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aSC "pFs... lO n.L,',l k ITrrrlkS MIT I 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