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HomeMy WebLinkAboutReport 01Exhibit Citywide Drainage Maintenance Program t �j r 0 Maintenance Location Surface Water Utility I G. Del Rosario I Printed 11/18/2010 0 2,250 4,500 I I _j Feet Ciy t N pla, hq- I ng W E I)i DIV ;4 Ts 44 Lake Washington Citywide Drainage Maintenance Program t �j r 0 Maintenance Location Surface Water Utility I G. Del Rosario I Printed 11/18/2010 0 2,250 4,500 I I _j Feet pp m o a W > E ° c E O O N 0 N h Q E m Q} 1 m � w d ❑ z 76 L] E w w () U C V V C V L [[ R x W W x R C ry R X R R x m W R W x R m R 4q ]w Z 7 w z W 2 w m 7= 3 w 2 7 2 s CD m � N V V a 0 V m U o m x m ami w V Z Q c W O a c a c a v n � a Y.0 V 4) m O Z Q Y m O N t E m O m 6 E pN c O m & E O m E mzm w E mo C] V c `o. W 91 3 m m m W Q d 3 v vi a m m m m 7 m 7 m m m m m w R m a N N m 7 ❑ x w a N m 7 N a ❑ co U> z P: c y c m R ? c m W > m m > ? m m > > e m R } c R m m } } m m } y L Z)w c= 'R O C m E m 'c O C m E m 'c O O E E O O c E E m O C w E m E C y R D O E E D O E E? 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A8. rn rn rn E w V1 a ¢ ¢ ¢ ¢ ¢ v �-' z Z z Z Z Z IV L y a .L.. o N a Q a¢ UL o aw vmcLLCL U r �� U{wl}Y m m[rL `w!'}•i`±� mmUU m2 E43' Cid�6 mo= Uh cnm o' } D mmo" y} 6LC �U) r ? s W } m ry W @m2 }�i o❑ ru m W mye C s o a} C N m C} m}} �n n¢¢ .- m U vj ❑ m U Q US ❑ C15 U d m Sl7 U d; fn R , U dw ¢ @ d U— ¢' d U 0 r' LU f. m m m m w m m ZC EXHIBIT C -ROUTINE MAINTENANCE TASKS Primary common tasks are described in the following paragraphs. Minor or suppdVtq' tasks, although not explicitly described, are also to be covered in the Washington State Department of Ecology programmatic HPA permit. Clean Drainage facilities included in Exhibit B will be cleaned to maintain an aesthetic appearance, to maintain structural and functional integrity, and to protect public health and safety. Cleaning will be accomplished by hand, by power tools, or by self-propelled machinery. Flus actor Pipes, manholes, catch basins, culverts, will be flushed and vactored to remove sediment, contaminants, and debris. The vactor allows capture and appropriate disposal of material. Control Vegetation Vegetation will be controlled to maintain an aesthetic appearance, to maintain access, to maintain structural and functional integrity, to protect public health and safety, to control noxious weeds, and to enhance the environment. Vegetation will be mowed, trimmed, removed, planted, watered, or nurtured depending on the need. Work will be accomplished by hand, by power tools, or by self-propelled machinery. Notification / approval from Development Services is required prior to removal of any trees in critical areas and critical area buffers. Remove Debris Debris will be removed to maintain an aesthetic appearance, to maintain access, to maintain structural and functional integrity, to protect public health and safety, and to enhance the environment. Debris may be natural or man-made. Debris will be removed by hand, by power tools, or by self-propelled machinery. Remove Sediment: Sediment will be removed from sediment traps to maintain their capacity for trapping sediment. Sediment will be removed from conveyance facilities to maintain their conveyance capacity. Routine maintenance of instream components may require excavation near or in water i.e. instream, sediment ponds, culvert entries and tailouts, sediment traps. The work area will be isolated from flowing water with stream or groundwater flows bypassed around the site. Receiving streams will be protected from contaminants. Sediment traps or sumps at channel transitions will be up to seven times as long as the change in channel width. One or more of the following methods will be implemented to remove sediment from each work site outlined in Exhibit B. Method(s) to be used at each site are indicated in Exhibit B under the column heading of 'Sediment Removal Method(s)'. • Vactor - Removal of sediment to be conducted with the use of a Vactor truck capable of vacuuming sediment directly from the site into a storage tank on the truck. Water accumulated through this process will be typically decanted onsite with filtration BMP's utilized before the water is allowed to re-enter the stream. • Excavator - Removal of sediment from the site through the use of an excavator or backhoe. Sediment will be deposited directly into awaiting dump trucks or temporarily stockpiled to allow water within the sediment to drain off. All stockpiled materials will have approved BMP measures in place to prevent sediment laden waters from re- entering the site_ Excavator operators will evaluate the site for access, enter and exit the site in a manner to prevent unnecessary damages to vegetation and stream banks and grade any ruts or other potential erosion concerns upon completion of the work. • Hand Work - In certain circumstances, hand work will be necessary to accomplish the job. This typically entails brushing of grasses, blackberries or other shrubs to clear the work zone prior to excavation or vactor activities. Hand work of this type will be restricted to the work area itself and all efforts will be taken to minimize unnecessary damages to surrounding vegetation. BMP's as needed will be utilized if the work bears erosion concerns to adjacent waters. Site #1 Site #18 ,. Site #20 EXHIBIT D - SITE PICTURES Site #1 Site #18 Site #20 City Of piOrx:`�ir� Rer��m� g Division QEL`22, Site #1 Site #18 Site #20 Site #32 Site #33 rl- Site #35 Site #39 Site #32 Site #33 Site #35 Site #32 Site #33 Site # 48 Site # 49 L LWI Site H 50 Site # 48 Site # 49 Site # 50 . mmomom Site # 51 Site # 51 Site # 48 Site # 49 Site # 50 fir, Site # 53 Site # 54 -f1 Site # 55 Site # 53 r . T$ i y � y Site # 54 r�. Site 56 Site # 53 Site # 56 Site # 56 Site # 53 r . T$ i y � y Site # 54 r�. Site 56 Site # 53 Site # 56 Site # 57 Site # 58 Site # 62 < 4r+_ J Site #64 Site # 57 Site #64 Site #64 R� ! Site #65 Site #71 Site #72 Site #71 Site #72 Site #71 Site #72 Site #73 Site #73 Site #73 ;i• % . fir. 7i Site #76 Site #77 Site #78 .y Site #76 Site #77 Site #78 Site #80 Site #80 Site #80 Site #82 !*&!. zt J7 Site #82 Site #83 Site #83 . I- gwA Site #82 END SECTION LENGTH SHALL BEAT LEAST SIX TIMES THE DIAMETER OF THE PSPF [SEE WSDOT STD. SPEC: 7�; END THERMOPLASTIC PIPE 41-1:7V pR ST�ffPgR CONCRETE PIPE 'H SHALL BE AT LEAST SIX TIMES THE DIAMETER OF THE PIPE {SEE WSDOT STD. SPEC. 7-02.31 4' MAX. O O O 4+i-ry OR s TfsagR 4' MAX. METAL PIPE NOTES 1. The culvert ends shall be beveled to match the embankment or ditch slope and shall not be beveled flatter than 4HAV. When slopes are between 41-1:1 V and SH:iV, shape the slope in the vicintiy of the culvert end to ensure that no part of the culvert protrudes more than 4' above the ground line. 2. Field cutting of culvert ends is permitted when approved by the Engineer. All field -cut culvert pipe shall be treated with treatment as shown in the Standard Specifications or General Special Provisions, SY szv. Pax — 221.00 w PT;BUC WORKS + ` DEPARTMENT BEVELED END SECTIONS 'P MARCH 2008 E FILL SLOPE - X y r m p u 2' wZ U SCLu W N O� j z z ¢ w 7Z w dU S2. W U coLU N FILL SLOPE -VARIABLE FILL SLOPE STRUCTURAL PLATE PIPE ARCHES AND UNDERPASSES 2' s w _ r Li UW 8aU O h6 Z } w N nz uJ W xU 7 Elf 0 4 � m� X6 PIPES AND STRUCTURAL PLATE PIPES - STEP MITERED PIPE PIPES AND STRUCTURAL PLATE PIPES - FULL MITERED PIPE D -D12 OR S,M FILL SLOPE ANCHOR BOLT (TYP.) - SEE DETAIL 8 NOTE 3 PIPE SECTION COMMERCIAL CONCRETE COMMERCSAL CONCRETE ANCHOR BOLTS - EOUALLY SPACED, 24' MAX. CENTER TO CENTER (SEE NOTE 3) ANCHOR BOLTS - EQUALLY SPACED, 24' MAX. CENTER TO CENTER ;SEE NOTE 3) ANCHOR BOLTS - EgUALLY SPACED, 24' MAX. CENTER TO CENTER (SEE NOTE 3) MMERCIAL iNCRETE 314' BOLT "112' ANCHOR BOLT DETAIL NOTES 1. The variable dimension indicated for the height of step for step mitered plpes shall conform to the manufacturers recommendations unless speci- fied differently an the plans or in the Special Provisions. 2. Reinforcing steel shall have 1 VT min, clear cover to all concrete surfaces. 3. Headwalls for concrete culvert pipe may omit anchor bolt attachment. 4. When steel pipe safety bars ar used, headwall thickness shall be increased to 8". ti x HEADWALLS FOR CULVERT STD. PLAN - 222.00 + * PUBLIC WORKS DEPARTMENT PAPE AND UNDERPASS MARCH 2008 CITY OF RENTON DEPARTMENT OF COMMUNITY & ECONOMIC DEVELOPMENT MEMORANDUM Date: May 11, 2011 To: City Clerk's Office From: Stacy M Tucker Subiect: Land Use File Closeout Please complete the following information to facilitate project closeout and indexing by the City Clerk's Office. Project Name: Citywide Drainage Maintenance Program LUA (file) Number: LUA-10-089, ECF, CAR, SME Cross -References: AKA's: Project Manager: Vanessa Dolbee Acceptance Date: January 4, 2011 Applicant: City of Renton Owner: City of Renton Contact: Hebe C. Bernardo, City of Renton i PID Number: : 4 ERC Decision Date: February 14, 2011 ERC Appeal Date: March 4, 2011 Administrative Approval: February 11, 2011 Appeal Period Ends: March 2, 2011 Public Hearing Date: Date Appealed to HEX: By Whom: e HEX Decision: Date: Date Appealed to Council: By Whom: Council Decision: Date: Mylar Recording Number: Project Description: The applicant has requested SEPA Environmental Review for continued maintenance of the Citywide stormwater infrastructure, including channels, ditches, catch basins, manhnlPs_ outfalls. nines and culverts. These facilities are located in critical areas. Location: Citywide Comments: a 0 Z D �— U E^ F"� a s n°i.� o n o.� c o c �E 3 o CLp�✓�,c V.o o •°`a� 'Pt aC,�4 c_' x� Y cE � W Z i� �' � ° � �cnr.=.�'v•a E�' �; „U.. � F"�'3w. �:pUa � �' ° � °'N V z ape, �.00P �' ca w°.0 caF v vi a� a Q F-OxCUy° o v tau v.C��3 z o y n- 2 '� v°' E c° W W Lx7 Z� c ¢' eq " C C w ❑Us .0 ti -� O .q ar U t p G4 W L E o v a, .E �-' b o 3 o`t c= C u Ev > a .c , E Y rn °q`E ^ o w R F o v �[U'L q.�. y y > ;+ EZa 1 s-. GG'�•�•� � c�i� 3.O C aG car Ocon U C1 a CJ � � •� � � R+ as � 3 a? .� cL4 Gz tbjU 121. Za a clL��cu ��� o a —Z Ilom 63 0 r" XR O O y CL, QQy a� y� Qj �0 (L) bpm �" ���.0 y� Oto tfi �. H V v T U v 4) v cG O bll a sG y y s. O W bq ca z en�-[--U oo DEPARTMENT OF COMMUNITY'" Cttyof _ AND ECONOMIC DEVELOPMENT PLANNING DIVISION CERTIFICATE OF EXEMPTION FROM CRITICAL AREAS REGULATIONS EVALUATION FORM & DECISION i CONCUR ENCE oAT� NAME INITIALMAT DATE OF PERMIT ISSUANCE: February 15, 2011 M LAND USE ACTION FILE NO.: LUAIO-089 ECF, SME, CAR i �y,, PROJECT NAME: Citywide Drainage Maintenance Prog ab cal'��lll +� Exemption PROJECT MANAGER: Vanessa Dolbee, Senior Planner OWNER/APPLICANT: City of Renton, 1055 South Grady Way, Renton, WA 98057 CONTACT (if other than Owner): Hebe C. Bernardo, City of Renton Surface Water, 1055 South Grady Way, Renton, WA 98057 PROJECT LOCATION: Citywide and Potential Annexation Areas if Annexed CRITICAL AREA: All Streams, Lakes, and associated wetlands PROPOSAL DESCRIPTION: The applicant has requested a Critical Areas Exemption for continued maintenance of the Citywide stormwater infrastructure, including channels, ditches, catch basins, manholes, outfalls, pipes and culverts. These facilities are located in critical areas: including, the Cedar River, May Creek, Springbrook Creek, Thunder Hills Creek, Panther Creek, Ginger Creek, Maplewood Creek, Honey Creek, Greens Creek, Kennydale Creek, Gypsy Creek, Johns Creek and Lake Washington. The purpose of the Citywide maintenance program is to maintain existing drainage facilities in order to ensure their optimum performance, by protecting the facilities against accumulation of debris, sediment and vegetation. Ongoing maintenance is needed to preserve or restore the original function of the existing drainage facilities so the balanced use of the water resource continues as intended. Maintenance tasks included cleaning the facilities to maintain structural integrity, flush or vactor - pipes manholes etc..., control vegetation, remove debris, and remove sediment. Sites included in the proposed maintenance program would be maintained from the existing right-of-way or easements dedicated to the City. No new access drives or roads would be required to be built as a part of any maintenance activities. 0 0 DEPARTMENT OF COMMUNITY Qty of. AND ECONOMIC DEVELOPMENT ` PLANNING DIVISION CERTIFICATE OF EXEMPTION FROM CRITICAL AREAS REGULATIONS EVALUATION FORM & DECISION DATE OF PERMIT ISSUANCE: February 16, 2011 LAND USE ACTION FILE NO.: LUA10-089 ECF, SME, CAR PROJECT NAME: Citywide Drainage Maintenance Program PROJECT MANAGER: Vanessa Dolbee, Senior Planner OWNER/APPLICANT: City of Renton, 1055 South Grady Way, Renton, WA 98057 CONTACT (if other than Owner): Hebe C. Bernardo, City of Renton Surface Water, 1055 South Grady Way, Renton, WA 98057 PROJECT LOCATION: Citywide and Potential Annexation Areas if Annexed CRITICAL AREA: All Streams, Lakes, and associated wetlands PROPOSAL DESCRIPTION: The applicant has requested a Critical Areas Exemption for continued maintenance of the Citywide stormwater infrastructure, including channels, ditches, catch basins, manholes, outfalls, pipes and culverts. These facilities are located in critical areas: including, the Cedar River, May Creek, 5pringbrook Creek, Thunder Hills Creek, Panther Creek, Ginger Creek, Maplewood Creek, Honey Creek, Greens Creek, Kennydale Creek, Gypsy Creek, Johns Creek and Lake Washington. The purpose of the Citywide maintenance program is to maintain existing drainage facilities in order to ensure their optimum performance, by protecting the facilities against accumulation of debris, sediment and vegetation. Ongoing maintenance is needed to preserve or restore the original function of the existing drainage facilities so the balanced use of the water resource continues as intended. Maintenance tasks include cleaning the facilities to maintain structural integrity, flush or vactor - pipes manholes etc..., control vegetation, remove debris and sediment. Sites included in the proposed maintenance program would be maintained from the existing right- of-way or easements dedicated to the City. No new access drives or roads would be required to be built as a part of any maintenance activities. City of Renton Department of Community & Economic Development Certificate of Option from Critical Areas Exemption Citywide Drainage Maintenance Program LUA10-089 ECF, SMF February 16, 2011 Page 2 of 4 Vegetation removal of grasses, shrubs, and trees may be necessary either for access purposes or because the vegetation is within the working area. The applicant proposes to keep vegetation removal to a minimum and has indicated that all native vegetation disturbed outside of work/access areas would be restored to pre -project conditions upon completion of maintenance activity. Furthermore, if any tree is to be removed, either the snag shall be left in the stream corridor or a new tree shall be planted within the stream corridor where the tree was removed. Tree and vegetation replacement is a mitigation measure identified in the SEPA review for the subject project, staff recommends such mitigation measures become conditions of approval of the subject Critical Areas Exemption. The City of Renton's Surface Water Utility has proposed to utilize the Regional Road Maintenance Endangered Species Act Program Guidelines to select and implement appropriate Best Management Practices to minimize the disruption to the natural environment. In addition, all applicable State and Federal requirements associated with the Clean Water Act (CWA) and Appendix D of the 2009 Surface Water Design Manual would be met through planning, application, and monitoring of Best Management Practices (BMP's). All maintenance activities would comply with provisions to be imposed by the Washington State Department of Fish and Wildlife (WDFW) through the Hydraulic Project Approval (HPA) permit. EXEMPTION JUSTIFICATION: Pursuant to RMC4-3-D5QC.5.e.ii Existing Parks, Trails, Roads, Facilities, and Utilities - Maintenance, Operation, Repair and RMC 4-3-050C.5.e.v Vegetation Management/Essential Tree Removal for Public or Private Utilities, Roads, and Public Parks, of the Critical Areas Regulations is hereby granted: X Normal routine maintenance and repair of stormwater facilities located in streams, lakes, and associated wetlands and their buffers. ii. Existing Parks, Trails, Roads, Facilities, and Utilities — Maintenance, Operation, Repair: Normal and routine maintenance, operation and repair of existing parks and trails, streets, roads, rights-of-way and associated appurtenances, facilities and utilities where no alteration or additional fill materials will be placed other than the minimum alteration and/or fill needed to restore those facilities to meet established safety standards. The use of heavy construction equipment shall be limited to utilities and public agencies that require this type of equipment for normal and routine maintenance and repair of existing utility structures and rights-of-way. In every case, critical area and required buffer impacts shall be minimized and disturbed areas shall be restored during and immediately after the use of construction equipment. Essential tree and vegetation removal in streams, lakes, and associated wetlands X and their buffers for related stormwater facility maintenance activities. City of Renton Department of Colkity & Economic Development Certificate of Exemption from Critical Areas Fxemption Citywide Drainage Maintenance Program _ LUAIO-089 ECF, SME February 16, 2011 Page 3 of 4 v. Vegetation Management/Essential Tree Removal for Public or Private Utilities, Roads, and Public Parks: Maintenance activities, including routine vegetation management and essential tree removal, and removal of non-native invasive vegetation or weeds listed by the King County Noxious Weed Board or other government agency, for public and private utilities, road rights-of-way and easements, and parks. Trees shall be retained as large woody debris in the stream/buffer corridor, where feasible. FINDINGS: The proposed development is consistent with the following findings pursuant to RMC section 4-3-050C.5: I. The activity is not prohibited by this or any other chapter of the RMC or state or federal law or regulation. 2. The activity will be conducted using best management practices as specified by industry standards or applicable Federal agencies or scientific principles if submitted plans are followed and the conditions of approval of this exemption are met. 3. Impacts will be minimized and disturbed areas will be immediately restored, if submitted plans are followed and the conditions of approval of this exemption are met. 4. Where wetland or buffer disturbance occurs during construction or other activities in accordance with this exemption, the site will be re -vegetated with native vegetation as required as a condition of approval for this exemption. DECISION: An exemption from the critical areas regulations is approved for normal maintenance and repair of the Citywide stormwater infrastructure located within streams, lakes, and associated wetlands and their buffers in addition to essential vegetation and tree removal; subject to the following conditions. 1. Any native vegetation, located outside the work/access area, that is damaged or disturbed during maintenance activities shall be restored and/or replanted immediately following the maintenance activity. 2. Any trees required to be removed shall be replanted within the stream/wetland buffer corridor or the snags shall be left within the stream/wetland buffer corridor following the maintenance activity. SIGNATURE: 4 c�1;1 _ 1 C.E. "Chip" Vincent, Planning Drector Planning Division 2 "► Date City of Renton Department of Community & Economic Development Certificate of Exemption from Critical Areas Regulations Citywide Drainage Maintenance Program Critcal Areas Exemption LUAI0-089 FCF, SME, CAR DATE OF PERMIT: February 16, 2411 Page 4 of 4 APPEALS: Appeals of permit issuance must be filed with the City of Renton Hearing Examiner by 5:00 p.m. on March 2, 2011. Appeals must be filed in writing, together with the required fee to the City of Renton Hearing Examiner, City of Renton, 1055 South Grady Way, Renton, WA 98057. City of Benton Municipal Code Section 4-8-110 governs appeals to the Hearing Examiner. Additional information regarding the appeal process may be obtained from the Renton City Clerk's Office, (425) 430-6510. EXPIRATION. Five (5) years from the date of approval (signature date). DEPARTMENT OF COMMUNITY c�ryo' R AND ECONOMIC DEVELOPMENT f � �r PLANNING DIVISION CERTIFICATE OF EXEMPTION FROM SHORELINE SUBSTANTIAL DEVELOPMENT EVALUATION FORM & DECISION DATE OF PERMIT ISSUANCE: LAND USE ACTION FILE NO.: PROJECT NAME: PROJECT MANAGER: OWNER/APPLICANT: CONTACT (if other than Owner): PROJECT LOCATION: LEGAL DESCRIPTION: SEC-TWN-R: February 15, 2011 LUA10-089, ECF, CAR, SME Citywide Drainage Maintenance Vanessa Dolbee, Senior Planner City of Renton, 1055 South Grady Way, Renton, WA 98057 Nebe C. Bernardo, City of Renton Surface Water, 1055 South Grady Way, Renton, WA 98057 Citywide and Potential Annexation Areas (if Annexed) Citywide T. 22 & 23 N, R. 4 & 5 E WATER BODY/WETLAND: All Class 1 waters within the City of Renton and the City of Renton's Potentential Anexation Area. Including but not limited to: Lake Washington, Cedar River, May Creek, and Springbrook Creek. PROPOSAL DESCRIPTION: The applicant has requested a Shoreline Exemption for continued maintenance of the Citywide stormwater infrastructure, including channels, ditches, catch basins, manholes, outfalls, pipes and culverts. These facilities are located in the Cedar River, Springbrook Creek, May Creek and Lake Washington. The purpose of the Citywide maintenance program is to maintain existing drainage facilities in order to ensure their optimum performance, by protecting the facilities against accumulation of debris, sediment and vegetation. Ongoing maintenance is needed to preserve or restore the original function of the existing drainage facilities so the balanced use of the water resource continues as intended. Maintenance tasks included cleaning the facilities to maintain structural integrity, flush or vactor - pipes manholes etc..., control vegetation, remove debris, and remove sediment. Sites included in the proposed maintenance program would be Cq off ; DEPARTMENT OF COMMUNITY C; AND ECONOMIC DEVELOPMENT PLANNING DIVISION CERTIFICATE OF EXEMPTION FROM SHORELINE SUBSTANTIAL DEVELOPMENT EVALUATION FORM & DECISION DATE OF PERMIT ISSUANCE: February 16, 2011 LAND USE ACTION FILE NO.: LUA10-089, ECF, CAR, SME PROJECT NAME: Citywide Drainage Maintenance Program PROJECT MANAGER: Vanessa Dolbee, Senior Planner OWNER/APPLICANT: City of Renton, 1055 South Grady Way, Renton, WA 98057 CONTACT (if other than Owner): Hebe C. Bernardo, City of Renton Surface Water, 1055 South Grady Way, Renton, WA 98057 PROJECT LOCATION: Citywide and Potential Annexation Areas (if Annexed) LEGAL DESCRIPTION: Citywide SEC-TWN-R: T. 22 & 23 N, R. 4 & 5 E WATER BODY/WETLAND: All Class 1 waters within the City of Renton and the City of Renton's Potentential Anexation Area. Including but not limited to: Lake Washington, Cedar River, May Creek, and Springbrook Creek. PROPOSAL DESCRIPTION: The applicant has requested a Shoreline Exemption for continued maintenance of the Citywide stormwater infrastructure, including channels, ditches, catch basins, manholes, outfalls, pipes and culverts. These facilities are located in the Cedar River, Springbrook Creek, May Creek and Lake Washington. The purpose of the Citywide maintenance program is to maintain existing drainage facilities in order to ensure their optimum performance, by protecting the facilities against accumulation of debris, sediment and vegetation. Ongoing maintenance is needed to preserve or restore the original function of the existing drainage facilities so the balanced use of the water resource continues as intended. Maintenance tasks include cleaning the facilities to maintain structural integrity, flush or vactor - pipes manholes etc..., control vegetation, remove debris and sediment. Sites included in the proposed maintenance program would be maintained City of Renton Departmeot of Commun, y & Economic Development Certificate of Exemp o, from Shoreline Substantial Development Citywide Drainage Maintenance Program LUA10-089, ECF, CAR, SME DATE OF PERMIT: February 16, 2011 Page 2 of 3 from the existing right-of-way or easements dedicated to the City. No new access drives or roads would be required to be built as a part of any maintenance activities. Vegetation removal of grasses and shrubs may be necessary either for access purposes or because the vegetation is within the working area. The applicant proposes to keep vegetation removal to a minimum and has indicated that all native vegetation disturbed outside of work/access areas would be restored to pre -project conditions upon completion of maintenance activity. The City of Renton's Surface Water Utility has proposed to utilize the Regional Road Maintenance Endangered Species Act Program Guidelines to select and implement appropriate Best Management Practices to minimize the disruption to the natural environment. In addition, all applicable State and Federal requirements associated with the Clean Water Act (CWA) and Appendix D of the 2009 Surface Water Design Manual would be met through planning, application, and monitoring of Best Management Practices (BM P's). All maintenance activities would comply with provisions to be imposed by the Washington State Department of Fish and Wildlife (WDFW) through the Hydraulic Project Approval (HPA) permit. An exemption from a Shoreline Management Substantial Development Permit is hereby granted on the proposed project in accordance with RMC 4-9-190C and/or for the following reason(s): Normal maintenance or repair of existing structures or developments, including damage by accident, fire or elements. a. Normal maintenance includes those usual acts to prevent a decline, lapse, or cessation from a lawfully established condition. b. Normal repair means to restore a development to a state comparable to its original condition, including but not limited to its size, shape, configuration, location and external appearance, within a reasonable period after decay or partial destruction, except where repair causes substantial adverse effects to the shoreline resource or environment. City of Renton Deportment of Commu' 7r & Economic Development Certificate of Exempt" from Shoreline Substontiol Development Citywide Drainage Maintenance Program LUA10,089, ECF, CAR, SMF DATE OF PERMIT: February 16, 2411 Page 3 of 3 The proposed development is consistent or inconsistent with (check one): CONSISTENT xx INCONSISTENT Policies of the Shoreline Management Act. N/A The guidelines of the Department of Ecology where no Master Program has been finally approved or adapted by the Department. ED C. E. "Chip" Vincent, Planning Director Planning Division Attachments: Vicinity/Neighborhood Detail Map Site Photos The City of Renton Shoreline Master Program. cc: Hebe C. Bernardo, City of Renton Surface Water City of Renton Official File Date r.. i...: L -'.A. Citywide Drainage Maintenance Program r �E�TT Lr Ds-, (a-,� 0 2,250 4,500 • Maintenance Location I I I I I Feet Surface Water Utility I G. Del Rosario I Printed 11/1812010 ... .. .• � :-.._.� �. rte. _ -�` Site #1 Site #18 Site #20 9 EXHIBIT D - SITE PICTURES Site #1 Site #18 Site #20 Site #1 77�t. r -' Site #18 Site #20 0 0 Site #32 Site #32 Site #32 Site #33 Site #33 Site #35 Site #35 Site #39 Site #33 0 0 ll,L Site ##43 Site # 44 Site #43 Site # 46 Site #42 it Site # 44 Site # 46 Site #43 Site # 46 Site #42 it Site # 44 Site # 49 r Site # 50 Site # 51 Site # 48 u r Site # 49 An Site # S0 - Yom Site # 51 411 Site # 48 Site # 49 VIA Site # 50 0 9 Site # 53 Site# 54 Site # 55 Site # 56 Site # 53 S Site # 54 Site 56 Site # 53 Site # 54 Site # 56 :Yrr� 12' Site t 'YT Site # 57 Site # 58 Site # 62 Site # 57 Site #64 Site #64 Site #64 0 "T I ~ Site #65 IW Site #71 Site #71 Site #71 0 Site #72 Site #72 Site #72 E Site #73 Site #73 Site #73 a -N, Site #76 Site #77 Site #78 W Site #76 Site #77 � 46'v Site #78 1�1 Site #80 site #80 Site #80 0 0 Site #82 Site #82 Site #82 Site #83 Site 483 NOTICE OF ENVIRONMENTAL DETERMINATION ISSUANCE OF A DETERMINATION OF NON -SIGNIFICANCE • MITIGATED DNS -Ml POSTED TO NOTIFY ATERESTED PERSONS OF AN ENVIRONMENtALACTION PRO1ECr NANIF: Cl"da Draf-irs Malnt.,-,.Program PROIECTNDMBER: LDA1a-de9, ECF, CAR, SME LOCA110N:Otrwlde DESCRIPTION: Tn• applicant hes requesled SEPA E-Innmental Re,lew for coAdnued Mint- ". M ". atywMe ,E —sbsr Infra m, mduding 6-0s, dhches, catch banns, manWei, odtfalis, Pipas and cuWerta. Thee tsdilti" am I—d.d In crid,.l anal: Including, the Cedar River, May Creek, HillGreMaplewood SprlAgbr"k Creek, Thornier s Creak, P.Mhar eek, Gi7er Crack, creak, hone, Creek. Greens Creak, Rennrdl Creek. Gypsy Geeir, loin. crank and Lk. W..hinglon. Same of these crhlol areae an Gan 1 watan of the state, and wwld be subject to the Shnnllns Manses, ment Pragnm ISMP)_ As each the appituM hat also mquotad a Sha 11- Exemplk,A and a 01hicai Area, D orphan tar work In alhw cIlinl anal that sn noS .uhN,t to the SMP nNlatlans Tha purpose of the Citywide maintm— pmgmm I, m maintain axl.dng drain"" Fadlda. In order t• even their apllmum pedormw.ce, by pntocpng the fallmss apW1 a—uladan M dehd,,,edlmenk and x.ge4hon. THE CITU OF RENTON ENVIRONMENTAL REVIEW CDMMrrTEE IERC) HAS DETERMINED THAT THE PROPOSED ACTION DOES NOT HAVE A SiGNIFKANT ADVERSE IMPACT ON THE ENVIRONMENT. Appeals of the erMmnmental determination must he Filed In writing on or before 5:00 p.m. on March 4, loll. Appeals must be fled In writing togethar with the required fee with: Hearing Examiner, City, of Renton, 5055 South Grady Wey, Renton, WA 98057. Appeals to the Examiner are governed by CRy of Renton Munlctpat Code Seal— 4-11-110-g. Addltlonaf Information regarding the appeal prxe,. mey be obtained from tha Ranton Ory Oark's Office, (425)43G-6510. IF THE ENVIRONMENTAL DETERMINATION H APPEALED, A PUBLIC HEAK4(3 WILL BE SET AND ALL PARTIES NOTIFIED. -__ _...._.. .. FOR FURTHER INFORMATION PLEASE CONTACT THE CITY OF RENTON, DEPARTMENT OF COMMUNITY & LONOMIC DEVELOPMEMrAT X4251 4347240. DO NOT REMOVE THIS NOTICE WITHOLIT PROPER AUTHORIZATION Please Include the project NUMBER when olling for proper file identification. :�.1119f41_r111141Z I, VA/IZ::S� 64/1�-e ,hereby certify that copies of the above document were posted in �s conspicuous places or nearby the described property on Dater ! IQs/% Signed:12F�4-D�cx. STATE OF WASHINGTON j j SS COUNTY OF ICING j I certify that I know or have satisfactory evidence that signed this instrument and acknowledged it to be his/her/their free and voluntary act for the uses and purposes mentioned in the instrument. `s c�r l f c I L ,� —_.., t%k Notary Public n and or the State of Washington I Notary (Print): My appointment expires: / V''.r ttrisihtttty�� I rE Of CITY OF RENTON DEPARTMENT OF COMMUNITY & ECONOMIC DEVELOPMENT - PLANNING DIVISION AFFIDAVIT OF SERVICE BY MAILING On the 16th day of February, 2011, 1 deposited in the mails of the United States, a sealed envelope containing ERC Determination, Critical Areas Exemption, Shoreline Exemption documents. This information was sent to: Name I Representing I Agencies I See Attached Hebe Bernardo, City of Renton - Utilities I Applicant/Contact (Signature of Sender): STATE OF WASHINGTON } T r. } SS COUNTY OF KING ) % •� I certify that I know or have satisfactory evidence that Stacy M. Tucker '41' Of YM�' 1�1 signed this instrument and acknowledged it to be his/her/their free and voluntary act for tlN'Ybm�`r'ti`� purposes mentioned in the instrument. Dated: Notary Notary (Print): My appointment expires: Project Name: t- Citywide Drainage Maintenance Program Project Numbers LUA10-089, ECF, CAR, SME template - affidavit of service by mailing .r- G -C', is in and for the State of Washington 3 0 E AGENCY (DOE) LETTER MAILING (ERC DETERMINATIONS) Dept. of Ecology * WDFW - Larry Fisher* Muckleshoot Indian Tribe Fisheries Dept. Environmental Review Section 1775 12th Ave. NW Suite 201 Attn: Karen Walter or SEPA Reviewer PO Box 47703 Issaquah, WA 98027 39015 — 172nd Avenue SE Olympia, WA 98504-7703 Auburn, WA 98092 WSDOT Northwest Region * Duwamish Tribal Office * Muckleshoot Cultural Resources Program Attn: Ramin Pazooki 4717 W Marginal Way SW Attn: Ms Melissa Calvert King Area Dev. Serv., MS -240 Seattle, WA 98106-1514 39015 172nd Avenue SE PO Box 330310 Auburn, WA 98092-9763 Seattle, WA 98133-9710 US Army Corp. of Engineers * KC Wastewater Treatment Division * Office of Archaeology & Historic Preservation* Seattle District Office Environmental Planning Supervisor Attn. Gretchen Kaehler Attn: SEPA Reviewer Ms. Shirley Marroquin PO Box 48343 PO Box C-3755 201 S. Jackson ST, MS KSC-NR-050 Olympia, WA 98504-8343 Seattle, WA 98124 Seattle, WA 98104-3855 Boyd Powers * Depart. of Natural Resources PO Box 47015 Olympia, WA 98504-7015 KC Dev. & Environmental Serv. City of Newcastle City of Kent Attn; SEPA Section Attn: Steve Roberge Attn: Mr. Fred Satterstrom, AICP 900 Oakesdale Ave. SW Director of Community Development Acting Community Dev. Director Renton, WA 98055-1219 13020 Newcastle Way 220 Fourth Avenue South Newcastle, WA 98059 Kent, WA 98032-5895 Metro Transit Puget Sound Energy City of Tukwila Senior Environmental Planner Municipal Liaison Manager Steve Lancaster, Responsible Official Gary Kriedt Joe Jainga 6200 Southcenter Blvd. 201 South Jackson Street KSC-TR-0431 PO Box 90868, MS: XRD-01W Tukwila, WA 98188 Seattle, WA 98104-3856 Bellevue, WA 98009-0868 Seattle Public Utilities Real Estate Services Attn. SEPA Coordinator 700 Fifth Avenue, Suite 4900 PO Box 34018 Seattle, WA 98124-4018 *Note: If the Notice of Application states that it is an "Optional DNS", the marked agencies and cities will need to be sent a copy of the checklist, Site Plan PMT, and the notice of application. template - affidavit of service by mailing City of r� :Y •CD OF ENVIRONMENTAL DETERMINATION ISSUANCE OF A DETERMINATION OF NON -SIGNIFICANCE - MITIGATED (DNS -M) POSTED TO NOTIFY INTERESTED PERSONS OF AN ENVIRONMENTAL ACTION PROJECT NAME: Citywide Drainage Maintenance Program PROJECT NUMBER: LUA10-089, ECF, CAR, SME LOCATION: Citywide DESCRIPTION: The applicant has requested SEPA Environmental Review for continued maintenance of the Citywide stormwater infrastructure, including channels, ditches, catch basins, manholes, outfalls, pipes and culverts. These facilities are located In critical areas: including, the Cedar River, May Creek, Springbrook Creek, Thunder Hills Creek, Panther Creek, Ginger Creek, Maplewood Creek, Honey Creek, Greens Creek, Kennydale Creek, Gypsy Creek, Johns Creek and Lake Washington. Some of these critical areas are Class 1 waters of the State, and would be subject to the Shoreline Management Program (SMP). As such the applicant has also requested a Shoreline Exemption and a Critical Areas Exemption for work in other critical areas that are not subject to the SMP regulations. The purpose of the Citywide maintenance program is to maintain existing drainage facilities in order to ensure their optimum performance, by protecting the facilities against accumulation of debris, sediment and vegetation. THE CITY OF RENTON ENVIRONMENTAL REVIEW COMMITTEE (ERC) HAS DETERMINED THAT THE PROPOSED ACTION DOES NOT HAVE A SIGNIFICANT ADVERSE IMPACT ON THE ENVIRONMENT. Appeals of the environmental determination must be filed in writing on or before 5:00 p.m. on March 4, 2011. Appeals must be filed in writing together with the required fee with: Hearing Examiner, City of Renton, 1055 South Grady Way, Renton, WA 98057. Appeals to the Examiner are governed by City of Renton Municipal Code Section 4-8-110.B. Additional information regarding the appeal process may be obtained from the Renton City Clerk's Office, (425) 430-6510, IF THE ENVIRONMENTAL DETERMINATION 15 APPEALED, A PUBLIC HEARING WILL BE SET AND ALL PARTIES NOTIFIED. FOR FURTHER INFORMATION, PLEASE CONTACT THE CITY OF RENTON, DEPARTMENT OF COMMUNITY & ECONOMIC DEVELOPMENT AT {425} 430-7200. DO NOT REMOVE THIS NOTICE WITHOUT PROPER AUTHORIZATION Please include the project NUMBER when calling for proper file identification. i Denis LawCity of Mayor - i Department of Community and Economic Development February 16, 2011 Alex Pietsch, Administrator Washington State Department of Ecology Environmental Review Section PO Box 47703 Olympia, WA 98504-7743 Subject: ENVIRONMENTAL (SEPA) DETERMINATION Transmitted herewith is a copy of the Environmental Determination for the following project reviewed by the Environmental Review Committee (ERC) on February 14, 2011: DETERMINATION OF NON -SIGNIFICANCE -MITIGATED PROJECT NAME: Citywide Drainage Maintenance Program PROJECT NUMBER: LUA10-089, ECF, CAR, SME LOCATION: Citywide DESCRIPTION: The applicant has requested SEPA Environmental Review for continued maintenance of the Citywide stormwater infrastructure, including channels, ditches, catch basins, manholes, outfalls, pipes and culverts. These facilities are located in critical areas: including, the Cedar River, May Creek, Springbrook Creek, Thunder Hills Creek, Panther Creek, Ginger Creek, Maplewood Creek, Honey Creek, Greens Creek, Kennydale Creek, Gypsy Creek, Johns Creek and Lake Washington. Appeals of the environmental determination must be filed in writing on or before 5:00 p.m. on March 4, 2011. Appeals must be filed in writing together with the required fee with: Hearing Examiner, City of Renton, 1055 South Grady Way, Renton, WA 98057. Appeals to the Examiner are governed by City of Renton Municipal Code Section 4-8- 110.B. Additional information regarding the appeal process.may be obtained from the Renton City Clerk's Office, (425) 430-6510. Please refer to the enclosed Notice of Environmental Determination for complete details. If you have questions, please call me at (425) 430-7314. For the Environmental Review Committee, Vanessa Dolbee Senior Planner Renton City Hall • 1055 South Grady Way • Renton, Washington 98057 • rentonwa.gov Washington State Department0cology Page 2 of 2 February 16, 2011 Enclosure cc: King County Wastewater Treatment Division Boyd Powers, Department of Natural Resources Karen Walter, Fisheries, Muckleshoot Indian Tribe Melissa Calvert, Muckleshoot Cultural Resources Program Gretchen Kaehler, Office of Archaeology & Historic Preservation 0 Ramin Paxooki, WSDOT, NW Region Larry Fisher, WDFW Duwamish Tribal Office US Army Corp. of Engineers 0 DEPARTMENT OF COMMUNITY D city of AND ECONOMIC DEVELOPMENT M E M O R A N D U M DATE: February 16, 2011 TO: Hebe C. Bernardo, Utilities FROM: Vanessa Dolbee, Planning_ SUBJECT: ERC Determination Citywide Drainage Maintenance Program LUA10-089, ECF, SME, CAR This memo is written on behalf of the Environmental Review Committee (ERC) to advise you that they have completed their review of the subject project and have issued a threshold Determination of Nan -Significance -Mitigated with Mitigation Measures. Please refer to the attached ERC Report and Decision, Part 2, Section B for a list of the Mitigation Measures. Appeals of the environmental determination must be filed in writing on or before 5:00 p.m. on March 4, 2011. Appeals must be filed in writing together with the required fee with: Hearing Examiner, City of Renton, 1055 South Grady Way, Renton, WA 98057. Appeals to the Examiner are governed by City of Renton Municipal Code Section 4-8- 110.8. Additional information regarding the appeal process may be obtained from the Renton City Clerk's Office, (425) 430-6510. If the Environmental Determination is appealed, a public hearing date will be set and all parties notified The preceding information will assist you in planning for implementation of your project and enable you to exercise your appeal rights more fully, if you choose to do so. If you have any questions or desire clarification of the above, please call me at x7314. Attachment: Environmental Review Committee Report DEPARTMENT OF COMMUNITY D UtyOf AND ECONOMIC DEVELOPMENT DETERMINATION OF NON -SIGNIFICANCE -MITIGATED MITIGATION MEASURES APPLICATION NO(S): LUA10-089, ECF, CAR, SME APPLICANT: City of Renton PROJECT NAME: Citywide Drainage Maintenance Program DESCRIPTION OF PROPOSAL: The applicant has requested SEPA Environmental Review for continued maintenance of the Citywide stormwater infrastructure, including channels, ditches, catch basins, manholes, outfalls, pipes and culverts. These facilities are located in critical areas: including, the Cedar River, May Creek, Springbrook Creek, Thunder Hills Creek, Panther Creek, Ginger Creek, Maplewood Creek, Honey Creek, Greens Creek, Kennydale Creels, Gypsy Creek, Johns Creek and Lake Washington. LOCATION OF PROPOSAL: Citywide LEAD AGENCY: The City of Renton Department of Community & Economic Development Planning Division MITIGATION MEASURES: 1. The subject environmental review shall be re -reviewed in 10 -years to determine whether conditions have changed. Any new information should be submitted to the Planning Division for review, at such time the Planning Director shall determine if a new SEPA review is warranted due to changes in conditions or if a SEPA Addendum is needed. 2. Any native vegetation, located outside the work/access area, that is damaged or disturbed during maintenance activities shall be restored and/or replanted immediately following the maintenance activity. 3. Any trees required to be removed shall be replanted within the stream buffer corridor or the snags shall be left within the stream buffer corridor following the maintenance activity. 4, The applicant shall comply with the Regional Road Maintenance Program (RRMP) as identified in the provided NMFS Endangered SpeciesAct—Section 7 Biological Opinion. 5. The Citywide Drainage Maintenance Program activities shall comply with the conditions of approval required as a part of the Hydraulic Project Approval (HPA) permit required to be issued by the Washington State Department of Fish and Wildlife (WDFW), including but not limited to maximum sediment removal, limits of work, and facility maintenance methods for each specific maintenance location. ERC Mitigation Measures Page 1 of 1 DEPARTMENT OF COMMUNITY yof AND ECONOMIC DEVELOPMENT DETERMINATION OF NON -SIGNIFICANCE -MITIGATED ADVISORY NOTES APPLICATION NO(S): LUA10-089, ECF, CAR, SME APPLICANT: City of Renton PROJECT NAME: Citywide Drainage Maintenance Program DESCRIPTION OF PROPOSAL: The applicant has requested SEPA Environmental Review for continued maintenance of the Citywide stormwater infrastructure, including channels, ditches, catch basins, manholes, outfalls, pipes and culverts. These facilities are located in critical areas: including, the Cedar River, May Creek, Springbrook Creek, Thunder Hills Creek, Panther Creek, Ginger Creek, Maplewood Creek, Honey Creek, Greens Creek, Kennydale Creek, Gypsy Creek, Johns Creek and Lake Washington. LOCATION OF PROPOSAL: Citywide LEAD AGENCY: The City of Renton Department of Community & Economic Development Planning Division Advisory Notes to Applicant: The following notes are supplemental information provided in conjunction with the environmental determination. Because these notes are provided as information only, they are not subject to the appeal process for environmental determinations. Planning: RMC section 4-4-030.C.2 limits haul hours between 8:30 am to 3:30 pm, Monday through Friday unless otherwise approved by the Development Services Division. Parks: Recommend coordination with Parks and Golf Director prior to conducting work on Park managed City property and Parks Planning and Natural Resources Director on open space/natural area City managed property. ERC Advisory Notes Page 1 of 1 0 0 DEPARTMENT OF COMMUNITY D city of `} 1� AND ECONOMIC DEVELOPMENT ENVIRONMENTAL (SEPA) DETERMINATION OF NON -SIGNIFICANCE - MITIGATED (DNS -M) APPLICATION NO(5): LUA10-089, ECF, CAR, SME APPLICANT: City of Renton PROJECT NAME: Citywide Drainage Maintenance Program DESCRIPTION OF PROPOSAL: The applicant has requested SEPA Environmental Review for continued maintenance of the Citywide stormwater infrastructure, including channels, ditches, catch basins, manholes, outfalls, pipes and culverts. These facilities are located in critical areas: including, the Cedar River, May Creek, Springbrook Creek, Thunder Hills Creek, Panther Creek, Ginger Creek, Maplewood Creek, Honey Creek, Greens Creek, Kennydale Creek, Gypsy Creek, Johns Creek and Lake Washington. LOCATION OF PROPOSAL: Citywide LEAD AGENCY: City of Renton Environmental Review Committee Department of Community & Economic Development The City of Renton Environmental Review Committee has determined that it does not have a probable significant adverse impact on the environment. An Environmental Impact Statement (EIS) is not required under RCW 43.21C.030(2)(c). Conditions were imposed as mitigation measures by the Environmental Review Committee under their authority of Section 4-6-6 Renton Municipal Code. These conditions are necessary to mitigate environmental impacts identified during the environmental review process. Appeals of the environmental determination must be filed in writing on or before 5:00 p.m. on March 4, 2011. Appeals must be filed in writing together with the required fee with: Hearing Examiner, City of Renton, 1055 South Grady Way, Renton, WA 98057. Appeals to the Examiner are governed by City of Renton Municipal Code Section 4-8- 110.8. Additional information regarding the appeal process may be obtained from the Renton City Clerk's Office, (425) 430-6510. PUBLICATION DATE: DATE OF DECISION: SIGNATURES: Gregg Zim e a dministrator Public Works Department Terry Higashiyama, Administrator Community Services Department February 18, 2011 February 14, 2011 Date �1��111 Date Mark Peterson, Administrator Fire & Emergency Services Alex Pietsch, Adminitrator Department of.Com unity & Economic Development Date IN If Date DEPARTMENT OF COMMUNITY p a city of AND ECONOMIC DEVELOPMENT Q� C ENVIRONMENTAL REVIEW COMMITTEE MEETING AGENDA TO: Gregg Zimmerman, Public Works Administrator Terry Higashiyama, Community Services Administrator Mark Peterson, Fire & Emergency Services Administrator Alex Pietsch, CED Administrator FROM: Jennifer Henning, Current Planning Manager MEETING DATE: Monday, February 14, 2011 TIME: 3:00 p.m. LOCATION: Sixth Floor Conference Room #520 Citywide Drainaige Maintenance Program (Dolbee) LUA10-089, ECF, CAR, SMF Location: Citywide. Description: The applicant has requested SEPA Environmental Review for continued maintenance of the Citywide stormwater infrastructure, including channels, ditches, catch basins, manholes, outfalls, pipes and culverts. These facilities are located in critical areas: including, the Cedar River, May Creek, Springbrook Creek, Thunder Hills Creek, Panther Creek, Ginger Creek, Maplewood Creek, Honey Creek, Greens Creek, Kennydale Creek, Gypsy Creek, Johns Creek, and Lake Washington. cc; D. Law, Mayor J. Covington, Chief Administrative Officer S. Dale Estey, CED Director W. Flora, Deputy Chief/Fire Marshal Richard Perteet, Deputy PW Administrator - Transportation C. Vincent, CED Planning Director 0 N. Watts, Development Services Director L. Warren, City Attorney F. Kaufman, Hearing Examiner D. Pargas, Assistant Fire Marshal J. Medzegian, Council DEPARTMENT OF COMMUNITY cityaf , , AND ECONOMIC DEVELOPMENT ENVIRONMENTAL REVIEW COMMITTEE REPORT ERC MEETING DATE: February 14, 2011 Project Name: Citywide Drainage Maintenance Program Owner/Applicant: City of Renton, 1055 South Grady Way, Renton, WA 98057 Contact: Hebe C. Bernardo, City of Renton Surface Water, 1055 South Grady Way, Renton, WA 98057 File Number: LUA10-089, ECF, CAR, SME Project Manager: Vanessa Dolbee, Senior Planner Project Summary: The applicant has requested SEPA Environmental Review for continued maintenance of the Citywide stormwater infrastructure, including channels, ditches, catch basins, manholes, outfalls, pipes and culverts. These facilities are located in critical areas: including, the Cedar River, May Creek, Springbrook Creek, Thunder Hills Creek, Panther Creek, Ginger Creek, Maplewood Creek, Honey Creek, Greens Creek, Kennydale Creek, Gypsy Creek, Johns Creek and Lake Washington. Some of these critical areas are Class 1 waters of the State, and would be subject to the Shoreline Management Program (SMP). As such the applicant has also requested a Shoreline Exemption and a Critical Areas Exemption for work in other critical areas that are not subject to the SMP regulations. The purpose of the Citywide maintenance program is to maintain existing drainage facilities in order to ensure their optimum performance, by protecting the facilities against accumulation of debris, sediment and vegetation. Project location: Citywide Exist. Bldg. Area SF: N/A Proposed New Bldg. Area (footprint): N/A Proposed New Bldg. Area (gross): N/A Site Area: N/A Total Building Area GSF: N/A STAFF Staff Recommends that the Environmental Review Committee issue a RECOMMENDATION: Determination of Non -Significance - Mitigated (DNS -M). Project Location Map FRC ReportL UA10-089. doc 0 0 City of Renton Department of Community & Economic Development Environmental Review Committee Report CITYWIDE DRAINAGE MAINTENANCE PROGRAM LUA10-089, ECF, CAR, SME Report of February 14, 2011 Page 2 of 7 PART ONE: PROJECT DESCRIPTION / BACKGROUND The applicant has requested SEPA Environmental Review of the Citywide Drainage Maintenance Program. This program is designed to be an ongoing program dedicated to maintaining existing drainage facilities (channels, ditches, catch basins, manholes, outfalls, pipes and culverts) that are located in streams, creeks, tributaries and rivers within the City. The drainage facilities are located in various locations along the Cedar River, May Creek, Springbrook Creek, Thunder Hills Creek, Panther Creek, Ginger Creek, Maplewood Creek, Honey Creek, Greens Creek, Kennydale Creek, Gypsy Creek, Johns Creek and Lake Washington. The Citywide Drainage Maintenance Program includes, but is not limited to the locations listed and described in Exhibit B. If areas within the City's Potential Annexation Area (PAA) become annexed to the City and drainage facilities are included as a part of such annexation, these facilities would be included in the subject Drainage Maintenance Program covered by this SEPA review. The duration of validity of the subject SEPA review shall be until conditions change and the proposed mitigation should be updated to reflect best available science and best management practices, as such staff recommends as a mitigation measure that the subject environmental review be re -reviewed in 10 -years to determine whether conditions have changed. The existing land use designation and zoning for the subject sites vary throughout the program area. However, the critical areas regulations and the Shoreline Master Program govern the actions of in -water work over zoning regulations. Ongoing maintenance is needed to preserve or restore the original function of the existing drainage facilities so the balanced use of the water resource continues as intended. The work needed to maintain the drainage facilities included in the proposed drainage maintenance program are described in Exhibit C. These tasks included cleaning the facilities to maintain structural integrity, flush or vactor - pipes manholes etc..., control vegetation, remove debris, and remove sediment. Sites included in the proposed maintenance program would be maintained from the existing right-of-way or easements dedicated to the City. No new access drives or roads would be required to be built as a part of any maintenance activities. Vegetation removal of grasses and shrubs may be necessary either for access purposes or because the vegetation is within the working area. The applicant proposes to keep vegetation removal to a minimum. The applicant has indicated that all native vegetation disturbed outside of work/access areas would be restored to pre -project conditions upon completion of maintenance activity. Renton Municipal Code section 4-3-050C.5.e.ii exempts routine maintenance activities from critical areas regulations for utilities where no alteration or additional fill materials will be placed other than the minimum alteration and/or fill needed to restore those facilities to meet established safety standards. RMC 4-3-050C.e.v permits the removal of vegetation including trees for public utilities maintenance activities including routine vegetation management. However, the removed trees shall be retained as large woody debris in the stream/buffer corridor, where feasible. Furthermore, RMC 4-3-050C.5.g.ii and 4- 4-130C.3 exempt maintenance of public utilities located in streams and the removal of trees within a stream buffer when associated with maintenance of a public utility. The City of Renton's Surface Water Utility has proposed to utilize the Regional Road Maintenance Endangered Species Act Program Guidelines to select and implement appropriate Best Management Practices to minimize the disruption to the natural environment. In addition, all applicable State and ERC ReportLUA10-089.doc City of Renton Department of Communit0conomic Development Eonmental Review Committee Report CITYWIDE DRAINAGE MAINTENANCE PROGRAM _ LUA10-089, ECF, CAR, SME Report of February 14, 2011 Page 3 of 7 Federal requirements associated with the Clean Water Act (CWA) and Appendix D of the 2009 Surface Water Design Manual would be met through planning, application, and monitoring of Best Management Practices (BMP's). All maintenance activities would comply with provisions to be imposed by the Washington State Department of Fish and Wildlife (WDFW) through the Hydraulic Project Approval (HPA) permit. Although maintenance activities may vary based on each specific site's condition, in general the following activities would take place: - Erosion control will be placed as needed around the work site and equipment. - Disturbance of riparian vegetation shall be limited to that which is necessary to conduct the maintenance. Affected critical area buffers would be restored to pre -project or improved habitat configuration following the maintenance activity. - If the stream is flowing at the time of maintenance, fish exclusion and stream bypass procedures would be put into place prior to any maintenance operations. A temporary bypass to divert flow around the work area would be in place prior to initiation of other work in the wetted perimeter. Upon completion of the project, all material used in the temporary bypass would be removed from the site and the site returned to pre -project or improved conditions. - All waste material such as debris, silt or excess dirt resulting from this project would be deposited above the limits of flood water in an approved upland disposal site. - Equipment used for maintenance would be checked daily for leaks and any necessary repairs would be completed prior to commencing maintenance activities along state waters. PART TWO: ENVIRONMENTAL REVIEW In compliance with RCW 43.210.240, the following environmental (SEPA) review addresses only those project impacts that are not adequately addressed under existing development standards and environmental regulations. A. Environmental Threshold Recommendation Based on analysis of probable impacts from the proposal, staff recommends that the Responsible Officials: Issue a DNS -M with a 14 -day Appeal Period. B. Mitigation Measures 1. The subject environmental review shall be re -reviewed in 10 -years to determine whether conditions have changed. Any new information should be submitted to the Planning division for review, at such time the Planning Director shall determine if a new SEPA review is warranted due to changes in conditions or if a SEPA Addendum is needed. 2. Any native vegetation, located outside the work/access area, that is damaged or disturbed during maintenance activities shall be restored and/or replanted immediately following the maintenance activity. 3. Any trees required to be removed shall be replanted within the stream buffer corridor or the snags shall be left within the stream buffer corridor following the maintenance activity. 4. The applicant shall comply with the Regional Road Maintenance Program (RRMP) as identified in the provided NMFS Endangered Species Act —Section 7 Biological Opinion. ERC ReportLUA10-089.doc • 0 City of Renton Department of Community & Economic Development Environmental Review Committee Report CITYWIDE DRAINAGE MAINTENANCE PROGRAM LUA10-089, ECF, CAR, SMF Report of February 14, 2011 Page 4 of 7 5. The Citywide Drainage Maintenance Program activities shall comply with the conditions of approval required as a part of the Hydraulic Project Approval (HPA) permit required to be issued by the Washington State Department of Fish and Wildlife (WDFW), including but not limited to maximum sediment removal, limits of work, and facility maintenance methods for each specific maintenance location. C. Exhibits Exhibit A Maintenance Location Map Exhibit B Drainage Facility Maintenance List Exhibit C Routine Maintenance Tasks Exhibit D Site Pictures D. Environmental Impacts The Proposal was circulated and reviewed by various City Departments and Divisions to determine whether the applicant has adequately identified and addressed environmental impacts anticipated to occur in conjunction with the proposed development. Staff reviewers have identified that the proposal is likely to have the following probable impacts: 1. Earth Impacts: The proposed Citywide Drainage Maintenance Program spans across the City, as such the soil types vary as well as slope for each particular site. Some drainage facilities may be located on slopes as steep as 40 percent. No fill or grading work is proposed as a part of the project, however accumulated sediment located in drainage faculties would be removed. All removed sediment would be loaded directly into awaiting dump trucks or vactor storage tanks. Removed sediments would then be transported off site and stockpiled for dewatering purposes. Stockpiled sediment would have appropriate BMP's in place to filter runoff from the dewatering process. Sediment disposal would be at an approved recycling/disposal facility. The proposed activities could result in erosion, however the applicant has proposed to utilize the Regional Road Maintenance Endangered Species Act Program Guidelines and Appendix D of the Surface Water Design Manual to select and implement appropriate BMP's, to minimize the disruption of the natural environment. BMP's would be chosen from the aforementioned manuals and guidelines that are nest suited for each specific maintenance site. Mitigation Measures: No further mitigation needed. Nexus: Not Applicable 2. Water a. Wetland, Streams, Lakes Impacts: The drainage facilities are located in various locations along the Cedar River, May Creek, Springbrook Creek, Thunder Hills Creek, Panther Creek, Ginger Creek, Maplewood Creek, Honey Creek, Greens Creek, Kennydale Creek, Gypsy Creek, Johns Creek and Lake Washington. These streams vary in classification however, maintenance of drainage facilities are exempt from the City of Renton's critical areas regulations. Work would be conducted within the stream channels and would include the removal of sediment and debris. Debris would be removed by hand, power tools, or by self-propelled machinery and sediment would be removed by Vactor, excavation, or ERC ReportLUA10-089.doc City of Renton Department of Community & Economic Development Environmental Review Committee Report CITYWIDE DRAINAGE MAINTENANCE PROGRAM LUA10-089, ECF, CAR, SME Report of February 14, 2011 Page 5 of 7 hand work. Sediment would be removed from sediment traps and from conveyance facilities in order for these facilities to maintain conveyance capacity. Furthermore, sediment ponds, culvert entries and tailouts, and sediment traps may require excavation in stream or near stream for routine maintenance. The applicant has proposed to isolate the work area from flowing water, and receiving streams would be protected from contaminants. In addition, the applicant has proposed to utilize the Regional Road Maintenance Endangered Species Act Program Guidelines to select and implement appropriate Best Management Practices to minimize the disruption to the natural environment. In addition, the applicant has proposed to comply with Appendix D of the 2009 King County Surface Water Design Manual (KCSWDM) to minimize impacts to the streams. Mitigation Measures: No further mitigation needed. Nexus: Not Applicable 3. Vegetation Impacts: The subject stream buffers and specific site locations will vary in terms of vegetative cover. However, at each site vegetation including grasses, shrubs, and trees may be required to be removed as necessary for access purposes or because the vegetation is within the working area. The applicant proposes to keep vegetation removal to a minimum and has indicated that all native vegetation disturbed outside of the work/access areas would be restored to pre -project conditions upon completion of the maintenance activity. RMC 4-3-050C.e.v permits the removal of vegetation including trees for public utilities maintenance activities including routine vegetation management. However, the removed trees shall be retained as large woody debris in the stream/buffer corridor, where feasible. Established trees, as well as large woody debris provide valuable fish and wildlife habitat, and should be retained if at all feasible, to reduce potential impacts. As such, staff recommends a mitigation measure that any native vegetation, located outside the work/access area, that is damaged or disturbed during maintenance activities shall be restored and/or replanted and any trees required to be removed shall be replanted or the snags shall be left within the stream buffer corridor. Mitigation Measures: 1) Any native vegetation, located outside the work/access area, that is damaged or disturbed during maintenance activities shall be restored and/or re -plated immediately following the maintenance activity. 2) Any trees required to be removed shall be replanted or the snags shall be left within the stream buffer corridor following the maintenance activity. Nexus: RMC 4-3-050 4. Wildlife Impacts: The subject maintenance activities would occur within streams therefore potentially impacting salmonids and other wildlife. However, maintenance of stormwater facilities is an essential function of their intended purpose. The applicant submitted with the application the Endangered Species Act — Section 7 Biological Opinion publication. This document summarizes the process and findings covered during the National Marine Fisheries Service (NMFS) review of the Regional Road Maintenance ESA Program (RRMP). The RRMP was developed with Washington ERC ReportLUA10-089.doc • • City of Renton Deportment of Community & Economic Development Environmental Review Committee Report CITYWIDE DRAINAGE MAINTENANCE PROGRAM LUA10-089, ECF, CAR, SME Report of February 14, 2011 Page 5 of 7 State and 24 Washington Counties and Cities, including the City of Renton. The document was developed so that routine road maintenance activities would be protective of salmonids and their habitat. The activities covered in this document include maintenance activities that are conducted on currently serviceable structures, facilities, and equipment, that do not involve expansion of or change in use, and do not result in significant negative hydrological impact. The proposed Citywide Drainage Maintenance Program would fall within the parameters of the provided Biological Opinion. The RRMP includes a biological review (BR) which concludes that the identified routine road maintenance activities conducted throughout Washington State under the RRMP will not impair properly functioning habitat, nor appreciably reduce the functioning of already impaired habitat, nor retard the long-term progress of impaired habitat toward persistence of properly functioning habitat conditions. The RRMP and its BR clearly identify anticipated impact to affected species likely to result from the proposed maintenance activities and identify measures that are necessary and appropriate to minimize those impacts. These effects include delivery of sediments to streams through routine road maintenance activities, vegetation removal, loss of large woody debris, and hydraulic modifications. As such, staff recommends as a mitigation measure that the applicant comply with the Regional Road Maintenance Program (RRMP) as identified in the provided NMFS Endangered Species Act — Section 7 Biological Opinion. The Muckleshoot Indian Tribe Fisheries Division provided comments on the subject application. Their comments addressed the importance of understanding which culverts in the City are barriers to fish. As well as identified the potential for cost savings, to the City, by replacing culverts that require a large amount of maintenance with a larger culvert that would allow for passage of debris as well as fish reducing the maintenance needs. While replacing new structures in particular locations throughout the City may be cost effective and at the same time improve fish passage, the subject project proposal does not consider the impacts of replacement or construction of any type of drainage facility. It should also be noted that if a culvert is replaced with a larger culvert a separate and complete set of permits would be required; however such facility would still require ongoing maintenance. If maintenance facilities are left un -maintained, sediment accumulation would reduce conveyance capacity, velocity, increase water temperature and block fish passage. Proper maintenance of drainage facilities would preserve or restore the original function of the existing drainage facilities so the balanced use of water resource continues as intended. Maintenance can also protect against collapse or failure of structures, which could result in significant sediment release to aquatic habitat. The proposed maintenance activities would have a positive impact to the aquatic habitat and would maintain fish passage. Furthermore, the Muckleshoot Indian Tribes Fisheries Division commented that a maximum amount of sediment removal should be identified at maintenance location where fish are present, in addition to limits of work. The City's Stormwater Division has been coordinating with the Washington State Department of Fish and Wildlife (WDFW) throughout the SEPA review process, to identify what conditions of approval would be applied to the required HPA permit for the subject work. It is anticipated that the future HPA would identify the maximum cubic yards of sediment removal, limits of work, and the method in which such facilities should be maintained. These conditions would limit potential impacts on fish habitat at the same time provided for the necessary conveyance capacity needed for the City's stormwater facility to function properly. As such, staff recommends a mitigation measure that the applicant shall comply with the conditions of approval included in the HPA permit required for the subject proposal. ERC Reportt UA10-089.doc 9 0 City of Renton Department of Community & Economic Development EnOro nmento] Review Committee Report CITYWIDE DRAINAGE MAINTENANCE PROGRAM L UA10-089, ECF, CAR, SME Report of February 14, 2011 Page 7 of 7 Mitigation Measures: 1) The applicant shall comply with the Regional Road Maintenance Program (RRMP) as identified in the provided NMFS Endangered Species Act—Section 7 Biological Opinion. 2) The Citywide Drainage Maintenance Program activities shall comply with the conditions of approval required as a part of the Hydraulic Project Approval (HPA) permit required to be issued by the Washington State Department of Fish and Wildlife (WDFW), including but not limited to maximum sediment removal, limits of work, and facility maintenance methods for each specific maintenance location. Nexus: SEPA, HFA E. Comments of Reviewing Departments The proposal has been circulated to City Department and Division Reviewers. Where applicable, their comments have been incorporated into the text of this report and/or "Advisory Notes to Applicant." 1 Copies of all Review Comments are contained in the Official File and may be attached to this report. Environmental Determination Appeal Process: Appeals of the environmental determination must be filed in writing on or before 5:00 PM, March 4, 7011. Renton Municipal Code Section 4-8-110.6 governs appeals to the Hearing Examiner. Appeals must be filed in writing at the City Clerk's office along with the required fee. Additional information regarding the appeal process may be obtained from the City Clerk's Office, Renton City Hall - 7th Floor, 1055 S. Grady Way, Renton WA 98057. ADVISORY NOTES TO APPLICANT The following notes are supplemental information provided in conjunction with the administrative land use action. Because these notes are provided as information only, they are not subject to the appeal process for the land use actions. Planning: RMC section 4-4-030.0.2 limits haul hours between 8:30 am to 3:30 pm, Monday through Friday unless otherwise approved by the Development Services Division. Parks: Recommend coordination with Parks and Golf Director prior to conducting work on Park managed City property and Parks Planning and Natural resources Director on open space/natural area City managed property. 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Q ) ) - ] £ _ LU } ) } z z } z z z 2[/ S22 \ \ \ z z U) z LU } ) ) ) ) ) m - zz z z z z ( / m m P r 2 )& .0 u o 0 0 0 k { ) f $ # r 2 7 7 _ z ) < < < = CE a a z » N �{ , } < & �ƒ/ \5 ��� /${\ U) \\\ a={e §�\3 ° oQ) /�f_ mEE��J /f - - {7� �`A° J£ §I§\2 -5 e±<< #)a 2)#) 2])§$ k)I|+ Primary common tasks are described in the following paragraphs. Minor of-$ it7tirovp_ tasks, although not explicitly described, are also to be covered in the Washington�g}�te' +`m ' r ), Department of Ecology programmatic HPA permit. Clean Drainage facilities included in Exhibit B will be cleaned to maintain an aesthetic appearance, to maintain structural and functional integrity, and to protect public health and safety. Cleaning will be accomplished by hand, by power tools, or by self-propelled machinery. Flushf Vactor Pipes, manholes, catch basins, culverts, will be flushed and vactored to remove sediment, contaminants, and debris. The vactor allows capture and appropriate disposal of material. Control Vegetation Vegetation will be controlled to maintain an aesthetic appearance, to maintain access, to maintain structural and functional integrity, to protect public health and safety, to control noxious weeds, and to enhance the environment. Vegetation will be mowed, trimmed, removed, planted, watered, or nurtured depending on the need. Work will be accomplished by hand, by power tools, or by self-propelled machinery. Notification / approval from Development Services is required prior to removal of any trees in critical areas and critical area buffers. Remove Debris Debris will be removed to maintain an aesthetic appearance, to maintain access, to maintain structural and functional integrity, to protect public health and safety, and to enhance the environment. Debris may be natural or man-made. Debris will be removed by hand, by power tools, or by self-propelled machinery. Remove Sediment: Sediment will be removed from sediment traps to maintain their capacity for trapping sediment. Sediment will be removed from conveyance facilities to maintain their conveyance capacity. Routine maintenance of instream components may require excavation near or in water i.e. instream, sediment ponds, culvert entries and tailouts, sediment traps. The work area will be isolated from flowing water with stream or groundwater flows bypassed around the site. Receiving streams will be protected from contaminants. Sediment traps or sumps at channel transitions will be up to seven times as long as the change in channel width. One or more of the following methods will be implemented to remove sediment from each work site outlined in Exhibit B. Method(s) to be used at each site are indicated in Exhibit B under the column heading of 'Sediment Removal Method (s)'. 0 • Vactor - Removal of sediment to be conducted with the use of a Vactor truck capable of vacuuming sediment directly from the site into a storage tank on the truck. Water accumulated through this process will be typically decanted onsite with filtration BMlys utilized before the water is allowed to re-enter the stream. • Excavator - Removal of sediment from the site through the use of an excavator or backhoe. Sediment will be deposited directly into awaiting dump trucks or temporarily stockpiled to allow= water within the sediment to drain off. All stockpiled materials will have approved BMP measures in place to prevent sediment laden waters from re- entering the site. Excavator operators will evaluate the site for access, enter and exit the site in a manner to prevent unnecessary damages to vegetation and stream banks and grade any ruts or other potential erosion concerns upon completion of the work. • Hand Work - In certain circumstances, hand work will be necessary to accomplish the job. This typically entails brushing of grasses, blackberries or other shrubs to clear the work zone prior to excavation or vactor activities. Hand work of this type will be restricted to the work area itself and all efforts will be taken to minimize unnecessary damages to surrounding vegetation. BM7s as needed will be utilized if the work bears erosion concerns to adjacent waters. 0 0 Site #1 Site #18 EXHIBIT D - SITE PICTURES Site #1 Site #18 city P�r�r?�,rrr �'�!nton ran DEC 2 � ftc[�Jw 'ea Site #1 Site #18 Site #20 Site #20 Site #20 0 0 Site #32 Site #33 Site #35 y.- Site #39 Site #32 Site #33 Site #35 Site #32 Site #33 E a Site #42 Site #43 Site # 44 Site #42 PRIZE Site #43 Site # 44 Site # 46 Site # 46 Site #42 Site # 44 Site # 48 Site # 49 Site # 50 Site # 51 0 0 Site # 48 Site # 49 - . k pill .9 r -FA Site # 50 Site # 51 044 A - Site # 48 Site # 49 Site # So 40 Site # 53 Site # 54 Site # 55 Site # 53 Site # 54 Site # 56 Site 56 0 Site 4 53 Site # 54 Site # 56 Site # 57 Site # 58 Site # 62 Site # 57 0 mw, r. • c: .sa..; r r Site #64 Site #64 Site #64 47 Site #65 Site #72 Site #73 0 0 A Site #71 Site #72 P -Ma Site #73 Site #71 Site #72 Site #73 Site #71 JK. A-4 Site #72 Site #73 0 0 A Site #71 Site #72 P -Ma Site #73 Site #71 Site #72 Site #73 Site #76 F-; tee. Site #77 Site #78 Site #80 Site #76 Site #77 Site #78 Site #80 0 Site #80 Site #82 Site #83 0 0 Site #82 Site #83 Site #82 City of Renton Deportment of Community & Economic Development ENVIRONMENTAL & DEVELOPMENT APPLICATION REVIEW SHEET REVIEWING DEPARTMENT: ' '�'� ' � COMMENTS DUE' JANUARY 1$r 2021 APPLICATION NO: LUA10-089, ECF, CAR, SME DATE CIRCULATED: JANUARY4, 2011 APPLICANT: City of Renton PROJECT MANAGER: Vanessa Dolbee PROJECT TITLE: Citywide Drainage Maintenance Program PROJECT REVIEWER: Kayren Kittrick SITE AREA: N/A EXISTING BLDG AREA (gross): N/A LOCATION: Citywide PROPOSED BLDG AREA (gross) N/A SUMMARY OF PROPOSAL: The applicant has requested SEPA Environmental Review for continued maintenance of the Citywide stormwater infrastructure, including channels, ditches, catch basins, manholes, outfalls, pipes and culverts. These facilities are located in critical areas including, the Cedar River, May Creek, Springbrook Creek, Thunder Hills Creek, Panther Creek, Ginger Creek, Maple Wood Creek, Honey Creek, Greens Creek, Kennydale Creek, Gypsy Creek, Johns Creek and Lake Washington. Some of these critical areas are Class 1 waters of the State, and would be subject to the Shoreline Management Program (SMP). As such the applicant has also requested a Shoreline Exemption and a Critical Areas Exemption for work in other critical areas that are not subject to the SMP regulations. The purpose of the Citywide maintenance program is to maintain existing drainage facilities in order to ensure their optimum performance, by protecting the facilities against accumulation of debris, sediment and vegetation. A. ENVIRONMENTAL IMPACT (e.g. Non -Code) COMMENTS Element of the Probable Probable More Environment Minor Major information Impacts Impacts Necessary Earth Air Water Plants Land/Shoreline Use Animals Environmental Health Energy/ Natural Resources Element of the Probable Probable More Environment Minor Major information Impacts impacts Necessary Housing Aesthetics Li h Glare Recreation Utilities Transportation Public Services Historic/Cultural Preservation Airport Environment 10,000 Feet 14,000 Feet B. POLICY -RELATED COMMENTS C. CODE -RELATED COMMENTS We have reviewed this application with particular attention to those areas in which we have expertise and have identified areas of probable impact or areas where additional information is nqeded to properly assess this proposal. i Signature of Dire r or Authorized Representative Date i 0 Vanessa Do.lbee L0,4 - 01,'o � From: Vanessa Dolbee Sent: Thursday, January 27, 2011 1:05 PM To: 'Karen Walter' Cc: Hebe Bernardo Subject: FW: Muckleshoot comments/questions - responses Karen, Please find responses to your questions below, in blue_ I also left you a voice mail today to talk about the project further. If you can return my call before Monday afternoon (3:00 pm) that would be fantastic. Thank you, Vanessa (Dof6ee Senior Planner Department of Community & Economic Development City of Renton Renton City Hall - 5th Floor 1055 South Grady Way Renton, WA 98057 425.430.7314 1. What is Exhibit C referenced on page 2 of the checklist? Exhibit C - Routine Maintenance Task describes the activities that may be performed as needed on sites throughout the City. Please find Exhibit C attached. << File: Exhibit C.pdf >> 2. Please note that NMFS' Biological Opinion and Magnuson -Stevens Fishery Conservation and Management Act Consultation document for the Regional Road Maintenance Program cited as environmental information related to this project does not address potential impacts to Puget Sound steelhead or bull trout; two species that may be found within the action area. The Biological Opinion and (Magnuson -Stevens Fishery Conservation and Maragernent Act Consultation analyzed the effects of the maintenance activities on salmonid and their habitat statewide, including the Puget Sound. The City will implement best manages'Ient practices (MBPS) in accordance with the Regional Road Maintenance BMPs as a mitigation measure for all maintenance activities throughout the City to ensure that protection to ALL stream habitat including steelhead or bull trout is provided. This will maintain the balance between protection of stream corridors habitat and maintenance of drainage facilities so they continue to function as originally designed, permitted and constructed. 1 0 0 3. When does the City anticipate to have completed a survey of all of its culverts for potential fish passage barriers? As noted below, the Cedar River and May Creek basin plans did not include comprehensive culvert surveys for fish passage barriers. The Citywide Drainage Maintenance Program is a program dedicated to maintaining existing drainage facilities that are located in critical areas, as necessary to restore the original function so it continues to function as designed, permitted and constructed. The subject project proposal does not consider activities other than maintenance (such as culvert replacement), therefore does not consider the impacts of replacement or construction of any new drainage facility. A comprehensive culvert survey for fish passage barriers is not within the scope of this proposal. Proposals resulting in culvert replacement will require a separate and complete set of permits and a separate SEPA review process; however such facility would still require ongoing maintenance to assure optimum performance. 4. We appreciate the City's general assessment of potential problems to fish and their habitats from sediment accumulation; however, we would like to know what specific data the City has to demonstrate that all of the proposed culverts to be maintained are currently blocking fish passage as a result of sediment accumulation. From the photos in Exhibit D, it appears that Sites 44, 49, 54, and 71 may qualify as such sites; however, without more data regarding the dimensions of the existing culverts, the average bankfull channel width, the contributing basin area, the 2 yr, 10 yr, and 25 yr flood elevations, the baseflow elevations, and the amount of sediment compared to the culvert inlet and outlets, it is very difficult to tell if these culverts are barriers to fish passage as a result of sediment accumulation or due to undersized culverts. The City should provide the necessary data to support the responses below. See response 3 above. Also, this project proposal is Citywide Program applicable to existing drainage facilities located in critical areas. Attachment D represent current conditions of some locations in the City were maintenance activities are currently needed. However, all the City's existing stormwater facilities do not currently need maintenance but within a few years may need maintenance. As such, the images provided in Attachment D do not represent the condition of the site at the time in which maintenance would be performed. Maintenance would not be performed at sites where maintenance is not needed. Attachment D does not include all locations included in this project proposal. In the future, maintenance of additional drainage facilities (with similar characteristics as the ones included in exhibit D and exhibit B) may be needed to maintain optimum performance. All maintenance activities will be performed in accordance with the RRMP (Regional Road Maintenance Program), the SEPA determination and the requirements included in the HPA required for that facility. 5. We are concerned that there is a lack of data or information to support the contention that the maintenance activities will have a positive impact on aquatic habitat. For example, Site 73 appears to involve the instream sediment pond constructed with Madsen Creek back in the early 1990's by King County as a flood control project. As shown in the pictures, it appears that this site is providing current fish habitat that could be lost or impaired by the proposal to remove sediment and debris at this site. The amount and type of sediment and debris to be removed is not described and cannot be evaluated against existing conditions and any proposed best management practices intended to mitigate for impacts because the details are not discussed in the SEPA materials. Likewise, Site 54 proposes to remove debris and sediment from what appears to be John's Creek, a stream known to be used by juvenile Chinook because of its low velocity and streambed conditions. Removing debris and sediment from this site will likely adversely affect the habitat conditions preferred by juvenile Chinook. The projects listed in Exhibit B should quantify and discuss the type of materials (i.e. sediment, debris, vegetation, etc) to be removed from each site so that site specific and cumulative impacts can be assessed. Site 73 (Madsen Creek Sediment Pond) is currently under the approval of HPA permit 117208-1 expiring May 12,2014. Maintenance activities in Madsen Creek Sediment Pond will comply with 2 0 0 the provisions includeC in -he current HPA Permit :and =L ture €r;cdifications to tie per :-lit. Sediment re€rcval and other maintenance activities will be conduct:d as needed and as aliorjed on the HPA expected to be obtained for each location. The propose mainterance activities are likely to have beneficial effects; clearing out sediment and de�ris from drairiage systems provides benefits to salmon habitat by preventing pollutants and sediments entrapped in stormwater facilities from entering surface or greundt,nater. 6. The City's responses below refer to compliance with a Memorandum of Understanding with the Washington Department of Fish and Wildlife. what is the MOU? What are the compliance provisions that will be followed? Refers to the provisions expected to be included in the Programmatic HPA Project Approval specific for identified drainage facilities. The subject SEPA review shall be completed prior to HPA approval. 7. Vegetation control is proposed at several sites that show open channels (i.e. 1, 23, 50, 53 etc.) where it appears there is existing vegetation providing shade. What analysis has the City completed to demonstrate that removing vegetation at the sites proposed in Exhibit B will not increase water temperatures and adversely affect salmonids? Vegetation will be controlled to maintain access; and to maintain structural and functional integrity so the facility continues to work as designed and constructed. Vegetation Control will not result in removing native trees along creek and river banks. In locations where removal of vegetation is necessary for access or to maintain structural integrity and function of the drainage facility; the City will comply with mitigation measures such as replanting of vegetation. The primary purpose of vegetation maintenance is to promote, maintain, sustain, manage, or encourage vegetation growth within the Right of Way (ROW) to comply with a variety of regulations and standards. Activities include suppressing non - desirable vegetation and enhancing desirable vegetation. No vegetation would be removed outside of the access and maintenance area. 8. Our third question below regarding the City's records indicating which culverts require frequent maintenance of sediment and wood removal actions was not directly answered. We expected a more direct response, including the data regarding the frequency of maintenance for the culverts in Exhibit B to determine if they should be replaced instead of prolonged through an ongoing maintenance program. We would appreciate the City's direct response to this question and the data to demonstrate how often each of the culverts in Exhibit B has required maintenance. See response 3 above. Also, City records of HPAs obtained in the past years demonstrates the low frequency of maintenance performed on drainage facilities (other than sediment ponds) located in critical areas. Past practices of the Surface Water Utility were to start a permitting process (including SEPA review) that would allow for maintenance of the identified facilities on individual bases. This project proposal will provide the City the ability to obtain a HPA Permits for drainage facilities (with similar characteristics and maintenance requirements as the sites included in exhibit A) where the City has identified the need for maintenance without going through an individual SEPA review process. Thank you and please let me know if you have any additional questions Hebe C. Bernardo Civil Engineer II City of Renton j Public Works I Surface Water Utility 1055 S. Grady Way 15th Floor I Renton, WA 98057 Direct: 425.430.7264 << OLE Object: Picture (Device Independent Bitmap)» 3 0 0 From: Vanessa Dolbee [VDolbee@Rentonwa.gov) Sent: Thursday, January 20, 2011 9:45 AM To: Karen Walter Subject: FW: Citywide Drainage Maintenance Program, LUA10-089, ECF, CAR, SME, Notice of Application and Proposed Determination of Non -Significance (DNS -M) Karen, Please find below, in blue, responses to your two outstanding questions . As you know, if you have any additional questions please feel free to ask. Regards, Vanessa Dolbee Senior Planner Department of Community & Economic Development City of Renton Renton City Hall - 6th Floor 1055 South Grady Way Renton, WA 98057 425.430.7314 From: Hebe Bernardo Sent: Wednesday, January 19, 2011 4:12 PM To: Vanessa Dolbee Subject: FW: Citywide Drainage Maintenance Program, LUA10-089, ECF, CAR, SME, Notice of Application and Proposed Determination of Non -Significance (DNS -M) Below are my answers (in blue) to Karen's questions. 2. As noted in the environmental checklist, culverts are one type of drainage facility that will be covered by this program. Has the City completed a comprehensive survey to determine which culverts in the proposed project area are barriers to fish? It is important to have this information to determine how the proposed maintenance activities may affect fish passage (both positively and negatively). Through Cedar River Basin Plan and May Creek Basin Plan, the City has identified culverts as fish passage. Not all the culverts in the City have been reviewed to determine which culverts are barriers to fish . In future culvert replacement CIP Projects, habitat surveys will be conducted upstream from fish barriers to help us obtain a design that have the most benefit to fish. Sediment accumulation reduces conveyance capacity, velocity, increases water temperature, and blocks fish passage. Proper maintenance of drainage facilities will preserve or restore the original function of the existing drainage facilities so the balanced use of the water resource continues as intended. Maintenance will also protect against collapse or failure of structures, which could result in significant sediment releases to aquatic habitat. The 4 0 0 proposed maintenance activities will have a positive impact to the aquatic habitat and will maintain fish passage. All applicable state and federal requirements associated with the Clean Water Act (CWA) and Appendix D of the 2009 Surface Water Design Manual will be met through planning, application, and monitoring of Best Management Practices (BMP's). Activities will comply with provisions described in the Memorandum of Understanding with WDFW. 3. Does the City have records indicating which culverts require frequent maintenance of sediment and wood removal actions? If so, this information should be identified discussed as it is likely more cost effective to replace these culverts with larger structures to avoid continued on-going maintenance. Fish would also like benefit from repairs of these culverts as they tend to block passage, trap sediment and wood necessary for downstream habitat In locations where maintenance activities are occurring too frequent and is determined that replacing the culvert will solve the problem and is cost effective, the culvert will be replaced as part of a CIP project. Replacing the Culver with larger structures will not eliminate the need for maintenance and therefore the need to obtain federal and state permits. Ongoing maintenance is required for all drainage facilities. Due to different mitigation measures, permit requirements and project cost; locations where culvert replacement and other construction activities have been identified are not included as part of this proposal. Thank you and please let me know if you have any additional questions. Hebe C. Bernardo Civil Engineer II City of Renton I Public Works Surface Water Utility 1055 S. Grady Way 15th Floor Renton, WA 98057 Direct: 425.430.7264 [cid:image001.jpg@01CBB7C1.15307720] From: Karen Walter[mailto:KWalter@muckleshoot.nsn.us] Sent: Friday, January 14, 2011 4:01 PM To: Vanessa Dolbee Cc: tarry Fisher Subject: Citywide Drainage Maintenance Program, LUA10-089, ECF, CAR, SME, Notice of Application and Proposed Determination of Non -Significance (DNS -M) Vanessa, The Muckleshoot Indian Tribe Fisheries Division has reviewed the Notice of Application Materials for the above referenced project. We need additional information to fully evaluate this proposal and also have some initial questions as noted below: 1. we need a copy of Exhibit B that has examples of the specific maintenance work activities to be performed at a specific location. Our packet was missing this Exhibit. 5 2. As noted in the environmental checklist, culverts are one type of drainage facility that will be covered by this program. Has the City completed a comprehensive survey to determine which culverts in the proposed project area are barriers to fish? It is important to have this information to determine how the proposed maintenance activities may affect fish passage (both positively and negatively). 3. Does the City have records indicating which culverts require frequent maintenance of sediment and wood removal actions? If so, this information should be identified discussed as it is likely more cost effective to replace these culverts with larger structures to avoid continued on-going maintenance. Fish would also like benefit from repairs of these culverts as they tend to block passage, trap sediment and wood necessary for downstream habitat. We appreciate the opportunity to review this proposal and may have comments subsequently once we have received the requested information and responses to our questions. Thank you, Karen Walter Watersheds and Land Use Team Leader Muckleshoot Indian Tribe Fisheries Division 39015 172nd Ave SE Auburn, WA 98092 253-876-3116 << File: image001.jpg » 6 Vanessa Dolbee CIA-'� From: Karen Walter [KWalter@muckleshoot.nsn.us] Sent: Friday, January 21, 2011 2:07 PM To: Vanessa Dolbee Cc: Larry, Fisher@dfw.wa.gov Subject: RE: Citywide Drainage Maintenance Program, LUA10-089, ECF, CAR, SME, Notice of Application and Proposed Determination of Non -Significance (DNS -M) Attachments: image001.jpg Follow Up Flag: Follow up Flag Status: Flagged Vanessa, Thank you for sending the City's responses to our questions below and for sending a copy of Exhibit D (Site photos) electronically. We have reviewed all of this information for the above referenced project and offer the following comments and follow-up questions. 1. What is Exhibit C referenced on page 2 of the checklist? 2. Please note that NMFS' Biological Opinion and Magnuson -Stevens Fishery Conservation and Management Act Consultation document for the Regional Road Maintenance Program cited as environmental information related to this project does not address potential impacts to Puget Sound steelhead or bull trout; two species that may be found within the action area. 3. When does the City anticipate to have completed a survey of all of its culverts for potential fish passage barriers? As noted below, the Cedar River and May Creek basin plans did not include comprehensive culvert surveys for fish passage barriers. 4. We appreciate the City's general assessment of potential problems to fish and their habitats from sediment accumulation; however, we would like to know what specific data the City has to demonstrate that all of the proposed culverts to be maintained are currently blocking fish passage as a result of sediment accumulation. From the photos in Exhibit D, it appears that Sites 44, 49, 54, and 71 may qualify as such sites; however, without more data regarding the dimensions of the existing culverts, the average bankfull channel width, the Contributing basin area, the 2 yr, 10 yr, and 25 yr flood elevations, the baseflow elevations, and the amount of sediment compared to the culvert inlet and outlets, it is very difficult to tell if these culverts are barriers to fish passage as a result of sediment accumulation or due to undersized culverts. The City should provide the necessary data to support the responses below. 5. We are concerned that there is a lack of data or information to support the contention that the maintenance activities will have a positive impact on aquatic habitat. For example, Site 73 appears to involve the instream sediment pond constructed with Madsen Creek back in the early 1990's by King County as a flood control project. As shown in the pictures, it appears that this site is providing current fish habitat that could be lost or impaired by the proposal to remove sediment and debris at this site. The amount and type of sediment and debris to be removed is not described and cannot be evaluated against existing conditions and any proposed best management practices intended to mitigate for impacts because the details are not discussed in the SEPA materials. Likewise, Site 54 proposes to remove debris and sediment from what appears to be john's Creek, a stream known to be used by juvenile Chinook because of its low velocity and streambed conditions. Removing debris and sediment from this site will likely adversely affect the habitat conditions preferred by juvenile Chinook. The projects listed in Exhibit B should quantify and discuss the type of materials (i.e. sediment, debris, vegetation, etc) to be removed from each site so that site specific and cumulative impacts can be assessed. 1 • 6. The City's responses below refer to compliance with a Memorandum of Understanding with the Washington Department of Fish and Wildlife. What is the MOU? What are the compliance provisions that will be followed? 7. Vegetation control is proposed at several sites that show open channels (i.e. 1, 23, 50, 53 etc.) where it appears there is existing vegetation providing shade. What analysis has the City completed to demonstrate that removing vegetation at the sites proposed in Exhibit B will not increase water temperatures and adversely affect salmonids? 8. Our third question below regarding the City's records indicating which culverts require frequent maintenance of sediment and wood removal actions was not directly answered. We expected a more direct response, including the data regarding the frequency of maintenance for the culverts in Exhibit B to determine if they should be replaced instead of prolonged through an ongoing maintenance program. We would appreciate the City's direct response to this question and the data to demonstrate how often each of the culverts in Exhibit B has required maintenance. We appreciate the City's prompt responses to our previous questions and requests for information cited but not included in our SEPA packet. We look forward to the City's responses to these follow-up questions and concerns. Thank you, Karen Walter Watersheds and Land Use Team Leader Muckleshoot Indian Tribe Fisheries Division 39015 172nd Ave SE Auburn, WA 98092 253-876-3116 From: Vanessa Dolbee [VDolbee@Rentonwa.gov] Sent: Thursday, January 20, 2011 9:45 AM To: Karen Waiter Subject: FW: Citywide Drainage Maintenance Program, LUA10-089, ECF, CAR, SME, Notice of Application and Proposed Determination of Non -Significance (DNS -M) Karen, Please find below, in blue, responses to your two outstanding questions . As you know, if you have any additional questions please feel free to ask. Regards, Vanessa Dolbee Senior Planner Department of Community & Economic Development City of Renton Renton City Hall - 6th Floor 1055 South Grady Way Renton, WA 98057 425.430.7314 2 From: Hebe Bernardo 0 Sent: Wednesday, January 19, 011 4:12 PM To: Vanessa Dolbee Subject: FW: Citywide Drainage Maintenance Program, LUA1e-o89, ECF, CAR, SME, Notice of Application and Proposed Determination of Non -Significance (DNS -M) Below are my answers (in blue) to Karen's questions. 2. As noted in the environmental checklist, culverts are one type of drainage facility that will be covered by this program. Has the City completed a comprehensive survey to determine which culverts in the proposed project area are barriers to fish? It is important to have this information to determine how the proposed maintenance activities may affect fish passage (both positively and negatively). Through Cedar River Basin Plan and May Creek Basin Plan, the City has identified culverts as fish passage. Not all the culverts in the City have been reviewed to determine which culverts are barriers to fish . In future culvert replacement CIP Projects, habitat surveys will be conducted upstream from fish barriers to help us obtain a design that have the most benefit to fish. Sediment accumulation reduces conveyance capacity, velocity, increases water temperature, and blocks fish passage. Proper maintenance of drainage facilities will preserve or restore the original function of the existing drainage facilities so the balanced use of the water resource continues as intended. Maintenance will also protect against collapse or failure of structures, which could result in significant sediment releases to aquatic habitat. The proposed maintenance activities will have a positive impact to the aquatic habitat and will maintain fish passage. All applicable state and federal requirements associated with the Clean Water Act (CWA) and Appendix D of the 2009 Surface Water Design Manual will be met through planning, application, and monitoring of Best Management Practices (BMP's). Activities will comply with provisions described in the Memorandum of Understanding with WDFW. 3. Does the City have records indicating which culverts require frequent maintenance of sediment and wood removal actions? If so, this information should be identified discussed as it is likely more cost effective to replace these culverts with larger structures to avoid continued on-going maintenance. Fish would also like benefit from repairs of these culverts as they tend to block passage, trap sediment and wood necessary for downstream habitat In locations where maintenance activities are occurring too frequent and is determined that replacing the culvert will solve the problem and is cost effective, the culvert will be replaced as part of a CEP project. Replacing the culver with larger structures will not eliminate the need for maintenance and therefore the need to obtain federal and state permits. ongoing maintenance is required for all drainage facilities. Due to different mitigation measures, permit requirements and project cost; locations where culvert replacement and other construction activities have been identified are not included as part of this proposal. Thank you and please let me know if you have any additional questions. 3 Hebe C. Bernardo Civil Engineer II City of Renton I Public Works Surface Water Utility 1055 S. Grady Way 15th Floor f Renton, WA 98057 Direct: 425.430.7264 [cid:image001.jpg@01CBB7C1.15307720] From: Karen Walter[mailto:KWalter@muckleshoot.nsn.us] Sent: Friday, January 14, 2011 4:01 PM To: Vanessa Dolbee Cc: Larry Fisher Subject: Citywide Drainage Maintenance Program, LUA10-089, Application and Proposed Determination of Non -Significance ECF, CAR, SME, Notice of (DNS -M) Vanessa, The Muckleshoot Indian Tribe Fisheries Division has reviewed the Notice of Application Materials for the above referenced project. we need additional information to fully evaluate this proposal and also have some initial questions as noted below: 1. We need a copy of Exhibit B that has examples of the specific maintenance work activities to be performed at a specific location. our packet was missing this Exhibit. 2. As noted in the environmental checklist, culverts are one type of drainage facility that will be covered by this program. Has the City completed a comprehensive survey to determine which culverts in the proposed project area are barriers to fish? It is important to have this information to determine how the proposed maintenance activities may affect fish passage (both positively and negatively). 3. Does the City have records indicating which culverts require frequent maintenance of sediment and wood removal actions? If so, this information should be identified discussed as it is likely more cost effective to replace these culverts with larger structures to avoid continued on-going maintenance. Fish would also like benefit from repairs of these culverts as they tend to block passage, trap sediment and wood necessary for downstream habitat. We appreciate the opportunity to review this proposal and may have comments subsequently once we have received the requested information and responses to our questions. Thank you, Karen Walter Watersheds and Land Use Team Leader Muckleshoot Indian Tribe Fisheries Division 39015 172nd Ave SE Auburn, WA 98092 253-876-3116 4 a Vanessa Dolbee From: Vanessa Dolbee Sent: Friday, January 21, 2011 7:66 AM To: 'Karen Walter Subject: RE: Citywide Drainage Maintenance Program, LUA10-089, ECF, CAR, SME, Notice of Application and Proposed Determination of Non -Significance (DNS -M) Attachments: Exhibit D.PDF Karen, Please find attached a copy of Exhibit D for LUA10-089. Vanessa Dolbee Senior Planner Department of Community & Economic Development City of Renton Renton City Hall. - 6th Floor 1055 South Grady Way Renton, WA 98057 425.430.7314 -----Original Message ----- From: Karen Walter mailto:KWalter uckleshoot.nsn.us Sent: Thursday, January 20, 2011 1:49 PM To: Vanessa Dolbee Subject: RE: Citywide Drainage Maintenance Program, LUA10-089, ECF, CAR, SME, Notice of Application and Proposed Determination of Non -Significance (DNS -M) Vanessa, Thank you for your email and for sending Exhibit B. The Table, Exhibit B, also references Exhibit D, which apparently is photos of each of the sites to be maintained. Is it possible for us to get a copy of Exhibit D, too? It will facilitate our review. Thank you, Karen Walter Watersheds and Land Use Team Leader Muckleshoot Indian Tribe Fisheries Division 39015 172nd Ave SE Auburn, WA 98092 253-876-3116 From: Vanessa Dolbee [VDolbee@aRentonwa.gov] Sent: Wednesday, January 19, 2011 9:56 AM To: Karen Walter Subject: RE: Citywide Drainage Maintenance Program, LUA10-089, ECF, CAR, SME, Notice of Application and Proposed Determination of Non -Significance (DNS -M) Karen, 1 Vanessa Dolbee From: Vanessa Dolbee Sent: Wednesday, January 19, 2011 9:56 AM To: 'Karen Walter Subject: RE: Citywide Drainage Maintenance Program, LUA10-089, ECF, CAR, SME, Notice of Application and Proposed Determination of Non -Significance (DNS -M) Attachments: Exhibit B.pdf Karen, Please find attached a copy of Exhibit S, as requested. Staff is compiling information to respond to your questions below, and will have a response foryou in the near future. Thank you for your questions/comments. Vanessa (D&Wee Senior Planner Department of Community & Economic Development City of Renton Renton City Hall - 6th Floor 1055 South Grady Way Renton, WA 98057 425.430.7314 From: Karen Waiter mailto:KWalter muckleshoot.nsn.us Sent: Friday, January 14, 20114:01 PM To: Vanessa Dolbee Cc: Larry Fisher Subject: Citywide Drainage Maintenance Program, LUA10-089, ECF, CAR, SME, Notice of Application and Proposed Determination of Non -Significance (DNS -M) Vanessa, The Muckleshoot Indian Tribe Fisheries Division has reviewed the Notice of Application Materials for the above referenced project. We need additional information to fully evaluate this proposal and also have some initial questions as noted below: 1. We need a copy of Exhibit B that has examples of the specific maintenance work activities to be performed at a specific location. Our packet was missing this Exhibit. 2. As noted in the environmental checklist, culverts are one type of drainage facility that will be covered by this program. Has the City completed a comprehensive survey to determine which culverts in the proposed project area are barriers to fish? It is important to have this information to determine how the proposed maintenance activities may affect fish passage (both positively and negatively). 3. Does the City have records indicating which culverts require frequent maintenance of sediment and wood removal actions? If so, this information should be identified discussed as it is likely more cost effective to replace these culverts with larger structures to avoid continued on-going maintenance. Fish would also like benefit from repairs of these culverts as they tend to block passage, trap sediment and wood necessary for downstream habitat. We appreciate the opportunity to review this proposal and may have comments subsequently once we have received the requested information and responses to our questions. Thank you, Karen Walter Watersheds and Land Use Team Leader Muckleshoot Indian Tribe Fisheries Division 39015 172nd Ave SE Auburn, WA 98092 253-876-3116 E Vanessa Dolbee From: Vanessa Dolbee Sent: Thursday, January 20, 2011 9:45 AM To: 'Karen Walter Subject: FW: Citywide Drainage Maintenance Program, LUA10-089, ECF, CAR, SME, Notice of Application and Proposed Determination of Non -Significance (DNS -M) Ka ren, Please find below, in blue, responses to your two outstanding questions , As you know, if you have any additional questions please feel free to ask. Regards, Vanessa 1Oofbee Senior Planner Department of Community & Economic Development City of Renton Renton City Hall - 6th Floor 1055 South Grady Way Renton, WA 98057 425.430.7314 From: Hebe Bernardo Sent: Wednesday, January 19, 20114:12 PM To: Vanessa Dolbee Subject: FW: Citywide Drainage Maintenance Program, LUA10-089, ECF, CAR, SME, Notice of Application and Proposed Determination of Non -Significance (DNS -M) Below are my answers (in blue) to Karen's questions. 2. As noted in the environmental checklist, culverts are one type of drainage facility that will be covered by this program. Has the City completed a comprehensive survey to determine which culverts in the proposed project area are barriers to fish? It is important to have this information to determine how the proposed maintenance activities may affect fish passage (both positively and negatively). Through Cedar River Basin Plan and May Creek Basin Plan, the City has identified culverts as fish passage, Not all the culverts in the City have been reviewed to determine which culverts are barriers to fish. In future culvert replacement CIP Projects, habitat surveys will be conducted upstream from fish barriers to help us obtain a design that have the most benefit to fish. Sediment accumulation reduces conveyance capacity, velocity, increases water temperature, and blocks fish passage. Proper maintenance of drainage facilities will preserve or restore the original function of the existing drainage facilities so the balanced use of the water resource continues as intended. Maintenance will also protect against collapse or failure of structures, which could result in significant sediment releases to aquatic habitat. The proposed maintenance activities will have a positive impact to the aquatic habitat and will maintain fish passage. All applicable stated faderal requirements associated with the Glean WaterAct (CWA) and Appendix D of the 2009 Surface Water Design Manual witl be n7et through planning, application, and monitoring of Best Management Practices (BMP's). Activities will comply with provisions described in the Memorandum of Understanding with WDFW. 3. Does the City have records indicating which culverts require frequent maintenance of sediment and wood removal actions? If so, this information should be identified discussed as it is likely more cost effective to replace these culverts with larger structures to avoid continued on-going maintenance. Fish would also like benefit from repairs of these culverts as they tend to block passage, trap sediment and wood necessary for downstream habitat In locations where maintenance activities are occurring too frequent and is determined that replacing the culvert will solve the problem and is cost effective, the culvert will be replaced as part of a C1P project. Replacing the culver with larger structures will not eliminate the need for maintenance and therefore the need to obtain federal and state permits. Ongoing maintenance is required for all drainage facilities. Due to different mitigation measures, permit requirements and project cost; locations where culvert replacement and other construction activities have been identified are not inciuded as part of this proposal. Thank you and please let me know if you have any additional questions. HeW C. Bernardo Civil Engineer I1 City of Renton i Public Works I Surface WateF Utility 1055 S. Grady Way 15th Floor I Renton, WA 98457 Direct: 425.430.7264 -"W— rrrY From: Karen Walter[mailto:KWalter@muckleshoot.nsn.us] Sent: Friday, January 14, 20114:01 PM To: Vanessa Dolbee Cc: Larry Fisher Subject: Citywide Drainage Maintenance Program, LUA10-089, ECF, CAR, SME, Notice of Application and Proposed Determination of Non -Significance (DNS -M) Vanessa, The Muckleshoot Indian Tribe Fisheries Division has reviewed the Notice of Application Materials for the above referenced project. We need additional information to fully evaluate this proposal and also have some initial questions as noted below: 1. We need a copy of Exhibit B that has examples of the specific maintenance work activities to be performed at a specific location. Our packet was missing this Exhibit. 2. As noted in the environmental checklist, culverts are one type of drainage facility that will be covered by this program. Has the City completed a comprehensive survey to determine which culverts in the proposed project area are barriers to fish? It is important to have this information to determine how the proposed maintenance activities may affect fish passage (both positively and negatively). 3. Does the City have records indicating which culverts require frequent maintenance of sediment and wood removal actions? If so, this information should be identified discussed as it is likely more cost effective to replace these culverts with larger structures to avoid continued on-going maintenance. Fish would also like benefit from repairs of these culverts as they tend to block passage, trap sediment and wood necessary for downstream habitat. We appreciate the opportunity to r this proposal and may have commentslosequently once we have received the requested information and respon*ol our questions. Thank you, Karen Walter Watersheds and Land Use Team Leader Muckleshoot Indian Tribe Fisheries Division 39015 172" d Ave SE Auburn, WA 98092 253-876-3116 0 0 City of Renton Department of Community & Economic Development ENVIRONMENTAL & DEVELOPMENT APPLICATION REVIEW SHEET REVIEWING DEPARTMENT: COMMENTS DUE: JANUARY 18, 2011 APPLICATION NO: LUA10-089, ECF, CAR, SME DATE CIRCULATED: JANUARY 4, 2011 APPLICANT: City of Renton PROJECT MANAGER: Vanessa Dolbee PROJECT TITLE: Citywide Drainage Maintenance Program PROJECT REVIEWER: Kayren Kittrick SITE AREA: N/A EXISTING BLDG AREA (gross): N/A LOCATION: Citywide PROPOSED BLDG AREA (gross) N/A SUMMARY OF PROPOSAL: The applicant has requested SEPA Environmental Review for continued maintenance of the Citywide stormwater infrastructure, including channels, ditches, catch basins, manholes, outfalls, pipes and culverts. These facilities are located in critical areas including, the Cedar River, May Creek, Springbrook Creek, Thunder Hills Creek, Panther Creek, Ginger Creek, Maple Wood Creek, Honey Creek, Greens Creek, Kennydale Creek, Gypsy Creek, Johns Creek and Lake Washington. Some of these critical areas are Class 1 waters of the State, and would be subject to the Shoreline Management Program (SMP). As such the applicant has also requested a Shoreline Exemption and a Critical Areas Exemption for work in other critical areas that are not subject to the SMP regulations. The purpose of the Citywide maintenance program is to maintain existing drainage facilities in order to ensure their optimum performance, by protecting the facilities against accumulation of debris, sediment and vegetation. A. ENVIRONMENTAL IMPACT (e.g. Non -Code) COMMENTS Element of the Probable Environment Minor Impacts Probable More Major information Impacts Necessary Earth Air Water Plants Land Shoreline Use Animals !_nvirownental Health Energy/ Natural Resources B. POLICY -RELATED COMMENTS C. CODE -RELATED COMMENTS Element of the Probable Probable More Environment Minor Major information Impacts Impacts Necessary Hovsin Aesthetics Light/Glare Recreation Utilities Transportation Public Services Historic/Cultural Preservation Airport Environment 10,000 Feet 14,0OD Feet We have reviewed this application with particular attention to those areas in which we have expertise and have identified areas of probable impact or areas where additional information is needed to properly assess this proposal. Z7r Signature of Director or Authorized Representative Date • i City of Renton Department of Community & Economic Development ENVIRONMENTAL & DEVELOPMENT APPLICATION REVIEW SHEET REVIEWING DEPARTMENT:�`_ COMMENTS DUE: JANUARY 18, 2011 APPLICATION NO: LUA10-089, ECF, CAR, SME DATE CIRCULATED: JANUARY4, 2011 APPLICANT: City of Renton PROJECT MANAGER: Vanessa Dolbee PROJECT TITLE: Citywide Drainage Maintenance Program PROJECT REVIEWER: Kayren Kittrick SITE AREA: N/A EXISTING BLDG AREA (gross): N/A LOCATION: Citywide PROPOSED BLDG AREA (gross) N/A SUMMARY OF PROPOSAL: The applicant has requested SERA Environmental Review for continued maintenance of the Citywide stormwater infrastructure, including channels, ditches, catch basins, manholes, outfalls, pipes and culverts. These facilities are located in critical areas including, the Cedar River, May Creek, Springbrook Creek, Thunder Hills Creek, Panther Creek, Ginger Creek, Maple Wood Creek, Honey Creek, Greens Creek, Kennydale Creek, Gypsy Creek, Johns Creek and Lake Washington. Some of these critical areas are Class 1 waters of the State, and would be subject to the Shoreline Management Program (SMP). As such the applicant has also requested a Shoreline Exemption and a Critical Areas Exemption for work in other critical areas that are not subject to the SMP regulations. The purpose of the Citywide maintenance program is to maintain existing drainage facilities in order to ensure their optimum performance, by protecting the facilities against accumulation of debris, sediment and vegetation. A. ENVIRONMENTAL IMPACT (e.g. Non -Code) COMMENTS Element of the Probable Probable More Environment Minor Major information Impacts impacts Necessary Earth Air Water Plants Land/Shoreline Use Animals Environmental Health Energy/ Natural Resources ell Element of the Environment Probable Probable More Minor Major Information Impacts Impacts Necessary Housing Aesthetics Light/Glare Recreation Utilities Trons ortation Public Services Historic/Cultural Preservation Airport Environment 10,000 Feet 14,0 Feet a B. POLICY -RELATED C. CODE -RELATED COMMENTS �I•e%r �'7��5 Cary i9� or� (J�JJ���{rd�ooal� We hove reviewed this application with particular attention to those areas in which we have expertise and have identified areas of probable impact or areas where additional informat4n is needed to properly assess this proposal_ Signature of Director or Authorized Representative Date • 0 City of Renton Department of Community & Economic Development ENVIRONMENTAL &DEVELOPMENT APPLICATION REVIEW SHEET REVIEWING DEPARTMENT: .yl{. - COMMENTS DUE: JANUARY 18, 2011 APPLICATION NO: LUA10-089, ECF, CAR, SME DATE CIRCULATED: JANUARY 4, 2011 APPLICANT: City of Renton PROJECT MANAGER: Vanessa Dolbee PROJECT TITLE: Citywide Drainage Maintenance Program PROJECT REVIEWER: Kayren Kittrick SITE AREA: N/A EXISTING BLDG AREA (gross): N/A LOCATION: Citywide PROPOSED BLDG AREA (gross) N/A SUMMARY OF PROPOSAL: The applicant has requested SEPA Environmental Review for continued maintenance of the Citywide stormwater infrastructure, including channels, ditches, catch basins, manholes, outfalls, pipes and culverts. These facilities are located in critical areas including, the Cedar River, May Creek, Springbrook Creek, Thunder Hills Creek, Panther Creek, Ginger Creek, Maple Wood Creek, Honey Creek, Greens Creek, Kennydale Creek, Gypsy Creek, Johns Creek and Lake Washington. Some of these critical areas are Class 1 waters of the State, and would be subject to the Shoreline Management Program (SMP). As such the applicant has also requested a Shoreline Exemption and a Critical Areas Exemption for work in other critical areas that are not subject to the SMP regulations. The purpose of the Citywide maintenance program is to maintain existing drainage facilities in order to ensure their optimum performance, by protecting the facilities against accumulation of debris, sediment and vegetation. A. ENVIRONMENTAL IMPACT (e.g. Nan -Code) COMMENTS Element of the Probable Probable More Environment Minor Major information Impacts impacts Necessary Earth Air Wo ter Plants Land/Shoreline Use Animals Environmental Health Energy/ Noturol Resources Element of the Probable Probable More Environment Minor Major information Impacts impacts Necessary Housin Aesthetics LightlGlore Recreation Utilities Transportation r Public Services HistoriclCuitarM Preservat' Airpo nvironment 1p^0 Feet 4,000 Feet We have review d this a plicotion with pprticular attention to those areas in which we have expertise and have identified areas of probable impact or areas where 6dditi0i inform tion i Oeded to properly assess this proposal. 7 Signature of Irecio or Autl.oriz epresentative Date l • 0 City of Renton Deportment of Community & Economic Development ENVIRONMENTAL & DEVELOPMENT APPLICATION REVIEW SHEET REVIEWING DEPARTMENT: i �- Y( (. li�ti- COMMENTS DUE: JANUARY 18, 2011 APPLICATION NO: LUA10-0$9, ECF, CAR, SME DATE CIRCULATED: JANUARY 4, 2011 APPLICANT: City of Renton PROJECT MANAGER: Vanessa Dolbee PROJECTTITLE: Citywide Drainage Maintenance Program PROJECT REVIEWER: Kayren Kittrick SITE AREA: N/A EXISTING BLDG AREA (gross): NIA LOCATION: Citywide PROPOSED BLDG AREA (gross) N/A SUMMARY OF PROPOSAL: The applicant has requested SEPA Environmental Review for continued maintenance of the Citywide stormwater infrastructure, including channels, ditches, catch basins, manholes, outfalls, pipes and culverts. These facilities are located in critical areas including, the Cedar River, May Creek, Springbrook Creek, Thunder Hills Creek, Panther Creek, Ginger Creek, Maple Wood Creek, Honey Creek, Greens Creek, Kennydale Creek, Gypsy Creek, Johns Creek and Lake Washington. Some of these critical areas are Class 1 waters of the State, and would be subject to the Shoreline Management Program (SMP). As such the applicant has also requested a Shoreline Exemption and a Critical Areas Exemption for work in other critical areas that are not subject to the SMP regulations. The purpose of the Citywide maintenance program is to maintain existing drainage facilities in order to ensure their optimum performance, by protecting the facilities against accumulation of debris, sediment and vegetation. A. ENVIRONMENTAL IMPACT (e.g. Non -Code) COMMENTS Element of the Probable probable More Environment Minor Major information impacts Impacts Necessary Earth Air Water Plants Land/Shoreline Use Animals Environmental Health Energy/ Natural Resources B. POLICY -RELATED COMMENTS / x /VE C. CODE -RELATED COMMENTS Element of the Probable Probable More Environment Minor Major information impacts Impacts Necessary Housin Aesthetics Light/Glare Recreation utilities Transportation Public Services Historic/Cultural Preservation Airport Environment 14,040 Feet 14,040 Feet We have reviewed this application with particular attention to those areas in which we have expertise and have identified areas of probable impact or areas w re additional informationisneeded to properly assess this proposal. Signature of Dire,/1'r or Authorized Representative Date 0 0 City of Renton Department of Community & Economic Development ENVIRONMENTAL & DEVELOPMENT APPLICATION REVIEW SHEET REVIEWING DEPARTMENT: 1 .' 4;{ .,. ; COMMENTS DUE: JANUARY 18, 2011 APPLICATION NO: LUA10-089, ECF, CAR, SME DATE CIRCULATED: JANUARY 4, 2011 APPLICANT: City of Renton PROJECT MANAGER: Vanessa Dolbee PROJECT TITLE: Citywide Drainage Maintenance Program PROJECT REVIEWER: Kayren Kittrick SITE AREA: N/A EXISTING BLDG AREA (gross): N/A LOCATION: Citywide PROPOSED BLDG AREA (gross) N/A SUMMARY OF PROPOSAL: The applicant has requested SEPA Environmental Review for continued maintenance of the Citywide stormwater infrastructure, including channels, ditches, catch basins, manholes, outfalls, pipes and culverts. These facilities are located in critical areas including, the Cedar River, May Creek, Springbrook Creek, Thunder Hills Creek, Panther Creek, Ginger Creek, Maple Wood Creek, Honey Creek, Greens Creek, Kennydale Creek, Gypsy Creek, Johns Creek and Lake Washington. Some of these critical areas are Class 1 waters of the State, and would be subject to the Shoreline Management Program (SMP). As such the applicant has also requested a Shoreline Exemption and a Critical Areas Exemption for work in other critical areas that are not subject to the SMP regulations. The purpose of the Citywide maintenance program is to maintain existing drainage facilities in order to ensure their optimum performance, by protecting the facilities against accumulation of debris, sediment and vegetation. A. ENVIRONMENTAL IMPACT (e.g. Non -Code) COMMENTS Element of the Probable Probable More Environment Minor Major information Impacts Impacts Necessary Earth Air Water Plants Land/Shoreline Use Animals Environmentol Neaith Energy/ Natural Resources M VV1_1- B. POLICY -RELATED COMMENTS kk% C.� C- -ODE-RELATED COMMENTS 1^ 1.4 Element of the Probable Probable More Environment Minor Major information Impacts Impacts Necessary Housing Aesthetics Light Glare Recreation Utilities Transportation Public Services NistoriclW Lural Preservation Airport Environment 10,000 Feet 14,000 Feet We have reviewed this application with particular attention to those areas in which we have expertise and have identified areas of probable impact or areas where additional information is needed to properly assess this proposal. Sign t r of Director or Authorized Representative Da • 9 City of Renton Department of Community & Economic Development ENVIRONMENTAL & DEVELOPMENT APPLICATION REVIEW SHEET REVIEWING DEPARTMENT: --�_ ;, .� = •� ! COMMENTS DUE: JANUARY 18, 2011 APPLICATION NO: LUA10-089, ECF, CAR, SME DATE CIRCULATED: JANUARY 4, 2011 APPLICANT: City of Renton PROJECT MANAGER: Vanessa Dolbee PROJECTTITLE: Citywide Drainage Maintenance Program PROJECT REVIEWER: Kayren Kittrick SITE AREA: N/A EXISTING BLDG AREA (gross): N/A ;. >:• , LOCATION: Citywide PROPOSED BLDG AREA (gross) N/A SUMMARY OF PROPOSAL: The applicant has requested SEPA Environmental Review for continued maintenance of the Citywide stormwater infrastructure, including channels, ditches, catch basins, manholes, outfalls, pipes and culverts. These facilities are located in critical areas including, the Cedar River, May Creek, Springbrook Creek, Thunder Hills Creek, Panther Creek, Ginger Creek, Maple Wood Creek, Honey Creek, Greens Creek, Kennydale Creek, Gypsy Creek, Johns Creek and Lake Washington. Some of these critical areas are Class 1 waters of the State, and would be subject to the Shoreline Management Program (SMP). As such the applicant has also requested a Shoreline Exemption and a Critical Areas Exemption for work in other critical areas that are not subject to the SMP regulations. The purpose of the Citywide maintenance program is to maintain existing drainage facilities in order to ensure their optimum performance, by protecting the facilities against accumulation of debris, sediment and vegetation. A. ENVIRONMENTAL IMPACT (e.g. Non -Code) COMMENTS Element of the Probable Probable More Environment Minor Major information Impacts Impacts Necessary Earth Air Water Plants Land/Shoreline Use Animals Environmental Health Energy/ Noturol Resources B. POLICY -RELATED COMMENTS 16OV4 C. CODE -RELATED COMMENTS Element of the Environment Probable Probable More Minor Major information Impacts Impacts Necessary Housing Aesthetics Light/Glare Recreation Utilities Transportation Public Services Historic/Cultural Preservation Airport Environment 10,000 Feet 14,000 Feet We have reviewed this application with particular attention to those areas in which we have expertise and have identified areas of probable impact or areas where additional information is needed to properly assess this proposal. urAof Director or Authorized Representative S Date 0 0 City of Renton Department of Community & Economic Development ENVIRONMENTAL & DEVELOPMENT APPLICATION REVIEW SHEET REVIEWING DEPARTMENT:A"- COMMENTS DUE: JANUARY 18, 2011 APPLICATION NO: LUA10-489, ECF, CAR, SME DATE CIRCULATED: JANUARY 4, 2011 APPLICANT: City of Renton PROJECT MANAGER: Va PROJECT TITLE: Citywide Drainage Maintenance Program PROJECT REVIE Kayren Kittrick SITE AREA: N/A EXISTING BLDG : N/A LOCATION: Citywide PROPOSED BLDG AREA (gross) N/A SUMMARY OF PROPOSAL: The applicant has requested SEPA Environmental Review for continued maintenance of the Citywide stormwater infrastructure, including channels, ditches, catch basins, manholes, outfalls, pipes and culverts. These facilities are located in critical areas including, the Cedar River, May Creek, Springbrook Creek, Thunder Hills Creek, Panther Creek, Ginger Creek, Maple Wood Creek, Honey Creek, Greens Creek, Kennydale Creek, Gypsy Creek, Johns Creek and Lake Washington. Some of these critical areas are Class 1 waters of the State, and would be subject to the Shoreline Management Program (SMP). As such the applicant has also requested a Shoreline Exemption and a Critical Areas Exemption for work in other critical areas that are not subject to the SMP regulations. The purpose of the Citywide maintenance program is to maintain existing drainage facilities in order to ensure their optimum performance, by protecting the facilities against accumulation of debris, sediment and vegetation. A. ENVIRONMENTAL IMPACT (e.g. Non -Code) COMMENTS Element of the Probable Probable More Environment Minor Majar information Impacts impacts Necessary Earth Air Water Plants Land/Shoreline Use Animals Environmental Health Energy/ Noturol Resources n (�_ Element of the Probable Probable More Environment Minor Major information impacts impacts Necessary Housing Aesthetics Light/Glare Recreation Utilities Transportation Public Services Historic/Cultural Preservation Airport Environment 10,000 Feet 14,000 Feet B. POLICY -RELATED COMMENTS C. CODE -RELATED COMMENTS We have reviewed this application with particular attention to those areas in which we have expertise and have identified areas of probable impact or areas where additional tpf rr otion is needed to)properly assess this proposal. Signature of Director or Authorized Representative Date 0 0 City of Renton Department of Community & Economic Development ENVIRONMENTAL & DEVELOPMENT APPLICATION REVIEW SHEET REVIEWING DEPARTMENT: COMMENTS DUE: JANUARY 18, 2411 APPLICATION NO: LUA10-089, ECF, CAR, SME DATE CIRCULATED: JANUARY 4, 2011 APPLICANT: City of Renton PROJECT MANAGER: Vanessa Dolbee PROJECT TITLE: Citywide Drainage Maintenance Program PROJECT REVIEWER: Kayren Kittrick SITE AREA: N/A EXISTING BLDG AREA (gross): N/A LOCATION: Citywide PROPOSED BLDG AREA (gross) N/A SUMMARY OF PROPOSAL: The applicant has requested SEPA Environmental Review for continued maintenance of the Citywide stormwater infrastructure, including channels, ditches, catch basins, manholes, outfalls, pipes and culverts. These facilities are located in critical areas including, the Cedar River, May Creek, Springbrook Creek, Thunder Hills Creek, Panther Creek, Ginger Creek, Maple Wood Creek, Honey Creek, Greens Creek, Kennydale Creek, Gypsy Creek, Johns Creek and Lake Washington. Some of these critical areas are Class 1 waters of the State, and would be subject to the Shoreline Management Program (SMP). As such the applicant has also requested a Shoreline Exemption and a Critical Areas Exemption for work in other critical areas that are not subject to the SMP regulations. The purpose of the Citywide maintenance program is to maintain existing drainage facilities in order to ensure their optimum performance, by protecting the facilities against accumulation of debris, sediment and vegetation. A. ENVIRONMENTAL IMPACT (e.g. Non -Code) COMMENTS Element of the Probable Environment Minor Impacts Probable More Major Information Impacts Necessary Earth Air Water Plants Land Shoreline Use Animals Environmental Health Energy/ Natural Resources B. POLICY -RELATED COMMENTS C. CODE RELATED COMMENTS Element of the Probable Probable More Environment Minor Major information Impacts impacts Necessary Housing Aesthetics Li h Glare Recreation Utifities Transportation Public Services Historic/Cultural Preservation Airport Environment 10,000 Feet 14,000 Feet We have reviewed this application with particular attention to those areas in which we have expertise and have identified areas of probable impact or areas where additional information is needed to properly assess this proposal. 1/41/11 Signature o ai ect hr or Authorized RepresentativeU Date NOTICE OF APPLICATION AND PROPOSED DETERMINATION of NON-SIGNIFICANCE-MITIGATEQ tDNS-M) BATE: JanUary4, 2011 LAND 115E NUMBER: LUAI"99, ECF, CAR, SME PROJECT NAME: Citywide Drainage Maintenance Program PROTECT DESCRIPTION: The applicant has requested SEPA Environmental Revlew for -iartenance of the Ctywlde starmweter Infrastructure, including channels, ditches, catch basim, manholes, Ou['alls, pipes and whores. These farigtks are footed In dritkal areas 'm,r.dlag, the Cedar Abler, May Creek, Sprinitril Geek, Thunder HIks,Cal Panther Geek, Ginger Creek, Maple Wood Creek, Honey Creek, Greens Creek, cana le Creek, Gypsy Creek, Johns Creek and Lake Washington, Some of these critical areas all Class 1 waters of the State, and wouid be subject to the Sharellne Management Program (SMP]. As such the applicant has also requested a Shoreline EvempUon and a Chhcal areas ExemP[lon For work to other critical areas that arc not subk[t to the SMP regulations. The purpose & the CNywlda maintenance pmlil Is m mall eaisling drainage facilities In Order to ensure their optimum performance, by protetting the facilllies against.—irrulatlan Of dedNs, Sediment and sulci llon. PACIECT LOCATION: Citywide OPTIONAL DETERMINATION OF NON -SIGNIFICANCE, Mrrilir EO IDNS-MI: AS the Lead Agency, the City of Renton has determined that slgniFkant environmental Impacts are unlikely to result from the pmpwed project. Therefore, as permltred under the Ill 4121C.110, the City of Renton Is using the Optional DNS -M process to give notloe that a ONS - M is likely to be issued. Comment pectoris For the project and the proposed DNS -M are integrated Into a single comment period. There will be no Gammen[ period tollomhE the Issuance of the Threshold Determination of Nor. Significance-Mhlgated ILMIS'MI. A 1"Ity appeal period will falkaw the issuance aft, ONS -M. PERMIT APPLICATION DATE: Derember 32, 2010 NOTICE OF COMPLETE APPUCA710MI Fanuc ry 4, 2011 APPLICANTJPROTECT CONTACT PERSON: Hsbl Bernardo, City of Renton -U11II11 i 10555 Grady Way: Renton, WA 99057; Earl: his -ra-rd 1plrentonwa.gaa P—halfaview Basi ltl: EMIrortnleiltll IllR,vI,w, Critical Areas EaenSpNon, Shoreline Exemption Othts-P.—its which may be required: Hyl llc Project APPtoysl, WOFW Permit Requested Studies: LAMES BIdoglcal OPlnlon Lusatlon where application may h.r—l... d: DgUn,tment of Community R Ecanamk Dewlopmerd(CED) – Planning Dlrlslan, Sixth Floor Raritan City Hall, M55 South Grady Way, Renton, WA 11 7 PUBLIC NEARING: N/A If you .-Id fixe [O be made a party of record to rocchlon e fvrther informal on this proposed project, mmir ete this farm and return to: City of Renton, CED – Planning Dintsion, 1055 So. Grady Way, Renton, WA 95057. NamelFlle Na.: CltMile Drainage Maintenance ProgramlLUA70-U89, ECF, CAR, SME NAME', MAILING ADDRESS: TELEPHONE 40.i EDNSISTENCY OVERM!(w! Lamng/tand Use: N/Allocated in streams and lakesl. Enr—cal al oocomente that Evaluate the Proposed Pmlect: Environmental (SEPA) Checkl,t D,relepment Regelatlans Used For Prolecl MIIIX, len: The d,di"t will be suojerl to the f,[ty'f SEPA ordinance, RMC 4 -3 -CSU, RMC a -9- i RMC 19-970 Old other applicable modes and regulatlOns as appropriate. Proposed Mitigation Measures: The following Mitigation Measures will likely be imposed an the proposed project. These rerommended Mitil ldn Measures addrpis project impacts not covered by a%ksting codes and regulations as cited above. Am, mance regetohon fact associaced Wim the ider lied mointeaocce acrml chat b domogrd or dlstvrbed dortng mafnrenonre ocrarwoa shoff he restored s di re -pi -ted, • Best Management Practices Shoff be utflJled during malare"i activrrres, as'drnNfsrd In the Endangered Species Act Si 7, BratugiCaf Odinkln and Mopausoa-Slevras Fishery Canservotlan and M—agernenr Act Consolorron, dnMdAugusr 15, 2MJ; provided i the prolect appfkanan; • Signifkoat trees shNf be maartioinso, to the extend pasrble. dorinp m—ce,.... e oct1w ias: Aid • Aar maintrnencr acrMhes that exceed the scope Mwon, identified in the prooecr oppncaloo will he required In -dergO o serparotereview process. Camm,Me an the above application moat be submitted In writing to Vanessa Ddb,,, Senior Planner, CED – Planning Dhlsian, 10.55 South Grady way, Renton, WA 99057, by 5:00 PM an January 19, 2011. If you neve duestiatts about this prnpoeal, or ell to be mad, a party of record and receive additional not fic.0dr, by all Contact the Project Manager. Anyonewho submRs written comments will autometicaily, become a parry cord of reand will be natihed of any derision on this Pral-L CONTACT PERSON: Vanessa Pulbee, Senior Planner; Tel: 425-430-7314; Ertl: vdafbeeOB rentonwa.gakr PLEASE INCLUDE THE PROJECT NUMBER WHEN CALLING FOR PROPER FILE IDENTIFICATION ;s- Q . u :- Citywide Cranage Malnissms— Prnpram AENTgN: ANEAa OFT UR+IE :.RFfition­4 CERTIFICATION I, l i ''F�` hereby certify that copies of the above document were posted in conspicuous places or nearby the described property on 1 Date:' Signed STATE OF WASHINGTON ) ) SS COUNTY OF KING } I certify that I know or have satisfactory evidence that Ve-rrl e �;y G 7k),� �c, e signed this instrument and acknowledged it to be his/her/their free and voluntary act for the uses and purposes mentioned in the instrument. 4A Notary Public in nd for the State of Washington � rte► Notary (Print): My appointment expires: 1441 4.n,•`` POy � ..... CITY OF RENTON DEPARTMENT OF COMMUNITY & ECONOMIC DEVELOPMENT - PLANNING DIVISION AFFIDAVIT OF SERVICE BY MAILING On the 4th day of January, 2011, 1 deposited in the mails of the United States, a sealed envelope containing NOA & Environmental Checklist documents. This information was sent to: Name Representing Agencies See Attached (Signature of Sender): STATE OF WASHINGTON ) V SS••� COUNTY OF KING ) I certify that I know or have satisfactory evidence that Stacy M. Tucker'6'ak iA signed this instrument and acknowledged it to be his/her/their free and voluntary act mentioned in the instrument. Dated: -),p[( 1 Notary Public 4n and for the State of Washington Notary (Print): 11 . "13'. i- ; 6'�6,c€ My appointment expires: ' a c,vti,3 3 purposes Project�Nam,e"G Citywide Drainage Maintenance Program Project,Number LUA10-089, ECF, CAR, SME template - affidavit of service by mailing City O ' rT., 71 �. NOTICE OF APPLICATION AND PROPOSED DETERMINATION OF NON -SIGNIFICANCE -MITIGATED (DNS -M) DATE: January 4, 2011 LAND USE NUMBER: LUA10-089, ECF, CAR, SME PROJECT NAME: Citywide Drainage Maintenance Program PROJECT DESCRIPTION: The applicant has requester[ SEPA Environmental Review for continued maintenance of the Citywide stormwater infrastructure, including channels, ditches, catch basins, manholes, outfalls, pipes and culverts. These facilities are located in critical areas including, the Cedar River, May Creek, Springbrook Creek, Thunder Hills Creek, Panther Creek, Ginger Creek, Maple Wood Creek, Honey Creek, Greens Creek, Kennydale Creek, Gypsy Creek, Johns Creek and Lake Washington. Some of these critical areas are Class 1 waters of the State, and would be subject to the Shoreline Management Program (SMP). As such the applicant has also requested a Shoreline Exemption and a Critical Areas Exemption for work in other critical areas that are not subject to the SMP regulations. The purpose of the Citywide maintenance program is to maintain existing drainage facilities in order to ensure their optimum performance, by protecting the facilities against accumulation of debris, sediment, and vegetation. PROJECT" LOCATION: Citywide OPTIONAL DETERMINATION OF NON -SIGNIFICANCE, MITIGATED (DNS -M): As the Lead Agency, the City of Renton has determined that significant environmental impacts are unlikely to result from the proposed project. Therefore, as permitted under the RCW 43.21C.110, the City of Renton is using the Optional DNS -M process to give notice that a DNS - M is likely to be issued. Comment periods for the project and the proposed DNS -M are integrated into a single comment period. There will be no comment period following the issuance of the Threshold Determination of Now Significance -Mitigated (DNS -M). A 14 -day appeal period will follow the issuance of the DNS -M. PERMIT APPLICATION DATE: December 22, 2010 NOTICE OF COMPLETE APPLICATION: January 4, 2011 APPLICANT/PROJECT CONTACT PERSON: Heb@ Bernardo, City of Renton - Utilities; 1055 5 Grady Way; Renton, WA 98457; Eml: hbernardo@rentonwa.gov Permits/Review Requested: Environmental (SEPA) Review, Critical Areas Exemption, Shoreline Exemption Other Permits which may be required: Hydralic Project Approval, WDFW Permit Requested Studies: NMFS Biological Opinion Location where application may be reviewed: Department of Community & Economic Development (CED) — Planning Division, Sixth Floor Renton City Hall, 1055 South Grady Way, Renton, WA 98057 PUBLIC HEARING: N/A If you would like to be made a party of record to receive further information on this proposed project, complete this form and return to: City of Renton, CED — Planning Division, LOSS So. Grady Way, Renton, WA 98057. Name/File No.: Citywide Drainage Maintenance Program/LUA10-089, ECF, CAR, SME NAME: MAILING ADDRESS: TELEPHONE NO.: .; CONSISTENCY OVERVIEW: Zoning/Land Use: Environmental Documents that Evaluate the Proposed Project: Development Regulations Used For Project Mitigation: Proposed Mitigation Measures: • N/A (located in streams and lakes). Environmental (SEPA) Checklist The project will be subject to the City's SEPA ordinance, RMC 4-3-050, RMC 4-3- 090, RMC 4-9-070 and other applicable codes and regulations as appropriate. The following Mitigation Measures will likely be imposed on the proposed project. These recommended Mitigation Measures address project impacts not covered by existing codes and regulations as cited above. Any native vegetation (not associated with the identified maintenance activity) that is damaged or disturbed during maintenance activities shall be restored and%r re -planted; Best Management Practices shall be utilized during maintenance activities, as identified in the Endangered Species Act Section 7, Biological Opinion and Magnuson -Stevens Fishery Conservation and Management Act Consolation, dated August 15, 2003; provided with the project application; Significant trees shall be maintained, to the extend possible, during maintenance activities; and Any maintenance activities that exceed the scope of work identified in the project application will be required to undergo a separate review process. Comments on the above application must be submitted in writing to Vanessa Dolbee, Senior Planner, CED — Planning Division, 1055 South Grady Way, Renton, WA 98057, by 5:00 PM on January 18, 2011. If you have questions about this proposal, or wish to be made a party of record and receive additional notification by mail, contact the Project Manager. Anyone who submits written comments will automatically become a party of record and will be notified of any decision on this project. CONTACT PERSON: Vanessa Dolbee, Senior Planner; Tel: 425-430-7314; Eml: vdolbee@rentonwa.gov PLEASE INCLUDE THE PROJECT NUMBER WHEN CALLING FOR PROPER FILE IDENTIFICATION Citywide Drainage Maintenance Program • 4.axrarancs'_araliai Feat • AGENCY (DOE) LETTER MAILING (ERC DETERMINATIONS) Dept. of Ecology * WDFW - Larry Fisher* Muckleshoot Indian Tribe Fisheries Dept. Environmental Review Section 1775 12th Ave. NW Suite 201 Attn: Karen Walter or SEPA Reviewer PO Box 47703 Issaquah, WA 98027 39015 —172°d Avenue SE Olympia, WA 98504-7703 Auburn, WA 98092 WSDOT Northwest Region * Duwamish Tribal Office * Muckleshoot Cultural Resources Program Attn: Ramin Paxooki 4717 W Marginal Way SW Attn: Ms Melissa Calvert King Area Dev. Serv., MS -240 Seattle, WA 98106-1514 39015 172nd Avenue SE PO Box 330310 Auburn, WA 98092-9763 Seattle, WA 98133-9710 US Army Corp. of Engineers * KC Wastewater Treatment Division * Office of Archaeology & Historic Preservation* Seattle District Office Environmental Planning Supervisor Attn: Gretchen Kaehler Attn: SEPA Reviewer Ms. Shirley Marroquin PO Box 48343 PO Box C-3755 2015. Jackson ST, MS KSC-NR-050 Olympia, WA 98504-8343 Seattle, WA 98124 Seattle, WA 98104-3855 Boyd Powers * Depart. of Natural Resources PO Box 47015 Olympia, WA 98504-7015 KC Dev. & Environmental Serv. City of Newcastle City of Kent Attn: SEPA Section Attn: Steve Roberge Attn: Mr. Fred Satterstrom, AICP 900 Oakesdale Ave. SW Director of Community Development Acting Community Dev. Director Renton, WA 98055-1219 13020 Newcastle Way 220 Fourth Avenue South Newcastle, WA 98059 Kent, WA 98032-5895 Metro Transit Puget Sound Energy City of Tukwila Senior Environmental Planner Municipal Liaison Manager Steve Lancaster, Responsible Official Gary Kriedt Joe Jainga 6200 Southcenter Blvd. 201 South Jackson Street KSC-TR-0431 PO Box 90868, MS: XRD-01W Tukwila, WA 98188 Seattle, WA 98104-3856 Bellevue, WA 98009-0868 Seattle Public Utilities Real Estate Services Attn: SEPA Coordinator 700 Fifth Avenue, Suite 4900 PO Box 34018 Seattle, WA 98124-4018 *Note: If the Notice of Application states that it is an "Optional DNS", the marked agencies and cities will need to be sent a copy of the checklist, Site Plan PMT, and the notice of application. template - affidavit of service by mailing DEPARTMENT OF COMMUNITY o." ity of��� AND ECONOMIC DEVELOPMENT M E M O RAN Q U M DATE: January 4, 2011 TO: Hebe Bernardo, Utilities ' FROM: Vanessa Dolbee, Planning SUBJECT: Notice of Complete Application Citywide Drainage Maintenance urogram The Planning Division of the City of Renton has determined that the subject application is complete according to submittal requirements and, therefore, is accepted for review. It is tentatively scheduled for consideration by the Environmental Review Committee on January 24, 2011. Prior to that review, you will be notified if any additional information is required to continue processing your application. Please contact me, at 430-7314 if you have any questions. cc: Yellow File h:\ced\planning\current plan ning\projects\1d-089.vanessa\acceptance memo 10-089.doc t7��-DEQ �vA 10-097 City of Renton for) LAND USE PERMIT cr; MASTER APPLICATIOIC'c PROPERTY OWNER(S) NAME: City of Renton ADDRESS: 1055 S Grady Way CITY: Renton ZIP: 98057 TELEPHONE NUMBER: 425-430-7264 APPLICANT (if other than owner) NAME: Same as above COMPANY (if applicable): ADDRESS: CITY: ZIP: TELEPHONE NUMBER CONTACT PERSON NAME: Hebe C. Bernardo COMPANY (if applicable): City of Renton ADDRESS: 1055 S. Grady Way CITY: Renton ZIP:98057 TELEPHONE NUMBER AND E-MAIL ADDRESS: 425-430-7264 / hbernardo@rentonwa.cov PROJECT INFORMATION PROJECT OR DEVELOPMENT NAME: Citywide Drainage Maintenance Program PROJECT/ADDRESS(S)/LOCATION AND ZIP CODE: Drainage facilities (channels, ditches, catch basins, manholes, outfalls, pipes and culverts) that are located in critical areas, as necessary in various locations along the Cedar River, May Creek, Springbrook Creek, Thunder Hills Creek, Panther Creek, Ginger Creek, Maple Wood Creek, Honey Creek, Greens Creek, Kennydale Creek, Gypsy Creek, Johns Creek and Lake Washington. The Citywide Drainage Maintenance Program locations include but are not limited to the various locations shown in Exhibit A (attached). KING COUNTY ASSESSOR'S ACCOUNT NUMBER(S): NIA EXISTING LAND USE(S): Drainage Facilities PROPOSED LAND USE(S): Drainage Facilities EXISTING COMPREHENSIVE PLAN MAP DESIGNATION: NIA PROPOSED COMPREHENSIVE PLAN MAP DESIGNATION Of applicable): N/A EXISTING ZONING: See Exhibit 8 — Maintenance List PROPOSED ZONING (if applicable): NIA 11RVFP5-021Dept51PW1File Sys'..SWA -Surface Water Section AdministrationLSWA 11- [ntera­eney Cooperation\[ 1-0004 WDFWU400 Permits -Prog. IIPAU300- SEPAVnasterapp.doc l - 08107 40JECT INFORMATION (conOued) SITE AREA (in square feet): NIA SQUARE FOOTAGE OF PUBLIC ROADWAYS TO BE DEDICATED: N/A SQUARE FOOTAGE OF PRIVATE ACCESS EASEMENTS: NIA PROPOSED RESIDENTIAL DENSITY IN UNITS PER NET ACRE (if applicable): NIA NUMBER OF PROPOSED LOTS (if applicable): NIA NUMBER OF NEW DWELLING UNITS (if applicable): NIA N/A NUMBER OF EXISTING DWELLING UNITS (if applicable):NIA SQUARE FOOTAGE OF PROPOSED RESIDENTIAL BUILDINGS (if applicable): NIA SQUARE FOOTAGE OF EXISTING RESIDENTIAL BUILDINGS TO REMAIN (if applicable): NIA SQUARE FOOTAGE OF PROPOSED NON-RESIDENTIAL BUILDINGS (if applicable): NIA SQUARE FOOTAGE OF EXISTING NON-RESIDENTIAL BUILDINGS TO REMAIN (if applicable): NIA NET FLOOR AREA OF NON-RESIDENTIAL BUILDINGS (if applicable): NIA NUMBER OF EMPLOYEES TO BE EMPLOYED BY THE NEW PROJECT (if applicable): N/A PROJECT VALUE: NIA IS THE SITE LOCATED IN ANY TYPE OF ENVIRONMENTALLY CRITICAL AREA, PLEASE INCLUDE SQUARE FOOTAGE (if applicable): • AQUIFER PROTECTION AREA ONE d AQUIFER PROTECTION AREA TWO d FLOOD HAZARD AREA sq. ft. d GEOLOGIC HAZARD sq. ft. d HABITAT CONSERVATION sq. ft. d SHORELINE STREAMS AND LAKES sq. ft. © WETLANDS sq. ft. 11RVFPS-021DeplsNPW\File SystSWA - Surface Water Section AdministrationlSWA H-1nteragency Cooperation\[ 1-0004 WDF vNA[400 Permits - Prog. HPAI1 i00- SPPA1inasterapp.doc - 2 - 08107 0 LEGAL DESCRIPTION OF PROPERTY (Attach legal description on separate sheet with the following information included) SITUATE IN THE QUARTER OF SECTION , TOWNSHIP , RANGE_, 1N THE CITY OF RENTON, KING COUNTY, WASHINGTON. I Citywide project. See attachement A Map of Maintenance Locations for various locations Included in the Citywide Drainage Maintenance Program. TYPE OF APPLICATION & FEES List all land use applications being applied for: 1. Environmental Review 4. 2. Critical Area Exemption 5 3. Shoreline Exemption Staff will calculate applicable fees and postage: $ AFFIDAVIT OF OWNERSHIP f, (Print Name/s) Ron Straka, declare that I am (please check one) the current owner of the property involved in this application or X the authorized representative to act for a corporation (please attach proof of authorization) and that the foregoing statements and answers herein contained and the information herewith are in all respects true and correct to the best of my knowledge and belief. ---) C- I certify that I know or have satisfactory evidence that signed this instrument and acknowledged it to be his/her/their free and voluntary act for the uses and purposes mentioned in the instrument. AJA �a. (Signat eo Owner/Representative) Notary Public in and for the Sta 'of Washington Notary (Print) j c .-ice`` t h h+- . f`% My appointment expires: 11RVFPS-02\Depts1,PWlFi1e Sys1SWA- Surface Watcr Section AdministrationlSWA I I- Interagency Cooperationit 1-0004 WDF44'11400 Permits - Prog. HPA11300- S\PAlmasterapp.doc - 3 - 08/07 PLANNING DIVISION WAIVEtOF SUBMITTAL REQUIREMENTS -Ion FOR LAND USE APPLICATIONS 1�ANO USS P.RM1T SUB�l1I'fT�4 A'IlV� r�IODIPIEC� RF-WRE-MENTS BY ! BY; i4ing County,Assssiar`s. Ma:p lnrcat�ag'ited Landscape Plan, Conceptual a I (o I ljve This requirement may be waived by: 1. Property Services 2, Public Works Plan Review 3. Building 4, Planning PROJECT NAME: CIqj� i`e�'V� � Oc DATE: 5& Ila H'%CEDIData\Forms-Templates\Self-Help Handouts\Planninglwaiverofsubmittalregs xis 06109 PLANNING DIVISION i WAIVEAF SUBMITTAL REQUIRAENTS FOR LAND USE APPLICATIONS LAND USEPERMIT SUBhAI WAIVER MOQtFIr;p GOMME�€T5 Plat Mame Reservation 4 Preappttcattoii Meeti►�g Sur€irnary 4 Public Works Approval Lettere Reh bil�takiori P€art 4 Screening Detail 4 c+ si- Stream or Lake Study, Standard 4 Stream ar:Lake StUtly Supplernerital4 Stream or Lake Mitigation Plan 4 tt�x5s cxt\\iia 5-(1101 ci StreetProft€es ICS; Title Report or Plat Certificate 4 TOpograPhY Mapa Traffic Study 2 _ Tree Cutting/Uhd'Clearing',. 4.' .. Urban Design Regulations Analysis 4 UtllR es Plan, Generalized ' Map of View Area 2 AND 3 Photosimulations 2 AND 3 This requirement may be waived by: 1. Property Services 2. Public Works Plan Review 3. Building 4. Planning ;6e� �� �I,nc� >✓ pw { Gn PROJECT NAME: M a n4ey1_ n L -L, DATE: �s 1(' IIy H:ICEDIDatalForms-TemplateslSelf-Help HandoutslPlanninglwaiverofsubmitlalregs,xls 06105 0 9 REQUEST FOR CRITICAL AREAS EXEMPTION FOR SEPA EXEMPT ACTIVITIES ( ) 1311 City of Renton Planning Division 1055 South Grady Way -Renton, WA 98057 Phone: 425-430-7200 Fax: 425-430-7231 Applicant Name Project Name Phone Number City of Renton - Surface Water Utility Citywide Drainage Maintenance Program 425) 430 - 7264 Parcel Number Project Address i NIA Citywide Brief Description of Project The Citywide Drainage Maintenance Program is an ongoing program dedicated to maintain drainage facilities (channels, ditches, catch basins, manholes, outfalls, pipes and culverts) that are located in critical areas, as necessary in various locations along the Cedar River, May Creek, 5pringbrook Creek, Thunder Hills Creek, Panther Creek, Ginger Creek, Maple Wood Creek, Honey Creek, Greens Creek, Kennydale Creek, Gypsy Creek, Johns Creek and Lake Washington. The Citywide Drainage Maintenance Program locations include but are not limited to the various locations shown in Exhibit A (attached). Each drainage system has its own nuances that rely on topography, area draining to the facility and conveyances. The work needed to maintain the drainage facilities on all locations included in this pro ram is described in Exhibit C. Type of Critical Area Shoreline, streams, wetlands, lakes ® Work Occurs in Critical Area ® Work Occurs in Buffer PURPOSE: Exempt activities provided with a letter of exemption from the Development Services Administrator may intrude into a critical area or required buffer (Subject to any conditions or requirements provided by the Administrator). APPLICABILITY OF EXEMPTIONS: The following is a general list of activities that may be exempt from the critical areas regulations. More specific descriptions of the activities are contained in the Critical Areas Regulations. Some of the listed activities may not be exempt in certain critical areas. The Planning Division will evaluate you request according to the City of Renton Critical Areas Regulations in RMC 4-3- 0500, J, L, and N. I AM REQUESTING A CRITICAL AREAS EXEMPTION FOR ONE OR MORE OF THE FOLLOWING ACTIVITIES: ® Conservation, Enhancement, and Related Activities: • Conservation or preservation of soil, water, vegetation, fish, and other wildlife • Enhancement activities as defined in chapter 4-11 RMC! • Any critical area, buffer restoration, or other mitigation activities that have been approved by the City ® Research and Site Investigation. • Nondestructive education and research • Site investigative work necessary for land use application submittals such as surveys, soil logs, etc. E -V 06109 NIRVFPS-02%DeptsNPW\File Sys�SWA -Surface Water Section Administration\SWA 11- Interagency Cooperation111-0004 WDFW11400 Permits - Prog. HPA11400 Permitsl1401 -CA ExemptioMcritareasexempt.doc 0 ❑ Agricultural, Harvesting, and Vegetation Management: + Harvesting wild foods • Existing/Ongoing agricultural activities 1 • Removal of dead, terminally diseased, damaged, or dangerous ground cover or hazardous trees which have been certified as such by a forester, registered landscape architect, or certified arborist ❑ Surface Water Alteration: • New surface water discharges provided the discharge meets the requirements of the Storm and Surface Water Drainage Regulations 1 2 3 • New or modified regional stormwater facilities 1 2 3 • Flood hazard reduction 1 3 4 s ® Roads, Parks, Public and Private Utilities: • Relocation of Existing Utilities out of Critical Area and Buffer • Maintenance, operation, and repair of existing parks, trails, roads, facilities, and utilities 1 2 • Installation, construction, replacement, or operation of utilities, traffic control, and walkways within existing improved right -if -way or easement 1 2 • Modification of existing utilities and streets by 10% or less 1 2 5 • Management and essential tree removal for public or private utilities, roads and public parks ❑ Wetland Disturbance, Modification, and Removal: • Any activity in small Category 3 wetlands 1 2 3 4 5 • Temporary disturbances of a wetland due to construction activities that do not include permanent filling 1 2 3 5 ❑ Maintenance and Construction for Existing Uses and Facilities: • Remodeling, replacing, or removing existing structures 1 2 + Normal and routine maintenance and repair of any existing public or private uses and facilities where no alteration of the critical area and required buffer or additional fill materials will be placed 1 2 • Construction activity connected with an existing single family residence or garage, provided that no portion of the new work occurs closer to the critical area or required buffers than the existing structure 1 2 • Existing activities which have not been changed, expanded or altered provided they comply with the applicable requirements of chapter 4.10 RMC 1 ® Emergency Activities: • Removal of trees or ground cover by a City department, agency, public, or private utility in an emergency situation • Public interest emergency use, storage, and handling of hazardous materials by governmental organizations in an Aquifer Protection Area -7- 111MM 11RVFPS-0M0epWP=File Sys1SWA - Surface Water Section Administration\SWA 11- Interagency Cooperation111-0004 WDFM1400 Permits - Prog. HPA1.1400 Permits11401 - CA ExemptioMcritareasexempt.doc 0 0 ADDITIONAL. PERMITS: Additional permits from other agencies may be required. It is the applicant's responsibility to obtain these other approvals. Information regarding these other requirements may be found at-httpJ/apps.ecy.wa,gov/opas/ IF -9 06/09 MVFPS-02MeptsTVV\Fi1e Sys1SWA - Surface Water Section Ad ministrationlSWA 11- Interagency Coope ratio n111-0004 WOFW11400 Permits - Prog- HPA11400 Permits11401 - CA Exemptonlcritareasexempt.doc 1, the undersigned, declare under penalty of perjury under the laws of the State of Washington, that to the best of my knowledge the above information is true and complete. <5� Applicant Signature: 7+1-o Date: .For City Use Only ❑ Exemption Granted C.E. "Chip" Vincent, Planning Director Planning Division Signature: Conditions of Approval: ❑ Exemption Denied Date: 'Exemption does not apply in Aquifer Protection Areas 2Exemption does not apply in Flood Hazard Areas 3Exemption does not apply in Geologic Hazard Areas 4Exemption does not apply in Habitat Conservation Areas 5Exemption does not apply in Streams and Lakes: Class 2 to 4 - 9 - 06109 fflVFPS-021DeptsTV%A ile Sys1SWA - Surface Water Section AdrninistrationlSWA 11- Interagency Coogeration\11-0004 WDt W11400 Permits - Prog. HPA11400 Permits11401 - CA Exemptionlcritareasexempt.doc 6Exemption does not apply in Wetlands -10- Pi 06108 fIiZVFPS-021t}eptsTMFi1e Sys1SWA - Surface Water Section AdministrationlSWA 11- Interagency Cooperation111-0004 WCFM1400 Permits - Prog. HPA11400 Permits11401 -CA ExemptionNcritareasexempt.doc 0 0 PLANNING DIVISION ENVIRONMENTAL CHECKLIST City of Renton Planning Division 017 1055 South Grady Way, Renton, WA 98057 Phone: 425-430-7200 Fax: 425-430-7231 PURPOSE OF CHECKLIST: ITV/ J The State Environmental Policy Act (SEPA), Chapter 43.21C RCW, requires all governfr -S11 to consider the environmental impacts of a proposal before making decisions. An Environmen I''- t Statement (EIS) must be prepared for all proposals with probable significant adverse impacts on the quality of the environment. The purpose of this checklist is to provide information to help you and the agency identify impacts from your proposal (and to reduce or avoid impacts from the proposal, if it can be done) and to help the agency decide whether an EIS is required. INSTRUCTIONS FOR APPLICANTS: This environmental checklist asks you to describe some basic information about your proposal. Governmental agencies use this checklist to determine whether the environmental impacts of your proposal are significant, requiring preparation of an EIS. Answer the questions briefly, with the most precise information known, or give the best description you can. You must answer each question accurately and carefully, to the best of your knowledge. In most cases, you should be able to answer the questions from your own observations or project plans without the need to hire experts. If you really do not know the answer, or if a question does not apply to your proposal, write "do not know" or "does not apply". Complete answers to the questions now may avoid unnecessary delays later. Some questions ask about governmental regulations, such as zoning, shoreline, and landmark designations. Answer these questions if you can. If you have problems, the governmental agencies can assist you. The checklist questions apply to all parts of your proposal, even if you plan to do them over a period of time or on different parcels of land. Attach any additional information that will help describe your proposal or its environmental effects. The agency to which you submit this checklist may ask you to explain your answers or provide additional information reasonably related to determining if there may be significant adverse impact. USE OF CHECKLIST FOR NONPROJECT PROPOSALS: Complete this checklist for nonproject proposals, even though questions may be answered "does not apply." IN ADDITION, complete the SUPPLEMENTAL SHEET FOR NONPROJECT ACTIONS (part D). For nonproject actions (actions involving decisions on policies, plans and programs), the references in the checklist to the words "project," "applicant," and "property or site" should be read as "proposal," "proposer," and "affected geographic area," respectively. - 1 - 02108 A. BACKGROUND 1. Name of proposed project, if ,applicable: Citywide Drainage Maintenance Program (2011-2015) 2. Name of applicant: City of Renton - Surface Water Utility 3. Address and phone number of applicant and contact person: Hebe C. Bernardo (425) 430 - 7264 4. Date checklist prepared: December 15, 2010 5. Agency requesting checklist: City of Renton 6. Proposed timing or schedule (including phasing, if applicable): Routine Maintenance Task as described in Exhibit C are scheduled to begin 2011. The proposed activities included are for multiyear ongoing work. Ongoing maintenance will be performed within the time period designated by the HPA Permit. Do you have any plans for future additions, expansion, or further activity related to or connected with this proposal? If yes, explain. Yes, potential addition of future sites or activities is anticipated. List any environmental information you know about that has been prepared, or will be prepared, directly related to this proposal. A Biological Opinion (attached) was prepared by NOAA's National Marine Fisheries Service pursuant to section 7 of the Endangered Species Act on the effects of the Regional Road Maintenance Program and Guidelines. In this opinion, NOAA Fisheries concludes that the proposed actions are not likely to jeopardize the continued existence of ESA -listed salmon or adversely modify their designated critical habitat. Do you know whether application s are pending for governmental approvals of other proposals directly affecting the property covered by your proposal? If yes, explain. No other applications are pending for approval at this time. An HPA will be submitted. 10. List any governmental approvals or permits that will be needed for your proposal, if known. Hydraulic Project Approval, SEPA, Shoreline Exemption, Critical Area Exemption 11. Give brief, complete description of your proposal, including the proposed uses and the size of the project and site. 11RVFPS-021Depts\PW\F Ie Sys1SWA - Surface Water Section Administration\SWA 11- Interagency Cooperation111-0004 WDFW11400 Permits - Prog HPA11300-SEPAISEPA envchlst 2.doc\HCBtp - 2 - 02iO� 0 0 The Citywide Drainage Maintenance Program is an ongoing program dedicated to maintain drainage facilities (channels, ditches, catch basins, manholes, outfalls, pipes and culverts) that are located in critical areas, as necessary in various locations along the Cedar River, May Creek, Springbrook Creek, Thunder Hills Creek, Panther Creek, Ginger Creek, Maple Wood Creek, Honey Creek, Greens Creek, Kennydale Creek, Gypsy Creek, Johns Creek and Lake Washington. The Citywide Drainage Maintenance Program locations include but are not limited to the various locations shown in Exhibit A (attached). Each drainage system has its own nuances that rely on topography, area draining to the facility and conveyances. The work needed to maintain the drainage facilities on all locations included in this program is described in Exhibit C. 12. Location of the proposal. Give sufficient information for a person to understand the precise location of your proposed project, including a street address, if any, and section, township, and range if known. If a proposal would occur over a range of area, provide the range or boundaries of the site(s). Provide a legal description, site plan, vicinity map, and topographic map, if reasonably available. While you should submit any pians required by the agency, you are not required to duplicate maps or detailed plans submitted with any permit applications related to this checklist. The Citywide Drainage Maintenance Program is an ongoing program dedicated to maintain drainage facilities (channels, catch basins, manholes, outfalls, pipes and culverts), as necessary in various locations along the Cedar River, May Creek, Springbrook Creek, Thunder Hills Creek, Panther Creek, Ginger Creek, Maple Wood Creek, Honey Creek, Greens Creek, Kennydale Creek, Gypsy Creek, Johns Creek and Lake Washington. B. ENVIRONMENTAL ELEMENTS EARTH a. General description of the site (circle one); 0 flat, 0 rolling, H hilly, 0 steep slopes, a mountainous, 0 other b. What is the steepest slope on the site (approximate percent slope?) Variable, some drainage facilities may be located on sites with slopes steeper than 40%. C. What general types of soils are found on the site (for example, clay, sand, gravel, peat, muck)? If you know the classification of agricultural soils, specify them and note any prime farmland. All soil types may apply to this proposal. Refer to Exhibit B for soil types on a specific drainage facility. The Citywide Drainage Maintenance Program will expand to other locations not specified in exhibit B. IIRVFPS-020epts\PWlFi1e Sys\SWA - Surface Water Section Administration%SWA 11- interagency Cooperation111-0004 WDFW11400 Permits - Prog. HPA11300-SEPAISEPA envchist 2.doclHCBtp - 3 - 0210E 0 0 d. Are there surface indications or history of unstable soils in the immediate vicinity? If so, describe. None at this time. e. Describe the purpose, type, and approximate quantities of any filling or grading proposed. indicate source of fill. No filling will be done as part of this project. No grading will be done as part of this project. Sediment that has been accumulated in drainage facilities will be removed as part of this program. f. Could erosion occur as a result of clearing, construction, or use? If so, generally describe. Yes, due to the maintenance activities associated with maintaining the drainage facility. The Regional Road Maintenance Endangered Species Act Program Guidelines and Appendix D of the Surface Water Design Manual will be used to select and implement appropriate Best Management Practices to minimize the disruption to the natural environment. g. About what percent of the site will be covered with impervious surfaces after project construction (for example, asphalt or buildings)? None. h. Proposed measures to reduce or control erosion, or other impacts to the earth, if any: BMPs' will be applied in accordance with the specifications provided in the Regional Road Maintenance Guidelines and the King County Surface Water Design Manual, Appendix D Erosion and Sediment Control. BMP's will be site specific. 2. AIR a. What types of emissions to the air would result from the proposal (i.e., dust, automobile, odors, industrial wood smoke) during construction and when the project is completed? If any, generally describe and give approximate quantities if known. None b. Are there any off-site sources of emission or odor that may affect your proposal? If so, generally describe. No C. Proposed measures to reduce or control emissions or other impacts to air, if any: None 3. WATER a. Surface Water: \IRVFPS-021DeptsIPW\File Sys1SWA - Surface Water Section Adm inistration\SWA 11- Interagency Cooperation111-0004 WDFW11400 Permits - Prog. HPA11300-SEPAISEPA envchlst 2.do6HCBtp - 4 - G2110: 0 0 1) Is there any surface water body on or in the immediate vicinity of the site (including year- round and seasonal streams, saltwater, lakes, ponds, wetlands)? If yes, describe type and provide names. If appropriate, state what stream or river it flows into. Yes, this proposal includes sites on or adjacent to the Cedar River, May Creek, Springbrook Creek, Thunder Hills Creek, Panther Creek, Ginger Creek, Maple Wood Creek, Honey Creek, Greens Creek, Kennydale Creek, Gypsy Creek, Johns Creek and Lake Washington. 2) Will the project require any work over, in, or adjacent to (within 200 feet) the described waters? If yes, please describe and attach available plans. Yes, instream sediment and debris removal. Reffer to Exhibit B for examples of specific maintenance work activities to be performed at a specific location. The Citywide Drainage Maintenance Program is not limited to the locations inlcuded in Exhibit B. 3) Estimate the amount of fill and dredge material that would be placed in or removed from surface water or wetlands and indicate the area of the site that would be affected. Indicate the source of fill material. No fill material will be placed in. Acumulated sediment removed will vary depending on site location and drainage facility. Sediment removal will be done as needed to ensure the drainage facilities function as designed. 4) Will the proposal require surface water withdrawals or diversions? Give general description, purpose, and approximate quantities if known. In some locations, temporary diversion will be implemented while maintenance avtivities are being performed. 5) Does the proposal lie within a 100 -year flood plain? If so, note location on the site plan. Yes, some locations are within a 100 -year flood plain. 6) Does the proposal involve any discharges of waste materials to surface waters? If so, describe the type of waste and anticipated volume of discharge. IMO b. Ground Water: 1) Will ground water be withdrawn, or will water be discharged to ground water? Give general description, purpose, and approximate quantities if known. No 2) Describe waste material that will be discharged into the ground from septic tanks or other sources, if any (for example: Domestic sewage; industrial, containing the following chemicals...; agricultural; etc.). Describe the general size of the system, the number of such systems, the number of houses to be served (if applicable), or the number of animals or humans the system(s) are expected to serve. None C. Water Runoff (including storm water): 11RVFPS-021Depts\PW\Fi1e Sys1SWA -Surface Water Section AdministrationlSWA 11- Interagency Cooperation111-0004 WDFW11400 Permits - Prog. HPA11300-SEPAISEPA envchlst 2.doc\HCBtp - 5 - 02V 0 0 1) Describe the source of runoff (including storm water) and method of collection and disposal, if any (include quantities, if known). Where will this water flow? Will this water flow into other waters, if so, describe. This proposal will not result in an increase in runoff. 2) Could waste material enter ground or surface waters? If so, generally describe. Potential for sediment to get stirred up. BMPs in accordance with the Regional Road and Maintenance guidelines and Appendix D of the 2409 King Coutny Surface Water Design Manual will be implemented on site to minimize impacts. d. Proposed measures to reduce or control surface, ground, and runoff water impacts, if any: BMP's will be site specifics. BMP's will be implemented and selected in accordance with the Reguinal Road and Maintenance guidelines, 4. PLANTS a. Check or circle types of vegetation found on the site: X deciduous tree: alder, maple, aspen, other X evergreen tree: fir, cedar, pine, other X shrubs X grass X pasture crop or grain X wet soil plants: cattail, buttercup, bullrush, skunk cabbage, other X water plants: water lily, eel grass, milfoil, other X other types of vegetation b. What kind and amount of vegetation will be removed or altered? Minimal vegetation removal based on site conditions. Vegetation removal of grasses and shrubs may be necessary either for access purposes or because the vegetation is within the working area. Vegetation removal will be kept to a minimum and disturbed areas will be stabilized upon completion of maintenance activity . C. List threatened or endangered species known to be on or near the site. Unknown d. Proposed landscaping, use of native plants, or other measures to preserve or enhance vegetation on the site, if any: Revegetaion with native plants and trees as needed to mirror pre -project conditions. 5. ANIMALS 11RVFPS-021DeptslP=File Sys1SWA -Surface Water Section Adrninistration\SWA 11- Interagency Coo peration111-0004 WDI'M400 Permits - Prog. HPAM0p-SEPAISEPA envchlst 2.doclHCBtp - 6 - 02/0 a. Circle any birds and animals, which have been observed on or near the site or are known to be on or near the site: Er Birds: hawk, heron, eagle, songbirds, other 1Z Mammals: deer, bear, elk, beaver, other EI Fish: bass, salmon, trout, herring, shellfish, other b. List any threatened or endangered species known to be on or near the site. Unknown C. Is the site part of a migration route? If so, explain Unknown d. Proposed measures to preserve or enhance wildlife, if any: Maintenance activities will be done within fish window as approved by HPA conditions. 6. ENERGY AND NATURAL RESOURCES a. What kinds of energy (electric, natural gas, oil, wood stove, solar) will be used to meet the completed project's energy needs? Describe whether it will be used for heating, manufacturing, etc. None b. Would your project affect the potential use of solar energy by adjacent properties? If so, generally describe. No C. What kinds of energy conservation features are included in the plans of this proposal? List other proposed measures to reduce or control energy impacts, if any: None 7. ENVIRONMENTAL HEALTH a. Are there any environmental health hazards, including exposure to toxic chemicals, risk of fire and explosion, spill, or hazardous waste, that could occur as a result of this proposal? If so, describe. No 1) Describe special emergency services that might be required. None 2) Proposed measures to reduce or control environmental health hazards, if any: M b. Noise 11RVFPS-021Depts%PWTile Sys1SWA - Surface Water Section AdrninistrationlSWA 11- Interagency Cooperatianll 1-0004 WDFW11400 Permits - Prog. HPA11300-SF-PA%SEPA envchlst 2.docl! C!Mp - 7 - 02l0" 0 1) What types of noise exist in the area which may affect your project (for example: traffic, equipment, operation, other)? None 2) What types and levels of noise would be created by or associated with the project on a short-term or a long-term basis (for example: traffic, construction, operation, other)? Indicate what hours noise would come from the site. None 3) Proposed measures to reduce or control noise impacts, if any: None 8. LAND AND SHORELINE USE a. What is the current use of the site and adjacent properties? Drainage facilitites. Most of the facilities are in protected lands (streams, buffers, etc.). Adjacent property land uses vary through out the City based upon zoning. b. Has the site been used for agriculture? If so, describe. Unknown C. Describe any structures on the site. Drainage facilities (catch basins, dithced, channels, culverts, outfalls, pipes, etc.) d. Will any structures be demolished? If so, what? No e. What is the current zoning classification of the site? All zoning designations may apply to this proposal. Refer to Exhibit B for zoning designations of a specific drainage facility. The Citywide Drainage Maintenance Program will expand to other locations not included in exhibit B. f. What is the current comprehensive plan designation of the site? N/A g. If applicable, what is the current shoreline master program designation of the site? All current shoreline master program designations in the City of Renton may apply. Refer to Exhibit B for the current master program designation of a specific drainage facility. The Citywide Drainage Maintenance Program will expand to other locations not included in exhibit B. h. Has any part of the site been classified as an "environmentally sensitive" area? If so, specify. IIRVFPS-421Depts\PWlFile Sys1SWA - Surface Water Section Administration\SWA 11- Interagency Cooperation111-0004 WDFW11400 Permits - Prog. HPA11300-SEPAISEPA envchist 2.docIHCBtp - 8 - 02/OE Most of the sites included in the Citywide Drainage Maintenance program are located in sensitive areas. i. Approximately how many people would reside or work in the completed project? N/A j Approximately how many people would the completed project displace? N/A k. Proposed measures to avoid or reduce displacement impacts, if any: None I. Proposed measures to ensure the proposal is compatible with existing and projected land uses and plans, if any: None 9. HOUSING a. Approximately how many units would be provided, if any? Indicate whether high, middle, or low-income housing. None b. Approximately how many units, if any, would be eliminated? Indicate whether high, middle, or low-income housing. None C. Proposed measures to reduce or control housing impacts, if any: None 10. AESTHETICS a. What is the tallest height of any proposed structure(s), not including antennas; what is the principal exterior building material(s) proposed. NIA b. What views in the immediate vicinity would be altered or obstructed? None C. Proposed measures to reduce or control aesthetic impacts, if any: None 11, LIGHT AND GLARE a. What type of light or glare will the proposal produce? What time of day would it mainly occur? 11r2VFPS-021DeptslPWTile Sys\SWA - Surface Water Section Administration\SWA 11- Interagency Cooperation111-0004 WDFW11400 Permits - Prog. HPA11300-SEPAISEPA envchlst 2.doc\HCBtp - 9 - 071f1;: C� None • b. Could light or glare from the finished project be a safety hazard or interfere with views? No C. What existing off-site sources of light or glare may affect your proposal? None d. Proposed measures to reduce or control light and glare impacts, if any: None 12. RECREATION a. What designated and informal recreational opportunities are in the immediate vicinity? Parks and trails are located near the sites. b. Would the proposed project displace any existing recreational uses? If so, describe. No C. Proposed measures to reduce or control impacts on recreation, including recreation opportunities to be provided by the project or applicant, if any: None 13. HISTORIC AND CULTURAL PRESERVATION a. Are there any places or objects listed on, or proposed for, national state, or local preservation registers known to be on or next to the site? If so, generally describe. No b. Generally describe any landmarks or evidence of historic, archaeological, scientific, or cultural importance known to be on or next to the site. NIA C. Proposed measures to reduce or control impacts, if any: None 14. TRANSPORTATION a. Identify public streets and highways serving the site, and describe proposed access to the existing street system. Show on site plans, if any. Various, most sites are served by public streets and highways. b. Is site currently served by public transit? If not, what is the approximate distance to the nearest transit stop? Unknown k%RVFPS-021Depts%PW\Fi1e Sys\SWA - 5urf2Ce Water Section Administration\SWA 11- Interagency Cooperation111-0004 WDFW11400 Permits - Prog. HPA11300-SEPAISEPA ervchist 2.doc\HCBtp _10- 02;0t c. How many parking spaces would the completed project have? How many would the project eliminate? None d. Will the proposal require any new roads or streets, or improvements to existing roads or streets, not including driveways? If so, generally describe (indicate whether public or private? No e. Will the project use (or occur in the immediate vicinity of) water, rail, or air transportation? If so, generally describe. No f. How many vehicular trips per day would be generated by the completed project? If known, indicate when peak volumes would occur, None g. Proposed measures to reduce or control transportation impacts, if any: None 16. PUBLIC SERVICES a. Would the project result in an increased need for public services (for example: fire protection, police protection, health care, schools, other)? If so, generally describe. No b. Proposed measures to reduce or control direct impacts on public services, if any. None 16. UTILITIES a. Circle utilities currently available at the site: electricity, natural gas, water, refuse service, telephone, sanitary sewer, septic system, other. Storm and surface water b. Describe the utilities that are proposed for the project, the utility providing the service, and the general construction activities on the site or in the immediate vicinity which might be needed. None C. SIGNATURE I, the undersigned, state that to the best of my knowledge the above information is true and complete. It is understood that the lead agency may withdraw any declaration of non -significance 11RVFPS-020epWPW\File SysISWA - Surface Water Section Administration\SWA 11- Interagency Cooperation111-0404 WDFW11400 Permits - Prog. HPA11300--SEPAISEPA envchlst 2.doc\HCBtp - 11 - 0210E that it might issue in reliance upon this checklist should there be any willful misrepresentation or willful lack of full disclosure on my part. Proponent: Name Printed: R6 Straka Date: 121Zo! Io 11RVFPS-021DeptslPWTile Sys1SWA - Surface Water Section Administration\SWA 11- Interagency Cooperation111-0004 WDFW11400 Permits - Prog. HPA11300-SEPAISEPA envchlst 2.do6HCBtp -12- 0210" I r 9 9 Citywide Drainage Maintenance L. Program 'Slon Prepared by City of Renton City of 0 July 14, 2010 Public Works Department Utility Systerns, Division -Surface Water Utility Renton City Hall --5th Floor 1055 South Grady Way Renton WA 98057-3232 0 0 1.0 INTRODUCTION The Citywide Drainage Maintenance Program is an ongoing program dedicated to maintain existing drainage facilities (channels, ditches, catch basins, manholes, outfalls, pipes and culverts) that are located in critical areas, as necessary in various locations along the Cedar River, May Creek, Springbrook Creek, Thunder Hills Creek, Panther Creek, Ginger Creek, Maple Wood Creek, Honey Creek, Greens Creek, Kennydale Creek, Gypsy Creek, Johns Creek and Lake Washington. The Citywide Drainage Maintenance Program locations include but are not limited to the various locations shown in Exhibit A (attached). Each drainage system has its own nuances that rely on topography, area draining to the facility and conveyances. Ongoing maintenance is needed to preserve or restore the original function of the existing drainage facilities so the balanced use of the water resource continues as intended. Each drainage system has its own nuances that rely on topography, area draining to the facility and conveyances. The work needed to maintain the drainage facilities included in this program is described in Exhibit C. Local, State and Federal Permits are required for activities that take place in or around the waters of the state. Past practices of the Surface Water Utility were to initiate several permits each year that would for each location to allow for the maintenance of these facilities. in 2010, the City developed a programmatic permit program that combined many of these drainage facilities into programmatic permits that would allow the maintenance of the drainage facilities including but not limited to the facilities listed in Exhibit B. 2.0 PROPOSED ACTION The purpose of the Citywide Maintenance Program is to maintain existing drainage facilities in order to ensure their optimum performance. Primary tasks outlined in Exhibit C of the enclosure include protecting the function against accumulation of debris, sediment and vegetation. 2.1 Location of the proposal The Citywide Drainage Maintenance Program will maintain drainage facilities (channels, catch basins, manholes, outfalls, pipes and culverts), as necessary in various locations along the Cedar River, May Creek, Springbrook Creek, Thunder Hills Creek, Panther Creek, Ginger Creek, Maple Wood Creek, Honey Creek, Kennydale Creek, Gypsy Creek, Johns Creek and Lake Washington. The Citywide Drainage Maintenance Program include but is not l i cited to the locations listed and described in Exhibit B. Facility addresses and existing land uses for various locations included in Citywide Drainage and Maintenance Program are included in Exhibit B. 0 0 2.2 Site Access Sites included in the Citywide Drainage Maintenance Program will be maintained from the existing Right -of -Way or easements dedicated to the City. 2.3 Zoning Designation of the Site All zoning designations may apply to this proposal. Refer to Exhibit B for zoning designations of a specific drainage facility. The Citywide Drainage Maintenance Program will expand to other locations not specified in exhibit B. 2.4 Soil Types All soil types may apply to this proposal. Refer to Exhibit B for soil types on a specific drainage facility. The Citywide Drainage Maintenance Program will expand to other locations not specified in exhibit B. 2.5 Vegetation Vegetation removal of grasses and shrubs may be necessary either for access purposes or because the vegetation is within the working area. Vegetation removal will be kept to a mirdmum and all native vegetation outside of work /access areas will be restored to pre - project conditions as soon as reasonably possible upon completion of maintenance activity. 2.6 Schedule Routine Maintenance Tasks as described in exhibit C are scheduled to begin 2011. Maintenance activities impacting aquatic waters with salmonids will be done within the designated Fish Window, determined by WDFW. 3.4 MITIGATION MEASURES Renton's Surface Water Utility is very aware of the need to protect the environment as one of the primary uses of the water resource, both in the functioning of the facilities and in their maintenance. The Regional Road Maintenance Endangered Species Act Program Guidelines (attached) will be used to select and implement appropriate Best Management Practices to minimize the disruption to the natural environment. All applicable state and federal requirements associated with the Clean Water Act (CWA) and Appendix D of the 2009 Surface Water Design Manual will be met through planning, application, and monitoring of Best Management Practices (BMP's). Activities will comply with provisions described in the Memorandum of Understanding with the WDFW. Maintenance activities may vary depending on site conditions and access at the time of work. 3.1 General Maintenance Work 3.1.1 Erosion control will be placed as needed around the work site and equipment. Installation and monitoring of erosion control will be conducted by a CESCL (Certified Erosion and Sediment Control Lead) throughout the duration of the maintenance activity. A listing of approved BMP methods can be found within the'Regional Road Maintenance Endangered Species Act Program Guidelines' (attached). 3.1.2 Disturbance of riparian vegetation shall be limited to that necessary to conduct the maintenance. Affected critical area buffers as defined in RMC4-3-050 shall be restored to pre -project or improved habitat configuration following the maintenance activity. 3.1.3 If the stream is flowing at the time of maintenance, fish exclusion and stream bypass procedures shall be put into place prior to any maintenance operations. A temporary bypass to divert flow around the work area will be in place prior to initiation of other work in the wetted perimeter. Upon completion of the project, all material used in the temporary bypass shall be remove from the site and the site returned to pre -project or improved conditions. 3.1.4 All waste material such as debris, silt or excess dirt resulting from this project shall be deposited above the limits of flood water in an approved upland disposal site. 3.1.5 Equipment used for maintenance shall be checked daily for leaks and any necessary repairs shall be completed prior to commencing maintenance activities along state waters. Fueling of equipment shall not occur near state waters. 3.2 Sediment Removal Maintenance activities performed under this program will generate stream sediments and a small quantity of vegetation that require management and off-site disposal. The following methods and actions will be employed to assure that materials are properly managed. 3.2.1 All removed sediment will be loaded directly into awaiting dump trucks or vactor storage tanks. Removed sediments will be transported and stockpile off site stockpiled for dewatering purposes. Stockpiled sediment will have appropriate BMP s in place to filter runoff from the dewatering process. Sediment disposal will be at an approved recycling/ disposal facility. 0 i 3.2.2 Sediments will be removed from the dewatered streambed using a small backhoe/excavator or vactor trucks. The specific method to be used at each site is listed in Exhibit A. 3.2.3 Vehicles will be staged on paved or graveled surfaces as available. Backhoes and Vactor truck hoses and tubes are capable of reaching the excavation area at each site from the paved or graveled surface. 3,3 Fish Exclusion Sediment removal activities at the fn -Stream facilities where fish have been identified will require diverting the stream, dewatering the construction area and the implementation of measures to exclude and remove fish from the reach. When necessary, Renton's Public Works Department - Maintenance Division trained personnel will perform fish exclusion. BMPs to minimize or reduce impacts to aquatic resources will be implemented. Fish exclusion work prior to dewatering will be performed in accordance with the WDFW Hydraulic Project Approval. A copy of the permit will be kept in the possession of the field personnel during fish exclusion and collection activities. 3.3.1 Field notes will be maintained that describe the activities performed and may also include information such as date, personnel, time, general site conditions, weather, length of stream reach, methods used, and any other general comments. 3.3.2 Any injuries or mortalities during fish exclusion will be documented and reported if it involves an ESA -listed species. Contact with an ESA -listed species during fish exclusion activities will be documented and reported to the Services. 3.3.3 Block nets will be installed a minimum of 30 ft upstream and downstream of the work area that isolate and exclude fish from entering the entire affected stream reach. Block net mesh size will be the same as the seine nets (9.5 millimeters stretched). Block nets will be installed and secured across the channel and up both banks sufficiently to withstand unforeseen rain events or debris accumulation 3.3A Block nets within the stream channel will be supported at 3 ft intervals using stakes or metal fence posts. Stream By -Pass 0 3.3.5 A temporary plastic Uned sandbag dike will be constructed across the reach approximately 20 feet upstream of the work area and downstream of the fish block net. 3.3.6 A pump inlet will be located below the upstream block net and equipped with a 1/8 -in mesh screen to prevent fish intake. 3.3.7 The stream reach will be visually inspected for the presence of fish prior to dewatering the reach. 3.3.8 The affected reach shall be dewatered slowly while observing for aquatic vertebrates. Any observed fish will be captured using hand- held dip nets and transferred immediately to the creek below the downstream block net. 3.3.9 Block nets will only be removed following completion of all sediment removal and re-establishment of permanent flow through the area where sediments were removed. 3.3.10 Block nets will be removed with care and checked for aquatic vertebrates. 4.0 CONSTRUCTION SEQUENCE The following sequence of events summarizes the proposed activities required to accomplish the activities listed in Exhibit B for each site. 4.1 Delineate the extent of the project site. 4.2 Field locate Utilities. 4.3 Install WDFW approved fish exclusion block nets at upper and lower extremes of each stream -reach, if work is performed in a location where it is required. 4.4 Install erosion control measures as needed around work site. 4.5 Conduct fish exclusion, if work is performed in a location where it is required. 4.6 Construct a temporary plastic lined sandbag dike across the reach approximately upstream of the work area work, if work is performed in a location where it is required. 4.7 Set-up pumps and layout discharge piping for stream by-pass system as necessary. Discharge areas will ensure filtration through natural vegetation 0 0 and/or the use of an approved bypass channel. If work is performed in a location where it is required. 4.8 Additional erosion control will be installed as needed. 4,9 Route the stream through the bypass system, If work is performed in a location where it is required 4.10 Allow the by-passed reach to naturally dewater, if work is performed in a location where it is required. 4.11 Stage small backhoe/excavator and Vactor trucks as needed on existing paved or graveled surfaces (as available) adjacent to each work area. 4.12 Remove accumulated sediments. 4.13 Remove the temporary sandbag dike and all materials used to construct the by-pass to allow the stream to return to its channel, . 4.14 Observe stream flow through the area of sediment removal to confirm free unhindered flow through the area impacted by construction. 4.15 After continuous free flow is achieved through the construction area, the downstream and upstream block nets .may be removed. 4.16 Photo document before and after conditions for activity record keeping. 0 0 and/or the use of an approved bypass channel. If work is performed in a location where it is required. 4.8 Additional erosion control will be installed as needed. 4.9 Route the stream through the bypass system, If work is performed in a location where it is required 4.10 Allow the by-passed reach to naturally dewater, if work is performed in a location where it is required. 4.11 Stage small backhoe/excavator and Vactor trucks as needed on existing paved or graveled surfaces (as available) adjacent to each work area. 4.12 Remove accumulated sediments. 4.13 Remove the temporary sandbag dike and all materials used to construct the by-pass to allow the stream to return to its channel,. 4.14 Observe stream flow through the area of sediment removal to confirm free unhindered flow through the area impacted by construction. 4.15 After continuous free flow is achieved through the construction area, the downstream and upstream block nets may be removed. 4.16 Photo document before and after conditions for activity record keeping. 0 ENDANGERED SPECIES ACT - SECTION 7 .J Jam' lii BIOLOGICAL OPINION and MAGNUSON-STEVENS FISHERY CONSERVATION AND MANAGEMENT ACT CONSULTATION Proposed Qualification of the Regional Road Maintenance Program Submitted by 25 Jurisdictions in Washington State for 12 Threatened Salmonid ESUs, Pursuant to Limit No. 10(ii) of the NMFS 4(d) Rule NMFS Tracking No.: 2003/00313 Agency: National Marine Fisheries Service Consultation Conducted By: National Marine fisheries Northwest Region Washington State Branch Office Approved by: -- , P& ��— (-- Date: August 15, 2003 D. Robert Lohn Regional Administrator 0 TABLE OF CONTENTS 1.0 INTRODUCTION......................................................... I 1.1 Background and Consultation History .................................... 1 1.2 Description of the Proposed Action ...................................... 2 1.3 Action Area'.........................................................3 2.0 ENDANGERED SPECIES ACT ............................................. 3 2.1 Biological Opinion...................................................3 2.1.1 Status of ESUs and Habitat ..................................... 3 2.1.2 Evaluating the Proposed Action ................................ 14 2.1.3 Analysis of Effects ........................................... 26 2.1.4 Effects on Critical Habitat ..................................... 35 2.1.5 Cumulative Effects ........................................... 35 2.1.6 Conclusion.................................................36 2.1.7 Reinitiation of Consultation .................................... 37 2.2 Incidental Take Statement ............................................ 37 3.0 MAGNUSON-STEVENS FISHERY CONSERVATION AND MANAGEMENT ACT .....................................................................37 3.1 Background........................................................37 3.2 Identification of EFH ............................ • ................... 38 3.3 Proposed Actions...................................................39 3.4 Effects of Proposed Action ............................................ 39 3.5 Conclusion........................................................41 3.6 Essential Fish Habitat Conservation Recommendations ..................... 41 3.7 Statutory Response Requirement ....................................... 41 3.8 Supplemental Consultation ............................................ 41 4.0 REFERENCES..........................................................42 AppendixA.................................................................47 0 1.0 INTRODUCTION IA Background and Consultation History 0 NOAA's National Marine Fisheries Service (NOAA Fisheries) published an Endangered Species Act (ESA) section 4(d) rule adopting regulations necessary and advisable to conserve listed species (July 10, 2000, 65 FR 42422). The 4(d) rule creates a mechanism by which application of ESA section 9(a)(1) take prohibitions may be limited for land and water activities that NOAA Fisheries has found will conserve listed salmonids' habitat, yet may incidentally take. The 4(d) rule includes thirteen enumerated limits upon the extent of the general take prohibition for 14 threatened Evolutionarily Significant Units (ESUS). Limit No. 10 covers routine road maintenance activities. For a state, city, county or port program to qualify under Limit No. 10(ii), it must adopt a road maintenance program that contributes to the attainment and persistence of properly functioning habitat condition (PFC). In 1999, in response to several listings of salmonids under the ESA, local governments in the Puget Sound area formed a coalition, known as the "Tri -County ESA Response Effort" (Tri -County Group), to implement programs to conserve listed species. The Tri -County ESA Response Effort identified several government agency program areas with the potential to contribute to conservation. Road maintenance was one of those program areas. At the same time, the Washington State Department of Transportation (WSDOT) began to develop their own road maintenance program. In the fall of 2001, after two years of collaborative effort, WSDOT joined with the Tri -County Group to become the Regional Road Maintenance Technical Working Group. This union expanded the Regional Program to include the entire State of Washington. In January 2002, 25 jurisdictions (24 local jurisdictions and WSDOT) jointly submitted the Regional Road Maintenance ESA Program (RRMP) for qualification under Limit No. 10(ii). On January 25, 2002, a Federal Register Notice was published (January 25, 2002, 67 FR 3688) announcing the availability of the RRMP for public comment. A 30 -day extension of the public comment period was announced on March 13, 2002 (March 13, 2002, 67 FR 11285). The public comment period closed on April 12, 2002, NOAA Fisheries completed its review and response to public comments in late -January 2003. NOAA Fisheries initiated ESA section 7 consultation with itself on March 28, 2003. The RRMP may affect 12 ESUs of threatened salmonids: Ten of the 14 ESUS addressed in the 4(d) Rule, and two additional ESUS (Snake River (SR) Fall -run and SR spring/summer-run chinook), not addressed in the 4(d) Rule. The 12 ESUs include: Puget Sound (PS), Lower Columbia River (LCR), SR fall -run, SR spring/summer-run, and Upper Willamette River (U WR) chinook salmon (Oncorhynchus tshawytscha); Hood Canal (HC) summer -run and Columbia River (CR) chum salmon (O. kela); Ozette Lake (OL) sockeye salmon (4. nerka), and; Snake River Basin (SRB), LCR, UWR, and Middle Columbia River (MCR) steelhead (O. mykiss). 0 0 The 4(d) Rule specifically excludes endangered species from its limits on the application of the ESA section 9(a)(1) take prohibitions. NOAA Fisheries, therefore, is not extending 4(d) Limit No. 10 coverage to RRMP activities within the delineated geographic boundaries of the three endangered ESUs Upper Columbia River (UCR) spring -run Chinook salmon, UCR steelhead, and SR sockeye salmon. However, these three endangered salmonid ESUs migrate outside the geographic boundaries of their ESUS through a portion of the RRMP's action area. The effects of RRMP activities (primarily conducted in tributary watersheds) on endangered salmonids migrating through the middle and lower mainstem Columbia River would likely be insignificant or discountable and thus not be likely to adversely affect the UCR spring -run Chinook salmon, UCR steelhead, or SR sockeye salmon. 1.2 Description of the Proposed Action NOAA Fisheries proposes to approve 25 Limit No. 10 programs for 25 state and local jurisdictions in Washington State. NOAA Fisheries decided to group these actions in a single consultation pursuant to 50 CFR 402.14(c) because the 25 routine road maintenance programs are similar in nature and duration. The State of Washington, through WSDOT, together with King, Pierce, Snohomish, Clallam, Kitsap, Mason, and Thurston Counties, and the Cities of Bellevue, Bremerton, Burien, Covington, Edgewood, Everett, Kenmore, Kent, Lake Forest Park, Lakewood, Maple Valley, Newcastle, Renton, Sammamish, Shoreline, Tacoma, and University Place developed the RRMP so that routine road maintenance activities would be protective of salmonids and their habitat. The RRMP defines what activities are routine road maintenance. As defined on page "x" of the RRMP (RRM-TWG 2001), covered maintenance activities are "conducted on currently serviceable structures, facilities, and equipment, involve no expansion of or change in use, and do not result in significant negative hydrological impact." The RRMP is divided into three parts. In .Part 1, the RRMP describes the program framework including the 10 program elements that comprise the program (Regional Forum, Program Review, Best Management Practices (BMPs) and Conservation Outcomes (element 10), Training, Compliance Monitoring, Research, Adaptive Management, Emergency Response, Biological Data Collection, and Reporting). In Part 2, the RRMP elaborates on the BMPs in much greater detail and provides detailed instructions to crews, supervisors, environmental support staff, design personnel, and managers. Part 3 describes a process by which additional counties, cities, and ports in Washington State may develop routine road maintenance programs by adopting RRMP Parts 1 and 2, and then submit their RRMP to NOAA Fisheries for review, public comment, and approval or disapproval. Finally, the RRMP includes a biological review (BR) of the RRMP prepared by WSDOT and the other entities named above. The BR analyzes the effects of the RRMP on the 12 threatened salmonid ESUS and their habitat statewide. The BR concludes that the identified routine road maintenance activities conducted throughout Washington State under the RRMP will not impair 2 properly functioning habitat, nor appreciably reduce the functioning of already impaired habitat, nor retard the long-term progress of impaired habitat toward PFC. The Federal action of approving the RRMP under Limit No. 10 required environmental review under the National Environmental Policy Act (NEPA). Two environmental assessments (EA) were prepared to meet NOAA Fisheries' environmental documentation requirements under NEPA: a programmatic EA for Limit No. 10 (NMFS 2003a) and a sequential EA that evaluated the environmental consequences associated with the RRMP submitted by the 25 Washington jurisdictions (NMFS 2003b). 1.3 Action Area The action area is defined in 50 CFR 402.02 to mean "all areas to be affected directly or indirectly by the Federal action and not merely the immediate area involved in the action." The 25 state and local jurisdictions applying for qualification of the RRMP under Limit No. 10 of the 4(d) Rule carry out routine road maintenance activities out on roads in urban and rural areas throughout the State of Washington. Because of potential direct and indirect effects on listed salmonids from implementation of the RRMP, the action area extends from southeastern Washington and crosses the Columbia Plateau, Cascade Mountains, and the Pacific Border provinces spanning Washington. It consists of the Columbia River basin downstream of Priest Rapids Dam, all coastal watersheds between the Columbia River in the south and the Canadian border in the north, and watersheds that drain to Puget Sound. Part or all of 28 counties fall within the action area, out of a total of 39 counties in Washington. 2.0 ENDANGERED SPECIES ACT 2.1 Biological Opinion 2. 1.1 Status of ESUS and Habitat The 12 threatened salmonid ESUS are in decline. The decline has been attributed to many different factors, including harvest, operation of hatcheries, hydropower development, and destruction of habitat (Federal Caucus 2000). Additionally, municipal and agricultural water withdrawals cause water shortages throughout the West, creating passage barriers, water quality declines, and eliminating habitat. Though less measurable, the effects of introduced aquatic nuisance species, which compete for habitat and prey on salmon, have caused a decline in salmon populations (He and Kitchell 1990). Recent research has shown that ocean conditions play a profound role in survival to spawning age, and contribute substantially to total salmon population numbers (Beamish et al. 2000). The listing status, biological information, and critical habitat designations for the 15 threatened and endangered species are described in Table 1. i 9 Table 1. References to Federal Register Notices and Status Reviews Containing Additional Information Concerning Listing status, Biological Information, and Critical Habitat Designations for Listed Species Considered in this Opinion. Species Listing Status Critical Habitat Biological Reference Reference Information Puget Sound chinook Threatened Species, No Critical Habitat Myers et al 1998 Salmon (Oncorhynchus (March 24, 1999, 64 Designated tshawytscha) FR 14308 Lower Columbia Threatened Species, No Critical Habitat Myers et al.1998 River (LCR) chinook (February 16, 2000, Designated salmon (O. tshawytscha) 65 FR 7764 ) Snake River fall -run (SRF) Threatened Species, Designated Critical Waples et al_ chinook salmon (O. (April 22, 1992, 57 Habitat, (December 1991b tshawytscha) FR 14653). See 28, 1993, 58 FR correction: (June 3, 68543) 1992, 57 FR 23458) Snake River spring/summer Threatened Species, Designated Critical Matthews and run (SRSS) chinook salmon (April 22, 1992, 57 Habitat,(December Waples 1991 (O. tshawytscha) FR 14653). See 28, 1993, 58 FR correction:(June 3 68543). See 1992, 57 FR 23458) update: (October 25, 1999, 64 FR 57399) Upper Columbia River Endangered Species, No Critical Habitat Myers et al. (UCR) spring -run chinook (March 24, 1999, 64 Designated 1998 salmon (O. tshawytscha) FR 14308) Upper Willamette River Threatened Species, No Critical Habitat Myers et al. (UWR) chinook salmon (O. (March 24, 1999, 64 Designated 1998 tshawytscha) FR 14308) Hood Canal (HC) Threatened Species, No Critical Habitat Johnson et al. summer -run chum (March 25, 1999, 64 Designated 1997 salmon (O. keta) FR 14508) Columbia River (CR) Threatened Species, No Critical Habitat Johnson et al chum salmon (O_ keta) (March 25, 1999, 64 Designated 1997 FR 14508) 4 0 1.J Ozette Lake sockeye (O. Threatened Species, No Critical Habitat Gustafson et al. nerka) (March 25, 1999, 64 Designated 1997 FR 14508) Snake River (SR) sockeye Endangered Species, Designated Critical Waples et al. (4. nerka) (November 20, 1991, Habitat, (58 FR 1991 a 58 FR 58619) 68543, December 28, 1993 Upper Willamette River Threatened Species No Critical Habitat Busby et al. (UWR) steelhead (O. (March 25, 1999, 64 Designated 1995; Busby et mykiss) FR 14517) al. 1996 Snake River Basin (SRB) Threatened Species, No Designated Busby et al. steelhead (O. mykiss) (August 18, 1997, 62 Critical Habitat 1995; Busby et FR 43937) al. 1996 Lower Columbia Threatened Species, No Critical Habitat Busby et al. River (CCR) steelhead (O. (March 19, 1998; 63 Designated 1995; Busby et mykiss) FR 13347) al. 1996 Middle Columbia River Threatened Species, No Critical Habitat Busby e£ al. (MCR) steelhead (O. (March 25, 1999, 64 Designated 1995; Busby et mykiss) FR 14517) al. 1996 Upper Columbia River Endangered Species, No Critical Habitat Busby et al. (UCR) steelhead (Q_ (August 18, 1997, 62 Designated 1996; mykiss) FR 43937) WCSBRT 1997 2-1J.] Paget Sound Chinook The threatened PS chinook salmon ESU encompasses all naturally spawned spring, summer and fall runs of chinook salmon in the Puget Sound region from the North Fork Nooksack River to the Elwha River on the Olympic Peninsula. Critical habitat is not presently designated for this ESU. Overall abundance of chinook salmon in this ESU has declined substantially from historical levels, and many populations are small enough that genetic and demographic risks are likely to be high. Although some natural spawning escapements in this ESU may be improving, the contribution of hatchery fish to natural escapements may be substantial, masking the trends in natural production. The widespread use of a limited number of hatchery stocks may have resulted in increased risk of loss of fitness and diversity among populations (Myers et al. 1998). Despite generally decreasing exploitation rates in Puget Sound since the implementation of the Pacific Salmon Treaty in 1985, spawning escapement trends have remained relatively constant. A strong decline in recruitment has largely been compensated for by decreases in harvest (WDF W and Puget Sound Indian Tribes 2001). Freshwater habitat throughout the range of the ESU has been blocked or degraded, with upper tributaries widely affected by poor forestry practices and lower tributaries and mainstem rivers affected by agriculture and urbanization. Other factors of decline include excessive harvest rates of natural stocks in mixed -stock fishing activities and the widespread use of a limited number of hatchery stocks. Spawning escapement since Myers ed al. (1998) indicates that 11 out of the 15 PS Chinook management units are either stable or have improved relative to the benchmark {1992-96) utilized in that assessment. The upswing in escapement for the majority of the management units is encouraging. However, since much of the additional escapement may have resulted from the near elimination of most harvest, it is too soon to determine if this represents the beginning of sustained improvement in .PS Chinook production (WDFW and Puget Sound Indian Tribes, 2001), 2.1.1.2 Lower Columbia River Chinook Salmon The threatened LCR chinook salmon ESU includes all natural -origin populations residing below impassable natural barriers from the mouth of the Columbia River to the crest of the Cascade Range just east of Hood River in Oregon and the White Salmon River in Washington. Critical habitat is not presently designated for this ESU. Estimated overall abundance of chinook salmon in the ESU is not cause for immediate concern. Long-term trends in fall -run escapement are mixed, with most larger stocks positive, while the spring -run trends are positive or stable. Short-term trends for both runs are more negative, some severely so (Myers et al_ 1998). However, apart from the relatively large and apparently healthy fall -run population in the Lewis River, production in this ESU appears to be predominantly hatchery -driven with few identifiable native, naturally reproducing populations. About half of the populations constituting this ESU are very small, increasing the likelihood that risks due to genetic and demographic processes in small populations will be important. Spawning and juvenile rearing areas have been eliminated or greatly reduced by dam construction, and freshwater habitat is in poor condition in many basins, due to forestry practices, urbanization and agriculture. Also of concern is the potential loss of fitness and diversity resulting from the introgression of hatchery fish within the ESU (Myers et al. 1998). 2.1.1.3 Snake River Fall -Run Chinook The threatened SR fall -run chinook salmon ESU includes all natural -origin populations of fall - run chinook in the mainstem Snake River and several tributaries including the Tucannon, Grande Ronde, Salmon, and Clearwater rivers. Fall -run chinook from the Lyons Ferry Hatchery are 6 0 included in the ESU but are not listed. Critical habitat was designated for SR fall -run Chinook salmon on December 28, 1993 (58 FR 68543). This ESU includes the mainstem river and all tributaries, from their confluence with the Columbia River to the Hells Canyon complex. Because genetic analyses indicate that fall -run Chinook salmon in the Snake River are distinct from the spring/summer-run in the Snake River basin (Waples et al. 1991 b), SR fall -run chinook salmon are considered separately from the other two forms. Some SR fall -run chinook historically migrated over 900 miles from the ocean. Although the SR population is now restricted to habitat in the lower river, genes associated with the lengthier migration may still reside in the population. Because longer freshwater migrations in chinook salmon tend to be associated with more -extensive oceanic migrations (Healey 1983), maintaining populations occupying habitat that is well inland may be important in continuing diversity in the marine ecosystem as well. Because of hydrosystem development, the most productive areas of the Snake River basin are now inaccessible or inundated. The upper reaches of the mainstem Snake River were the primary areas used by fall -run chinook salmon, with only limited spawning activity reported downstream from river mile 272. The Snake River has contained hatchery -reared fall -run chinook salmon since 1981 (Busack 1991). The hatchery contribution to Snake River escapement has been estimated at greater than 47% (Myers et al. 1998). Artificial propagation is recent, so cumulative genetic changes associated with it may be limited. Wild fish are incorporated into the brood stock each year, which should reduce divergence from the wild population. Release of subyearling fish may also help minimize the differences in mortality patterns between hatchery and wild populations that can lead to genetic change (Waples 1999). For the SR fall -run chinook salmon ESU as a whole, NOAH Fisheries estimates that the median population growth rate (lambda) over the base period ranges from 0.94 to 0.86, decreasing as the effectiveness of hatchery fish spawning in the wild increases compared to that of fish of wild origin (McClure el al. 2000). NOAA Fisheries has also estimated the risk of absolute extinction for the aggregate SR fall -run chinook salmon population, using the same range of assumptions about the relative effectiveness of hatchery fish. At the low end, assuming that hatchery fish spawning in the wild have not reproduced (i.e., hatchery effectiveness equals zero), the risk of absolute extinction within 100 years is 0.40 (McClure et al. 2000). At the high end, assuming that the hatchery fish spawning in the wild have been as productive as wild -origin fish (hatchery effectiveness equals 100%), the risk of absolute extinction within 1.00 years is 1.00 ( McClure et al. 2000). 0 0 2.1,1.4 Snake River Spring/Summer-Run Chinook Salmon The threatened SR spring/summer Chinook salmon includes all natural -origin populations in the Tucannon, Grande Ronde, Imnaha, and Salmon rivers. Some or all of the fish returning to several of the hatchery programs are also listed including those returning to the Tucannon River, Imnaha, and Grande Ronde hatcheries, and to the Sawtooth, Pahsimeroi, and McCall hatcheries on the Salmon River. Critical habitat was designated for SR spring/summer chinook salmon on December 28, 1993 (58 FR 68543), and was revised on October 25, 1999 (64 FR 57399). Even before mainstem dams were built, habitat was lost or severely damaged in small tributaries by construction and operation of irrigation dams and diversions, inundation of spawning areas by impoundments, and siltation and pollution from sewage, farming, logging, and mining (Fulton 1968). Recently, the construction of hydroelectric and water storage dams without adequate provision for adult and juvenile passage in the upper Snake River has kept fish from all spawning areas upstream of Hells Canyon Dam. There is a long history of human efforts to enhance production of chinook salmon in the Snake River basin through supplementation and stock transfers. The evidence is mixed as to whether these efforts have altered the genetic makeup of indigenous populations. Straying rates appear to be very low. For the SR spring/summer chinook salmon ESU as a whole, NOAA Fisheries estimates that the median population growth rate (lambda) over the base period ranges from 0.96 to 0.80, decreasing as the effectiveness of hatchery fish spawning in the wild increases compared to the effectiveness of fish of wild origin (McClure et al. 2000). NOAA Fisheries has also estimated median population grow=th rates and the risk of absolute extinction for the seven spring/summer chinook salmon index stocks, using the same range of assumptions about the relative effectiveness of hatchery fish. At the low end, assuming that hatchery fish spawning in the wild have not reproduced (i.e., hatchery effectiveness equals zero), the risk of absolute extinction within 100 years for the wild component ranges from zero for Johnson Creek to 0.78 for the Imnaha River (McClure et al. 2000). At the high end, assuming that the hatchery fish spawning in the wild have been as productive as wild -origin fish (hatchery effectiveness equals 100%), the risk of absolute extinction within 100 years ranges from zero for Johnson Creek to 1.00 for the wild component in the Imnaha River (.McClure et al_ 2000). 2.1.1.5 Upper Willamette River Chinook Salmon The threatened UWR chinook salmon ESU includes native spring populations in the Willamette River and tributaries upstream of Willamette Falls, including naturally produced spring -run fish in the Clackamas River. Critical habitat is not presently designated for this ESU. The abundance of naturally -produced spring -run chinook in the ESU has declined substantially from historic levels. Historic escapement levels may have been as high as 200,000 fish per year (Myers el al. 1998). Current natural escapement is less than 5,000 fish, and about two-thirds of 8 0 9 the natural spawners are estimated to be first -generation hatchery fish (Myers et al. 1998). Although natural escapements are substantially depressed, the number of naturally spawning fish have gradually increased .in recent years (NMFS 2001). Although natural escapements are depressed, the number of naturally spawning fish has gradually increased in recent years. The primary cause of decline of chinook in this ESU is the blockage of access to large areas of spawning and rearing habitat by dam construction. The remaining habitat has been degraded by thermal effects of dams, forestry practices, agriculture, and urbanization. Another concern for this ESU is that commercial and recreational harvest were high, relative to the apparent productivity of natural populations. New fishing regulations are expected to reduce harvest mortality by 70% from historic levels. Efforts have been taken to remedy some of the past hatchery practices including limiting the proportion of hatchery spawners in some natural production areas, and reincorporating local -origin wild fish into the hatchery broodstock. .2.1.1.6 Ozette Lake Sockeye The threatened OL sockeye salmon ESU includes all sockeye salmon that return to Lake Ozette through the Ozette River and currently spawn primarily in lakeshore upwelling areas on Ozette Lake. A small proportion of this ESU may also spawn below the lake in the Ozette River and its tributary, Coal Creek. Critical habitat is not presently designated for this ESU. The historical abundance of OL sockeye is poorly documented, but is believed to have declined significantly from historic levels. Historical estimates indicate run sizes of a few thousand sockeye salmon, with a peak recorded harvest of nearly 1.8,000 in 1949. Between 1977 and 1999, the average annual abundance level for the total (lake and tributary -origin) was 1,075 (ranging from 263 to 2,191 per year). This most recent four year annual mean run size from 1996 to 1999 for this predominantly four-year-old age at return escapement average compares to a mean escapement of 811 for the previous four years of the cycle (1992 to 1995, ranging from less than 267 to 2,548 per year). Sockeye salmon originating from Ozette Lake tributaries comprised an average of 9.8% of the total Ozette Lake escapement in recent years. Recent run size estimates and analysis of previous estimation methods indicate that sockeye abundance within the ESU may be relatively stable or increasing. Some of this increase is attributable to the hatchery supplementation and recovery program initiated in response to the decline in population abundance. Factors likely contributing to the decline of this ESU include introduced species, predation, loss of tributary populations, decline in quality of beach -spawning habitat, unfavorable ocean conditions, excessive historical harvests, introduced diseases, and the potential genetic effects of past and on-going hatchery practices (Dlugokenski et al. 1981; Beauchamp et al. 1995; Jacobs et al. 1996). Habitat degradation in the form of sedimentation, stream -bed scouring, increased flows, and degraded water quality have been primarily attributed to logging and associated road building. 0 0 2-.1,1,7 Hood Canal Summer -Run Chum Salmon The threatened HC summer -run chum ESU includes populations in Hood Canal and in Discovery and Sequim Bays on the Strait of Juan de Fuca. The ESU also includes summer -run churn salmon in the Dungeness River, but their status is uncertain (WDFW and PNPTT 2000). Critical habitat is not presently designated for this ESU. AIthough abundance was high in the late 1970s, abundance for most HC summer -run chum populations declined rapidly beginning in 1979, and has remained at depressed levels. The terminal run size for this ESU averaged 28,971 during the 1974 to 1978 period, declining to an average of 4,132 during 1979 to 1993. Abundance during the 1995 to 2000 period improved, averaging 8,724 adults. However, much of the increase in abundance can be attributed to a supplementation program begun in 1992 (WDFW and PNPTT 2000). The causes of decline for this ESU include a combination of the cumulative effects of habitat degradation, high fishery exploitation rates. and shifts in climatic conditions that have changed patterns and intensity of precipitation. Channel, riparian forest, and sub -estuarine conditions were moderately to severely degraded in all watersheds due to a history of logging, road building, rural development, agriculture, water withdrawal, and channel manipulations throughout the ESU (WDFW and PNPTT 2000). Total exploitation rates have dropped dramatically since 1995 as a result of fishery actions taken to protect summer -run chum and other salmonid species. Supplementation programs were instituted beginning in 1992 due to assessments of moderate or high risk of extinction for several stocks (WDFW and PNPTT 2000). These programs are scheduled to end in 12 years, unless re-evaluation at that time indicates extending them would be beneficial to recovery of the ESU. 2.1.1.8 Columbia River Chum Salmon This threatened ESU includes all naturally produced chum salmon populations that enter the Columbia River. Historically, chum salmon were abundant in the lower reaches of the Columbia River and may have spawned as far upstream as the Walla Walla River (Johnson et al. 1997). However, reductions in available habitat currently limit chum salmon in the Columbia River to tributaries below Bonneville Dam. Presently, only two chum salmon populations are recognized and monitored in the Columbia River (Grays River and Hardy and .Hamilton Creeks/Ives Island group), although chum have been reported in other areas, including the East Fork Lewis River (Salo 1991; Kostow 1995). Critical habitat is not presently designated for this ESU. Current abundance is less than one percent of historic levels, and the ESU has lost some of its original genetic diversity. The estimated minimum run size for this ESU has been relatively stable, since the run collapsed during the mid-1950s (Johnson et al_ 1997). information from stream surveys of the remaining populations suggests that there may be a few thousand chum spawning in the Columbia River basin (Johnson et al. 1997), 10 E Decline of this ESU is attributed to dams and habitat degradation primarily from diking and wetland loss (Johnson et al, 1997). Hatchery fish have had little influence on the wild component of the Columbia River chum salmon ESU (Johnson et al. 1997). 2.1.19 Upper Willamette Steelhead The UWR steelhead ESU includes all naturally produced steelhead in the Willamette River and its tributaries upstream of Willamette Falls. No estimates of abundance prior to the 1960s are available. Abundance has been declining steeply since the late 1980s going from an average of over 15,000 in the 1970s and 1980s to several thousand today (Busby et al. 1.996). Critical habitat is not presently designated for this ESU. The potential negative influence of hatchery fish through genetic effects and competition between native and non-native stocks was noted as the primary factor of concern for this ESU (Busby et al. 1996). Habitat blockage from dams and habitat degradation from logging and urbanization have contributed to stream flow and temperature problems and loss of riparian habitat (Bottom et al. 1985, Busby et al. 1996). 2.1.1,10 Lower Columbia River Steelhead The threatened LCR steelhead ESU includes all naturally produced steelhead in tributaries to the Columbia River between the Cowlitz and Wind Rivers in Washington and the Willamette and Hood Rivers in Oregon, excluding steelhead in the upper Willamette River above Willamette Falls and steelhead in the little and Big White Salmon Rivers in Washington (Middle Columbia ESU) (Busby et al. 1996). Critical habitat is not presently designated for this ESU. No estimates of historical abundance (pre -1960s) specific to this ESU are available. A conservative estimate of current abundance puts the average run size at greater than 16,000. Abundance trends are mixed and possibly affected by short-term climate conditions. At the time ofNOAA Fisheries' status review (Busby el al. 1996), the majority of stocks for which data are available within this ESU were declining, although some had increased strongly. Since 1996, listed LCR steelhead populations have generally increased, with some populations rebounding more quickly than others. The magnitude of hatchery production, habitat blockages from dams, and habitat degradation from logging and urbanization are areas of concern. The widespread production of hatchery steelhead within this ESU creates specific concerns for summer steelhead and Oregon winter -run steelhead stocks, where there appears to be substantial overlap in spawning between hatchery and natural fish (Busby et al. 1996). Most of the hatchery stocks originate from stocks within the ESU, but many are not native to local river basins. 0 0 2.1.1.11 Middle Columbia River Steelhead The threatened MCR steelhead ESU includes all natural -origin populations in the Columbia River basin above the Wind River in Washington, and the Hood River in Oregon (exclusive), including the Yakima River in Washington, except for steelhead in the Snake River basin (Busby et al. 1996). This ESU includes the only populations of winter -run inland steelhead in the United States (in the Klickitat River, Washington, and Fifteenmile Creek, Oregon). Both the Deschutes River and Umatilla River hatchery stocks are included in the ESU, but are not listed. Critical habitat is not presently designated for MCR steelhead. Substantial habitat blockages are present in this ESU. Water withdrawals, and loss of riparian vegetation caused by overgrazing have seriously reduced summer flows in the principal summer - run steelhead spawning and rearing tributaries of the Deschutes River. High summer and low winter temperatures are limiting factors for salmonids in many streams in this region (Bottom et al. 1985; Busby et al, 1996). Continued increases in the proportion of stray steelhead in the Deschutes River basin is a major concern. The ODFW and the Confederated Tribes of the Warm Springs Reservation of Oregon estimate that 60% to 80% of the naturally spawning population consists of strays, which greatly outnumber naturally produced fish. Although the reproductive success of stray fish has not been evaluated, the genetic contribution of non -indigenous, hatchery stocks may have reduced the fitness of the locally adapted, native fish. A decrease in fitness could have occurred through hybridization and associated reductions in genetic variation or introduction of deleterious (non - adapted) genes. Hatchery fish can also directly displace natural spawning populations, compete for food resources, or engage in agonistic interactions (Campton and Johnston 1985; Waples 1991b; Hilbom 1992; Busby et al. 1996). The negative effects of any interbreeding between stray and native steelhead will be exacerbated if the stray steelhead originated in geographically distant river basins, especially if the river basins are in different ESUS. A key unresolved question about the large number of strays in the Deschutes basin is how many stray fish remain in the basin and spawn naturally. Historical abundance in the ESU may have been in excess of 300,000 (Busby et al. 1996). Total abundance was estimated at about 200,000 by the early 1980s, and by the early 1990s average abundance was 142,000 with 39,000 naturally produced. Total steelhead abundance in the ESU appears to have been increasing recently, and the naturally produced component has been relatively stable. However, the majority of natural stocks for which there are data within this, ESU have been declining. There is particular concern about Yakima River and winter -run steelhead stocks. Winter -run steelhead are reported within this ESU only in the Klickitat River and Fifteenmile Creek. No abundance information exists for winter -run steelhead in the Klickitat River, but winter -run steelhead are reported to have been declining in abundance in Fifteenmile Creek. Escapement 12 0 0 trends for natural summer and winter steelhead have been increasing over the last few years but are still below historic levels. For the MCR steelhead ESU as a whole, NOAA Fisheries estimates that the median population growth rate (lambda) over the base period ranges from 0.88 to 0.75, decreasing as the effectiveness of hatchery fish spawning in the wild increases compared with that of fish of wild origin ( McClure et al_ 2000). NOA.A Fisheries has also estimated the risk of absolute extinction for four of the subbasin populations, using the same range of assumptions about the relative effectiveness of hatchery fish. At the low end, assuming that hatchery fish spawning in the wild have not reproduced (Le., hatchery effectiveness equals zero), the risk of absolute extinction within 100 years ranges from zero for the Yakima River summer run to 1.00 for the Umatilla River and Deschutes River summer runs (McClure et al. 2000). Assuming that the hatchery fish spawning in the wild have been as productive as wild -origin fish (hatchery effectiveness equals 100%), the risk of absolute extinction within 100 years ranges from zero for the Yakima River summer -run to 1.00 for the Deschutes River summer -run (McClure et al. 2000). 2.1.1.12 Snake River Basin Steelhead The threatened SRB steelhead includes all naturally produced steelhead in the Snake River basin of southeast Washington, northeast Oregon and Idaho (Busby et al. 1996). None of the hatchery stocks in the Snake River basin is listed, but several are included in the ESU. Critical habitat is not presently designated for SRB steelhead. Hydrosystem projects create substantial habitat blockages in this ESU; the major ones are the .l tells Canyon Dam complex (mainstcm Snake River) and Dworshak Dam (North Fork Clearwater River). Minor blockages are common throughout the region. Steelhead spawning areas have been degraded by overgrazing, as well as by historical gold dredging and sedimentation due to poor land management. The habitat degradation has resulted in significant temperature and flow fluctuations, sedimentation, and loss of riparian vegetation. Habitat in the Snake River basin is warmer and drier and often more eroded than elsewhere in the Columbia River basin or in coastal areas (Busby et al. 1996). Hatchery fish are widespread and stray to spawn naturally throughout the region. In the 1990s, an average of 86% of adult steelhead passing Lower Granite Dam were of hatchery origin. Hatchery contribution to naturally spawning populations varies, however, across the region. Hatchery fish dominate some stocks, but do not contribute to others (Busby et al. 1996). For the SRB steelhead ESU as a whole, NOAA Fisheries estimates that the median population growth rate (lambda) over the base period ranges from 0.91 to 0.70, decreasing as the effectiveness of hatchery fish spawning in the wild increases compared to that of fish of wild origin (McClure et al. 2000). NOAA Fisheries has also estimated the risk of absolute extinction for the A- and B -runs, using the same range of assumptions about the relative effectiveness of hatchery fish. At the low end, assuming that hatchery fish spawning in the wild have not reproduced (i.e., hatchery effectiveness equals zero), the risk of absolute extinction within 13 0 0 100 years is 0,01 for A -run steelhead and 0.93 for B -run fish (McClure et al. 2000). At the high end, assuming that the hatchery fish spawning in the wild have been as productive as wild -origin fish (hatchery effectiveness equals 100%), the risk of absolute extinction within 100 years is 1.00 for both runs (McClure et al. 2000). 2.1,1,13 Summary of the Evolutionarily Significant Units' Current Status Average population abundances in the 12 threatened ESUS are clearly substantially less than historical levels. The current low average abundances of the species and the range of different activities currently affecting the species underscore the critical need for continued rigorous monitoring and evaluation of population parameters and the effects of various activities on those populations. The biological requirements of the 12 threatened ESUS are currently not being met under the environmental baselines. Their status is such that there must be significant improvements in the environmental conditions of the ESUs' respective baselines. Previous NOAA Fisheries listing decisions and consultations, and the biological review prepared for the RRMP, provide additional, detailed discussions of the environmental baselines. Current scientific information suggests that a multitude of factors, past and present, human and natural, have contributed to the decline of these ESUS. For example, there is evidence to suggest that previous and current destruction and modification of freshwater habitats contribute to the decline of these species. 2.1.2 Evaluating the Proposed Action The standards for determining jeopardy and destruction or adverse modification of critical habitat are set forth in section 7(a)(2) of the ESA. In conducting analyses of habitat -altering actions under section 7 of the ESA, NOAA Fisheries uses the following steps of the consultation regulations and when appropriate combines them with The Habitat Approach, Implementation of Section 7 of 'the .Endangered Species Act for Actions Affecting the Habitat of Pacific Anadromous Salmonids (NMFS 1999): (1) Consider the biological requirements and status of the listed species; (2) evaluate the relevance of the environmental baseline in the action area to the species' current status; (3) determine the effects of the proposed or continuing action on the species, and whether the action is consistent with any available recovery strategy; and (4) determine whether the species can be expected to survive with an adequate potential for recovery under the effects of the proposed or continuing action, the effects of the environmental baseline, and any cumulative effects, and considering measures for survival and recovery specific to other life stages. In completing this step of the analysis, NOAA Fisheries determines whether the action under consultation, together with all cumulative effects when added to the environmental baseline, is likely to jeopardize the ESA -listed species or result in the destruction or adverse modification of critical habitat. If jeopardy or adverse modification are found, NOAA Fisheries may identify reasonable and prudent alternatives for the action that avoid jeopardy and/or destruction or adverse modification of critical habitat. 14 0 9 The fourth step above (jeopardy/adverse modification analysis) requires a two-part analysis. The first part focuses on the action area and defines the proposed action's effects in terms of the species' biological requirements in that area (i.e., effects on essential features). The second part focuses on the species itself. It describes the action's effects on individual fish, populations, or both - and places that impact in the context of the ESU as a whole. Ultimately, the analysis seeks to determine whether the proposed action is likely to jeopardize a listed species' continued existence or destroy or adversely modify its critical habitat. 2.1.2.1 Biological Requiremenis The first step in the methods NOAA Fisheries uses for applying ESA section 7(a)(2) to listed salmon is to define the species' biological requirements that are most relevant to each consultation. NOAA Fisheries also considers the current status of the listed species; taking into account population size, trends, distribution, and genetic diversity. To assess the current status of the listed species, NOAA Fisheries starts with the determinations made in its original decision to list the species for protection under the ESA. Additionally, the assessment will consider any new information or data that are relevant to the determination. The relevant biological requirements are those necessary for the listed species to survive and recover to naturally reproducing population levels at which time protection under the ESA would be unnecessary. Species or FSUs not requiring ESA protection have the following attributes: population sizes large enough to maintain genetic diversity and heterogeneity, the ability to adapt to and survive environmental variation, and are self-sustaining in the natural environment. The 12 threatened species covered by this consultation have similar basic biological requirements. These requirements include food, flowing water (quantity), high quality water (cool, free of pollutants, high dissolved oxygen concentrations, low sediment content), functioning riparian conditions, stable streambank conditions, flood plain connectivity, adequate in -stream abundance and sources of woody material recruitment, clean spawning substrate, and unimpeded migratory access to and from spawning and rearing areas (adapted from Spence et al. 1996). NOAA Fisheries has related the biological requirements for listed salmonids to a number of habitat attributes, or pathways, in the Matrix of Pathways and Indicators (MPI). These pathways (Water Quality, Habitat Access, Habitat Elements, Channel Condition and Dynamics, Flow/Hydrology, Watershed Conditions, Disturbance History, and Riparian Reserves) indirectly measure the baseline biological health of listed salmon populations through the health of their habitat. Specifically, each pathway is made up of a series of individual indicators (e.g., indicators for water quality include temperature, sediment, and chemical contamination) that are measured or described directly. Based on measurement or description, each indicator is classified within a category of the properly functioning condition (PFC) framework: (1) properly functioning, (2) at risk, or (3) not properly functioning. Properly functioning condition is defined as "the sustained presence of natural habitat forming processes in a watershed that are necessary for the long-termsurvival of the species through the full range of 15 environmental variation." The specific biological requirements affected by the proposed RRMP include food availability and habitat attributes including water quality, flow/hydrology, habitat access, riparian elements and channel condition and dynamics. 2.1.2.2 Environmental Baseline The environmental baseline represents the current set of basal conditions to which the effects of the proposed action are then added. Environmental baseline is defined as "the past and present impacts of all Federal, state, and private actions and other human activities in the action area, the anticipated impacts of all proposed Federal projects in the action area that have already undergone formal or informal section 7 consultation, and the impact of state or private actions which are contemporaneous with the consultation process" (50 CFR 402.02). The term "action area" is defined as "all areas to be affected directly or indirectly by the federal action and not merely the immediate area involved in the action." For the purpose of this consultation, the action area includes all waters throughout the State of Washington within the range of the 12 threatened salmon and steelhead ESUs. The action area may extend upstream or downstream of permitted projects, based on their potential to affect fish passage, riparian succession, the hydrologic cycle, the erosion, transportation, and deposition of sediments, and other ecological processes related to the formation and maintenance of salmon habitats. Indirect effects may occur throughout the watershed where other activities depend on RRMP activities for their justification or usefulness. The major factors influencing the environmental baseline within the action area include: (l) habitat modifications; (2) hatchery practices; and (3) harvest management. 2.1.2.2.1 Habitat, Introduction. The scale of the analysis appears large as the action area includes much of Washington State. However, the effects of underlying routine road maintenance activities are highly repetitive and predictable. To enable an appropriate analysis for intra -agency consultation, programmatic consultation must fact the condition of habitat elements, statewide. NOAA Fisheries summarized status information reported in several documents, including Washington State Department of Natural Resources' (WDNR) Changing Our Water Ways: Trends in Washington's Water Systems (WDNR 2000), the Washington State Conservation Commission's (WSCC) Habitat Limiting Factors Reports (WSCC 1999 - 200 1) and the Regional Road Maintenance Technical Working Group's Biological Review of the Regional Road Maintenance ESA Program Guidelines (RRM-TWG 2001). These documents review the trends affecting aquatic resources statewide. Declines in the status of salmon and steelhead in Washington State are attributed to myriad factors, including habitat functional quality and amount. Both natural and human -induced activity have contributed to this decline; under formal consultation NOAA Fisheries focuses primarily on human activities. 16 0 9 While human disturbances may have minimal impacts individually, the number, magnitude, duration, and cumulative impacts since Euro -American settlement combine to form the primary cause of the decline of numerous salmon stocks in fresh water. Historical and current human - caused disturbances include: clearing and channelizing rivers, sending logs down streams via splash dams, extensive land clearing, diverting water, livestock grazing in waterways, mining run-off, constructing logging roads and accelerating erosion, removing old growth forests, filling and diking of wetlands and estuaries, armoring shorelines and streambanks, developing hydroelectric dams, creating barriers to fish migration, increasing surface run-off, contaminating water and sediments, introducing non-native plants and animals, changing levels of oxygen and nutrients in waterways and over fishing. Human activity and development have significant and damaging impacts on the environment, and the growing population indicates increasing pressure on the state's aquatic resources. Washington's population (5.8 million in 2000) is expected to increase by nearly 2 million by the year 2020. Although each watershed is unique, the impacts of development can be grouped into broad categories: • Interrupting the flow of water • Alterations to aquatic ecosystems • Shoreline modifications • Effects of shipping and transportation • Pollution Interrupted flow regime. Today, approximately 1,025 dams obstruct the flow of water in Washington; this number includes any structure than can store 10 or more acre-feet of water. Because dams obstruct the flow of rivers, they change the physical flow of water, resulting in areas that are either drier than normal or flooded. Changing the depth and flow of rivers also affects the water's temperature. Dams also change the flow of materials carried in river water. They stop the flow of debris, nutrients, sediments, and reduce the size and quality of floodplains. As a result, reservoirs eventually fill with sediments and inadequate amounts of sediments reach the deltas and estuaries. Dams also change the movement of fish migrating between the streams and oceans. In addition to the many dams blocking fish movement, the Washington Department of Fish and Wildlife (WDFW) indicates there is a minimum of 2,400 to 4,000 human -made barriers blocking 3,000 to 4,500 miles of freshwater spawning and rearing habitat for salmon. A recent critique of the Washington State Hydraulic Code estimated that there are approximately 8,800 culvert related barriers blocking over 6,000 miles of habitat. The authors estimated an annual lost opportunity of 10 million adult salmon (Hollowed and Wasserman 2000). Irrigation projects significantly changed the timing, quantity; and quality of flow in many rivers and tributaries. Flood control dikes and highway construction cut off rivers from their historic flood plains and wetlands, resulting in habitat destruction, changes in stream temperature and nutrient composition alterations. In the Yakima River basin, these changes contributed to the 17 9 0 reduction of historically abundant runs of salmon and steelhead. Today, summer -run chinook, native coho and anadromous sockeye are extinct and spring chinook declined from 9,300 in 1986 to 645 in 1997. Human impacts and natural events can combine to change the flow of a river. The natural course of a river includes its floodplain. When the East Fork Lewis River was captured by floodplain gravel pits in 1995, it abandoned 1,700 feet of gravel spawning beds, and when captured again in 1996, it abandoned another 3,200 feet. The availability of water has long been a major issue for all Washington residents, including its aquatic species. Of Washington's 62 Water Resource Inventory Areas (WRIAs), 16 have both an ESA -listed salmon stock and a water supply problem. In addition, about 450 lakes and streams in Washington are partially or completely closed to further withdrawals. Another issue associated with growth in Washington is increased coverage by impervious surfaces. Impervious surfaces affect the amount of water that seeps into the ground and washes into streams; they also affect how quickly the water gets there. When land is covered with pavement or buildings, the area available for rainwater and snowmelt to seep into the ground and replenish the groundwater is drastically reduced: in many urban areas it is virtually eliminated. The natural movement of water through the ground to usual discharge points such as springs and streams is altered. Instead, the natural flow is replaced by storm sewers or by more concentrated entrance points of water into the ground. Changing the timing and amount of water run-off can lead to too much water going directly into streams in the rainy months of winter instead of soaking into the ground. Consequently, there is not enough water in the ground to slowly release into streams in the dry months of summer. Too much water in the winter can cause fish habitat to be scoured by unnaturally swift currents; not enough water in streams in the summer leads to water temperatures too high to support fish. Studies show that when impervious surfaces such as pavement and buildings cover between five percent to eight percent of a watershed, the health of streams and the fish in them declines, despite stormwater controls. In the south Puget Sound area, most urban watersheds are 20% to 40% covered with hard surfaces, altering stream flows, water temperatures, and in -stream habitat for everything from insects to fish. Altered Aquatic Ecosystems_ Wetlands improve water quality by filtering out sediments, nutrients, and toxic chemicals. However, research shows that a watershed can withstand having only five percent to eight percent of its land base covered with buildings, roads, and other impervious surfaces before significant changes in wetland functions and stream hydrology begin to occur. Washington has almost two centuries of wetland conversion. Since statehood, Washington has lost 33% of its wetland areas, from 1.4 million acres to 938,000 acres. Estuary losses have occurred primarily through conversions to farms and cities. In the Skagit Valley, for example, a large majority of the estuary mud flats and flood plain was converted to farmland before the first land surveys of 1889. Nearly 75% of the wetland area was lost before 18 0 0 statehood. Currently less than 3 square miles of tidal estuary wetland remain, a 93% loss. When tidal flood plains and estuaries are destroyed or significantly disturbed, critical functions are at risk. The vast food source is diminished and silt that is carried along by currents to replenish beaches and nearshore habitat is lost. Replacing estuaries with farms, industry, and cities destroys habitat critically needed by salmon. Eelgrass, a marine flowering plant, grows low in the intertidal zone and in mud and sand in the shallow subtidal zone. it is critical to salmon recovery efforts because it provides fish a place to hide and evade predators. it also provides food and habitat for salmon prey. Because of where it grows, eelgrass is largely inaccessible and hard to survey. As a result, it is unclear how much eelgrass has disappeared from Puget Sound waters over the past 100 years. However, the historical data that scientists do have suggest that eelgrass beds in Bellingham Bay have declined by about 50% over the past 100 years; a figure fairly consistent throughout its range in Washington. The amount of dissolved oxygen in water is an important measurement of overall water quality. Areas of Puget Sound are experiencing lower levels of dissolved oxygen. In March 2000, the Puget Sound Water Quality Action Team identified 87 areas in Puget Sound that had problem with low dissolved oxygen. Human actions are the main contributor to depleted oxygen. Excessive fertilizers and nitrogen applied to yards and fields, and fecal matter from septic fields and failing septic systems, contribute pathogens and nutrients that can deplete oxygen. Because there is little historical data on dissolved oxygen concentrations in marine waters, it is difficult to compare the health of Washington's marine waters of today to those of the past. However, based on measurements of dissolved oxygen in the southern part of Hood Canal made in the 1950s and 1960s, today's dissolved oxygen concentrations are lower, more frequently. The introduction of non-native species has been known to profoundly affect ecosystems by disrupting food webs and displacing native species. Because of a lack of natural predators or competitors, these introduced species can spread rapidly. In 1998, an expedition discovered more than 52 invasive species in Puget Sound. Non-native species are introduced primarily through shipping, aquaculture, research, and aquaria industries. Other tenacious and insidious non-native species that have invaded Washington's waters and aquatic ecosystems include: • Eurasian Water Milfoil, an aquatic plant found in lakes and slow-moving streams. it can lower dissolved oxygen and increase pH; displace native aquatic plants and increase water temperature. • Parrotfeather is limited to coastal lakes and streams, the Columbia River, the Chehalis River and private ponds and lakes. The emergent stems shade the water column, eliminating algal growth, which is the basis of the aquatic food web. • Purple Loosestrife generally grows in marshes, ponds, streambanks, ditches and lake shores. Because it grows so aggressively, large stands take over an area and eventually replace the native plant species, eliminating the natural food and cover essential to native shoreline and 19 0 wetland inhabitants. 0 • Hydrilla roots in lake sediments and grows rapidly under very low light conditions. Hydrilla can fill the water column with vegetation, displacing native fish and wildlife. • Spartina is an non-native species of intertidal cordgrass. If left uncontrolled, Spartina transforms mud flats into dense, raised meadows, cut by narrow, deep channels. The loss of mud flats, eelgrass, and algae directly affect native fish species that depend on these areas for feeding, spawning and rearing. Shoreline _Wodification. Washington has more than 3,000 miles of marine shoreline. When these shorelines are changed or eradicated, intertidal and nearshore habitat is affected or lost, causing significant stress on the salmon that rely on these habitats. Modifications of shorelines include bulkheads, docks, piers, or areas that have been filled or dredged. Few statistics exist on the extent of freshwater shoreline modification. One lake that has received some attention is Lake Washington, in Seattle. More than 80% of its shoreline has been armored against erosion and over 3,000 residential piers cover approximately 2.5% of the lake's surface. Adverse effects of these shoreline modifications include loss of riparian vegetation, shading of the nearshore aquatic zone, and an increase in attractive refugia for piscivorous birds and fish. Development of Washington's marine and estuarine shoreline over the past 100 years has created a landscape that is dramatically different from what the first settlers found. About 800 miles of the Puget Sound shoreline have been modified, with 25% of the modifications in the intertidal areas. Up to 52% of the central Puget Sound shoreline and about 35% of the shorelines of Whidbey Island, Hood Canal, and south Puget Sound have been changed or eradicated. To help protect their shoreline property from erosion, many waterfront homeowners construct bulkheads between their land and the beach. Ironically, one consequence of bulkheads is the loss of sand from the beach and beach erosion. The natural process of bluff erosion provides a supply of sand and rocks to the beach. Construction of bulkheads cuts off this supply of beach -building material and prevents the wave's energy from dissipating. A 1998 survey in Puget Sound found that nearly 15% of armored beaches had mostly large rocks and minimal sediment compared to only one percent of unarmored beaches. The loss of sand and pebbles affects small fish that use this habitat for spawning. These small fish form the base of the food chain for larger fish. The Shoreline Management Act was passed in 1971 to protect the state's shorelines from development impacts. However, since passage of the Act, about 26,000 permits have been issued statewide for substantial shoreline development projects. This number does not include single family homes, which are exempt from the permit process. Shipping and Transportation. Since the days of early settlement, marine shipping has played a key role in the state's economy, and ports are the critical hub of this waterborne trade. Early dredging, filling, and other alterations of shallow estuarine areas were devastating to the fish that 20 0 0 depended on the habitat as a transition from freshwater to saltwater. Over time, the increased demand for shipping facilities led to more dredging and filling until today an average of 50% of the original wetland habitat in Puget Sound's major bays has been destroyed. Bays near urban centers such as Tacoma and Seattle have less than five percent of their natural intertidal habitat left. There are 48 ports in Washington's waters. The total tonnage shipped from those ports has increased 60% over the past five decades, and shipping container traffic is expected to double in the next 20 years. Not only are there more ships, but the ships are being built bigger. To accommodate larger ships, ports expand and shipping channels are dredged deeper. Dredging the bottom of bays and rivers displaces plants and animals living there and can stir up contaminated sediments. Dumping dredged materials elsewhere in the water smothers habitat. 1n the late 1990s, the Army Corps of Engineers proposed deepening the Columbia River's existing navigation channel to accommodate larger ships. Over the 50 -year life of the project, the deeper channel will result in 267 million cubic yards of material which would need to be disposed in the river, in the ocean, or on land. The disposal of dredged material will result in the loss of at least 67 acres of habitat in the river, 200 acres of agricultural land, and 20 acres of wetlands. The dredging project will alter the designated critical habitat of listed salmon, damage prey species stocks, and alter the food web. Ports expand to accommodate not only more ships, but larger ships as well. The shipping industry continually builds larger ships to carry larger cargo loads. In response, ports enlarge their facilities and deepen their navigation channels so that larger vessels can dock and unload their goods. The larger vessels carry more ballast water, which when dumped into Washington's waters has the potential of introducing non-native species. Increased shipping activity affects more than just the waterfront it also results in an increased need for overland transportation. More trucks and rail cars are needed to transfer goods to and from ships and inland destinations. Aquatic ecosystems are at risk of becoming polluted by more petroleum -carrying run-off from increased traffic on roads. Pollutants. Washington is rich in water resources, but there are unseen risks in many of the state's water bodies. Of the 1,099 lakes, streams, and estuaries for which there is data, 643 (59%) are so impaired they do not adequately provide for swimming, fishing or habitat. The main causes of water quality problems are related to human activities, such as farming, failing septic systems, increased erosion along streams, and pollutants added to land and water. The mud and sand in many places beneath Washington's waters are so contaminated they do not meet state and federal standards. More than 3,000 acres of Puget Sound sediments are so contaminated that federal laws require they be cleaned up. Of the state's 112 contaminated sites identified by the Washington State Department of Ecology, 93 are in saltwater and 19 are in freshwater. Contaminated sediments are detrimental to the health and diversity of aquatic populations. 21 0 0 Declines in Fish. Salmon provide critical links in an entire food web. They transport energy and nutrients between the ocean, estuaries, and freshwater environments, even in death. Recent calculations indicate that only three percent of the marine nutrients once delivered by anadromous salmon to the rivers of Puget Sound, the Washington Coast, and the Columbia River are currently reaching those streams. Researchers surmise this is due to the substantial decline in salmon populations over the past several decades. The decline in salmon over the past several decades is the result of both natural and human factors. Forestry, agriculture, mining, and urbanization have degraded, simplified, and fragmented habitat. Water diversions for agriculture, flood control, domestic, and hydra power purposes have greatly reduce or eliminated historically accessible habitat. Studies indicate that in most western states, about 80% to 90% of the historic riparian habitat has been eliminated. Road Maintenance Activities. Current RRMP activities affect peak and base flows in streams as a result of the permanent removal of vegetation, earth clearing work and hydraulic modification work. Runoff of pollutants from roadways and accidental spills in work areas affects water quality indicators, including chemical contamination. Lack of sufficient erosion control measures leave exposed soil susceptible to the erosive forces of flowing water. Excess sediment loading into receiving waterbodies and streams, together with increased turbidity levels impairs gills of fish, smothers eggs, embeds spawning gravels, disrupts feeding and growth patterns of juveniles, delays upstream migration of adults, and scours nutrients from the stream substrate. Maintenance activities near streams disturb fish and causes them to temporarily abandon suitable habitat. The long-term or permanent removal of riparian vegetation has resulted in degraded water quality (e.g., increased water temperature). Habitat Summary. Although specific habitat concerns differ among watersheds, there are some common findings: • Adjacent land management practices and direct actions within stream corridors have significantly altered natural stream ecological processes; • fine sediment (less than 0.85mm) levels in stream gravels regularly exceed the less -than - 12% level identified as representing suitable spawning habitat (USFWS 1999); • Adequate Large Woody Debris (LWD) is lacking in streams, particularly larger key pieces needed to develop pools, logjams, and other habitat components important to salmonids; • Adequate pools are lacking for rearing juvenile salmonids and supporting adult salmonids during their upstream migration; • High rates of channel constrictions and the alteration of natural hydrology further worsens the rate of streambank erosion and substrate instability due to loss of streambank and riparian integrity; 22 0 9 • Riparian function is lost due to removal, or alteration, of natural riparian vegetation. This habitat loss affects water quality, lateral erosion, streambank stability, and instream habitat conditions; • A significant number of barriers, including culverts, screens, water diversions, and dams, prevent unrestricted upstream and downstream access to juvenile and adult salmonids; • Dams have altered temperature profiles, inundated spawning habitat, created passage barriers, diminished sediment transport, altered seasonal flow patterns, imparted broad diel flow fluctuations, eliminated lotic channel characteristics, and created habitat for species that prey on or compete with salmonids (Spence et al. 1996; Wydoski and Whitney 1979; Tabor et al. 1993); • Heavily development in uplands has altered natural stream hydrology. The threat of similar impacts to streams experiencing current and future development growth; • fertilizers, pesticides, petroleum products and other industrial and agricultural contaminants have degraded water quality; • Altered natural estuaries have significantly affected estuarine and marine functions. 2.1.2.2.2 Hateheries. For more than 100 years, hatcheries in the Pacific Northwest have been used to replace natural production lost as a result of hydropower and other development, not to protect and rebuild natural populations. As a result, most salmon populations in this region are primarily hatchery fish. In 1987, for example, 95% of the coho, 70% of the spring -run chinook, 80% of the summer -run chinook, 50% of the fall -run chinook, and 70% of the steelhead returning to the Columbia River basin originated in hatcheries. (CBFWA 1990). While hatcheries certainly have contributed greatly to the overall numbers of salmon, only recently has the effect of hatcheries on native wild populations been demonstrated. In many cases, these effects have been substantial. For example, production of hatchery fish, among other factors, has contributed to the 90% reduction in wild coho salmon runs in the lower Columbia River over the past 30 years (NMFS 2000a). NOAA Fisheries has identified four primary categories of risk that hatcheries can pose on wild - run salmon and steelhead: 1) ecological effects; 2) genetic effects; 3) overharvest effects; and 4) masking effects (NMFS 2000a). Ecologically, hatchery fish can increase predation on, displace, and/or compete with wild fish. These effects are likely to occur when fish are released in poor condition and do not migrate to marine waters, but rather remain in the streams for extended rearing periods during which they may prey on or compete with wild fish. Hatchery fish may also transmit hatchery -borne diseases, and hatcheries themselves may release diseases into stream via water effluents. 23 0 0 Genetically, hatchery fish can affect the genetic variability of native fish via interbreeding, either intentionally or accidentally. interbreeding can also result from the introduction of native stocks from other areas. Theoretically, interbred fish are less adapted to, or productive, within the unique local habitats where the original native stock evolved. In many areas, hatchery fish provide increased fishery opportunities. When wild fish mix with hatchery stock, fishing pressure can lead to overharvest of smaller or weaker wild stocks. Further, when migrating adult hatchery and wild fish mix on the spawning grounds, the health of the wild runs and the condition of the habitat's ability to support runs can be overestimated, because the hatchery fish mask surveyors' ability to discern actual wild run conditions. Recent hatchery reforms include supplementation and reintroduction programs conducted to minimize adverse genetic, ecological, and demographic effects on naturally -produced salmonids. Monitoring and evaluation programs have been designed to identify the ecological and genetic effects of hatchery programs listed fish. The role of hatcheries in the future of Washington's salmonids is presently unclear; it will depend on the values people place on fish production and biological diversity. Clearly, conservation of biological diversity is gaining support, and the future role of hatcheries may shift toward judicial use of hatcheries to meet these goals rather than opposing them. 2.1.2.2.3 Harvest. Non -Indian fisheries began in about 1830 with the arrival of European settlers; by 1861, commercial fishing was an important economic activity that developed with the advent of canning technologies. The early commercial fishery used gill nets, seines hauled from shore, traps, and fish wheels. Later, purse seines and trolling (using hook and line) fisheries developed. Recreational (sport fishing) began in the late 1800s, occurring primarily in tributary locations (NMFS 2000a). Whereas freshwater fisheries in Washington were declining during the first half of the twentieth century, primarily due to high harvest rates, ocean fisheries were growing, particularly after World War Il. This trend occurred up and down the West Coast as fisheries with new gear types leapfrogged over the others to gain first access to the migrating salmon runs. Large, mixed -stock fisheries in the ocean gradually supplanted the freshwater fisheries, which were increasingly restricted or eliminated to protect spawning escapements. By 1949, the only freshwater commercial gear types remaining were gill nets, dip nets, and hoop nets (NMFS 2000a). This leapfrogging by various fisheries and gear types resulted in conflicts about harvest allocation and the displacement of one fishery by another. Ocean trolling peaked in the 1950s; recreational fishing peaked in the 1970s. The ocean harvest has declined since the early 1980s as a result of declining fish populations and increased harvest restrictions. The capacity of salmonids to produce more adults than are needed for spawning offers the potential for sustainable harvest of naturally produced (versus hatchery -produced) fish. This potential can be realized only if two basic management requirements are met: 1) enough adults return to spawn and perpetuate the run, and 2) the productive capacity of the habitat is maintained. Catches may fluctuate in response to such variables as ocean productivity cycles, 24 0 0 periods of drought, and natural disturbance events. However, as long as the two management requirements are met, fishing can be sustained indefinitely. Unfortunately, both prerequisites for sustainable harvest have been violated routinely in the past. The lack of coordinated management across jurisdictions, combined with competitive economic pressures to increase catches or to sustain them in periods of lower production, resulted in harvests that were too high and escapements that were too low. At the same time, habitat has been increasingly degraded, reducing the capacity of the salmon stocks to produce numbers in excess of their spawning escapement requirements. For years, the response to declining catches was hatchery construction to produce more fish. Because hatcheries require fewer adults to sustain their production, harvest rates in the fisheries were allowed to remain high, or even increase, further exacerbating the effects of overfishing on the naturally produced (non -hatchery) runs mixed in the same fisheries. More recently, harvest managers have instituted reforms including weak stock, abundance based, harvest rate, and escapement -goal management. 2.1.2.2.4 Natural Conditions. Changes in the abundance of salmonid populations are substantially affected by changes in the freshwater and marine environments. For example, large-scale climatic regimes, such as E1 Nino, affect changes in ocean productivity. Much of the Pacific Coast was subject to a series of very dry years during the first part of the 1990s. In more recent years, severe flooding has adversely affected some stocks. Salmon and steelhead are exposed to high rates of natural predation, particularly during freshwater rearing and migration stages. Ocean predation may also contribute to significant natural mortality, although the levels of predation are largely unknown. In general, salmonids are prey for pelagic fishes, birds, and marine mammals, including harbor seals, and killer whales. There have been recent concerns that the rebound of sea[ and sea lion populations, following their protection under the Marine Mammal Protection Act of 1972, has resulted in substantial mortality for salmonids. A key factor substantially affecting many West Coast stocks has been the general pattern of a 30 -year decline in ocean productivity. The mechanism whereby stocks are affected is not well understood. The pattern of response to these changing ocean conditions has differed among stocks, presumably due to differences in their ocean timing and distribution. It is presumed that survival is driven largely by events occurring between ocean entry and recruitment to a subadult life stage. Time -series of survival rate information for UWR spring chinook, Lewis River fall - run chinook, and Skagit fall -run chinook salmon show highly variable or declining trends in early ocean survival, with very low survival rates in recent years ( NMFS 2000a). Recent evidence suggests that marine survival of salmonids fluctuates in response to 20- to 30 -year cycles of climatic conditions and ocean productivity (Cramer et al. 1999). This phenomenon has been referred to as the Pacific Decadal Oscillation. Ocean conditions that affect the productivity of Washington salmonid populations appear to have been in a low phase of the cycle for some time and to have been an important contributor to the decline of many 25 stocks. The survival and recovery of these species will depend on their ability to persist through periods of low natural survival. Additional detailed information regarding the status of the species and factors affecting the species environment within the action area can be found in various recent NMFS and NOAA Fisheries Opinions on artificial propagation, harvest, and habitat activities. Additional sources of baseline information include NMFS and NOAA Fisheries status reports, Washington Conservation Commission's Limiting Factors Reports, and WDFW/tribal harvest management plans. 2.1.2.2.5 Environmental Baseline Summary. Notwithstanding improvements in hatchery, harvest and habitat management practices, environmental conditions in the action area are still generally poor with respect to salmonid survival in a number of their life stages. In fact, for many stocks, survival must improve by an order of magnitude in order for the ESUs to survive and recover. Smolt -to -adult return rates in 1998 for SR spring/summer-run chinook, for example, were less than one-half of one percent — about one-tenth the rate needed for sustainability (NMFS 2000a). The continuous and cumulative reduction in habitat productive capacity has influenced the ability of the 12 threatened species to recover by reducing population resiliency and lowering survival rates. Improvement in habitat, hatchery and harvest conditions over those currently available under the environmental baseline is needed to meet the biological requirements for survival and recovery of these species. Permanent degradation of these conditions would have a significant impact due to the amount of risk they presently face under the environmental baseline. As analyzed below, the intent of the RRMP is to address some of the identified habitat limiting factors. 2.1.3 Analysis of Effects NOAA Fisheries' ESA implementing regulations define "effects of the action" as "the direct and indirect effects of an action on the species, together with the effects of other activities that are interrelated or interdependent with that action, that will be added to the environmental baseline." Direct effects are immediate effects of the project on the species or its habitat, and indirect effects are those that are caused by the proposed action and are later in time, but are still reasonably certain to occur (50 CFR 402.02). The RRMP is a conservative program consisting of specific approaches to conducting routine road maintenance activities, complemented by a suite of Program Elements to ensure that road maintenance activities protect salmonids. The State of Washington and local road maintenance agencies that will use the RRMP will be effectively changing their road maintenance activities to meet the ecological needs of listed salmonids, to the extent that routine road maintenance activities affect those needs. Nevertheless, road maintenance activities might affect elements of the environment in ways that have implications for listed salmonids. These effects are described below. 26 0 0 2.1, 3.1 Road ?Maintenance Activities A complete application package for qualification under 4(d) Limit No. (I0)(ii) includes a number of required items, including a description of the manner in which the activities may affect listed species or critical habitat, and an analysis of the effects of the program on those species and habitats, including short-term and long-term effects, indirect and cumulative effects. To determine the effects of the RRMP on listed salmonids, the Biological Subcommittee of the 25 jurisdictions prepared a Biological Review (BR) (RRM-TWG 2001), using a modified version of NOAA Fisheries' Matrix of Pathways and Indicators (MPI). The MPI identifies six conceptual pathways (e.g., water quality, channel condition) of 18 habitat condition indicators (water temperature, width/depth ratio) for determining the effect of an action. The Biological Subcommittee consulted with NOAA Fisheries during the preparation of the BR. NOAA Fisheries agrees with the conclusions drawn in the BR. In addition to a traditional effects analysis, the BR contains several tables (BR Tables 23 and 24) (RRM-TWG 2001) to serve as visual aids in comparing the effects of road maintenance activities in compliance with the RRMP to road maintenance work without implementation of the RRMP. The Tables use MPI indicator criteria to determine whether an RRMP-compliant activity restores, degrades, or is not likely to adversely affect (NLAA) baseline indicators. The RRMP intends to address many of the typical ways road maintenance activities could adversely affect listed species. These include effects on (a) water quality; (b) changes in channel conditions and dynamics: (c) alteration of stream flows; (d) shifts in watershed condition; and (e) direct harm to salmon and steelhead by altering development, bioenergetics, growth, and behavior. Without the RRMP, these impacts would occur during earthwork, hydraulic modifications, vegetation modifications, asphalt and concrete paving, and fish exclusion activities. Even with the RRMP, effects from these activities remains a possibility (although they would be specifically addressed by the RRMP program), and thus they are described below. Clearing, Drilling, Excavating, filling, Grading, Grubbing, Cleaning, Grinding, and Cutting. These activities include all work necessary to maintain roadways, streambanks, roadside ditches, culverts, catch basins, inlets, and detention/retention basins. This type of work is likely to have beneficial effects; cleaning out sediment and debris from drainage systems provides benefits to salmon habitat by preventing pollutants and sediments entrapped in stormwater facilities from entering surface or groundwater. There remains a possiblity that these activities can also have adverse water quality impacts, directly effecting aquatic species. These impacts occur through the generation of sediments and side casting of windborne dust and paint particles. Clearing ditches, culverts, and drainage systems and grading shoulders can dislodge sediments and expose soils, allowing an increase of sediment transport during storm events. Because stormwater conveyance systems often discharge into salmon habitat, the resultant temporary increase of sediment loads can adversely affect water quality in fish -bearing waters. Excess sediment loading and turbidity levels can clog gills of fish, smother eggs, embed spawning gravels, disrupt feeding and growth patterns of juveniles, delay up -stream migration of adults, and scour nutrients from the stream substrate (Burton et. al 1990 and WSCC 1999). 27 0 0 Earth surface and cleaning activities near streams can disturb fish and cause them to abandon suitable habitat. These activities can have noise levels above ambient conditions or increase light at night. Detour routes may result in concentrated traffic volumes and increased access to aquatic habitat that may affect salmon. The use of gas and diesel powered equipment creates a potential for accidental spills of substances toxic to fish. Removal of riparian vegetation occurring from grading at storm outfalls and during the removal of debris can affect prey resources, reduce cover habitat, reduce LWD recruitment, increase sedimentation, and increase water temperature. On balance, the RRMP addresses these issues both through activity specific BMPs, and through the general Program Elements (see section 2.1.3.2 below). Shore Defense Works. Most shore defense road maintenance work involves repair or replacement of existing bank stabilizing structures. New structures designed to armor streambanks are part of Capital Improvement Projects (CiP) and outside the scope of the RRMP. Most CIP bank stabilization projects require a U.S. Army Corps of Engineers permit, thus triggering ESA section 7 consultation with NOAA Fisheries. In general terms, however, hardened embankments simplify stream channels, alter hydraulic processes, and prevent natural channel adjustments (reduced sinuosity) (Spence et al. 1996). Bank hardening can cause an increase in stream velocities that contribute to channel incision and streambank failure. It can also potentially hinder localized water exchange processes (i -e-, hyporheic-surface water exchange) and floodplain connectivity within the small area adjacent to the project site. As amplified erosive forces attack different locations and landowners respond with more bank hardening, the river eventually attains a continuous fixed alignment lacking complexity and function in riparian and near shore habitats (COE 1977). Maintenance requirements in these streamside settings may be intermittent, but typically the presence of hardened banks transfers stream energy and shifts erosion points leading to perpetual maintenance requirements upstream and downstream of the armored bank. The effects of increased sediment disturbance, riparian vegetation modification, spills of toxic substances from gas- and diesel -powered equipment, and increased noise from shore defense road maintenance work are expected to be similar to those described in the earthworks section, above. Channelization or Ditching. Regular channelization or ditching maintenance in or adjacent to watercourses and streams is required to remove built-up sediments, debris or blockages, and to maintain capacity. Channelization and ditching can result in the alteration or loss of salmon habitat through the removal of snags and trees that could function as future LWD recruitment. These activities may also degrade hydrogeomorphology, wetlands, riparian vegetation, erosion/deposition balance, soils and water quality, and may affect the creation of critical off - channel habitat. Instream gravel bars can move due to changes in hydrodynamics, resulting in fewer meanders and reduced quantities of gravel for spawning habitat. Juvenile fish that may be rearing in the vicinity would most likely be displaced during maintenance work. The effects to 28 salmonids of increased scdiment disturbance, riparian vegetation modification, spills of toxic substances from gas- and diesel -powered equipment, and increased noise are expected to be similar to those described in the earthworks section, above. Removal of Large Woody Debris, The LWD will be removed only when and where there is a safety hazard, such as debris build-up against bridge abutments. Removal activities can cause an increase of turbidity, sediment, gravel, rocks, nutrients, bacteria, oxygen demanding materials, heavy metals, petroleum hydrocarbons, synthetic organics and other solids. Excess sediment loading and high turbidity levels can impact redds by smothering eggs with fine sediments and reduced water circulation. Removal of LWD can affect al I life history stages of salmonids as a result of excess sediment loading and high turbidity levels. Fish could be impacted by sub -lethal conditions, including the disruption of feeding, attenuated growth patterns of juveniles, or delaying the upstream migration of adults. The LWD removal may also change a stream's hydrology, with effects similar to those identified in the preceding sections. Work Area Isolation, Temporary Water Diversions and Fish Exclusion. Road maintenance activities frequently require work within streams that contain salmonids. Some of these activities require a site to be temporarily dewatered. Although work area isolation techniques can temporarily prevent usage of the work area by listed salmonids, these techniques also decrease or avoid the exposure of listed fish to the effects of construction activities in the work area. In fact, in such cases, work area isolation and fish removal will be necessary. Road maintenance activities that may require fish exclusion actions include work on open drainage systems, watercourses and streams (e.g., sediment removal), culvert repairs, bridges, and emergency slide/washout repairs. Work area isolation is a conservation measure intended to reduce the exposure of listed fish adverse effects of erosion and runoff on aquatic life. However, diversions, isolation, and exclusion can significantly impact listed fish in the area. Water diversion and temporary structure work creates a physical barrier to migrating salmon. Maintenance work on diversion structures could result in increases in sediment disturbance, riparian vegetation modification, spills of toxic substances from gas- and diesel -powered equipment, and increased noise are similar to those described in the earthworks section, above, resulting in similar effects to salmonids as identified in the preceding sections. Additionally, improper placement of equipment in or around riparian habitat may erode streambanks. Electrofishing is one means of fish capture. It is employed when other methods prove ineffective and may not be recommended in all situations. Its use will be determined through permit requirements and/or site conditions, as prescribed in the RRMP's Fish Exclusion Protocol (Appendix E of the RRMP). This protocol is based on NOAA Fisheries' Guidelines for F'.lectroflshing Waters Containing Salmonids Under the Endangered Species Act (NMFS 2000b). Although the practice is potentially hard on fish, clectrofishing is intended to locate residual fish in the isolated work area to reduce incidental take. 29 Electrofishing is a process by which an electrical current is passed through water containing fish in order to stun them—thus making them easy to capture. It can cause a suite of effects ranging from simple harassment to actually killing the fish. The amount of unintentional mortality attributable to electrofishing may vary widely depending on the equipment used, the settings on the equipment, and the expertise of the technician. Electrofishing can have severe effects on adult salmonids and will be limited to the direct and indirect effects of exposure to an electric field, capture by netting, holding captured fish in aerated tanks, and the effects of handling associated with transferring the fish back to the river, Physical injuries from electrofishing include internal hemorrhaging, spinal misalignment, or fractured vertebrae. The primary contributing factors to stress and death from fish exclusion activities are excessive doses of anesthetic, improper electrofishing techniques, differences in water temperatures (between the river and wherever the fish are held), dissolved oxygen conditions, the amount of time that fish are held out of the water, and physical trauma. It is also common that re- introduction of the stream to a newly constructed project will temporarily increase turbidity downstream. Vegetation jVod fcation: The primary purpose of vegetation maintenance is to promote, maintain, sustain, manage, or encourage vegetation growth within the Right of Way (ROW) to comply with a variety of regulations and standards. Activities include suppressing non -desirable vegetation and enhancing desirable vegetation. Short- and long-term vegetation modifications may occur during routine maintenance of open and closed drainage systems, watercourses and streams, stream crossings, bridges, and emergency washout repairs. The removal of vegetation adjacent to watercourses or streams may impact water quality and various habitat elements. Vegetation removal may contribute to a decrease in stream sinuosity and complexity, resulting in the degradation of hydrogeomorphology. It can also decrease refuge and rearing habitat for macroinvertebrates, and increase the water temperature of the immediate area. Pesticide Applications: The RRMP's Vegetation Management Maintenance category allows for the application of chemicals (herbicides and pesticides), and describes the manner and location in which applications may occur. BMPs are included in the RRMP to ensure that agencies electing to use herbicides and pesticides as part of their vegetation management program do so appropriately. NOAA Fisheries does not believe that there is currently sufficient information available to ensure that such chemical applications are not creating sublethal affects to listed species. NOAA Fisheries is currently working with Federal Agencies on an appropriate monitoring regimen to investigate the fate and transport of chemicals applied during a variety of activities. The monitoring intensity is beyond the scope of the RRM P; therefore NOAA Fisheries is not providing consultation, nor take authorization, on any road maintenance activities that propose the application of chemicals, herbicides or pesticides. Addition of'lmpervious Surfaces: Generally, significant increases in impervious surface area within the ROW do not fall under the definition of maintenance. Projects that increase impervious surface area are usually part of roadway CIPS, and typically are federally funded or permitted. Roadway CIPS are not addressed by the RRNLP and are not covered by this 30 consultation. The Federal nexus requires a separate ESA section 7 consultation. Under some circumstances, however, maintenance activities add impervious surface for safety reasons, rather than to add capacity. New impervious surface associated with maintenance work can result in increased levels of heavy metals, hydrocarbons, and other pollutants. Impervious surfaces can also increase water temperature by reducing shaded conditions, and by increasing solar exposure to surface water that would otherwise infiltrate or remain shaded beneath vegetation. New impervious surface area near streams can cause impacts to riparian vegetation, resulting in reduced cover for fish, a reduction in prey species, increased water temperature, and water quality degradation. RRMP actions that increase flows, such as increases in impervious surfaces, can disturb gravel in salmon or steelhead redds and can also agitate or dislodge developing young and cause their damage or loss. Similarly, actions that reduce subsurface or surface flows, reduce shade, deposit silt in streams, or otherwise reduce the velocity, temperature, or oxygen concentration of surface water as it cycles through a redd can adversely affect the survival, timing, and size of emerging fry. 2.1.3.2 Integrated Minimization Measures `The RRMP is a program that focuses on achieving desired environmental outcomes while providing jurisdictions maximum flexibility in responding to changing conditions at the worksite. Conservation outcomes of the RRMP fall into the following general categories: sediment collection, worksite pollutant containment, blockage removal, restoration of flow velocities and volumes, removal of fish passage barriers, revegetation, infiltration, prevention of utility leaks, and addressing chronic maintenance problems. Sediment Collection: Containment of sediment/pollutants maintains or restores the sediment collection process by removing sediments from many collection points in the drainage system (e.g., catch basins, maintenance holes, retention/detention facilities, pipes, inlets, and vaults). Proper maintenance of the ROW structure also protects against collapse or failure of the structure, which could result in significant sediment releases to aquatic habitat. Worksite Pollutant Containment: Many RRMP BMPs involve containment of sediment and other pollutants at the worksite. Similar to collection and removal of sediments and other pollutants from the ROW structure, containing loose soils, sediment, and other pollutants on the worksite reduces the amount of pollutants that can reach aquatic habitat_ A critical component of worksite pollutant containment in the RRMP is an effectiveness monitoring LIMP. Blockage Removal: The timely removal of drainage system blockages reduces the potential for sediment, turbidity, offsite erosion and debris to adversely affect fish habitat. Blockage removal also reduces the likelihood of system failure, which can have significant adverse habitat effects. BMPs used during this type of work achieve the same objectives as those identified in Sediment Collection and Worksite Pollutant Containment above. 31 Restoration of Flow Velocities and Volumes: Maintaining or restoring flow velocities and volumes required for health aquatic habitat is an important conservation outcome that is spelled out in a number of maintenance categories involving drainage system maintenance. The RRMP requires appropriate system design for system repair or replacement, appropriate maintenance of existing systems, and removal of sediment or blockages. • Removal of Fish Passage Barriers: When performing stream crossing maintenance activities, the RRMP prescribes the removal of fish passage barriers. All fish passage work requires adherence to all Federal, state and local permit and regulatory requirements. • Revegetation: The RRMP specifies the need for revegetation of disturbed areas to reduce erosion and sediment transport. Revegetation provides biofiltration, shading, and bank stabilization in riparian areas. It also promotes macro invertebrate population growth, lowers herbicide use, and suppresses non -desirable vegetation. • Infiltration: The RRMP specified the maximization of opportunities for increased infiltration and biofiltration. Cleaning and maintaining roadway shoulders and grass -line ditches improves infiltration. • Prevention of Utility Leaks: Maintenance of water and sewer systems prevents increased flow volumes and velocities, severe erosion, and the introduction of pollutants caused by breaks, leaks and malfunctions. • Addressing Chronic Maintenance Problems: To reduce the number of chronic maintenance problems that contribute to habitat degradation, the RRMP commits implementing agencies to refer chronic maintenance and habitat problems to agency - specific capital improvement programs. The potential adverse effects of the RRMP arc avoided and minimized by these conservation measures designed to achieve the RRMPs conservation outcomes. With implementation of the conservation measures, most RRMP activities fall into the "'restore" and "NLAA" categories. Among the various Federal, state, and local regulations or ordinances with which road maintenance agencies must already comply, the RRMP relies on the value of Washington State's Hydraulics Code (Revised Code of Washington (RCW) Chapter 77.55) as contributing to protecting ecological resources important to listed salmonids. Specifically, certain in -water activities carried out under the RRMP require review by the WDFW and compliance with any Hydraulics Project Approval (HPA) permits issued by the WDFW upon such review. NOAA Fisheries has not formally evaluated the Hydraulics Code for the purpose of issuing general CSA assurances for projects conducted under the State of Washington's HPA Program. However, NOAA Fisheries has reviewed and assessed HPAs program for the limited purpose of 32 0 9 determining the adequacy of the HPAs issued for routine road maintenance activities in contributing to the protection of listed salmonids (attached to this Biological Opinion (Opinion) as Appendix A). To make this determination, NOAA Fisheries reviewed the Hydraulic Code, the existing rules for administration of the 14PA (Washington Administrative Code (WAC) Chapter 222-110), the WDFW HPA manual (1998), the WDFW document "Hydraulic Project Approvals—Basics and How to Process" (2002), the WDFW Mitigation Policy (1999), WDFW technical resources, and WDFW's .February 22, 2002 comments to NOAA Fisheries regarding the proposed 4(d) limit for the RRMP. In addition, NOAA Fisheries reviewed two statewide general maintenance HPAs, and 52 individual HPAs provided by WDFW for typical road maintenance activities. In the review of the above -listed material, NOAA Fisheries considered the adequacy in protecting listed salmonids affected by routine maintenance activities in the context of the specifc actions for which the HPAs were issued. Based on that review, and for the limited purpose of conducting this consultation, NOAA Fisheries concluded that the HPA permitting program established in Washington State law and regulation would adequately protect resources meeting the ecological needs of threatened salmonids in the context of routine road maintenance activities undertaken by RRMP participants. Similar to other BMPs in the RRMP, the HPA process will be monitored under the RRMP's adaptive management program (see below). Additionally, the collection of listed salmonids requires a special permit from the WDFW, which in turn requires possession of an ESA section 10(a)(1)(a) permit. Although most jurisdictions have their own section 10(a)(1)(a) permit, some jurisdictions do not, in which case a WDFW Biologist does the collection work. The WDFW staff are covered by a NOAA Fisheries section 10(a)(1)(a) permit issued to WDFW. In -water work restrictions, including seasonal construction restrictions, arc often included in HPAs. In addition to the required compliance with numerous Federal, state and local regulations, 54 other BMPs are proposed in the RRMP to minimize worksite pollutants, restore and maintain surface water drainage, reduce turbidity and reduce sediments from entering watercourses and streams. Examples of BMPs include worksite containment of sediments and contaminants, restoration of flow velocities and volumes, stormwater infiltration, fish barrier removal, prevention of utility leaks, identification and referral of chronic maintenance problems, bioengineering, native revegetation, and LWD replacement. Furthermore, the RRMP requires adherence to the conservation measures described in Appendix E of the RRMP. The measures in Appendix E include specially developed fish exclusion and electrofishing guidance, based on NOAA Fisheries' clectrofishing guidelines (NMFS 2000b). Despite the outcome -based approach, the BMPs may not be fully effective at achieving the conservation outcomes and some RRMP activities could continue to adversely affect salmonids. In a general sense, BMPs are only as effective as their selection, installation, maintenance, monitoring and staff training. Without effective BMP implementation, road maintenance activities such as vegetation management, hydraulic modification, and excavation could adversely affect water temperature, increase sediment mobilization, decrease pool frequency and 33 quality, and reduce floodplain connectivity. However, these impacts are expected to be short- term and minor in scale. To overcome the possibility of the ineffective use of BMPs, the RR -MP includes nine mandatory Program Elements {in addition to Program Element 10 - BMPs and Conservation Outcomes} to minimize the risk of adverse impacts from routine road maintenance activities. The nine Program Elements form an integrated process of training, monitoring, and adaptive management that tracks the effectiveness of the BMWs in achieving the RRMP's conservation outcomes. The Program Elements include the Regional Forum, training, monitoring, scientific research, adaptive management, and reporting. Regional Forum. Each jurisdiction receiving a limit to the 4(d) take prohibition by means of the RRMP will be required to participate in the Regional Forum. The .Regional Forum will meet quarterly to share information and experiences that could lead to improvement of the RRMP. Information shared will include crew experiences implementing BMPs, discovery of new products and BMPs, results of scientific research, and feedback on training. • Training. The specially designed RRMP training program will provide crew members and supervisors appropriate training in when to use BMPs and recognizing problems with BMPs. Engineering and environmental support staff will be trained to ensure that potential technical problems are addressed in the planning stages of projects that require design or environmental support. NOAH Fisheries will approve the training. • Monitoring. Each local jurisdiction will establish a formal monitoring program for monitoring compliance and effectiveness of BMP outcomes during the course of maintenance activities and after work is completed, if necessary. if problems occur, BMPs will be modified or added to achieve the RRMPs conservation outcomes. • Scientific Research. A program of field studies and literature searches will evaluate and improve the effectiveness and selection of various BMPs. • Adaptive Management. The RRMP jurisdictions have committed to developing an adaptive management process to be implemented at the local and regional levels. The adaptive management process provides for learning from experience and for reducing uncertainty through scientific research. Local ESA teams and the Regional Forum will gather and evaluate information during the course of maintenance activities, BMP implementation, monitoring, and scientific research. Both the RRMP itself, and its implementation by local jurisdictions, will be modified as necessary to achieve its conservation objectives. Reports. NOAA Fisheries will receive a biennial report from the Regional Forum. The reports will include a review of the ten program elements, updates on research, recommended BMP changes, and recommended updates on each program element. 34 0 0 As an additional level of assurance, Limit No. 10 of the 4(d) rule (July 10, 2000, 65 FR 42422) authorizes NOAA Fisheries to periodically evaluate a qualified road maintenance program for its effectiveness in maintaining and achieving habitat function that provides for conservation of the listed salmonids. Whenever warranted, NOAA Fisheries will identify to the local jurisdictions ways in which the program needs to be altered or strengthened. Changes may be identified if the program is not protecting desired habitat functions, or where even with the habitat characteristics and functions originally targeted, habitat is not supporting population productivity levels needed to conserve the listed species. If any jurisdiction covered by Limit No. 10 does not make changes to respond adequately to the new information in the shortest amount of time feasible, but not longer than one year, NOAH Fisheries will publish notification in the Federal Register announcing its intention to withdraw the limit so that take prohibitions would then apply to the program as to all other activity not within a limit. 2.1.4 Effects on Critical Habitat NOAA Fisheries designates critical habitat based on physical and biological features that are essential to the listed species. Essential features for designated critical habitat include substrate, water quality, water quantity, water temperature, food, riparian vegetation, access, water velocity, space and safe passage. Critical habitat has been designated for three of the 15 species addressed in this Opinion: SR fall -run chinook (December 28, 1993, 58 FR 68543), SR spring/summer-run chinook (December 28, 1993, 58 FR 68543, updated October 25, 1999, 64 .FR 57399), and SR sockeye (November 20, 1999, 58 .FR 58619). Using NOAA Fisheries' Habitat Approach (NMFS 1999) as a surrogate for estimating fish mortality, this Opinion identified and analyzed the extent of project effects on habitat salmon need to express certain essential behavior patterns. The effects of the RRMP to designated critical habitat are expected to be the same as those described in section 2.3, above. 2.1.5 Cumulative Effects Cumulative effects include the effects of future state, tribal, local or private actions that arc reasonably certain to occur in the action area considered in this Opinion. Future Federal actions unrelated to this action, including the ongoing operation of hydropower systems, hatcheries, fisheries, and land management activities are being (or have been) reviewed through separate ESA section 7 consultation processes and are not considered in this section. A number of reasonably foreseeable non -Federal resource management strategies will affect listed ESUs and their habitat within the action area. Tribal, state, and local government actions are likely to be in the form of legislation, administrative rules, or policy initiatives. These actions may include changes to land use patterns and water use allocations, which can affect the intensity and location of these across the action area. There are uncertainties related to the implementation of these government actions due to budget and policy constraints, which when 35 0 0 taken into account over a wide geographic area, makes this cumulative effects analysis difficult. A general description of the primary Tribal, state, and local programs is summarized in Table 17 of the Environmental Assessment for the RRMP (NOAA Fisheries 2003, in publication). These activities affecting listed salmonids activities within the action area are expected to increase with a projected increase in population of nearly 2 million people by the year 2020 (WDNR 2000). Thus, NOAA Fisheries assumes that future private and state actions will continue within the action area, but at increasingly higher levels as population density climbs. The RRMP could have minor impacts and short-term negative effects associated with listed salmonids and aquatic habitat. These reach -scale effects may be minor on an individual basis, however, their cumulative effect could potentially be negative for a short period of time. Alternatively, the cumulative impact of the RRMP at the watershed scale may have minor beneficial effects because of reasonably foreseeable Tribal, state, local and private plans, policies, and programs aimed at benefitting water quantity and quality, fish passage, shoreline and fish habitat conditions. Tribal, state, and local plans, programs, and activities include water quality and pollution control, streamflow enhancement, watershed planning, environmental land use planning and zoning, shoreline protection, and habitat conservation plans (NOAA Fisheries 2003, in publication). 2.1.6 Conclusion NOAA Fisheries has reviewed the direct, indirect, and cumulative effects of the proposed action on the 12 threatened species. NOAH Fisheries evaluated these effects in light of existing conditions in the action area, the measures included in the action to minimize the risk of effects, and the significant oversight authority of NOAA Fisheries provided in the 4(d) Rule. The proposed action may cause short-term adverse effects on listed species by temporarily increasing sedimentation rates, water temperatures, and flows; decreasing dissolved oxygen and fish passage; and by collecting, removing and transporting fish during fish exclusion activities. Long-term ecosystem effects of the RRMP include changes in the complexity of their habitat, periodic changes to primary and secondary production (food web effects), and changes in hydrodynamics and sedimentology. These effects are reasonably certain to result in incidental take, but the extent of harm is likely to be minimized by specific measures included in the action. Additionally, the RRMP's 10 Program Elements and NOAA Fisheries' oversight role shall provide for constant improvements to routine road maintenance practices in Washington State. Thus, the proposed actions would not reduce pre -spawning survival, egg -to -smolt survival, or survival during upstream or downstream migration to a level that would appreciably diminish the likelihood of survival and recovery of proposed or listed fishes. Consequently, it is NOAA Fisheries' Opinion that the proposed action is not likely to jeopardize the continued existence of these species. Nor is the project likely to destroy or adversely modify designated critical habitat for the SR fall -run chinook salmon, SR spring/summer-run chinook salmon or SR sockeye salmon. At this time, no critical habitat is designated for the other 12 listed salmonid species in the action area. 36 0 9 2.1.7 Reinitiation of Consultation This concludes formal consultation on NOAA Fisheries' proposed qualification of the RRMP. As provided in 50 CFR section 402.16, reinitiation of formal consultation is required where discretionary Federal agency involvement or control over the action has been retained (or is authorized by law) and if: (1) the amount or extent of incidental take is exceeded; (2) new information reveals effects of the agency action that may affect listed species or critical habitat in a manner or to an extent not considered in this opinion; (3) the agency action is subsequently modified in a manner that causes an affect to the listed species or critical habitat not considered in this opinion; or (4) a new species is listed or critical habitat designated that may be affected by the action. In instances where the amount or extent of incidental take is exceeded, any operations causing such take must cease pending reinitiation. Additional reinitiation requirements, including re-evaluation and modification requirements, are set forth in the RRMP and in Limit No. 10 of the 4(d) Rule (July 2000), which are incorporated herein. 2.2 incidental Tame Statement Where NOAA Fisheries approves a 4(d) Limit, there is no take liability for threatened species, and so there is no need of a take exemption through ESA section 7(o). The 4(d) Rule specifically excludes endangered species from its limits on the application of the ESA section 9(a)(1) take prohibitions. NOAA .Fisheries, therefore is not extending 4(d) Limit No. 10 coverage to RRMP activities within the delineated geographic boundaries of the three endangered ESUS. The three endangered salmonids (UCR spring -run chinook salmon, UCR steelhead, and SR sockeye salmon) migrate outside the geographic boundaries of their ESUS, through a portion of the RRMP's action area. NOAA Fisheries conducted a separate assessment on these species and concluded that the effects of RRMP activities (primarily conducted in tributary watersheds) on endangered salmonids migrating through the middle and lower mainstem Columbia River would likely be insignificant or discountable and thus not be likely to adversely affect the UCR spring -run chinook salmon, UCR steelhead, or SR sockeye salmon. Thus, there is no need of a take exemption through ESA section 7(o) for the endangered species, either. 3.0 MAGNUSON-STEVENS FISHERY CONSERVATION AND MANAGEMENT ACT 3.1 Background The Magnuson -Stevens Fishery Conservation and Management Act (MSA), as amended by the Sustainable Fisheries Act of 1996 (Public Law 104-267), established procedures designed to identity, conserve, and enhance Essential Fish Habitat (EFI-1) for those species regulated under a Federal fisheries management plan. Pursuant to the MSA: 37 Federal agencies must consult with NOAA Fisheries on all actions, or proposed actions, authorized, funded, or undertaken by the agency, that may adversely affect EFH (section 305(b)(2)); NOAA Fisheries must provide conservation recommendations for any Federal or state action that would adversely affect EFH (section305(b)(4)(A)); Federal agencies must provide a detailed response in writing to NOAA Fisheries within 30 days after receiving EFH conservation recommendations. The response must include a description of measures proposed by the agency for avoiding, mitigating, or offsetting the impact of the activity on EFH. in the case of a response that is inconsistent with NOAA Fisheries EFH conservation recommendations, the Federal agency must explain its reasons for not following the recommendations (section 305(b)(4)(B)). Essential Fish Habitat means those waters and substrate necessary to fish for spawning, breeding, feeding, or growth to maturity (MSA section 3). For the purpose of interpreting this definition of EFH: Waters include aquatic areas and their associated physical, chemical, and biological properties that are used by fish and may include aquatic areas historically used by fish where appropriate; substrate includes sediment, hard bottom, structures underlying the waters, and associated biological communities; necessary paeans the habitat required to support a sustainable fishery and the managed species' contribution to a healthy ecosystem; and "spawning, breeding, feeding, or growth to maturity" covers a species' full life cycle (50 CFR 600.10). Adverse effect means any impact which reduces quality and/or quantity of EFH, and may include direct (e.g., contamination or physical disruption), indirect (e.g., loss of prey or reduction in species fecundity), site-specific or habitat -wide impacts, including individual, cumulative, or synergistic consequences of actions (50 CFR 600.810). Essental Fish Habitat consultation with NOAA Fisheries is required regarding any Federal agency action that may adversely affect EFH, including actions that occur outside EFH, such as certain upstream and upslope activities. Any reasonable attempt to encourage the conservation of EFH must take into account actions that occur outside EFH, such as upstream and upslope activities, that may have an adverse effect on EFH. Therefore, EFH consultation with NOAA Fisheries is required by Federal agencies regarding any activity that may adversely affect EFH, regardless of its location. "rhe objectives of this EFH consultation are to determine whether the proposed action would adversely affect designated EFH and to recommend conservation measures to avoid, minimize, or otherwise offset potential adverse effects to EFH resulting from the proposed action. 3.2 Identification of EFH Pursuant to the MSA the Pacific Fisheries Management Council (PFMC) has designated EFH for federally -managed fisheries within the waters of Washington, Oregon, and California. Designated EFH for groundfish and coastal pelagic species encompasses all waters from the mean high water line, and the upriver extent of saltwater intrusion in river mouths, along the 38 0 0 coasts of Washington, Oregon and California, seaward to the boundary of the U.S. exclusive economic zone (370.4 km) (PFMC 1998x, 1998b). Freshwater EFH for Pacific salmon includes all those streams, lakes, ponds, wetlands, and other water bodies currently, or historically accessible to salmon in Washington, Oregon, Idaho, and California, except areas upstream of certain impassable man-made barriers (as identified by the PFMC 1999), and .longstanding, naturally -impassable barriers (i.e., natural waterfalls in existence for several hundred years) (PFMC 1999). In estuarine and marine areas, designated salmon EFH extends from the nearshore and tidal submerged environments within state territorial waters out to the full extent of the exclusive economic zone (370.4 km) offshore of Washington, Oregon, and California north of Point Conception to the Canadian border (PFMC 1999). Detailed descriptions and identifications of .EFH are contained in the fishery management plans for groundfish (PFMC 1998a), coastal pelagic species (PFMC 1998b), and Pacific salmon (PFMC 1999). Casillas el al. (1998) provides additional detail on the groundfish EFH habitat complexes. Assessment of the potential adverse effects to these species' EFH from the proposed action is based, in part, on these descriptions. 3.3 Proposed Actions The proposed action and action area are detailed above in Section 1.2 of this document. Routine road maintenance activities conducted in accordance with the RRMP and occurring outside the geographic boundaries of ESA ESUS, but within designated EFH (e.g., the Chehalis River basin), arc covered by this MSA consultation. The exceptions (i.e., not covered by this MSA consultation) are activities occurring within the geographic boundaries of the UCR spring -run chinook salmon, UCR steelhead, and SR sockeye salmon. The action area includes habitats that have been designated as EFH for various life -history stages of 47 species of groundfish, 5 coastal pelagic species, and 3 species of Pacific salmon (Table 2). 3.4 Effects of Proposed Action As described in detail in Section 2.1.3.1 of this Opinion, the proposed action may result in short-term adverse effects to a variety of habitat parameters. The RRMP and its Biological Review clearly identify anticipated impacts to affected species likely to result from the proposed activities and the measures that are necessary and appropriate to minimize those impacts. These effects include delivery of sediments to streams through routine road maintenance activities, vegetation removal, loss of LV4'D, and hydraulic modifications. 39 0 Table 2. Fish species with designated EFH in Washington State. Groundfish redstripe rockfish English sole Species S. proriger Parophrys vetulus soupfin shark rosethorn rockfish flathead sole Galeorhinus aleus S. helvomaculatus Hippoglossoides elassodon spiny dogfish rosy rockfish petrale sole S ualus acanthias S. rosaceas Eo sena jordani big skate rougheye rockfish rex sole Raja binoculata S. aleutianus Glyptocephalus zachirus California skate sharpchin rockfish rock sole Raja inornata S. zacentrus Le ido setta bilineata longnose skate splitnose rockfish sand sole Raja rhina S. di to roa Psettichthvs melanostictus ratfish striptail rockfish starry flounder H drola us colliei S. saxicola Platichth s stellalus Pacific cod tiger rockfish arrowtooth flounder Gadus macrocephalus S. ni rocincius Atheresthes stomias Pacific whiting (hake) vermilion rockfish Merluccius produclus S. miniatus black rockfish yelloweye rockfish Coastal Pelagic Sebastes melano s S ruberrimus Species bocaccio yellowtail rockfish jack mackeral S paucispinis S. flavidus Trachurus s mmetricus brown rockfish shortspine thornyhead anchovy S auriculatus Sebastolobus alascanus En raulis mordax canary rockfish cabezon Pacific sardine S. inni er Scor aenichth s marmoratus Sardino s ser ax China rockfish lingcod Pacific mackerel S. nebulosus O hiodon elon acus Scomher 'a onicus copper rockfish kelp greenling market squid S, caurinus Hexa rammos deco rammus Loll o o aleseens darkblotch rockfish sablefish S. crameri Ano to oma rmbria greenstriped rockfish Pacific sanddab Pacific Salmon S. elan alus Citharichth s sordidus Species Pacific ocean perch butter sole chinook salmon S. alutus Iso .setter isole is Oncorh thus tshaw tscha quillback rockfish curlfin sole coho salmon S. mall er Pleuronichth s decurrens O_ kisutch redbanded rockfish Dover sole Puget Sound pink salmon S. babcocki Microstomus aci rcus O. orbuscha 40 0 3.5 Conclusion 0 NOAH Fisheries concludes that the proposed action would adversely affect the EFH for the groundfish, coastal pelagic, and Pacific salmon species listed in Table 1. 3.6 Essential Fish Habitat Conservation Recommendations Pursuant to Section 305(b)(4)(A) of the MSA, NOAA Fisheries is required to provide EFH conservation recommendations to Federal agencies regarding actions which may adversely affect EFH. NOAA Fisheries understands that the conservation measures described in the RRMP will be implemented by the jurisdictions approved under Limit No. 10(ii). Furthermore, it believes that these measures are sufficient to address the adverse impacts to EF.14 described above. 3.7 Statutory Response Requirement Pursuant to the MSA {section 305(b)(4)(B)) and 50 CFR 600.9200}, Federal agencies are required to provide a detailed written response to NOAA Fisheries` EFH conservation recommendations within 30 day=s of receipt of these recommendations. The response must include a description of measures proposed to avoid, mitigate, or offset the adverse impacts of the activity on EFH. In the case of response that is inconsistent with the EFH conservation recommendations, the response must explain the reasons for not following the recommendations, including the scientific justification for any disagreements over the anticipated effects of the proposed action and the measures needed to avoid, minimize, mitigate, or offset such effects. 3.8 Supplemental Consultation NOAA Fisheries must reinitiate EFH consultation with itself if the proposed action is substantially revised in a manner that may adversely affect EFH, or if new information becomes available that affects the basis for NOAA Fisheries' EFH conservation recommendations (50 CFR. 600.920(1)). 41 Printed_ 12-22-2010 0 CITY OF RENTON 1055 S. Grady Way Renton, WA 98055 Land Use Actions RECEIPT Permit#: LUA10-089 Payment Made: 12/22/2010 11:30 AM Total Payment: 9,030.00 Current Payment Made to the Following Items: 0 rir Receipt Number: R1005583 Payee: Interfund Transfer Request Trans Account Code Description Amount ------ 3080 ------------------ 503.000000.004.322 ------------------------------ Technology Fee ---------------- 30.00 5010 000.000000.007.345 Environmental Review 1,000.00 Payments made for this receipt Trans Method Description Amount Payment IOT PW - CED 1,030.00 Account Balances Trans Account Code Description Balance Due 3021 303.000000.020.345 Park Mitigation Fee .00 3080 503.000000.004.322 Technology Fee .00 5006 000.000000.007.345 Annexation Fees .00 5007 000.000000.011.345 Appeals/Waivers .00 5008 000.000000.007.345 Binding Site/Short Plat .00 5009 000.000000.007.345 Conditional Use Fees .00 5010 000.000000.007.345 Environmental Review .00 5011 000.000000.007.345 Prelim/Tentative Plat .00 5012 000.000000.007.345 Final Plat .00 5013 000.000000.007.345 PUD .00 5014 000.000000.007.345 Grading & Filling Fees 00 5015 000.000000.007.345 Lot Line Adjustment .00 5016 000.000000.007.345 Mobile Home Parks 'CO 5017 000.000000.007.345 Rezone .00 5018 000.000000.007.345 Routine Vegetation Mgmt .00 5019 000.000000.007.345 Shoreline Subst Dev .00 5020 000.000000.007.345 Site Pian Approval .00 5021 000.000000.007.345 Temp Use, Hobbyk, Fence .00 5022 000.000000.007.345 Variance Fees .00 5024 000.000000.007.345 Conditional Approval Fee .00 5036 000.000000.007.345 Comprehensive Plan Amend .00 5909 000.000000.002.341 Booklets/EIS/Copies .00 5941 000.000000.007.341 Maps (Taxable) .00 5954 650.237.00.00.0000 DO NOT USE - USE 3954 .00 5998 000.000000.000.231 Tax .00 Remaining Balance Due: $0.00