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March 21. 2016
HZTTZTAB COUNTY
DEPARTMENT OF PUBLIC WORKS
Mark R. Cook, PE Director
Mr. Chris Horner, DPA
Kittitas County Prosecuting Attorney Office
Ellensburg, WA 98926
Dear Mr. Horner:
Kittitas County Public Works is in receipt of claim number 201603040039, date stamped
03/04/20106. In response, our maintenance supervisor and road crew foreman conducted a
physical test of Truck No. 190 with its sander attached to measure actual sand throw radius from
the back of the truck (attached as EXHIBIT 1). I asked the throw be evaluated at the top end of
the operating range (speed rate 8 and speed rate 9). The associated throw radius of each
speed rate is 47 feet at 8 and 57 feet at 9. Our maintenance staff estimate the maximum impact
distance behind the sanding truck as being four full size trucks (four -door with long box).
Our Lower County Shop Road Foreman confirms Truck No. 190 was engaged in sanding
operations the morning of 12-16-2016 (time card confirmation). We were responding to ice
conditions resulting from precipitation the night before. The claimant contends the pavement
was bare and dry. We do not apply sand during bare and dry pavement conditions. We also do
not operate our snowplowing or sanding operations without activating all warning lights on our
trucks. The claimant asserts that our sander was traveling at approximately 30-35 MPH. We
generally operate sanding operations in the range of 25 — 35 MPH. It is common for our
operators to hug the centerline when deploying sand for maximum coverage in the opposing
lane. The claimant contends that he was about 100 —125 feet behind the sander when the
operator began deploying sand. This distance is at far end of the sanders deployment range.
The claimant also contends that our operator "...all but tried to run me off the road." During sand
deployment, it is difficult for our operators to see traffic behind them. If someone is engaged in a
passing maneuver during sand deployment, it is highly likely that our operator would not see the
vehicle until it emerged from the sand along -side our truck.
The damage is consistent with sustained exposure to flying sand. It is inconsistent with the
distance stated at 100 —125 feet behind the sander. It is also so odd to see this claim so long
after the stated event date of 12-16-2016.
In closing, we affirm that we were engaged in sanding operation along Kilmore Road at
approximately 8:30 AM on the morning of 12-16-2016. The stated damage is consistent with
prolonged exposure to flying sand in close proximity of our sander.
Sincerely,
Mark R. Cook
Director/Interim County Engineer
411 N. Ruby St, Suite #1 TEL (509) 962-7523
Ellensburg, WA 98926 FAX (509) 962-7663
Dept. of Public Works
Page 2
EXHIBIT 1: MEASURED SAND THROW FROM TRUCK NO. 190
411 N. Ruby St, Suite #1 TEL (509) 962-7523
Ellensburg, WA 98926 FAX (509) 962-7663