The decision to require a property owner to select the property’s source of water supply resulted from an analysis of water quality, water quantity, equity, enforcement options and environmental factors. There are generally two types of exempt wells within Covington’s service area, domestic or potable water system wells and irrigation wells. The criteria for establishing the policy of water service is based on the following:
- Environmental: Environmental issues related to hydraulic continuity with streams and lakes are not a District issue, per se, but they are of great concern. The Green River basin is closed to any new water uses (WAC 173-509), so a permit-exempt well is withdrawing from a watershed that doesn’t have water available according to state hydrologic experts. Eventually the excess withdrawals could impact the District’s ability to meet its customers’ needs.
- Water Quantity: The District has a “Duty to Serve” water as outlined in the 2003 Municipal Water Law, and it plans for water service to meet the projected land use and zoning decisions made by the appropriate land use agencies (Covington, Maple Valley, Black Diamond and portions of unincorporated King County). At this time the Department of Ecology does not require exempts wells to be metered. There is no accountability for the amount of water withdrawn from an aquifer. The District owns and operates 10 municipal wells which supply approximately 37% of the District’s total water supply. The risk of taking existing water by this kind of unrestricted well poses an unacceptable risk to the District’s water supply.
- Water Quality: Irrigation wells have no water quality testing or monitoring requirements. While potable exempt well systems have significantly less restrictive water quality requirements than the District’s municipal wells, one presumes that homes on potable exempt wells have the same health and welfare concerns that the District does for its system’s customers. Every well shaft into the aquifer is a conduit that allows for any and all foreign materials such as lawn fertilizers, fecal matter from animals, and other contaminants, to seep into the aquifer. No one at the local, state or federal level monitors irrigation wells for water quality at any level. The potential for aquifer contamination through permit-exempt wells is an unreasonable risk for all 18,500 District customers.
- Fair Investment: From 1994-1997 the District experienced a water supply shortage that resulted in a water and building moratorium. As a result the District invested in the Howard Hansen Dam additional water supply project, which has cost the District customers $65 million. While the capital costs are financed over 30 years, the investment was made on behalf of customers who have connected since the year 2000 and all future customers. The District is meeting its “Duty to Serve” and customers, the investors in the water supply, have a reasonable expectation that all customers contribute to the costs of the investment.
- Enforcement: As mentioned above, there is not currently any oversight of permit-exempt wells, neither is there enforcement should they be operated outside of their required limitations. Permit-exempt well owners could easily extract more than the limitations listed in #2 and deplete a confined aquifer, pay no attention to the distribution of fertilizers or other chemicals near the well and contaminate the aquifer, or allow domestic animals to roam near/to the wellhead and potentially contaminate the aquifer with fecal bacteria. No one will know if the aquifer is depleted or contaminated until it is too late – the risk to municipal systems is too great. The District’s wells are monitored daily and all water quality and withdrawal exceptions are reported immediately. District customers expect and rely on this level of service, yet exempt wells with no enforcement to any standards have the potential to negatively impact the water quality and quantity of the District’s municipal wells without consequence.