Email to Ted Wixom 3/11/2004:

Ted

I found a Ecology guidelines that allow us to use estimated use for exempt wells and recharge of the ground water due to septic systems. These are not "case law", but they are published by ECY as guidelines and subject to peer review:

This first one is a bit vague, but the next two are very specific.
ECY's guidelines under section 4.5 "Estimating Water Rights and Uses"
http://www.ecy.wa.gov/pubs/99106.pdf
at least implies that we should estimate the number of exempt wells and the amount of water used.

This is not the proof we want, but it is an indication that we should estimate real use. If all that mattered was 5000 gpd, then there would be no mention of real use since 5000 gpd would be used.

The addendum is much more broad sweeping: pg 139/178:
http://www.ecy.wa.gov/pubs/0206005.pdf

"Exempt wells can represent an important factor in local ground water withdrawals ... Planning units may wish to consider whether and how exempt wells should be addressed in the watershed plan, including management recommendations"

WRIA 55 - 57 Watershed planning:
http://www.ecy.wa.gov/watershed/55scope%20of%20work.htm
Sub—Task 3.5 Estimate recharge to the system and discharge out of the system from used water.

   1. Collect water quantity inflow data from the Waste Water Treatment Plant. Separate into residential, commercial / industrial, and stormwater values.
   2. Estimate recharge from residential and agricultural irrigation.
   3. Determine the number of households using septic systems and estimate recharge from septic systems.


This is good, the guidelines allow us to do the right thing.

Sandy