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HomeMy WebLinkAboutWWP272163 (2)MAR-01-1994 14:13 FROM DROWN g CALDWELL SEATTLE TO 902352541 P.001i001 MeiaoraanduM. -ADOLFSO . To: Mike O'Ne9l, Brown and Caldwell ASSQCIATES: •IiY�. ; From,: Gail Roberp . ON Dater 03/01/9* , : Subject: Corps of Engineers permitting for.Honey Creek/May Valley project I spokewith lack- Gossett. at the Regulatory Branch of the Corps of tiVoeers'regarding.the permitting issaea fbi the:Honey Creek/May Valley project, .,although the Corps does not like to cots niit.themseWes to deterininations prior to receiving perrttit applu;atiops; he did confirm4he folio' !considerations:' Ordinarily, utility'piojefiss; such as sewer pipelines, which have minor impacts on Wetlands and other.:aquatic rtsourG%. cart be permitted under the Nationwide Permit Nd, 12'.' 71nlity Vne.Bacl4ill and Bedding. ' In the can of the Honey Creek/May,- aWicy projecf, , howur cr, the wetlands impacted.by.'the proposed gravity line alternatives would be considered by,the Corps as adjacent to Sidney and May Creeks: This adjacency. detrsminadon, coupled with 'the fact that`wdtlands'i#Acts would not be insignificant for the project, •means'' the gravity litres . wvukt ha�'e 'to be permitted under an Individual P6d&t' . and would bave 'to demonst ate'zornp*ce; with' -the Clean. Water Act Section 404(b)(1).'Guidelines (Guidelines). Fgi'a,project that is not "water dependent", i.e.; does not iequirq proximity to water to be viable . (a marina), these Guidelines require an alternatives: analysis to ' . demonstrate that the alternative is the only feasible alternative and.that no other less emvkonm0rttalty dapmaging practicable alternatives exist: 'The �SPA'has dellned practicable ,2s "available and capable of being done after taking into consideration ' cost, . existing teehnology, and logl9tics in light of the overall project purposes.": Since the alto hat ves analysis for the project would have to mentidd the fo;. main alternatives, I believe the Corps would consider them "practicable",'and would-dedy the perittit for the gravity lines on those grounds. This belief has also been confirmed by Mr. Gossett." The -denial could be *"elevated" to an authority higher than the local Regulatory Branch, such as the Regional Branch and/or the EPA, but this would take sortie dine, effort, and money, and I,da not believe it would be productive in the long term. If you hive: any questions about this memo, please give me a call. Post-V brand fax transmittal memo 7671 Aorpages ► l To avVif mse from ry Co. Co. Dept- Phone p Fax N 23 _ZL� Fax Envlro:snse�ttal 1in�l�%r; 6��49„Siridskals Ala. NW, 'Seattle, WA 9814T :one. fZ061t'ascaiol raxsoa� TWA. TOTAL P.01 MUCKLESHOOT INDIAN TRIBE FISHERIES DF>j?- T1 WNT?� SEP 9 -1994 7 September 1994 Mr. David Christensen CITY OF RENTON City of Renton Wastewater Utility Engineering Dept. Planning/Building/Public Works Department City of Renton Renton, Washington 98055 RE: HONEY CREEK (WRIA 08.0285) SUBBASIN/MAY VALLEY INTERCEPTOR PROTECT (METRO AND THE CITY OF RENTON) Ref: Muckleshoot Fisheries letter of 13 December 1993 Dear Mr. Christensen The Environmental Division of the Muckleshoot Indian Tribe has continued its review of the subject proposal. In the letter and at the inter -agency site visit, the Tribal Environmental Division stated that the force main alternative would have the least potential for direct adverse impacts upon aquatic resources, while the gravity sewer would have the potential for adverse impacts. After further consideration of the proposal, we have become more convinced that the proposed gravity sewer alternative will have significant adverse impacts upon aquatic resources and salmonids, impacts that cannot be mitigated. The proposed route for the gravity sewer is at the base of a hill. Despite the use of best management practices, the loose nature of the slope material will result in erosion and sedimentation into Honey Creek, both during and following construction. In addition, the slopes to be traversed or paralleled by the gravity line contain numerous seeps. The existing informal trail at the base of the hill already serves to impede shallow groundwater flow along the hill gradient. This impairment manifests itself through groundwater upwelling on the uphill side of the trail. The compaction and depth of disturbance caused by the sewer placement will result in increased groundwater blockage and upwelling on the uphill side. This will increase surface runoff, erosion and sloughing. Evidence of small hill side collapses are frequent, with such collapses depositing material into the stream channel. This deposition harms aquatic habitat as well as impairs salmonid spawning and rearing. Furthermore, placing the proposed gravity sewer into Honey Creek would be the first phase of a gravity sewer into May Creek (WRIA 08.0282). Similar problems, as specified in this letter, would then occur in May Creek, a major salmonid producer. 39015 172nd Avenue S.E. 9 Auburn, Washington 98002 • (206) 931-0652 9 FAX (206) 931-0752 The gravity alternative should be dropped and the force main alternative adopted. The problems of sewers running near or across streams have been amply demonstrated, with Madson Creek (WRIA 08.0305) the most notable example. The constant maintenance work in Madson Creek has had considerable impact upon salmonid habitat. Honey and May Creeks should be spared such avoidable insults. I thank you for your attention to our concerns. If you have any questions regarding this letter call me at 931-0652. Sincerely, 4J7�" vee-� Roderick Malcom Habitat Biologist cc: WDFW / Larry Fisher Brown and Caldwell / Mr. Michael O'Neal METRO April 28, 1994 Ron Post SAY 2 1994 Water Quality Communication Metro CIn OF RENTON 821 2nd Ave Engineering Dept. M.S. 95 Seattle, WA 98104 RE: Plans for improved sewage service to the Honey Creek Subbasin Dear Ron, On April 5, 1994 I attended a public meeting on two proposed alternatives for providing additional sewer capacity for the City of Renton. I have some concerns I would like addressed. The Newcastle Community plan states" local sewer areas represent the maximum area which could potentially be sewered consistent with local land use plans and policies." A sewer interceptor in May Valley, could bring pressure to bear to extend the present Local Sewer Area into unsewered areas which is contrary to the Newcastle Community Plan. Policy N-56 of the Newcastle Community Plan states" when an existing or potential health hazard develops outside a sewer service area, and a boundary adjustment of other local service area amendment if requested, the applicant must demonstrate that other wastewater disposal alternatives are not financially or technically feasible." The proposed alternative of a forced main has been shown by the City of Renton's consultants to be financially feasible without the major environmental constraints of the gravity fed alternative. Therefore, why per Mike O'Neil, engineer with the City of Renton's consultants, is the "sense of urgency of Renton driving the plan", rather than the Newcastle Community Plan and other Washington State policies and laws? There are serious environmental issues with the gravity fed (alternative #1) to place a sewer interceptor down May Creek. Gail Roberge, sub -consultant for the City of Renton discussed these concerns: 1. Wetlands- Wetlands and their impact to the May Creek flood plain. Ms. Roberge stated placing a sewer "line through a wetland may change it's hydrology and may even take it out of existence." May Valley already has significant flooding and needs the cumulative effect of all the wetlands in order not to exacerbate the present flooding. Ms. Roberge cited a concern of King County Surface Water Management, you "won't solve flooding in May Valley by putting a sewer interceptor down the creek." 2. Fish & Wildlife- Per Ms. Roberge, alternative #1 utilizes "2-3 stream crossings." "In Honey Creek, cutthroat and coho salmon are present according to (Washington State) Fisheries. In May Creek, coho, sockeye, cutthroat, chinook, and steelhead are present." The location where "Honey Creek flows into May Creek, SWM has identified as a locally significant resource area in terms of habitat for plants & animals." "As a wildlife priority habitat", this corridor should be preserved not adversely impacted by a sewer interceptor. 3. Geotechnic-"There are concerns for serious sliding and slumping hazards. De -stabilizing slopes causes sloughing which leads to erosion which in turn causes siltation which adversely effects salmon spawning." Another concern I would like addressed is that of surface water management within the May Creek Basin. The May Creek Basin is designated a Critical Drainage Basin by King County Surface Water Management. Being a Critical Basin, higher standards are required to be used in terms of surface water management. The extreme environmental sensitivity of the May Creek Basin demands that highly stringent requirements be used which reflect the most recent knowledge and technology in the surface water management field. Allowing a sewer interceptor into this area and the subsequent urbanization which would follow, would not encourage the highly stringent requirements needed, as evidenced by the example of the Summerwind development in Renton. This specific area needs careful consideration to protect resources and reduce the significant problems of flooding, erosion, and degradation of May Creek. The natural controls of this area are maxed out, and I am not convinced the technology exists to be able to duplicate the natural controls of surface water. Per Ms. Roberge,the "old fashioned notion of putting a sewer down a creek is a tough balancing act." Per Ms. Roberge, enhancing the environment as governed by Washington State laws is not financially feasible with the gravity fed alternative. You "can't guarantee the environment will be enhanced." Why is the gravity fed alternative with tremendous environmental constraints, being further pursued if there are possible and feasible options(forced main alternative)? I look forward to your reply. Sincerely vr- �.L J n Rollins /`(3,,J Aug fC- 12", wh+ 1�j 0.5 IT 1084 Kirkland Ave. NE Renton, WA. 98056 April 22nd, 1994 Ron Post Communications Environmental Programs METRO 821 Second Ave. M.S. 95 Seattle, WA 98104-1598 RE: Honey Creek -May Creek Sewer Interceptor Dear Mr. Post: CITY OF RENTON Engineering Dept. Thank you for facilitating the informational meeting regarding potential plans to improve sewer service to the City of Renton's Honey Creek sub - basin. We were extremely pleased to see the enlightened outlook that METRO and the City of Renton now have compared to a few years ago. It was refreshing to sense the concern for environmentally sensitive May Creek. On the other hand it was disturbing to listen to several candidates for council positions with the new city of Newport Hills (some now elected, some not). Several of them, speaking unofficially of course, seemed to be in support of building a sewer interceptor in May Creek. I trust that as they become more familiar with environmental issues, state law and the Newcastle Community Plan that they will realize their off hand comments do not represent the will of the community at large nor the position of the new city's full council. From a strict engineering stand point running a gravity sewer interceptor down a basin's primary natural drainage course makes perfect sense both physically and probably economically. However from an environmental sense we have now learned that it is sheer folly. Sewer interceptors, their necessary service roads, and creeks just do not mix; especially, one as fragile as May Creek. As was acknowledged in the meeting the "track record for such projects is poor." Every one is asking, where have all the salmon gone? The economical as well as the environmental loss is beginning to be felt all over Western Washington. The stretch of May Creek that the proposed gravity sewer interceptor and service road would be in is one of the most valuable and beautiful stretches of May Creek. The not yet released preliminary draft May Creek Basin Plan states that "the best stream habitat in the system exists in the lower four miles of May Creek" (page 9-1 Aquatic Habitat May Creek Basin -DRAFT). This is reason enough to seriously consider the alternative forced main proposal. Other reasons to support the forced main alternative are: 1. That an area within the City of Renton will then be able to get sewer service thus more fully using Renton's funding within its own city limits and providing a further source of on going utility revenue. 2. The Newcastle Plan does not permit bringing sewer service into areas not already sewered or within a sewer local service area. Further, "boundary adjustments and other amendments to the sewer local service area are not anticipated during the life of the Newcastle Plan." (page 85) 3. King County Resolution No. 6146 which authorizes a Memorandum of ' Agreement with the City of Renton for implementation of the Phase III. enlargement of the treatment plant in the City of Renton was passed June 6, 1991. Section 5.3 outlines conditions of the May Valley Interceptor, Phase I. Subsection 5.3.2 specifically states that any proposed interceptor be subject to land use plan certifications pursuant to Resolution No. 2933" which would include the Newcastle land use plan. 4. Much of the May Creek Basin east of 148th Ave SE is outside the King County Growth Management Planning Council's designated urban area and therefore is not eligible to receive urban sewer services. 5. Interceptor alignment problems necessitate that the route would pass through several large wetlands and there would be 2 or 3 stream crossings, possibly resulting in severe unavoidable permanent damage. In summary the lower reaches of May Creek are a beautiful natural resource. This fact has been recognized in that both the county and the City of Renton have set aside much of the area as park land for all citizens to enjoy. It is not just to spoil such an amenity with a sewer interceptor project no matter what precautions are taken. The area is a narrow and geotechnically unstable, any service road and sewer line cuts could result in mud slides and possibly a catastrophic failure. we ask that METRO and the City of Renton support the forced main alternative even if the short term cost is greater. Thank you. Sincerely, A. Duffus cc: Dave Christenson mc9ever042294m9wH DEC-16-1993 16:04 FROM BROWN S CALDWELL SEATTLE TO 902352541 P.001i002 - - /aYAVA /y3 l a 0 �yslhn9 , v STATE OF WASHINGTON DEPARTMENT OF FISHERIES Post Office Box 43135 • Olympia, Washington 98504-3135 • (206) 902-2200 • SCAN 902-2200 • TDD 902-2207 December 9, 1993 Michael O'Neal Brown and Caldwell Consultants 100 West Harrison Street Seattle, Washington 98119-4186 Rost -It' brand fax transmittal memo 7671 1# of pages ► 2— To Qi✓ �` F rom AI o?4 i Co. Co. Dept. Phone p Fax Faz# SUBJECT: Preliminary Review - Honey Creek Subbasin/May Valley Interceptor Project - Honey Creek, Tributary to May Creek, WRIA 08.0285 and May Creek, Tributary to Lake Washington, WRIA 08.0282, King County Dear Mr. O'Neal: The Washington Department of Fisheries (WDF) understands that the Municipality of Metropolitan Seattle and the City of Renton Sewer Utility are considering further construction of sewer lines within the bed, banks, and associated wetlands of Honey and May Creeks. We wish to express our concerns with the concept early in the review process. Honey Creek is an important salmonid producing stream which contributes to the fish production of the Lake Washington system. Species use includes sockeye and coho salmon and steelhead and cutthroat trout. May Creek supports these species and also chinook salmon. There have been many problems associated with the current sewer pipeline which exists. in Honey Creek. These problems have contributed to the decline of fish productivity and use in the creek.. WDF has information indicating that the sewer line construction is directly responsible for the loss of fish life in Honey Creek. Lake Washington small tributaries, as a category, are now under consideration by fisheries professionals for listing under the Endangered Species Act. Honey Creek needs restoration of the damage which has been caused by the existing sewer facilities, including removal of the culvert which impairs upstream fish migration, not extensions of the lines further down the creek. This culvert was apparently constructed in violation of RCW 75.20.060 and RCW 75.20.100 and has resulted in the elimination of upstream access by anadromous fish. 1I DEC-16-1993 16:04 FROM DROWN & CALDWELL SEATTLE TO 902352541 P.002i002 Michael Page 2 December O'Neal 9, 1993 We should all have learned by now that sewer lines lead 'to serious problems in creeks and wetlands such as this and that appropriate, less damaging, alternatives. must be utilized. It is inconsistent with the Growth Management Act to pursue construction of gravity sewers in these critical habitat areas. WDF cannot fulfill its legislative mandate to protect fish life or its policy of no net habitat loss by approving any of the gravity sewer alternatives. We would be obligated to consider denial of a Hydraulic Project Application for construction of further gravity sewer lines in stream corridors and associated wetlands in order to properly protect fish life. If you have any questions or need additional information, please contact Larry Fisher, WDF Regional Habitat Manager, at (206) 392- 9159. We appreciate your cooperation in our efforts to protect, perpetuate., and manage the fish resources of the state of Washington. Sincerely, Millard S. Deusen Regional Supervisor, Freshwater Permits Habitat Management Division