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HomeMy WebLinkAboutThunder Hills Memo #8 FINAL 102115 CITY OF RENTON Technical Memorandum No. 8 Alternative 1 Summary of Sensitive Area Impacts Thunder Hills Sanitary Sewer Interceptor Alternative Analysis October 21, 2015 Prepared By: Hugh Mortensen , Sarah Sandstrom, and Katy Crandall 750 6th Street South Kirkland, WA 98033 425-822-5242 The Watershed Company Project No. 131113 Contents 1.0 INTRODUCTION ......................................................................................................................1 2.0 SENSITIVE AREAS ....................................................................................................................1 2.1 WETLANDS .................................................................................................................................... 1 2.2 STREAMS ....................................................................................................................................... 1 2.3 OTHER CRITICAL AREAS ................................................................................................................. 2 3.0 POTENTIAL IMPACTS ...............................................................................................................2 3.1 AVOIDANCE AND MINIMIZATION MEASURES .............................................................................. 4 3.2 ENDANGERED SPECIES AND HABITAT ........................................................................................... 5 3.3 IMPLICATIONS OF IMPACTS TO BUFFERS ..................................................................................... 5 3.4 IMPLICATIONS OF DIRECT IMPACTS TO STREAMS ........................................................................ 6 3.5 IMPLICATIONS OF DIRECT IMPACTS TO WETLANDS ..................................................................... 7 ALTERNATIVE NO. 1 Thunder Hills Sanitary Sewer Interceptor Summary of Sensitive Area Impacts The Watershed Company October 21, 2015 1 1.0 INTRODUCTION The City of Renton seeks to repair and relocate the Thunder Hills Sanitary Sewer Interceptor and reestablish maintenance access. The purpose of this memorandum is to document anticipated impacts to wetlands, streams, and habitats and related implications for design and permitting. A separate memorandum, Technical Memorandum No. 9, prepared by Stantec, discusses the permit needs and required permit application materials. The findings discussed in this memorandum are based on the attached plans, dated August 21, 2015. The findings of this report are subject to verification and agreement by the appropriate local, state and federal regulatory authorities. 2.0 SENSITIVE AREAS Wetlands and streams within the project study area were delineated and preliminarily documented in a delineation memorandum dated May 12, 2014. That memorandum identified Thunder Hills Creek, seven tributary streams, and six wetlands in the study area. In 2015, after the delineation memo was completed, the City of Renton updated its critical areas regulations, resulting in changes to stream classifications and wetland and stream buffers. Updated information relating to stream and wetland classification and applicable standard buffer widths are presented below. 2.1 WETLANDS The delineation memorandum initially rated wetlands using the Washington State Department of Ecology’s (Ecology) Western Washington Wetland Rating System (2004), which was in effect at the time and accepted by local, state and federal permitting agencies. Ecology’s rating system was updated in 2014 and all wetlands were re-rated to be consistent with local, state and federal requirements (2014 forms and figures attached). Updated wetland classifications, based on the 2014 rating system, and buffers based on the City of Renton’s updated critical area regulations are reported in Table 1. 2.2 STREAMS For the preparation of this memorandum, additional investigation of stream typing incorporated information from the Forest Practices Application Mapping Tool (FPAMT) (https://fortress.wa.gov/dnr/protectiongis/fpamt/index.html), Salmonscape (http://apps.wdfw.wa.gov/salmonscape/map.html), and the City of Renton Maps Application (http://rp.rentonwa.gov/SilverlightPublic/Viewer.html?Viewer=COR-Maps). The stream typing reported in the May 12, 2014 memorandum is generally consistent with the findings from the review of mapping, except that the city’s stream classification system has changed from Class 1-5 to Class S, F, Ns, and Np, consistent with the Washington Department of Natural Resources (WDNR) permanent stream typing criteria. Thunder Hills Creek was previously described as a Class 3, non- salmonid bearing, perennial stream. The FPAMT and the City of Renton Maps identify Thunder Hills Creek as a Type N non-fish bearing stream. Salmonscape identifies the piped section of stream under Interstate 405 as a total fish passage barrier. Whereas the City of Renton Maps classify Thunder Hills TECHNICAL MEMORANDUM NO. 8 ALTERNATIVE NO. 1 Thunder Hills Sanitary Sewer Interceptor Summary of Sensitive Area Impacts The Watershed Company October 21, 2015 Creek as perennial, Salmonscape identifies the upper two-thirds of the project area as seasonal. Downstream from Interstate 405, the City of Renton Maps and field observations indicate that Thunder Hills Creek meets Rolling Hills Creek, which runs southwest through an open channel for approximately 1,000 feet before being piped through the stormwater infrastructure under the Renton Village Shopping Center. Eventually, Rolling Hills Creek drains into the Black River and from there into the Duwamish River. Based on the limited watershed area upstream of the project area, and the total fish passage barriers downstream of the project area, the Type N classification for Thunder Hills Creek within the project area is warranted. Based on field observations, Thunder Hills Creek is assumed to be perennial in years of normal rainfall within the project area. Stream C and Stream H were delineated in the field; however, these streams were not located by the survey. These streams are on the opposite bank of Thunder Hills Creek from the proposed sewer work; therefore, they do not affect the conclusion of this memorandum. Nevertheless, in the interest of complete documentation the general location of these streams should be noted in project plans and permit application documents. 2.3 OTHER CRITICAL AREAS In addition to wetlands and streams, the project is located at the base of a ravine, and is mapped by the City of Renton as a high severity erosion hazard area and a moderate severity landslide hazard area. Geologically hazardous area standards will apply; a geotechnical report, and potentially an independent review, will be required. Independent review can be administratively waived by the City Administrator. No priority habitats or species have been mapped or field identified within the project area, therefore, additional local standards for habitat conservation areas are not expected to apply. Floodplains are also not mapped within the project area. 3.0 POTENTIAL IMPACTS Potential permanent impacts to sensitive areas, including wetlands and streams have been generally summarized in Table 1, and are based upon the attached project plans (Sewer Plan and Profile Alternative No. 1) provided by Stantec and dated August 21, 2015 and a site visit meeting on July 2, 2015. The full extent of all temporary impacts, including construction entrances, staging areas, and other temporary clearing areas have not been fully documented. For the purposes of this memorandum, it is assumed that all temporary impacts will be limited to buffer areas and appropriately mitigated following project completion. According to the preliminary site plans, the project will impact the buffers of all wetland and stream critical areas identified in the study area. Additionally, direct impacts will occur to portions of Thunder Hills Creek, Stream G, and Wetlands E and F. Stream F could also be modified if Stream G is rerouted. ALTERNATIVE NO. 1 Thunder Hills Sanitary Sewer Interceptor Summary of Sensitive Area Impacts The Watershed Company October 21, 2015 3 Table 1. Classifications of streams and wetlands along Thunder Hills Creek, per Renton Municipal Code, and projected impacts to each feature and its associated buffer. Critical Area Renton Municipal Code Classification (2014 Ecology rating – wetlands only) Standard Buffer Width (ft) Direct Impact to Feature Impact to Buffer Thunder Hills Creek Class Np 75 Possible direct impact from culvert work associated with Stream G drainage Entire project within buffer Stream B Class Ns 50 None Gravel road in buffer Stream C Class Ns 50 Stream D Class Ns 50 Stream E Class Ns 50 None Gravel road, gravity wall or rockery, and parallel sewer in buffer Stream F Class Ns 50 Possible modifications to banks if Stream G is rerouted Stream G Class Ns 50 Repair/replace culvert or reroute stream; Cut into portion of stream Gravel road, slope cut, and gravity wall or rockery in buffer Stream H Class Ns 50 None Gravel road and parallel sewer in buffer Wetland A Category 3, Low Habitat Function (4 points) 75 None Gravel road and gravity wall or rockery in buffer Wetland B Category 3, Moderate Habitat Function (6 points) 100 None Gravel road, parallel sewer, slope cut, and gravity wall or rockery in buffer Wetland C Category 4, Moderate Habitat Function (5 points) 50 None Gravel road, paved road, and parallel sewer in buffer TECHNICAL MEMORANDUM NO. 8 ALTERNATIVE NO. 1 Thunder Hills Sanitary Sewer Interceptor Summary of Sensitive Area Impacts The Watershed Company October 21, 2015 Critical Area Renton Municipal Code Classification (2014 Ecology rating – wetlands only) Standard Buffer Width (ft) Direct Impact to Feature Impact to Buffer Wetland D Category 3, Moderate Habitat Function (5 points) 100 None Gravel road, parallel sewer, slope cut, and gravity wall or rockery in buffer Wetland E Category 3, Moderate Habitat Function (5 points) 100 Small portion of gravel road in wetland Gravel road in buffer Wetland F Category 3, Moderate Habitat Function (5 points) 100 Gravel road through wetland Gravel road and parallel sewer in buffer 3.1 AVOIDANCE AND MINIMIZATION MEASURES Permit applications will need to document unavoidable critical area impacts. This includes temporary construction-related impacts, as well as permanent impacts from the project. As part of that documentation, all available avoidance and minimization measures must be discussed and addressed. Examples of proposed avoidance measures currently planned for this project include: • Using existing access points to avoid the need for new stream crossings. • Using a slip-line approach to repair the existing sewer line where it crosses Thunder Hills Creek. Examples of proposed minimization measures include: • Relocating the sewer line under the access road to minimize the footprint of construction and maintenance impacts. • Locating the proposed road over the existing unmaintained trail to minimize impacts to vegetation in the buffer. • Locating the road as far from the stream as possible, given topographic constraints. • Using a narrower width path (7 feet compared to 12-foot road) for specialized equipment on the northern portion of the project area. ALTERNATIVE NO. 1 Thunder Hills Sanitary Sewer Interceptor Summary of Sensitive Area Impacts The Watershed Company October 21, 2015 5 • Implementation of a Temporary Erosion and Sediment Control plan. • Timing construction to avoid the wet season when sedimentation and erosion would be anticipated. A mitigation plan will also be necessary to demonstrate that all unavoidable impacts to functions and values will be appropriately compensated or replaced consistent with local, state, and federal guidance. 3.2 ENDANGERED SPECIES AND HABITAT A review of online mapping resources and site visit observations indicate that no federally threatened or endangered species are located in the project area. The project area is in an urban environment, where available upland habitat is limited to isolated patches of forests that experience regular disturbance. Listed birds, mammals, and amphibians are not likely to occur in the vicinity of the project area because they are generally restricted to less developed areas with large areas of contiguous habitat. Similarly, as discussed above, Thunder Hills Creek does not support listed salmonid fish, and the nearest salmon- bearing stream is the Black River, 1.8 miles downstream of the project extent. Because the project area is well-removed from the likely occurrence of a federally listed species, a biological evaluation will not likely be required, but a no-effect letter is recommended to describe the project area relative to the location of listed species. The no-effect letter would be submitted as an attachment to the JARPA when applying for federal permits. This letter provides the Corps with necessary documentation to evaluate and confirm that their consultation with National Marine Fisheries Service and U.S. Fish and Wildlife Service is not necessary. 3.3 IMPLICATIONS OF IMPACTS TO BUFFERS As described above and in Table 1, the entire project would be located within stream and wetland buffers designated by the City of Renton. Renton Municipal Code (RMC) 4-3-050.C.3 exempts repair and replacement of existing utilities within an existing improved public road right-of-way or easement from critical area standards. Based on the plans, we assume that the proposed project would not qualify for this exemption, as it would extend beyond the existing improved area and include instream work. Renton Municipal Code (RMC) 4.3-050.J.2.b. also provides criteria for administrative approval of new utilities in streams, lakes, and buffers with an approved critical area study, provided: i. Fish and wildlife habitat areas are avoided to the maximum extent possible; and ii. The utility is designed consistent with one or more of the following methods: (a) Installation shall be accomplished by boring beneath the scour depth and hyporheic zone of the water body and channel migration zone; or (b) The utilities shall cross at an angle greater than sixty (60) degrees to the centerline of the channel in streams or perpendicular to the channel centerline; or (c) Crossings shall be contained within the footprint of an existing road or utility crossing; and TECHNICAL MEMORANDUM NO. 8 ALTERNATIVE NO. 1 Thunder Hills Sanitary Sewer Interceptor Summary of Sensitive Area Impacts The Watershed Company October 21, 2015 iii. New utility routes avoid paralleling the stream or following a down-valley course near the channel; and iv. The utility installation shall not increase or decrease the natural rate of shore migration or channel migration; and v. Seasonal work windows are determined and made a condition of approval; and vi. Mitigation criteria are met. Although the above standards are intended for new utilities, replacement of an existing utility line is expected to qualify for the same administrative approval process. The City of Renton allows for buffer averaging or reduction, provided that the selected approach meets the city’s minimum width standards and maintains or improves ecological functions. Since the entire project falls within the buffer of Thunder Creek (as well as numerous additional, overlapping wetland and stream buffers) and since the project area is mainly on private property, there is likely no opportunity for buffer expansion under an averaging plan. Therefore, buffer impacts are best mitigated through enhancement of existing buffers (removing weeds, planting native plants, monitoring and maintaining vegetation until established). There is ample opportunity for such enhancement throughout much of the project site. The specific approach to buffer enhancement will need to be discussed as a part of the critical areas report. 3.4 IMPLICATIONS OF DIRECT IMPACTS TO STREAMS Direct impacts are those that alter the physical stream bed or banks. Such impacts would require approval by the City of Renton, WDFW, and the Corps. The applicant should anticipate that WDFW will require that any stream culverts modified as a part of the project to be appropriately sized to accommodate transport of high flows (100-year event) and debris. There is additional potential that WDFW will require that all culverts within the project area are updated to pass high flows. Fish passage standards should not apply given the permanent status of the complete fish passage barrier downstream (under Interstate 405). There is the potential that a short segment of Stream G will be relocated as part of the proposed plan since it appears Stream G and Stream F were joined at some time the in recent past. RMC 4-3-050.J.2.e. allows administrative approval for stream relocation for expansion of public road or other public facility improvements where no feasible alternative exists, provided the following: (a) Buffer widths shall be based upon the new stream location. (b) The provided buffer between the facility and the relocated stream shall be enhanced or improved to provide appropriate functions given the class and condition of the stream. ALTERNATIVE NO. 1 Thunder Hills Sanitary Sewer Interceptor Summary of Sensitive Area Impacts The Watershed Company October 21, 2015 7 (c) Applicable mitigation criteria must be met. (d) Proper notification to the City must be made. As noted above, the project area does not include fish-bearing streams, and the downstream barrier under Interstate 405 is very unlikely to be corrected. Nevertheless, it should be noted that the project area is within the designated as Usual and Accustomed (U&A) fishing grounds of the Muckleshoot Tribe. As such, the Muckleshoot Tribe may review and comment on permits through the public review period. The Corps heavily weighs comments and recommendations from the tribes, particularly as they relate to stream habitat and fish passage. Early and frequent coordination with Muckleshoot Tribe during the permitting phase of this project is advised. 3.5 IMPLICATIONS OF DIRECT IMPACTS TO WETLANDS Direct wetland impacts are those that change the physical shape or configuration of the wetland itself. Based on the preliminary project plans, it is estimated that the project will directly impact (eliminate) approximately 2,000 square feet of wetland. Mitigation will need to be provided for direct wetland impacts. Frequently, wetland mitigation takes the form of replacement wetland areas rehabilitated, constructed, or enhanced on-site. However, given the steep nature of the project site and the lack of public ownership, on-site mitigation does not appear feasible. Additionally, the Corps and Ecology have established a preference for use of mitigation banks or in lieu fee programs over on-site, permittee- responsible mitigation. This is in contrast to the city’s preference for mitigation, which prioritizes re- establishing, rehabilitating, creating, enhancing, and preserving wetlands on-site over mitigation banks or in-lieu fee programs. The City of Renton has an approved wetland mitigation bank on Springbrook Creek and King County operates an in lieu fee program through its Mitigation Reserves Program. The use of either site would be permitted by local, state, and federal standards. The credits required from either the Springbrook Creek Mitigation Bank or the Mitigation Reserves Program would be determined by the mitigation banking agreement and/or certification process. Based on the project plans, it is estimated that if the applicant were to use the Springbrook Creek Mitigation Bank, approximately 0.04 credits would be needed. SO - D P 6 SO - D P 6 I - 4 0 5 EX . 8 " A C S S STREAM D WETLAND E STREAM B WETLAND F WET BFR WET BFR WET BFR WET BFR WET BFR WET BFR WET BFR WET BFR WET BFR WET BFR WET BFR WET BFR WET BFR WE T B F R WE T B F R WE T B F R WET BFR WET BFRWET BFR WET BFR WET BFR WET BFR WET BFR WET BFR WET BFR WE T B F R WE T B F R WET BFR WET BFR WET BFR WET BFR WET B F R WET B F R WET B F R WET BFR WET B F R WET BFR WET BFR WET BFR WET BFR I - 4 0 5 EX . 8 " A C S S MA T C H L I N E - S T A . 3 + 5 0 . 0 0 SE E S H E E T 2 20 0 6 6*70&'4*+..5+06'4%'2614 #.6'40#6+8'5#0#.;+5+5 WET BFR EX . 8 " A C S S WET BFR WET BFR WET BFR WET BFR WE T B F R WE T B F R WE T B F R WET BFRWET BFR EX . 8 " A C S S ADDITIONAL ESMT WILL BE NECESSARY FOR TURN-AROUND TO BE REMOVED MA T C H L I N E - S T A . 3 + 5 0 . 0 0 SE E S H E E T 1 MA T C H L I N E - S T A . 7 + 0 0 . 0 0 SE E S H E E T 3 20 0 6 6*70&'4*+..5+06'4%'2614 #.6'40#6+8'5#0#.;+5+5 WET BFR X X X TO BE REMOVED MA T C H L I N E - S T A . 7 + 0 0 . 0 0 SE E S H E E T 2 MA T C H L I N E - S T A . 1 0 + 5 0 . 0 0 SE E S H E E T 4 20 0 6 6*70&'4*+..5+06'4%'2614 #.6'40#6+8'5#0#.;+5+5 WET BFR EX. 10" D I S S EX. 12" DI SS WETLAND D, LOCATION APPROX. (NOT SURVEYED). SURVEY MAY BE REQUIRED FOR PERMITS WE T B F R WE T B F R WE T B F R WET BFR WET BFR WET BFR WE T B F R WE T B F R WE T B F R WE T B F R WET B F R WET B F R WET B F R WET B F R EX. 10" D I S S EX. 12" DI SS THUNDER HILLS CREEK OPTIONAL GRAVITY WALL OR ROCKERY - MAY NOT BE NEEDED ADD CULVERT & DIRECT SWALE TO THUNDER HILLS CREEK MA T C H L I N E - S T A . 1 0 + 5 0 . 0 0 SE E S H E E T 3 MA T C H L I N E - S T A . 1 4 + 0 0 . 0 0 SE E S H E E T 5 20 0 6 6*70&'4*+..5+06'4%'2614 #.6'40#6+8'5#0#.;+5+5 WET BFR DP 2 DP 2 EX. 10 " D I S S WETLAND C, LOCATION APPROX. (NOT SURVEYED). SURVEY MAY BE REQUIRED FOR PERMITS WETLAND B THIS SECTION OF THUNDERHILLS CREEK APPROX. (NOT SURVEYED). SURVEY MAY BE WET BFR WET BFR WET BFR WET B F R WET B F R WET BFR WET BFR WET BF R WET BFR WET BF R WET B F R WET B F R WET B F R WE T B F R WET BFR WET BFRWE T B F R WE T B F R WET B F R EX. 10 " D I S S OPTIONAL GRAVITY WALL OR ROCKERY - MAY NOT BE NEEDED CUT INTO TOE OF SLOPE TO CREATE 12' WIDE GRAVEL RD CUT INTO TOE OF SLOPE TO CREATE 12' WIDE GRAVEL RD MA T C H L I N E - S T A . 1 4 + 0 0 . 0 0 SE E S H E E T 4 MA T C H L I N E - S T A . 1 7 + 5 0 . 0 0 SE E S H E E T 6 20 0 6 6*70&'4*+..5+06'4%'2614 #.6'40#6+8'5#0#.;+5+5 WET BFR EX. 10" AC SS EX. 10" A C S S EX. 10 " D I S S THUNDER HILLS CREEK EX. 10" AC SS EX. 10" A C S S THUNDER HILLS CREE K EX. 10 " D I S S CUT INTO TOE OF SLOPE TO CREATE 12' WIDE GRAVEL RD CUT INTO TOE OF SLOPE TO CREATE 12' WIDE GRAVEL RD CUT INTO TOE OF SLOPE TO CREATE 12' WIDE GRAVEL RD MA T C H L I N E - S T A . 1 7 + 5 0 . 0 0 SE E S H E E T 5 MA T C H L I N E - S T A . 2 1 + 0 0 . 0 0 SE E S H E E T 7 20 0 6 6*70&'4*+..5+06'4%'2614 #.6'40#6+8'5#0#.;+5+5 WET BFR EX. 10" AC SS STREAM F STREAM G EX. 10" AC SS THUNDER HILLS CREEK CUT INTO TOE OF SLOPE TO CREATE 12' WIDE GRAVEL RD CUT INTO TOE OF SLOPE TO CREATE 12' WIDE GRAVEL RD CUT INTO TOE OF SLOPE TO CREATE 12' WIDE GRAVEL RD CUT INTO TOE OF SLOPE TO CREATE 12' WIDE GRAVEL RD CUT INT O T O E O F SLOPE TO C R E A T E 12' WIDE G R A V E L R D MA T C H L I N E - S T A . 2 1 + 0 0 . 0 0 SE E S H E E T 6 MA T C H L I N E - S T A . 2 4 + 5 0 . 0 0 SE E S H E E T 8 20 0 6 6*70&'4*+..5+06'4%'2614 #.6'40#6+8'5#0#.;+5+5 WET BFR SO-D P 1 SO-D P 1 /// /// /// /// /// /// /// /// /// /// /// /// /// ////// /// /// /// /// /// /// /// /// /// /// /// /// //////////// /// /// /// /// /// /// /// /// WE T B F R WE T B F R WE T B F R WE T B F R WE T B F R WE T B F R WET B F R WET B F R WET B F R WET B F R WET B F R WET B F R WET B F R WET B F R WET B F R WE T B F R WET B F R WE T B F R WET B F R WETLAND A STREAM E THUNDER HILLS CREEK CUT IN T O T O E O F SLOP E T O C R E A T E 12' WI D E G R A V E L R D CUT INTO TOE OF SLOPE TO CREATE 12' WIDE GRAVEL RD RE - P A V E & W I D E N OPTIONAL GRAVITY WALL OR ROCKERY - MAY NOT BE NEEDED MA T C H L I N E - S T A . 2 4 + 5 0 . 0 0 SE E S H E E T 7 MA T C H L I N E - S T A . 2 8 + 0 0 . 0 0 SE E S H E E T 9 20 0 6 6*70&'4*+..5+06'4%'2614 #.6'40#6+8'5#0#.;+5+5 WET BFR //////////// /// //////////// /// /// /// /// /// /// /// //////////////////////// /// ////////////////// /// /// /// /// /// /// /// /// /// /// /// /// /// /// /// /// /// /// /// /// /// /// /// /// /// /// /// SS SS SS SS SS S S SS /// /// /// /// /// /// /// //////////////////////////////////////////////////////////// /// /// /// /// /// /// /// /// /// /// /// /// /// /// /////////////////////////////////////////////////////////////// /// /// /// /// WET BFR WET BFR WET BFR WET BFR WET BFR WET B F R WET B F R WET B F R WET B F R WET B F R WET B F R GRANT AVE S S 1 8 t h S T /// /// /// /// /// /// /// RE-PAVE & WIDEN ACCESS ROAD M A T C H L I N E - S T A . 2 8 + 0 0 . 0 0 S E E S H E E T 8 20 0 6  #.6'40#6+8'5#0#.;+5+5 WET BFR