John Worthington "shall" put this in the mail today.
RE: Cover Letter and Introduction to ESA Citizen Suit Notice of Intent (NOI)
TO:
• Secretary of the Interior, U.S. Department of the Interior
• Secretary of Commerce, U.S. Department of Commerce
• Assistant Administrator for Fisheries, National Marine Fisheries Service (NMFS)
FROM:
John Worthington
DATE: September 21, 2026
SUBJECT: Notice of Intent to Sue Under Section 11(g) of the Endangered Species Act (ESA) — Unlawful Habitat Modification and Failure to Consult on Critical Salmonid Spawning Gradients and One-Year Freshwater Rearing Habitats.
________________________________________
INTRODUCTION & SUMMARY OF THE COMPLAINT
This letter serves as an introductory cover letter and formal notification that [Your Name / Association] intends to file suit against the National Marine Fisheries Service (NMFS) and the U.S. Fish and Wildlife Service (USFWS) for severe, ongoing violations of Section 7 and Section 9 of the Endangered Species Act (ESA).
The core of this action addresses a fatal, unaddressed systemic oversight in regional river-mouth management: the deliberate, federally permitted encroachment of high-density commercial tribal infrastructure directly atop the geographically rare 3% to 4% stream spawning gradients and low-flow estuarine floodplains. This localized development directly destroys the irreplaceable habitats required for wild Puget Sound Chinook (King Salmon) and Coho (Silver Salmon) to successfully fulfill their mandatory one-year freshwater biological cycle.
The Biological Mandates: The 3–4% Grade and the One-Year River Residence
Unlike other salmonids that migrate to the ocean shortly after emerging from the gravel, wild King and Silver salmon are strictly dependent on freshwater systems for an extended duration. Juvenile Kings and Silvers must live, feed, and shelter in their natal rivers for a full, consecutive year before transitioning to the ocean. This one-year residency makes them uniquely vulnerable to river-mouth development. Their survival dictates two non-negotiable habitat requirements that only exist in the lower reaches of systems like the Elwha River and Jimmycomelately Creek:
1. Hydraulic Sorting and Spawning (The 3% to 4% Grade): Wild King and Silver salmon are biologically tethered to a precise hydraulic window found almost exclusively at channel slopes of 3% to 4%. This specific gradient creates the water velocity required to naturally rinse fine silts out of the channel bed, leaving behind the clean, porous gravel matrix necessary for spawning. At this grade, the natural pool-and-riffle sequence drives oxygen-rich surface water deep into the gravel bed (hyporheic flow), preventing the suffocation of embedded eggs.
2. Year-Round Nursery and Thermal Refuge (The Lower Floodplains): Because juvenile Kings and Silvers must survive all four seasons in the river, they require stable, slow-moving complex habitats to grow. They cannot survive a year in a single, fast-moving main channel. They rely entirely on low-gradient side channels, logjams, backwaters, and estuarine edge-habitats. These zones provide structural cover from winter floods, critical shade to keep water temperatures cool during summer peaks, and an abundant insect food supply.
If a river mouth is stripped of its complex floodplain, or if its 3% to 4% gradient transitions are choked by development, juvenile salmon have nowhere to hide. They are either washed prematurely into salt water—where their underdeveloped bodies cannot handle the salinity—or they suffocate and starve in stagnant, degraded pockets of water.
The Violations: Structural Encroachment on Nursery Grounds
Despite the absolute biological reliance on these localized, year-round habitats, the federal government has repeatedly permitted major structural layouts directly over or adjacent to these exact 3% to 4% zones and rearing floodplains. Under a hyper-complex, multi-layered governance loop, modern tribal economic enterprises have been granted a practical ecological pass to pave over, alter, and fragment these irreplaceable ecosystems:
• Jimmycomelately Creek / Sequim Bay Watershed: The continuous physical expansion of the Jamestown S’Klallam Tribe's 7 Cedars Casino and its corresponding north campus infrastructure has systematically encroached upon the lower floodplain and critical migratory-to-spawning gradient transitions of the Jimmycomelately system. Paving over these floodplains with massive impervious parking lots and commercial structures permanently destroys the off-channel rearing pockets where juvenile Silver and King salmon must live for their first year. Urban stormwater runoff and direct bank stabilization have fundamentally altered the local geomorphology, choking the nearby 3% to 4% gravel zones with toxic sediment and stripping the creek of the natural woody debris required for juvenile shelter.
• The Elwha River Mouth: While the historic removal of the Elwha River dams was celebrated as an open corridor for wild recovery, the federal government has permitted the Lower Elwha Klallam Tribe to maintain an intensive, high-density structural footprint—consisting of concrete hatchery infrastructure, residential subdivisions, and heavy riprap—directly at the primary river-to-estuary transition. This intense structural congestion interrupts the natural gravel transport and lateral river migration. By pinning the river mouth in place to protect infrastructure, the government has stopped the formation of the low-gradient side channels and estuarine marshes that wild, self-sustaining juvenile Kings and Silvers require to survive their critical first year of life.
Conclusion
Historically, early American pioneers and municipal developers in Port Angeles altered the landscape with sluice hoses to build a downtown out of silt—actions taken long before the codification of modern ecological science. Today, however, the federal government possesses the science but refuses to enforce it universally. By ignoring the heavy, high-traffic structural footprints of modern tribal commercial developments built squarely on top of the region's primary King and Silver salmon rearing and spawning habitats, NMFS and USFWS have failed their statutory duties under the ESA.
True recovery cannot be achieved by selectively auditing historic Western infrastructure while allowing active commercial resorts to pave over the precise 3% to 4% channel gradients and yearling nursery grounds that wild salmon need to survive.
WHO IN THE COMPREHENSIVE PLAN IS PART OF THE SHOULD VS SHALL? WHO SHOULD, WOULD AND COULD BENEFIT THE MOST? WHO IS THE REAL VOICE BEHIND LaTRISHA SUGGS? IS IT "him who we SHALL not name."?
Clallam County Marine Resource Committee LaTrisha Suggs, Chair.
or
CEO of the Jamestown S’Klallam Tribe, W. Ron Allen, Tribal Chair (who is on many state committees including federal committees)
Chair W. Ron Allen, Tribal Chair and CEO of the Jamestown S’Klallam Tribe
(Secretary’s appointment)
This seven member Tribal advisory committee advises the Secretary on significant matters related to the taxation of Indians, the training of Internal Revenue Service field agents, and the provisions of training and technical assistance to Native American financial officers. The membership has three appointees nominated by the Secretary, two appointed by the House Committee on Ways and Means and two nominated by the Senate Committee on Finance.
Atlas Suggs is bad medicine. As I stated before in my 18 layer break down of the world governance system we have been living under the lower level actually tells the Commissioners what to do. Atlas Suggs has said so herself. She has also said we need to listen to Canada." Atlas Suggs hits the European Colonizer where it hurts. Somebody has to hit back in a similar way using the same environmental hammer that the world governing system does. My name is Crackpot Worthington and I am here all week.
SUBJECT: INTERACTION NOTICE: Imminent Threat and Substantial Endangerment Notification under RCRA Section 7003, Title 23 U.S.C. Highway Resilience Mandate, FEMA BRIC Policy Precedent, and Federal Trust Responsibility – Central Blyn Hazardous Fuel Storage Infrastructure and U.S. Highway 101 Corridor on Tribal Trust Land
I. JURISDICTIONAL STATEMENT & STATUTORY CITATION
This administrative filing serves as a formal public safety complaint and a multi-agency federal intervention request under Subtitle I of the Resource Conservation and Recovery Act (RCRA) (40 CFR Part 280), Title 23, United States Code (Highways), the Endangered Species Act (ESA) (16 U.S.C. § 1531 et seq.), and the federal trust responsibility owed to the Jamestown S’Klallam Tribe under the Department of the Interior and the Bureau of Indian Affairs.
Because the high-capacity Underground Storage Tank (UST) systems operating at the 7 Cedars Longhouse Market & Fueling Station are situated on sovereign tribal trust land within the low-lying Central Blyn basin floor, primary environmental regulatory enforcement over these hazardous containment units vests exclusively with the United States Environmental Protection Agency (EPA) Region 10. Concurrently, the United States Department of the Interior (DOI) and the Bureau of Indian Affairs (BIA) bear the federal trust responsibility for the protection of tribal trust lands and resources.
Local planning authorities—specifically the Clallam County Department of Community Development (DCD) and the Clallam Economic Development Council (EDC)—have formally disclaimed administrative and permitting jurisdiction over these infrastructural corridors. Consequently, this action bypasses local administrative remedies and places this critical hazard profile directly before federal environmental, tribal trust, transit safety, and hazard-mitigation authorities.
II. GEOLOGIC FACTUAL DETERMINATION: THE CENTRAL BLYN LIQUEFACTION LIABILITY
The target infrastructure is located entirely within a low-lying, saturated marine silt and alluvial deposition plain designated by the Washington State Department of Natural Resources and USGS as a High Liquefaction, Lateral Spreading, and Catastrophic Tsunami Inundation Hazard Zone.
Official Washington Geological Survey modeling (Map Series 2022-01, extended L1 Mw 9.0 Cascadia scenario) predicts approximately 5 feet of tsunami inundation at Blyn, with first-wave arrival approximately 90 minutes after the earthquake. Nearby areas show greater depths (approximately 10 feet at Dungeness and up to 33 feet at Discovery Bay).
The subterranean physical properties of the earth do not recognize municipal lines. In a major Cascadia Subduction Zone seismic event, the saturated sub-soil floor of the Central Blyn basin will experience absolute structural failure, instantly transforming the foundations beneath these high-volume fueling systems into un-bonded, flowing quicksand. Coseismic subsidence will further increase relative inundation depths before the tsunami arrives.
III. THE EXPLOSIVE VOLATILIZATION SEEN OVER FEDERAL LIFELINES (U.S. 101)
The structural placement of millions of gallons of highly volatile petroleum products trapped directly inside an active liquefaction and tsunami pathway represents an unmitigated threat to federal transit continuity and to tribal trust resources:
1.Shear and Rupture of Containment Cells: The shifting, liquefied earth will twist, shear, and crush the structural integrity of the Longhouse UST secondary and primary containment walls, releasing mass volumes of petroleum directly into the sub-surface water table.
2.Stormwater Pipe and Drainage Volatilization: Because the groundwater flows in direct hydraulic connection with surface networks, the leaked fuel will immediately track the path of least resistance. It will flood the public open ditches, stormwater pipes, and the adjacent Jimmycomelately Creek drainage basin—a critical salmonid habitat legally protected under the federal Endangered Species Act (ESA) and constituting a tribal trust resource.
3.The U.S. 101 Choke Point (“The Wall of Fire”): Once ignited, this subterranean and surface petroleum slick will transform the public stormwater infrastructure into an explosive delivery system. A single ignition point will generate an unrestricted, uncontrollable wall of fire burning directly across and over U.S. Highway 101. This will physically consume the pavement, explode vehicles, and permanently sever the single landward emergency evacuation route and logistical supply line for the entire North Olympic Peninsula.
IV. MANDATED FEDERAL RELIEF REQUESTED
To ensure regional transportation resilience, protect hydraulically connected salmon-bearing critical areas, and fulfill the federal trust responsibility for tribal trust lands and resources, the following actions are demanded of the federal agencies:
1.EPA Region 10 Subtitle I Audit: Order an immediate, emergency federal inspection of the Central Blyn UST arrays under RCRA Section 7003 to determine if the current
seismic and tsunami mitigation failsafes meet strict federal environmental safety standards for a catastrophic liquefaction zone.
2.DOI / BIA Trust Responsibility Review: Require the Department of the Interior and the Bureau of Indian Affairs to evaluate the placement of high-capacity hazardous fuel storage on tribal trust land within a documented high liquefaction and tsunami inundation zone, and to exercise their trust responsibility to protect tribal trust resources from catastrophic failure and downstream environmental harm.
3.FHWA / WSDOT Long-Term Corridor Resilience Evaluation and Conditioning of Title 23 Funding: Instruct the Federal Highway Administration and the Washington State Department of Transportation to formally evaluate the permanent relocation of U.S. Highway 101 out of the low-lying liquefaction and tsunami inundation corridor of Central Blyn and onto more geologically stable outermost foothill and glacial-outwash locations east of Sequim.
Such relocation is necessary to eliminate the single-point-of-failure risk that a Cascadia Subduction Zone event will sever the sole landward emergency evacuation and logistical supply route for the entire North Olympic Peninsula. Because the current alignment crosses documented high-liquefaction soils and areas of modeled tsunami inundation, any long-term solution that keeps the highway on the basin floor is inherently non-resilient.
Condition all future Title 23 federal highway funding for the U.S. 101 corridor on the completion of this evaluation and on a concrete plan to shift the highway to stable high ground. Recognize that such a realignment would necessitate coordinated tribal relocation planning for affected Jamestown S’Klallam trust lands and facilities currently located in the hazard zone; this planning must be conducted in full partnership with the Tribe under the federal trust responsibility and must include fair compensation, replacement of critical infrastructure, and protection of treaty resources.
4.FEMA BRIC Hazard Mitigation Funding Activation: Formally classify both (a) the relocation of high-capacity fueling centers out of the Central Blyn basin floor and (b) the long-term realignment of U.S. 101 onto stable foothill terrain as critical pre-disaster projects. The federal government must incentivize the migration of heavy logistics, commercial transit, and tribal infrastructure to the high, geologically secure glacial plain of East Sequim (in the vicinity of the Simdars Road / East Brownfield Road intersection and adjacent outermost foothill alignments). This placement rests on unyielding, rock-solid outwash that can safely support regional energy and transportation lifelines while balancing commercial opportunity on both sides of a resilient Highway 101 corridor.
5.Federalized Walkability & Environmental Safeguards: Demand that any relocated infrastructure loop—whether fueling facilities or a realigned U.S. 101—feature strict federal GMA walkability standards, a mandatory 75-foot managed meander flood-catchment corridor for Bell Creek and related drainages, and advanced commercial seasonal rainwater harvesting systems equipped with clean diversion loops to guarantee the project does not trigger seasonal drought emergencies or drop neighboring water tables.
Public safety, transit continuity, and the federal trust responsibility for tribal trust lands cannot be bartered away to protect corporate write-off economies or short-term convenience. Federal oversight is required immediately to correct this dangerous local planning failure and to place both critical fuel infrastructure and the primary regional highway on geologically stable ground.
John Worthington "shall" put this in the mail today.
RE: Cover Letter and Introduction to ESA Citizen Suit Notice of Intent (NOI)
TO:
• Secretary of the Interior, U.S. Department of the Interior
• Secretary of Commerce, U.S. Department of Commerce
• Assistant Administrator for Fisheries, National Marine Fisheries Service (NMFS)
FROM:
John Worthington
DATE: September 21, 2026
SUBJECT: Notice of Intent to Sue Under Section 11(g) of the Endangered Species Act (ESA) — Unlawful Habitat Modification and Failure to Consult on Critical Salmonid Spawning Gradients and One-Year Freshwater Rearing Habitats.
________________________________________
INTRODUCTION & SUMMARY OF THE COMPLAINT
This letter serves as an introductory cover letter and formal notification that [Your Name / Association] intends to file suit against the National Marine Fisheries Service (NMFS) and the U.S. Fish and Wildlife Service (USFWS) for severe, ongoing violations of Section 7 and Section 9 of the Endangered Species Act (ESA).
The core of this action addresses a fatal, unaddressed systemic oversight in regional river-mouth management: the deliberate, federally permitted encroachment of high-density commercial tribal infrastructure directly atop the geographically rare 3% to 4% stream spawning gradients and low-flow estuarine floodplains. This localized development directly destroys the irreplaceable habitats required for wild Puget Sound Chinook (King Salmon) and Coho (Silver Salmon) to successfully fulfill their mandatory one-year freshwater biological cycle.
The Biological Mandates: The 3–4% Grade and the One-Year River Residence
Unlike other salmonids that migrate to the ocean shortly after emerging from the gravel, wild King and Silver salmon are strictly dependent on freshwater systems for an extended duration. Juvenile Kings and Silvers must live, feed, and shelter in their natal rivers for a full, consecutive year before transitioning to the ocean. This one-year residency makes them uniquely vulnerable to river-mouth development. Their survival dictates two non-negotiable habitat requirements that only exist in the lower reaches of systems like the Elwha River and Jimmycomelately Creek:
1. Hydraulic Sorting and Spawning (The 3% to 4% Grade): Wild King and Silver salmon are biologically tethered to a precise hydraulic window found almost exclusively at channel slopes of 3% to 4%. This specific gradient creates the water velocity required to naturally rinse fine silts out of the channel bed, leaving behind the clean, porous gravel matrix necessary for spawning. At this grade, the natural pool-and-riffle sequence drives oxygen-rich surface water deep into the gravel bed (hyporheic flow), preventing the suffocation of embedded eggs.
2. Year-Round Nursery and Thermal Refuge (The Lower Floodplains): Because juvenile Kings and Silvers must survive all four seasons in the river, they require stable, slow-moving complex habitats to grow. They cannot survive a year in a single, fast-moving main channel. They rely entirely on low-gradient side channels, logjams, backwaters, and estuarine edge-habitats. These zones provide structural cover from winter floods, critical shade to keep water temperatures cool during summer peaks, and an abundant insect food supply.
If a river mouth is stripped of its complex floodplain, or if its 3% to 4% gradient transitions are choked by development, juvenile salmon have nowhere to hide. They are either washed prematurely into salt water—where their underdeveloped bodies cannot handle the salinity—or they suffocate and starve in stagnant, degraded pockets of water.
The Violations: Structural Encroachment on Nursery Grounds
Despite the absolute biological reliance on these localized, year-round habitats, the federal government has repeatedly permitted major structural layouts directly over or adjacent to these exact 3% to 4% zones and rearing floodplains. Under a hyper-complex, multi-layered governance loop, modern tribal economic enterprises have been granted a practical ecological pass to pave over, alter, and fragment these irreplaceable ecosystems:
• Jimmycomelately Creek / Sequim Bay Watershed: The continuous physical expansion of the Jamestown S’Klallam Tribe's 7 Cedars Casino and its corresponding north campus infrastructure has systematically encroached upon the lower floodplain and critical migratory-to-spawning gradient transitions of the Jimmycomelately system. Paving over these floodplains with massive impervious parking lots and commercial structures permanently destroys the off-channel rearing pockets where juvenile Silver and King salmon must live for their first year. Urban stormwater runoff and direct bank stabilization have fundamentally altered the local geomorphology, choking the nearby 3% to 4% gravel zones with toxic sediment and stripping the creek of the natural woody debris required for juvenile shelter.
• The Elwha River Mouth: While the historic removal of the Elwha River dams was celebrated as an open corridor for wild recovery, the federal government has permitted the Lower Elwha Klallam Tribe to maintain an intensive, high-density structural footprint—consisting of concrete hatchery infrastructure, residential subdivisions, and heavy riprap—directly at the primary river-to-estuary transition. This intense structural congestion interrupts the natural gravel transport and lateral river migration. By pinning the river mouth in place to protect infrastructure, the government has stopped the formation of the low-gradient side channels and estuarine marshes that wild, self-sustaining juvenile Kings and Silvers require to survive their critical first year of life.
Conclusion
Historically, early American pioneers and municipal developers in Port Angeles altered the landscape with sluice hoses to build a downtown out of silt—actions taken long before the codification of modern ecological science. Today, however, the federal government possesses the science but refuses to enforce it universally. By ignoring the heavy, high-traffic structural footprints of modern tribal commercial developments built squarely on top of the region's primary King and Silver salmon rearing and spawning habitats, NMFS and USFWS have failed their statutory duties under the ESA.
True recovery cannot be achieved by selectively auditing historic Western infrastructure while allowing active commercial resorts to pave over the precise 3% to 4% channel gradients and yearling nursery grounds that wild salmon need to survive.
WHO IN THE COMPREHENSIVE PLAN IS PART OF THE SHOULD VS SHALL? WHO SHOULD, WOULD AND COULD BENEFIT THE MOST? WHO IS THE REAL VOICE BEHIND LaTRISHA SUGGS? IS IT "him who we SHALL not name."?
Clallam County Marine Resource Committee LaTrisha Suggs, Chair.
or
CEO of the Jamestown S’Klallam Tribe, W. Ron Allen, Tribal Chair (who is on many state committees including federal committees)
https://tribalbusinessnews.com/sections/policy-and-law/15769-treasury-tribal-affairs-office-undergoes-leadership-change-as-founding-director-departs
(Picture is the back of Ron Allen’s head)
Treasury Tribal Advisory Committee
Chair W. Ron Allen, Tribal Chair and CEO of the Jamestown S’Klallam Tribe
(Secretary’s appointment)
This seven member Tribal advisory committee advises the Secretary on significant matters related to the taxation of Indians, the training of Internal Revenue Service field agents, and the provisions of training and technical assistance to Native American financial officers. The membership has three appointees nominated by the Secretary, two appointed by the House Committee on Ways and Means and two nominated by the Senate Committee on Finance.
https://home.treasury.gov/policy-issues/tribal-affairs/treasury-tribal-advisory-committee
Last meeting was September 11, 2026. Ironically, the meetings are held at U.S. Department of the Treasury Washington DC in the ‘CASH ROOM’.
Atlas Suggs is bad medicine. As I stated before in my 18 layer break down of the world governance system we have been living under the lower level actually tells the Commissioners what to do. Atlas Suggs has said so herself. She has also said we need to listen to Canada." Atlas Suggs hits the European Colonizer where it hurts. Somebody has to hit back in a similar way using the same environmental hammer that the world governing system does. My name is Crackpot Worthington and I am here all week.
SUBJECT: INTERACTION NOTICE: Imminent Threat and Substantial Endangerment Notification under RCRA Section 7003, Title 23 U.S.C. Highway Resilience Mandate, FEMA BRIC Policy Precedent, and Federal Trust Responsibility – Central Blyn Hazardous Fuel Storage Infrastructure and U.S. Highway 101 Corridor on Tribal Trust Land
I. JURISDICTIONAL STATEMENT & STATUTORY CITATION
This administrative filing serves as a formal public safety complaint and a multi-agency federal intervention request under Subtitle I of the Resource Conservation and Recovery Act (RCRA) (40 CFR Part 280), Title 23, United States Code (Highways), the Endangered Species Act (ESA) (16 U.S.C. § 1531 et seq.), and the federal trust responsibility owed to the Jamestown S’Klallam Tribe under the Department of the Interior and the Bureau of Indian Affairs.
Because the high-capacity Underground Storage Tank (UST) systems operating at the 7 Cedars Longhouse Market & Fueling Station are situated on sovereign tribal trust land within the low-lying Central Blyn basin floor, primary environmental regulatory enforcement over these hazardous containment units vests exclusively with the United States Environmental Protection Agency (EPA) Region 10. Concurrently, the United States Department of the Interior (DOI) and the Bureau of Indian Affairs (BIA) bear the federal trust responsibility for the protection of tribal trust lands and resources.
Local planning authorities—specifically the Clallam County Department of Community Development (DCD) and the Clallam Economic Development Council (EDC)—have formally disclaimed administrative and permitting jurisdiction over these infrastructural corridors. Consequently, this action bypasses local administrative remedies and places this critical hazard profile directly before federal environmental, tribal trust, transit safety, and hazard-mitigation authorities.
II. GEOLOGIC FACTUAL DETERMINATION: THE CENTRAL BLYN LIQUEFACTION LIABILITY
The target infrastructure is located entirely within a low-lying, saturated marine silt and alluvial deposition plain designated by the Washington State Department of Natural Resources and USGS as a High Liquefaction, Lateral Spreading, and Catastrophic Tsunami Inundation Hazard Zone.
Official Washington Geological Survey modeling (Map Series 2022-01, extended L1 Mw 9.0 Cascadia scenario) predicts approximately 5 feet of tsunami inundation at Blyn, with first-wave arrival approximately 90 minutes after the earthquake. Nearby areas show greater depths (approximately 10 feet at Dungeness and up to 33 feet at Discovery Bay).
The subterranean physical properties of the earth do not recognize municipal lines. In a major Cascadia Subduction Zone seismic event, the saturated sub-soil floor of the Central Blyn basin will experience absolute structural failure, instantly transforming the foundations beneath these high-volume fueling systems into un-bonded, flowing quicksand. Coseismic subsidence will further increase relative inundation depths before the tsunami arrives.
III. THE EXPLOSIVE VOLATILIZATION SEEN OVER FEDERAL LIFELINES (U.S. 101)
The structural placement of millions of gallons of highly volatile petroleum products trapped directly inside an active liquefaction and tsunami pathway represents an unmitigated threat to federal transit continuity and to tribal trust resources:
1.Shear and Rupture of Containment Cells: The shifting, liquefied earth will twist, shear, and crush the structural integrity of the Longhouse UST secondary and primary containment walls, releasing mass volumes of petroleum directly into the sub-surface water table.
2.Stormwater Pipe and Drainage Volatilization: Because the groundwater flows in direct hydraulic connection with surface networks, the leaked fuel will immediately track the path of least resistance. It will flood the public open ditches, stormwater pipes, and the adjacent Jimmycomelately Creek drainage basin—a critical salmonid habitat legally protected under the federal Endangered Species Act (ESA) and constituting a tribal trust resource.
3.The U.S. 101 Choke Point (“The Wall of Fire”): Once ignited, this subterranean and surface petroleum slick will transform the public stormwater infrastructure into an explosive delivery system. A single ignition point will generate an unrestricted, uncontrollable wall of fire burning directly across and over U.S. Highway 101. This will physically consume the pavement, explode vehicles, and permanently sever the single landward emergency evacuation route and logistical supply line for the entire North Olympic Peninsula.
IV. MANDATED FEDERAL RELIEF REQUESTED
To ensure regional transportation resilience, protect hydraulically connected salmon-bearing critical areas, and fulfill the federal trust responsibility for tribal trust lands and resources, the following actions are demanded of the federal agencies:
1.EPA Region 10 Subtitle I Audit: Order an immediate, emergency federal inspection of the Central Blyn UST arrays under RCRA Section 7003 to determine if the current
seismic and tsunami mitigation failsafes meet strict federal environmental safety standards for a catastrophic liquefaction zone.
2.DOI / BIA Trust Responsibility Review: Require the Department of the Interior and the Bureau of Indian Affairs to evaluate the placement of high-capacity hazardous fuel storage on tribal trust land within a documented high liquefaction and tsunami inundation zone, and to exercise their trust responsibility to protect tribal trust resources from catastrophic failure and downstream environmental harm.
3.FHWA / WSDOT Long-Term Corridor Resilience Evaluation and Conditioning of Title 23 Funding: Instruct the Federal Highway Administration and the Washington State Department of Transportation to formally evaluate the permanent relocation of U.S. Highway 101 out of the low-lying liquefaction and tsunami inundation corridor of Central Blyn and onto more geologically stable outermost foothill and glacial-outwash locations east of Sequim.
Such relocation is necessary to eliminate the single-point-of-failure risk that a Cascadia Subduction Zone event will sever the sole landward emergency evacuation and logistical supply route for the entire North Olympic Peninsula. Because the current alignment crosses documented high-liquefaction soils and areas of modeled tsunami inundation, any long-term solution that keeps the highway on the basin floor is inherently non-resilient.
Condition all future Title 23 federal highway funding for the U.S. 101 corridor on the completion of this evaluation and on a concrete plan to shift the highway to stable high ground. Recognize that such a realignment would necessitate coordinated tribal relocation planning for affected Jamestown S’Klallam trust lands and facilities currently located in the hazard zone; this planning must be conducted in full partnership with the Tribe under the federal trust responsibility and must include fair compensation, replacement of critical infrastructure, and protection of treaty resources.
4.FEMA BRIC Hazard Mitigation Funding Activation: Formally classify both (a) the relocation of high-capacity fueling centers out of the Central Blyn basin floor and (b) the long-term realignment of U.S. 101 onto stable foothill terrain as critical pre-disaster projects. The federal government must incentivize the migration of heavy logistics, commercial transit, and tribal infrastructure to the high, geologically secure glacial plain of East Sequim (in the vicinity of the Simdars Road / East Brownfield Road intersection and adjacent outermost foothill alignments). This placement rests on unyielding, rock-solid outwash that can safely support regional energy and transportation lifelines while balancing commercial opportunity on both sides of a resilient Highway 101 corridor.
5.Federalized Walkability & Environmental Safeguards: Demand that any relocated infrastructure loop—whether fueling facilities or a realigned U.S. 101—feature strict federal GMA walkability standards, a mandatory 75-foot managed meander flood-catchment corridor for Bell Creek and related drainages, and advanced commercial seasonal rainwater harvesting systems equipped with clean diversion loops to guarantee the project does not trigger seasonal drought emergencies or drop neighboring water tables.
Public safety, transit continuity, and the federal trust responsibility for tribal trust lands cannot be bartered away to protect corporate write-off economies or short-term convenience. Federal oversight is required immediately to correct this dangerous local planning failure and to place both critical fuel infrastructure and the primary regional highway on geologically stable ground.
Respectfully Submitted,
John Worthington