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SEPA Environmental Checklist (WAC 197-11-960) Page 1 of 15
SEPA ENVIRONMENTAL CHECKLIST
A. Background
1. Name of proposed project, if applicable:
Renton Kennydale Lakeline Sewer Condition Assessment
2. Name of applicant:
City of Renton, Utility Systems Division – David Christensen
3. Address and phone number of applicant and contact person:
Address: 1055 S Grady Way, 5th Floor, Renton, WA 98057
Phone: (425) 430‐7212
Contact Person: David Christensen, City of Renton
4. Date checklist prepared:
January 30, 2018
5. Agency requesting checklist:
City of Renton, Utility Systems Division
6. Proposed timing or schedule (including phasing, if applicable):
City of Renton, Utilities Division proposes to complete the physical inspection and
installation of manholes along the Kennydale Lake Line between July 16, 2018 and
September 30, 2018. These dates align with WDFW’s in‐water work windows for areas
of Lake Washington more than 1 mile form Mercer Slough and the Cedar River where
beach spawning by sockeye salmon has been recorded in the past.
7. Do you have any plans for future additions, expansion, or further activity related to or
connected with this proposal? If yes, explain.
This project is a system evaluation. The results of this evaluation will determine the
remaining useful life and vulnerability of the system and may result in
recommendations for future improvements.
Future improvements, maintenance or replacement of the Kennydale system would
undergo environmental evaluation after the scope and schedule for those improvements
are known.
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8. List any environmental information you know about that has been prepared, or will be
prepared, directly related to this proposal.
An environmental conditions report characterizing the Lake Washington habitats above
and adjacent to the existing Kennydale Sewer Line was completed in April 2017
(Confluence Environmental 2017).
A Joint Aquatic Resource Permit Application (JARPA) and a Biological Evaluation for
compliance with Section 7 of the federal Endangered Species Act (ESA) have been
prepared for this project.
9. Do you know whether applications are pending for governmental approvals of other
proposals directly affecting the property covered by your proposal? If yes, explain.
No.
10. List any government approvals or permits that will be needed for your proposal, if known.
Department of Army permit to meet requirmeents of the Rivers and Harbors
Act Section 10 and Section 404 of the Clean Water Act.
Section 401 Water Quality Certification from Washington State Department of
Ecology (Possibly required)
Hydraulic Project Approval from WDFW
City of Renton Shoreline Exemption
11. Give brief, complete description of your proposal, including the proposed uses and the size
of the project and site. There are several questions later in this checklist that ask you to
describe certain aspects of your proposal. You do not need to repeat those answers on this
page. (Lead agencies may modify this form to include additional specific information on project
description.)
This maintenance project is intended to evaluate pipeline conditions at up to thirteen
locations. Condition evaluation will include ultrasonic thickness testing at five locations,
collection of a single coupon on the mainline, collection of up to three coupons on lateral
lines, and temporary access at two existing manholes for lakeline cleaning. Two
additional locations will be accessed, pipe sections will be removed for evaluation, and
the sections will be replaced with manholes below grade. The project locations are
aquatic and all work will be staged from a floating barge or boat. Divers will be
deployed from the boat/barge to expose the sewer lakeline and conduct maintenance
activities.
Work at each location will follow a similar approach which will be customized based on
site conditions. In general, the work plan will involve the installation of site isolation
best management practices (BMPs), followed by placement of a shoring system, if
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required, and pipeline excavation using a suction dredge. Once the pipeline is exposed
the pipeline will be evaluated and sediment sampling or corrosion/thickness
measurement may occur. Depending on the location, one of three types of actions will
occur at this point. Either 1) a pipeline sample or coupon will be removed for corrosion
and thickness testing and repaired with a compression fitting, 2) ultrasonic pipeline
thickness testing, or 3) a section of pipeline will be removed for testing, and replaced
with a manhole. Following pipeline repair, the substrate will be returned to pre‐
construction conditions and BMPs will be removed. No substantial changes will be
made to the overall structure or layout of the pipeline and all elements will be below
final grade.
Work Plan:
1. Surround the work area with a floating silt curtain, starting with a collapsed curtain
and expanding it so as to eliminate fish from the work area. Once expanded to enclose
the work area, the bottom of the silt curtain will be anchored to the lake bed with
sandbags at four foot intervals. The curtain will remain in place throughout the work
and for a sufficient period after the work to allow the vast majority of sediments to
settle.
2. Conduct turbidity monitoring adjacent to the work zone before, during, and after the
work. Results will be documented and any noted exceedances will lead to a) adjustment
of work practices, or b) stoppage of the work until suitable adjustments can be made.
3. Place a shoring box along the pipeline surrounding the excavation zone. The shoring
box will settle down to the base of the excavation as the work progresses.
4. Expose the buried pipeline by suction dredging within the shoring system. Dredging
will be conducted using a boat/barge‐mounted trash pump. Excavated materials will be
placed outside the shoring but within the silt curtain perimeter.
5. Reduced water usage will be requested of home owners adjacent to the sewer prior to
commencement of work. Flush the pipeline with municipal water to remove most of the
sewage prior to cutting the pipe.
6. Cut a 4‐6‐inch diameter hole from the pipe for thickness and corrosion testing. Seal the
hole with a pipe repair coupling
7. Cut through the pipe at the downstream end of the work zone and place a plate to
seal the downstream pipe from excessive lake water intrusion. Cut through the pipe at
the upstream end of the work zone and removing the existing pipe between the cuts.
8. Replace the removed pipe section with a new pipe segment that includes a manhole to
facilitate future cleaning operations. The manholes will be left below the lake bed as
shown in Figures 6 and 7. Install repair couplings to join and seal the replacement
segment to the existing pipeline.
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9. Return the sewer system to normal operation. Check for leaks and ensure lakeline is
functioning properly.
10. Suction dredge excavated materials back into the excavation zone while removing
the shoring system. Shovel/rake/hydrojet finished surface to original grade.
11. Wait until sediments have settled from the work area before removing the floating
silt curtain.
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 plans required by the agency, you
are not required to duplicate maps or detailed plans submitted with any permit applications
related to this checklist.
See attached Figures 1‐4.
B. ENVIRONMENTAL ELEMENTS
1. Earth
a. General description of the site:
The project is located in Lake Washington, waterward of the Ordinary High Water Line.
Adjacent uplands are residential, realtively flat, and rolling.
b. What is the steepest slope on the site (approximate percent slope)?
Slopes in each project location are less than 1%. The project is not located near steep
slopes and will not affect steep slopes. The bathymetry of the lake is gradual in the
project vicinity with water depths between 6 and 20 feet.
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
agricultural land of long-term commercial significance and whether the proposal results in
removing any of these soils.
The sediment characteristics underlying the water along the vessel routes in the study
area include sand, gravel, and cobble, along with various combinations of these
sediment types.
d. Are there surface indications or history of unstable soils in the immediate vicinity? If so,
describe.
No. The sewer line has been in place since 1972 with no history of failure due to unstable
soils.
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e. Describe the purpose, type, total area, and approximate quantities and total affected area of
any filling, excavation, and grading proposed. Indicate source of fill.
Excavation would be limited to the volumes sufficient to expose the sewer pipe.
Excavated areas will be no larger than 20 feet wide, by 36 feet long by 6 feet deep. After
completing inspection and repair at each location, excavated sediments would be used
to return the lakebed to it’s original grade.
f. Could erosion occur as a result of clearing, construction, or use? If so, generally describe.
No erosion is expected. Excavation and site restoration would occur over approximately
5 working days at each site.
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:
A sediment curtain will be used to prevent material from being discharged beyond the
project site. Excavation will be limited to the small amount necessary to expose the pipe
and conduct inspections and/or make repairs.
2. Air
a. What types of emissions to the air would result from the proposal during construction,
operation, and maintenance when the project is completed? If any, generally describe and
give approximate quantities if known.
The project would require a work barge and boat which includes water‐jetting or
suction dredge to perform underwater excavation. Emissions from project construction
would be limited to approximately 3 gasoline generators during daily operations plus
outboard boat engines for site access and environmental monitoring during operations.
Upstream sewage will be re‐directed and the pipeline will be flushed with freshwater
prior to commencing with work. This will ensure that no sewer gases are released into
the environment.
b. Are there any off-site sources of emissions 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:
Engines will be turned off when not in use.
3. Water
a. Surface Water:
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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.
The project is situated in Lake Washington.
May Creek, a small perennial stream draining approximately 9,000 acres, is located
approximately 0.2 miles north of the northernmost project location. The stream is well
outside the action area and the project will have no effect on the stream.
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. The project includes inspection of the existing sewer line which is buried in the lake
bed.
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.
Up to approximately 279 cubic yards of material may be excavated (between 5 and 234
cubic yards depending upon the activity proposed at each site). Material will be
stockpiled inside the floating turbidity curatin to restore the lakebed to it’s original
grade once inspection and repairs are completed.
4) Will the proposal require surface water withdrawals or diversions? Give general
description, purpose, and approximate quantities if known.
No.
5) Does the proposal lie within a 100-year floodplain? If so, note location on the site plan.
Yes, the site is waterward of the ordinary highwater mark of Lake Washignton.
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.
No. Upstream sewage will be diverted to Pump Station #14 wet well for storage and the
lakeline will be flushed with freshwater prior to work commencing. Should the work
take long enough to fill the wet well, vactor trucks will be available to empty the wet
well and dispose of the sewage in another sewer service area. This will ensure that no
waste will enter the lake.
b. Ground Water:
1) Will groundwater be withdrawn from a well for drinking water or other purposes? If so,
give a general description of the well, proposed uses and approximate quantities
withdrawn from the well. Will water be discharged to groundwater? Give general
description, purpose, and approximate quantities if known.
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No groundwater use or withdrawal.
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.
No waste material will be discharged.
c. Water runoff (including stormwater):
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.
The project is in the lake so no surface runoff will occur. A floating turbidity curtain will
enclose the work areas to ensure that no elevated tubidity levels are experienced within
the lake.
2) Could waste materials enter ground or surface waters? If so, generally describe.
No. Upstream sewage will be diverted to Pump Station #14 wet well for storage and the
lakeline will be flushed with freshwater prior to work commencing. Should the work
take long enough to fill the wet well, vactor trucks will be available to empty the wet
well and dispose of the sewage in another sewer service area. This will ensure that now
waste will enter the lake.
3) Does the proposal alter or otherwise affect drainage patterns in the vicinity of the site? If
so, describe.
No.
d. Proposed measures to reduce or control surface, ground, and runoff water, and drainage
pattern impacts, if any:
Not Applicable. Because the project is aquatic, no runoff will occur.
4. Plants
a. Check the types of vegetation found on the site:
____deciduous tree: alder, maple, aspen, other
____evergreen tree: fir, cedar, pine, other
____shrubs
____grass
____pasture
____crop or grain
____ Orchards, vineyards or other permanent crops.
____ wet soil plants: cattail, buttercup, bullrush, skunk cabbage, other
__X_water plants: milfoil, elodea
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____other types of vegetation
b. What kind and amount of vegetation will be removed or altered?
No vegetation will be removed or altered.
c. List threatened and endangered species known to be on or near the site.
No listed plants are known to be on or near the site.
d. Proposed landscaping, use of native plants, or other measures to preserve or enhance
vegetation on the site, if any:
None/Not Applicable.
e. List all noxious weeds and invasive species known to be on or near the site.
Common non‐native species in Lake Washignton include: milfoil, hydrilla, elodea and
water hyacinth. Excavations are anticipated to occur outside of vegetated beds but some
non‐native aquatic vbegetation may be present at some sites.
5. Animals
a. List any birds and other animals which have been observed on or near the site or are known
to be on or near the site.
Examples include:
birds: hawk, heron, eagle, songbirds, other:
mammals: deer, bear, elk, beaver, other:
fish: bass, salmon, trout, herring, shellfish, other ________
b. List any threatened and endangered species known to be on or near the site.
Puget Sound Chinook salmon, Puget Sound steelhead, and bull trout.
c. Is the site part of a migration route? If so, explain.
Yes. Multiple species migrate through Lake Washington. Migratory birds may use the
area as a stopover site, and migratory fish moving to Puget Sound, Lake Washington or
the Lake Washington tributaries may move past the site.
d. Proposed measures to preserve or enhance wildlife, if any:
Isolation of the in‐water work area using a floating turbidity curtain will remove and
exclude fish from the vicinity of the project, while also containing project‐related
turbidity.
e. List any invasive animal species known to be on or near the site.
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New Zealand mud snail, oriental weatherfish, walleye, and northern pike are all known
to occur in Lake Washington and/or it’s tributaries. Specific surveys of the project sites
have not been conducted.
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.
Gasoline would be used for operation of engines to power generators, pumps, and/or
outboards during inspection and repair activities.
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.
1) Describe any known or possible contamination at the site from present or past uses.
None known.
2) Describe existing hazardous chemicals/conditions that might affect project development
and design. This includes underground hazardous liquid and gas transmission pipelines
located within the project area and in the vicinity.
None known.
3) Describe any toxic or hazardous chemicals that might be stored, used, or produced
during the project's development or construction, or at any time during the operating
life of the project.
Gasoline may be used on support boats and/or barges.
4) Describe special emergency services that might be required.
Should an accident occur, the injured individual(s) would be transported by boat to an
appropriate dock for offloading and transport to hospital for treatment.
5) Proposed measures to reduce or control environmental health hazards, if any:
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Best management practices related to the handling and storage of any environmental
health hazards will be implmenented during the sewer line inspection to avoid and
minimize any potential hazards.
b. Noise
1) What types of noise exist in the area which may affect your project (for example:
traffic, equipment, operation, other)?
Ambient noise conditions are from adjacent residences, Interstate 405, and recreational
boats operating on Lake Washington.
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)? Indi-
cate what hours noise would come from the site.
Noise would be generated during transit to and from the inspection sites from outboard
engines. Noise during inspection would be from the operation of water jet/suction
dredge and any generators required to operate this equipment or compressors to
provide air to underwater workers. Project‐related noise is anticipated to attenuate to
background levels within 283 feet of the project. No changes to noise levels would occur
following the completion of the project.
3) Proposed measures to reduce or control noise impacts, if any:
Inspection activities will occur during daylight hours.
8. Land and Shoreline Use
a. What is the current use of the site and adjacent properties? Will the proposal affect current
land uses on nearby or adjacent properties? If so, describe.
Adjacent properties are primarily single family residential properties. Two parks are
located in the project vicinity – Kennydale Beach Park is within the project action area
and Gene Coulon Park is approximately 0.5 miles to the south.
b. Has the project site been used as working farmlands or working forest lands? If so, describe.
How much agricultural or forest land of long-term commercial significance will be converted to
other uses as a result of the proposal, if any? If resource lands have not been designated,
how many acres in farmland or forest land tax status will be converted to nonfarm or
nonforest use?
No/Not Applicable.
1) Will the proposal affect or be affected by surrounding working farm or forest land normal
business operations, such as oversize equipment access, the application of pesticides,
tilling, and harvesting? If so, how:
No/Not Applicable.
c. Describe any structures on the site.
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The project will inspect an 8‐inch ductile pipe that is buried under the lakebed in most
locations. This is the only structure on the project sites.
Adjacent structures are primarily single family residences and auxiliary structures (e.g.,
sheds, bulkheads, docks, boat lifts).
d. Will any structures be demolished? If so, what?
No.
e. What is the current zoning classification of the site?
Residential‐8
f. What is the current comprehensive plan designation of the site?
Residential Medium Density
g. If applicable, what is the current shoreline master program designation of the site?
Single‐family residential
h. Has any part of the site been classified as a critical area by the city or county? If so, specify.
Yes. Aquatic sites are designated critical areas.
i. Approximately how many people would reside or work in the completed project?
The project would provide temporary employment for individuals during the period of
inspection.
The project does not provide housing.
j. Approximately how many people would the completed project displace?
None.
k. Proposed measures to avoid or reduce displacement impacts, if any:
Not Applicable.
L. Proposed measures to ensure the proposal is compatible with existing and projected land
uses and plans, if any:
This project is maintenance of an existing sewer line so does not change existing or
projected land uses.
m. Proposed measures to reduce or control impacts to agricultural and forest lands of long-term
commercial significance, if any:
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None. The proposed project will not affect agricultural or forest lands of long‐term
commercial significance.
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?
All proposed repairs will be buried below‐grade.
b. What views in the immediate vicinity would be altered or obstructed?
During inspection and repair activities, a barge and/or boat would be located at the site.
These would not be higher than 10 feet above the water level and would be on site for
up to 5 days at each location. Upon completion, all structures will be buried below grade
in the bed of the lake.
b. Proposed measures to reduce or control aesthetic impacts, if any:
None proposed.
11. Light and Glare
a. What type of light or glare will the proposal produce? What time of day would it mainly
occur?
The project will occur during daylight hours and therefore is not expected to contribute
to lighting or glare. Flashlights or similar may be used to illuminate work surfaces under
water.
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?
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Not applicable.
d. Proposed measures to reduce or control light and glare impacts, if any:
None, not applicable.
12. Recreation
a. What designated and informal recreational opportunities are in the immediate vicinity?
Gene Coulon Memorial Beach Park provides numerous upland recreation activities in
addition to boat launches and a summer swimming area. Kennydale Beach Park
includes a swim area and recreation and picnic areas.
Informal recreational opportunities in the area include park amenities, boating,
kayaking, fishing, and wildlife viewing.
b. Would the proposed project displace any existing recreational uses? If so, describe.
No. The finished project will be buried below grade. Temporary inspection and repair
activities may limit boating or fishing in the immediate vicinity of project activities.
c. Proposed measures to reduce or control impacts on recreation, including recreation
opportunities to be provided by the project or applicant, if any:
None, not applicable.
13. Historic and cultural preservation
a. Are there any buildings, structures, or sites, located on or near the site that are over 45 years
old listed in or eligible for listing in national, state, or local preservation registers ? If so,
specifically describe.
No historic structures or sites are present in the project area. Maintenance and repair activites
include excavation of an already‐buried pipeline. Because the pipeline was installed in 1972,
all relevant lake sediments have been previously disturbed.
b. Are there any landmarks, features, or other evidence of Indian or historic use or occupation?
This may include human burials or old cemeteries. Are there any material evidence, artifacts,
or areas of cultural importance on or near the site? Please list any professional studies
conducted at the site to identify such resources.
No known sites are in the project vicinity. Historic and pre‐historic settlements are
known to have existed around Lake Washington. However, the sites are currently
submerged and would have been historically submerged as well. Furthermore, the
pipeline is buried in soils disturbed during the initial pipeline installation. The project
footprint is within the footprint of excavation in 1970’s for pipeline installation.
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c. Describe the methods used to assess the potential impacts to cultural and historic resources
on or near the project site. Examples include consultation with tribes and the department of
archeology and historic preservation, archaeological surveys, historic maps, GIS data, etc.
None. It is assumed that, because the existing pipe was buried in the lake bed in the
early 1970s, there are no historic artifacts in the area anticipated for excavation.
d. Proposed measures to avoid, minimize, or compensate for loss, changes to, and disturbance
to resources. Please include plans for the above and any permits that may be required.
The project will limit activities to the sediments immediately above the existing pipe.
Probes will be used to confirm the pipe’s location prior to excavation and therefore
excavation will be limited to sediments disturbed during the initial installation of the
pipeline.
14. Transportation
a. Identify public streets and highways serving the site or affected geographic area and
describe proposed access to the existing street system. Show on site plans, if any.
None. The project site is aquatic and will be accessed by boats launched from nearby
boat launches.
b. Is the site or affected geographic area currently served by public transit? If so, generally
describe. If not, what is the approximate distance to the nearest transit stop?
No. Site is wholly aquatic.
c. How many additional parking spaces would the completed project or non-project proposal
have? How many would the project or proposal eliminate?
None.
d. Will the proposal require any new or improvements to existing roads, streets, pedestrian,
bicycle or state transportation facilities, not including driveways? If so, generally describe
(indicate whether public or private).
No.
e. Will the project or proposal use (or occur in the immediate vicinity of) water, rail, or air
transportation? If so, generally describe.
Small, private boats and/or barges will be used to access the site and stage inspection
and repair activities.
f. How many vehicular trips per day would be generated by the completed project or proposal? If
known, indicate when peak volumes would occur and what percentage of the volume would
be trucks (such as commercial and nonpassenger vehicles). What data or transportation
models were used to make these estimates?
Upto10vehicleroundtripscouldoccuraspartofthisproject.Vehicleswillbeusedtodeliverdivers,inspectors,andsupportpersonneltonearbyboatrampsfortransportbyboattothein-waterprojectsites.g.Willtheproposalinterferewith,affectorbeaffectedbythemovementofagriculturalandforestproductsonroadsorstreetsinthearea?Ifso,generallydescribe.No.h.Proposedmeasurestoreduceorcontroltransportationimpacts,ifany:Notapplicable.15.PublicServicesa.Wouldtheprojectresultinanincreasedneedforpublicservices(forexample:fireprotection,policeprotection,publictransit,healthcare,schools,other)?Ifso,generallydescribe.No.b.Proposedmeasurestoreduceorcontroldirectimpactsonpublicservices,ifany.Noneproposed.16.Utilitiesa.Circleutilitiescurrentlyavailableatthesite:electricity,naturalgas,water,refuseservice,telephonetasewsepticsystem,TheprojectentailstheinspectionandrepairoftheexistingsewerlineinLakeWashington.b.Describetheutilitiesthatareproposedfortheproject,theutilityprovidingtheservice,andthegeneralconstructionactivitiesonthesiteorintheimmediatevicinitywhichmightbeneeded.Noneproposed.C.SignatureTheaboveanswersaretruean.ciñt,totesmynowledge.Iunderstandthattheleadagencyisrelyingonth9riitomakeitJcision.Signature:________________________________________________________NameofsigneeL7-.iiiz’.PositionandAgency/Orgayizationc”tt-17L-64/2’DateSubmitted:___________SEPAEnvironmentalChecklist(WAC197-11-960)Page15of16