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Comment for Public Hearing 5/19/25 from Cameron DexterJudi Funk From: Cameron Dexter <cameron@flatheadcitizens.org> Sent: Monday, May 19, 2025 6:37 PM To: Kalispell Meetings Public Comment Subject: EXTERNAL Comment for Public Hearing 5/19/25 Attachments: Comment for Main St. Safety Plan Public Hearing.pdf [NOTICE: This message includes an attachment -- DO NOT CLICK on links or open attachments unless you know the content is safe.l Cameron Dexter, J.D. Director of Planning and Policy Citizens for a Better Flathead 137 South Main Street Kalispell, MT. 59901 Flatheadcitizens.org May 19, 2025 Kalispell City Council, Thank you for your time in reviewing the Kalispell Main Street Concept Design. And, thank you to the staff for their hard work on this project. Citizens for a Better Flathead supports the City in moving forward with an application to the U.S. Department of Transportation Safe Streets and Roads for All Implementation Grant Program if the following concerns can be effectively addressed. We have submitted prior comments on these issues, but have not yet seen how the City plans to address our comments. Citizens for a Better Flathead represents many residents in the Kalispell area who share our concerns. CBF is recommending that in moving forward with this design, it be made clear how green spaces will be implemented into this plan. Gardens, trees and green spaces along the proposed expanded sidewalks and in the middle of the proposed round -a -bouts would supply the City with not only beauty and add to traffic calming, but serve as a way to offset emissions through photosynthesis and the carbon cycle. Additionally, CBF wants to ensure that Ashley Creek is not further impaired by this project. The recent recommendation, prior to any public hearing, regarding the UAA by DEQ does not mandate or support reclassification, but does allow for a site -specific standard for lower Ashley Creek of 3.2 mg Total Nitrogen/L and o.o8 mg Topal Phosphorus/L from June 1 through September 3oth of each year. According to the DEQ's analysis of the Ashley Creek UAA, the concentrations just mentioned reflect what concentration levels are currently "achieved [during] the instream growing season below the Advanced Wastewater Treatment Plant..." (DEQ Evaluation of UAA, p. 15). The evaluation understands that implementing these concentration metrics would "ensure that under current conditions the probability of future exceedances of these criteria is nil." Rather, we feel that the lower standards currently being suggested by DEQ for Ashley Creek are not based in sound science and do not comply with the criteria set forth in the Clean Water Act. While the criteria holds the City to a "more attainable" standard, it does not address the fact that the creek has been impaired, slowly, over many years, due to anthropogenic impacts that have not been given the careful consideration they deserve, particularly with the hindsight of the City now asking DEQ to allow it further and through rulemaking to lower the water quality of Ashley Creek. The Main Street Safety Action Plan as well as other integrations of growth policy chapters (i.e. housing), present themselves as areas where the city can and must improve water quality as the city grows and changes. For far too long, as is reflected in the current degraded status of Ashley Creek, plans similar to the Main Street Safety Action Plan have failed to incorporate more aggressive and effective strategies to improve water quality. This is why we feel it is important to incorporate more robust and proper stormwater and runoff drainage into this plan, so that as Citizens for a Better Flathead PO Box 2198, Kalispell, MT 59903 (406) 756-8993 www.flatheadeitizens.org the population grows and climatic conditions change, the city is able to improve rather than further degrade Ashley Creek. Additionally, while we've raised this issue before, we would like to see more staff discussion and evaluation as to how this plan can complement and retain the downtown's historic character. The public and the council needs to hear, prior to the council making a decision, not just the benefits of a plan like this, but what consideration has been given to mitigating potential negative impacts to other city goals. While some may be unsupportive of elements of this plan and the new infrastructure it brings β€” like the proposed round -a -bouts, which we support as they can improve traffic flow and safety β€” CBF sees this plan as offering the city tools and funding to meet the public's desire for more walkable streets, parking to support local businesses, traffic calming andβ€” last but not least β€” safer roads for our residents. And as noted above, grant programs like this should also become a regular opportunity to look at critical water quality issues, which if not addressed in plans like this will continue to lead to further degradation of waterbodies like Ashley Creek. Thank you for your time and consideration, Cameron Dexter Director of Policy and Planning Citizens for a Better Flathead Citizens for a Better Flathead PO Box 2198, Kalispell, MT 59903 (406) 756-8993 www.flatheadeitizens.org