Protect Fall City’s Drinking Water and the Snoqualmie River
Protect Fall City’s Drinking Water and the Snoqualmie River
The Issue
A Call for Coordination from State and County Leaders to Protect Fall City’s Drinking Water and the Snoqualmie River
To:
State Representatives for District 12: Senator Keith Goehner, Representative Brian Burnett, Representative Mike Steele
State Representatives for District 5: Senator Victoria Hung, Representative Lisa Callan, Representative Zach Hall
Washington Department of Ecology
Washington Attorney General’s Office
King County Executive, Girmay Zahilay
Director of Local Services, King County, Leon Richardson
King County Council
Summary of the Ask
We, the undersigned residents of Fall City, Washington, request a temporary pause on permitting, clearing, grading, and construction activity for subdivision developments in the rural town of Fall City until the groundwater and environmental impact analysis ordered by the King County Hearing Examiner is completed (December, 2024). Click here to read the Hearing Examiner Decision and a full summary of the legal and environmental issues in this petition.
This pause is not an attempt to stop development. It is a safeguard to ensure that King County and the Applicant honor the Hearing Examiner's decision that groundwater and river-impact analysis must be completed before any irreversible harm occurs to Fall City’s drinking water and the Snoqualmie River. The cumulative analysis is already underway and expected to conclude within a reasonable and limited timeframe - however the plats involved the the analysis are still being permitted and allowed to proceed to clearing and grading.
Specific asks to Representatives and Agencies are outlined below.
Why care about Fall City?
Fall City is a rural community of 3,000 residents in unincorporated King County (District 12), situated along the banks of the Snoqualmie River and home to major salmon recovery projects. The town depends on a shared well system drawing from a sole-source aquifer, and most of Fall City sits within wellhead protection zones and Critical Aquifer Recharge Areas. Fast moving groundwater flows directly below town before entering the Snoqualmie, creating a delicate and highly vulnerable link between our drinking water, our soils, and the river.
Seven related subdivisions in Fall City are being permitted separately while their combined wastewater impacts flow to the same sole-source aquifer and Snoqualmie River, creating a cumulative risk that cannot be addressed through isolated permit reviews.
Why Fall City is at risk for a contamination event
Like many rural communities, Fall City has no sewer system. Homes rely on individual septic systems that disperse wastewater into the soils and the underlying aquifer. The seven proposed developments, totaling roughly 120 new homes, instead use Large Onsite Sewage Systems (LOSS). These community drain field systems collect and treat wastewater from multiple homes, then discharge it at a single point directly into the groundwater. This concentrated loading is located immediately upslope of the community drinking-water wells and the Snoqualmie River. Combined with the town’s existing septic density, the risks of placing multiple high-capacity discharge systems in close proximity have not yet been evaluated.
Emerging Information & Missing Data
Recent hydrogeologic studies show elevated nitrate levels in Fall City’s shallow groundwater and fast transport toward the river. Nitrate contamination is permanent once it enters groundwater and cannot be removed. Communities that experience nitrate contamination face long-term health risks and significant financial costs, and elevated nitrate levels in waterways can impair salmon health and survival.
The King County Hearing Examiner reviewed the new, emerging environmental information for one of the plats and ordered a cumulative groundwater impact analysis for the Fall City developments - in accordance with state law and SEPA requirements. That analysis is already underway. The community is looking to this data for reassurance on unanswered questions like:
- How much net new nitrate will these projects collectively add to the aquifer?
- Can the soils handle the new loading over time?
- How quickly will contaminants travel towards wells and the Snoqualmie River?
- How does the upper aquifer interact with the lower aquifer?
- Which monitoring and protections are missing to safeguard against a contamination event?
- Would alternative wastewater designs (like individual septics) compare to LOSS for overall nitrate loading?
These questions must be answered before development can begin to comply with anti-degradation law and to ensure the future safety of water resources. If the data shows that these systems are safe and all risks have been addressed then due diligence has been done.
Intervention is urgent
Despite being explicitly named in the cumulative analysis, four of the developments (Fall City II, Cedar, Cha, and Mt. Si) are rapidly moving toward clearing and grading before the cumulative impacts analysis is finished. It is critical that all agencies pause permitting until the record is complete. Starting development without the analysis is like stepping off a curb without looking for oncoming traffic.
Agencies working in Silos
No agency has stepped forward to coordinate the scientific review. The community has carried the financial and logistical burden of pushing for data, including hiring experts to contribute independent review. Worse, no agency has assumed responsibility for cleanup if contamination occurs, again leaving the community to bear the costs of securing a new and safe drinking water source.
For these developments, King County leads SEPA and land use, Department of Ecology oversees groundwater and drinking-water quality, Department of Health regulates individual LOSS systems, and the Fall City Water District protects the wellfield. Each agency is operating within its own silo, and no one has stepped up to ensure coordination or confirming that the necessary cumulative-impact analysis is completed.
For a tangible example: King County defers all groundwater impacts to the Department of Health for LOSS impacts, however the Department of Health is not required (and will not) assess the cumulative groundwater effects of LOSS and thus refers that issue back to King County. But again, King County states they don’t assess groundwater impacts. This circular structure leaves no agency responsible for evaluating the combined impacts to the aquifer or the Snoqualmie River. The expected outcome would be that the Department of Health provides King County with the loading data from the LOSS, King County evaluates LOSS cumulative loading from all LOSS in conjunction with other groundwater concerns (like stormwater), and then provides the Department of Health with cumulative impacts from LOSS for consideration in their risk analysis. This partnership has not occurred.
Our Requests
To Senator Goehner, Senator Hunt, Representatives Burnett, Steele, Callan and Hall
As your constituents, our community requests that you please contact the Department of Ecology and request that Ecology assume the coordinating SEPA lead role for cumulative groundwater and river-impact analysis. Under WAC 197-11-946 and WAC 197-11-948, lead-agency responsibilities may be reassigned when impacts span multiple jurisdictions or when the existing lead agency is not positioned to conduct the required cumulative analysis. This situation meets those conditions.
As our community's legislative leaders, you are the only level of government with oversight across all state and county entities involved. Without your involvement, no agency has the mandate to require cooperation or to ensure that cumulative impacts to the sole-source aquifer and the Snoqualmie River are evaluated.
We recognize that Ecology often prefers to defer SEPA leadership to counties. However, in this case the impacts cross groundwater, surface water, stormwater, and river-temperature domains - areas where Ecology alone has statewide jurisdiction. King County’s authority is limited to land-use approvals; DOH’s is limited to LOSS engineering; neither agency can direct basin-scale cumulative impact analysis.
Urging Ecology to coordinate this review is a simple, low-risk step that stays fully within existing law and does not halt development. It closes the jurisdictional gap that currently prevents agencies from working together and ensures that SEPA’s core requirement - evaluation of cumulative environmental impacts - is actually met.
To the Attorney General’s Office
Please assist in resolving the jurisdictional gaps among Ecology, King County, the Water District, and related agencies by providing clarification or guidance on their duties under SEPA, the Water Pollution Control Act, and Washington’s public health and environmental statutes. Under RCW 43.10 and the Attorney General’s authority to advise state agencies, your office is uniquely positioned to clarify responsibilities when jurisdictions overlap or when an environmental review gap creates potential risk to a sole-source aquifer.
We request that your office evaluate whether the current SEPA lead-agency structure satisfies the requirements of WAC 197-11-060, WAC 197-11-792, and WAC 197-11-948 regarding cumulative impact review, and provide guidance or coordination if these obligations are not being met. A clarification of duties - not a change in policy - would enable Ecology, King County, the Water District, and DOH to coordinate their reviews and ensure that cumulative groundwater risks are assessed before irreversible harm occurs.
This intervention does not halt development. It simply ensures that state and local agencies understand and fulfill their statutory responsibilities in a coordinated, lawful, and scientifically protective manner.
To the Department of Ecology
Please assume the coordinating SEPA role necessary to complete the cumulative groundwater and environmental impact analysis ordered by the King County Hearing Examiner for the Fall City subdivisions. Under WAC 197-11-060, WAC 197-11-792, and WAC 197-11-946/948, Ecology may assume or be assigned lead responsibilities when impacts span multiple jurisdictions, involve statewide water resources, or require technical expertise beyond a local agency’s capacity. This situation meets those criteria.
Ecology has the broadest jurisdiction over groundwater protection, wellhead protection areas, stormwater, and surface-water quality under RCW 90.48 and RCW 43.21A. No other agency is positioned to evaluate combined impacts from multiple LOSS and septic systems, nor to assess the interaction between shallow groundwater, nitrate loading, temperature changes, and impacts on the Snoqualmie River and ESA-listed salmon.
We request that Ecology coordinate directly with King County and the Fall City Water District to complete the basin-wide analysis needed to evaluate:
• cumulative nitrate loading and groundwater transport;
• wellhead protection and the sole-source aquifer characteristics;
• river impacts, including temperature and nutrient contributions;
• interactions among multiple wastewater and septic systems in a confined recharge area.
This analysis must be completed and applied before clearing or construction begins to ensure that irreversible impacts do not occur before SEPA review is complete. Taking leadership now will fulfill Ecology’s statutory responsibilities for groundwater and water-quality protection and will close the jurisdictional gap that prevents other agencies from conducting a cumulative analysis on their own.
To the King County Executive, King County Council, and Department of Local Services
Please institute an administrative, temporary pause on permitting, clearing, grading, and construction for the Fall City II, Cedar, Cha, and Mt. Si subdivisions until the cumulative groundwater impact analysis ordered by the Hearing Examiner is complete. This pause is narrow, time-limited, and consistent with SEPA’s requirement (WAC 197-11-070) that agencies avoid actions that would limit reasonable alternatives before environmental review is finished.
We also request that the County convene coordinated discussions with Ecology, the Water District, and DOH to ensure that all missing information needed for the Hearing Examiner ordered cumulative analysis is obtained and integrated. This includes baseline groundwater data, cumulative nitrate loading, OSS comparisons, attenuation capacity, wellhead protection information, groundwater travel times, and any other technical inputs required to assess cumulative impacts across multiple developments and wastewater systems to the groundwater and Snoqualmie River.
If staff capacity or resources constrain the County’s ability to complete this basin-wide review promptly, we ask that you utilize the SEPA lead-agency transfer provisions under WAC 197-11-946/948 to share or transfer responsibilities to the Department of Ecology, which has full jurisdiction over groundwater and surface-water quality.
These steps do not require legislation. They ensure SEPA compliance, fulfill the Hearing Examiner’s directive, and prevent irreversible harm to Fall City’s sole-source aquifer and the Snoqualmie River while the required scientific review is completed.
Signed respectfully,
The Fall City Community
We, the undersigned residents and supporters, want responsible development that protects Fall City’s only drinking-water source and the Snoqualmie River. We are asking for cooperation between state and county agencies, completion of the required analysis, and protection from irreversible contamination. A short pause now allows science to guide decision making and prevents long-term harm to the aquifer and to the Snoqualmie River.
Please sign to support drinking-water safety, responsible development, and protection of the river for future generations.
(If you are having trouble signing with your address, be sure to use your street address and not your Fall City PO Box)
1,273
The Issue
A Call for Coordination from State and County Leaders to Protect Fall City’s Drinking Water and the Snoqualmie River
To:
State Representatives for District 12: Senator Keith Goehner, Representative Brian Burnett, Representative Mike Steele
State Representatives for District 5: Senator Victoria Hung, Representative Lisa Callan, Representative Zach Hall
Washington Department of Ecology
Washington Attorney General’s Office
King County Executive, Girmay Zahilay
Director of Local Services, King County, Leon Richardson
King County Council
Summary of the Ask
We, the undersigned residents of Fall City, Washington, request a temporary pause on permitting, clearing, grading, and construction activity for subdivision developments in the rural town of Fall City until the groundwater and environmental impact analysis ordered by the King County Hearing Examiner is completed (December, 2024). Click here to read the Hearing Examiner Decision and a full summary of the legal and environmental issues in this petition.
This pause is not an attempt to stop development. It is a safeguard to ensure that King County and the Applicant honor the Hearing Examiner's decision that groundwater and river-impact analysis must be completed before any irreversible harm occurs to Fall City’s drinking water and the Snoqualmie River. The cumulative analysis is already underway and expected to conclude within a reasonable and limited timeframe - however the plats involved the the analysis are still being permitted and allowed to proceed to clearing and grading.
Specific asks to Representatives and Agencies are outlined below.
Why care about Fall City?
Fall City is a rural community of 3,000 residents in unincorporated King County (District 12), situated along the banks of the Snoqualmie River and home to major salmon recovery projects. The town depends on a shared well system drawing from a sole-source aquifer, and most of Fall City sits within wellhead protection zones and Critical Aquifer Recharge Areas. Fast moving groundwater flows directly below town before entering the Snoqualmie, creating a delicate and highly vulnerable link between our drinking water, our soils, and the river.
Seven related subdivisions in Fall City are being permitted separately while their combined wastewater impacts flow to the same sole-source aquifer and Snoqualmie River, creating a cumulative risk that cannot be addressed through isolated permit reviews.
Why Fall City is at risk for a contamination event
Like many rural communities, Fall City has no sewer system. Homes rely on individual septic systems that disperse wastewater into the soils and the underlying aquifer. The seven proposed developments, totaling roughly 120 new homes, instead use Large Onsite Sewage Systems (LOSS). These community drain field systems collect and treat wastewater from multiple homes, then discharge it at a single point directly into the groundwater. This concentrated loading is located immediately upslope of the community drinking-water wells and the Snoqualmie River. Combined with the town’s existing septic density, the risks of placing multiple high-capacity discharge systems in close proximity have not yet been evaluated.
Emerging Information & Missing Data
Recent hydrogeologic studies show elevated nitrate levels in Fall City’s shallow groundwater and fast transport toward the river. Nitrate contamination is permanent once it enters groundwater and cannot be removed. Communities that experience nitrate contamination face long-term health risks and significant financial costs, and elevated nitrate levels in waterways can impair salmon health and survival.
The King County Hearing Examiner reviewed the new, emerging environmental information for one of the plats and ordered a cumulative groundwater impact analysis for the Fall City developments - in accordance with state law and SEPA requirements. That analysis is already underway. The community is looking to this data for reassurance on unanswered questions like:
- How much net new nitrate will these projects collectively add to the aquifer?
- Can the soils handle the new loading over time?
- How quickly will contaminants travel towards wells and the Snoqualmie River?
- How does the upper aquifer interact with the lower aquifer?
- Which monitoring and protections are missing to safeguard against a contamination event?
- Would alternative wastewater designs (like individual septics) compare to LOSS for overall nitrate loading?
These questions must be answered before development can begin to comply with anti-degradation law and to ensure the future safety of water resources. If the data shows that these systems are safe and all risks have been addressed then due diligence has been done.
Intervention is urgent
Despite being explicitly named in the cumulative analysis, four of the developments (Fall City II, Cedar, Cha, and Mt. Si) are rapidly moving toward clearing and grading before the cumulative impacts analysis is finished. It is critical that all agencies pause permitting until the record is complete. Starting development without the analysis is like stepping off a curb without looking for oncoming traffic.
Agencies working in Silos
No agency has stepped forward to coordinate the scientific review. The community has carried the financial and logistical burden of pushing for data, including hiring experts to contribute independent review. Worse, no agency has assumed responsibility for cleanup if contamination occurs, again leaving the community to bear the costs of securing a new and safe drinking water source.
For these developments, King County leads SEPA and land use, Department of Ecology oversees groundwater and drinking-water quality, Department of Health regulates individual LOSS systems, and the Fall City Water District protects the wellfield. Each agency is operating within its own silo, and no one has stepped up to ensure coordination or confirming that the necessary cumulative-impact analysis is completed.
For a tangible example: King County defers all groundwater impacts to the Department of Health for LOSS impacts, however the Department of Health is not required (and will not) assess the cumulative groundwater effects of LOSS and thus refers that issue back to King County. But again, King County states they don’t assess groundwater impacts. This circular structure leaves no agency responsible for evaluating the combined impacts to the aquifer or the Snoqualmie River. The expected outcome would be that the Department of Health provides King County with the loading data from the LOSS, King County evaluates LOSS cumulative loading from all LOSS in conjunction with other groundwater concerns (like stormwater), and then provides the Department of Health with cumulative impacts from LOSS for consideration in their risk analysis. This partnership has not occurred.
Our Requests
To Senator Goehner, Senator Hunt, Representatives Burnett, Steele, Callan and Hall
As your constituents, our community requests that you please contact the Department of Ecology and request that Ecology assume the coordinating SEPA lead role for cumulative groundwater and river-impact analysis. Under WAC 197-11-946 and WAC 197-11-948, lead-agency responsibilities may be reassigned when impacts span multiple jurisdictions or when the existing lead agency is not positioned to conduct the required cumulative analysis. This situation meets those conditions.
As our community's legislative leaders, you are the only level of government with oversight across all state and county entities involved. Without your involvement, no agency has the mandate to require cooperation or to ensure that cumulative impacts to the sole-source aquifer and the Snoqualmie River are evaluated.
We recognize that Ecology often prefers to defer SEPA leadership to counties. However, in this case the impacts cross groundwater, surface water, stormwater, and river-temperature domains - areas where Ecology alone has statewide jurisdiction. King County’s authority is limited to land-use approvals; DOH’s is limited to LOSS engineering; neither agency can direct basin-scale cumulative impact analysis.
Urging Ecology to coordinate this review is a simple, low-risk step that stays fully within existing law and does not halt development. It closes the jurisdictional gap that currently prevents agencies from working together and ensures that SEPA’s core requirement - evaluation of cumulative environmental impacts - is actually met.
To the Attorney General’s Office
Please assist in resolving the jurisdictional gaps among Ecology, King County, the Water District, and related agencies by providing clarification or guidance on their duties under SEPA, the Water Pollution Control Act, and Washington’s public health and environmental statutes. Under RCW 43.10 and the Attorney General’s authority to advise state agencies, your office is uniquely positioned to clarify responsibilities when jurisdictions overlap or when an environmental review gap creates potential risk to a sole-source aquifer.
We request that your office evaluate whether the current SEPA lead-agency structure satisfies the requirements of WAC 197-11-060, WAC 197-11-792, and WAC 197-11-948 regarding cumulative impact review, and provide guidance or coordination if these obligations are not being met. A clarification of duties - not a change in policy - would enable Ecology, King County, the Water District, and DOH to coordinate their reviews and ensure that cumulative groundwater risks are assessed before irreversible harm occurs.
This intervention does not halt development. It simply ensures that state and local agencies understand and fulfill their statutory responsibilities in a coordinated, lawful, and scientifically protective manner.
To the Department of Ecology
Please assume the coordinating SEPA role necessary to complete the cumulative groundwater and environmental impact analysis ordered by the King County Hearing Examiner for the Fall City subdivisions. Under WAC 197-11-060, WAC 197-11-792, and WAC 197-11-946/948, Ecology may assume or be assigned lead responsibilities when impacts span multiple jurisdictions, involve statewide water resources, or require technical expertise beyond a local agency’s capacity. This situation meets those criteria.
Ecology has the broadest jurisdiction over groundwater protection, wellhead protection areas, stormwater, and surface-water quality under RCW 90.48 and RCW 43.21A. No other agency is positioned to evaluate combined impacts from multiple LOSS and septic systems, nor to assess the interaction between shallow groundwater, nitrate loading, temperature changes, and impacts on the Snoqualmie River and ESA-listed salmon.
We request that Ecology coordinate directly with King County and the Fall City Water District to complete the basin-wide analysis needed to evaluate:
• cumulative nitrate loading and groundwater transport;
• wellhead protection and the sole-source aquifer characteristics;
• river impacts, including temperature and nutrient contributions;
• interactions among multiple wastewater and septic systems in a confined recharge area.
This analysis must be completed and applied before clearing or construction begins to ensure that irreversible impacts do not occur before SEPA review is complete. Taking leadership now will fulfill Ecology’s statutory responsibilities for groundwater and water-quality protection and will close the jurisdictional gap that prevents other agencies from conducting a cumulative analysis on their own.
To the King County Executive, King County Council, and Department of Local Services
Please institute an administrative, temporary pause on permitting, clearing, grading, and construction for the Fall City II, Cedar, Cha, and Mt. Si subdivisions until the cumulative groundwater impact analysis ordered by the Hearing Examiner is complete. This pause is narrow, time-limited, and consistent with SEPA’s requirement (WAC 197-11-070) that agencies avoid actions that would limit reasonable alternatives before environmental review is finished.
We also request that the County convene coordinated discussions with Ecology, the Water District, and DOH to ensure that all missing information needed for the Hearing Examiner ordered cumulative analysis is obtained and integrated. This includes baseline groundwater data, cumulative nitrate loading, OSS comparisons, attenuation capacity, wellhead protection information, groundwater travel times, and any other technical inputs required to assess cumulative impacts across multiple developments and wastewater systems to the groundwater and Snoqualmie River.
If staff capacity or resources constrain the County’s ability to complete this basin-wide review promptly, we ask that you utilize the SEPA lead-agency transfer provisions under WAC 197-11-946/948 to share or transfer responsibilities to the Department of Ecology, which has full jurisdiction over groundwater and surface-water quality.
These steps do not require legislation. They ensure SEPA compliance, fulfill the Hearing Examiner’s directive, and prevent irreversible harm to Fall City’s sole-source aquifer and the Snoqualmie River while the required scientific review is completed.
Signed respectfully,
The Fall City Community
We, the undersigned residents and supporters, want responsible development that protects Fall City’s only drinking-water source and the Snoqualmie River. We are asking for cooperation between state and county agencies, completion of the required analysis, and protection from irreversible contamination. A short pause now allows science to guide decision making and prevents long-term harm to the aquifer and to the Snoqualmie River.
Please sign to support drinking-water safety, responsible development, and protection of the river for future generations.
(If you are having trouble signing with your address, be sure to use your street address and not your Fall City PO Box)
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Petition created on December 2, 2025