use sanitary
drain fields. They go on to say that the most efficient system, drip irrigation, would need
to be "evaluated for cost effectiveness':
Thornburgh states that the total hydraulic load of 625,000 gallons per day will be
disposed of in a DEQ approved method, but nowhere do they define the level of
treatment proposed. Pronghorn Resort uses Level 4 treated effluent from the City of
Bend. What is the cost of constructing 2 private sewage treatment plants that are capable
of sanitizing waste to Level 4? Would they be evaluated as cost effective? If this Project
is truly planned to be a world class resort, then that should be the resident's expectation
in order to protect public health.
Does Thornburgh propose to store the treated water in the ponds and lakes throughout the
golf courses and landscaping? If they spray the water on the course, how will they
account for the dispersal caused by the high, prevalent windy conditions? What about the
effects to wildlife that will be attracted to drink from the ponds? Can they prevent
children from playing in the water? Will there be buffer zones? Warning signage? These
questions and many more must be addressed when choosing the level of treatment for
reclaimed water use.
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Exhibit_J~J
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I have attached Table 1: Treatment and Monitoring Requirements for Use of Reclaimed
Water, (OAR 340-055-015) and the DEQ Regulations pertaining to the use of reclaimed
water (Treated Effluent) from Sewage Treatment Plants. The purpose of these rules is to
protect the environment and public health in Oregon by prescribing the methods,
procedures and restrictions required for the use for beneficial purposes of reclaimed
waters. As you can see, the choice to irrigate with treated wastewater has consequences.
Thornburgh "expects to utilize a system similar to that of Eagle Crest." On page 9 it
states: "At nearby Eagle Crest Resort, dispersal is accomplished by collecting filtered
effluent in a pond and using the reused water to irrigate the golf course." Eagle Crest
Resort does not use treated effluent on their golf course. They have used a series of drain
fields. In 2001 the DEQ was notified by a nearby Eagle Crest resident of discharge of
sewage to the ground surface on a drain field adjacent to Hwy 126. Eagle Crest received
3 DEQ "Notice of Noncompliance" letters dated April 2, April 6 and May 17, 2001.
Because of drain field failures, Eagle Crest now operates a mechanical system capable of
Level 3 treatment. Eagle Crest is allowed to use their level 2 treatment to irrigate on 50
acres of their land north of Hwy 126 and on other land that belongs to a local farmer.
Attached are the DEQ noncompliance letters.
On page 1, Exhibit B-14, the project is described as two sewer basins including 15 miles
of pipe, 1430 septic tanks, an effluent lift station and at least two treatment and dispersal
facilities. "At full build-out, peak daily sewage flows are expected to be 625,000 gallons
per day". Septic tanks will flow through connected piping to the sewer system by gravity
flow. The dispersal system will consist of a community drain field, OR underground drip
system OR above ground irrigation. Yet their application does NOT identify any type of
monitoring method for their sewage. What guarantee is there that Thornburgh's drain
fields will not contaminate adjacent down gradient BLM lands? Can Thornburgh contain
their entire waste disposal system within their own lands or will they need to pump waste
to an offsite drain field? Diverting their waste to the adjacent public lands is simply not
acceptable.
As the resort plans to construct in phases over the course of 10 years, what are the plans
for the sewage waste while the project grows? If they propose a drain field system in the
early phases of construction, then they will need to install monitoring wells. How much
land will need to be dedicated to drain fields?
In the Deschutes County staff report, page 5, states: "Sewer evaluation and permit must
be applied for through DEQ" According to the DEQ, Thornburgh has not yet completed
an application that defines their plans for their waste disposal system. As of Friday,
December 17, 2005, the DEQ has stated that they do not have a file for this project.
Thornburgh has not paid any application fees. Furthermore, an engineer representing
Thornburgh Resorts has verbally instructed Tom Hall at DEQ to put a hold on evaluating
the mechanical treatment plant because of questions regarding the amount of space
required.
On page 3 they state that the proposed facility is not located within the service boundary
of a municipal sanitary sewerage system, yet on the same page they state that "During the
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course of the project, it may become feasible to discharge a portion of the sewage
generated by this project to the City of Redmond Sewer system. This statement is
repeated on pages 5 and 8. Would public funds be expected to support this backup plan?
This is a direct contradiction to the repeatedly stated intention that all sewer and waste
disposal will be provided on site.
The City of Redmond recently sent out a questionnaire to local businesses seeking
information on the types of businesses and waste that each produces so that they can
monitor the types of waste created by different types of enterprises. I have attached a
copy. Thornburgh lists in their application 53 different types of proposed commercial
businesses. Their Sewage and Waste Plan does not account for the special needs of a
brewery, dry cleaner, barber and beauty salons, recreational vehicle and camping
facilities, service station, gas and auto services, grounds maintenance facility or
alternative power generation facilities.
Item 3, page 27, Exhibit B-26 states: "Total Project water needs at full build out are
estimated to be 2,355 acre feet on an annualized volumetric basis" or 767,379,105
gallons. This is the estimated groundwater requirement If conservation methods are
implemented for the Project's irrigation, and if all water and sewage is carried to central
treatment facilities by a connected piping system, and if efficient methods are used to
disperse the treated effluent on site, then these conscientious conservation methods will
prevent the seepage of 1,276 acre feet of the water back into the groundwater. 1,276 acre
feet cannot be mitigated at merely a 40 % consumption rate.
Mitigation consumptive use must be divided into both quasi-municipal use, at 40% and a
separate rate for all irrigation use at least 60% to 70%, though for practical purposes golf
course irrigation technology should include precision application that will result in close
to 100% consumption through careful monitoring of dispersal volumes to match plant
needs and environmental conditions.
The Thornburgh plan has presented many options, while committing to none. They use
the shield of choosing the most cost effective option, and target tapping into the
Redmond municipal system as a long term solution.
Thombugh can't have it both ways. Either they intend to saturate the ground with
irrigation water volumes that greatly exceed local farming practices and send commercial
and household sewage waste into vast septic drain fields, thereby returning the surplus to
the water table OR they intend to practice modern water conservation methods and fully
use the water pumped from the aquifer. They MUST be required to mitigate for their full
consumption volumes for irrigation. Thornburgh has grossly underestimated their
mitigation requirements and should be denied approval.
Marianne Fellner
65044 Highland Rd
Bend, Oregon 97701
December 20, 2005
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Exhibit N
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