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T ECHNICAL M EMORANDUM
Date: November 2, 2017
To: Rebecca Saur, Stantec
From: Hugh Mortensen, Tess Brandon, and Sarah Sandstrom
Project Number: 131113
Project Name: Thunder Hills Creek Sanitary Sewer Interceptor Rehabilitation
Subject: Springbrook Creek Mitigation Bank Use Plan
The proposed Thunder Hills Creek Sanitary Sewer Interceptor Project will have
unavoidable direct wetland impacts. The applicant, the City of Renton Public Works,
proposes to mitigate for these direct wetland impacts at the Springbrook Creek Wetland
and Habitat Mitigation Bank (Springbrook Bank).
This memorandum describes how the Thunder Hills Creek sanitary sewer interceptor
rehabilitation project complies with the appropriate process for use of the Springbrook
Creek mitigation bank, and is intended to serve as the bank use plan for that transaction.
The contents of this plan are based on Using Credits from Wetland Mitigation Banks:
Guidance to Applicants on Submittal Contents for Bank Use Plans (Interagency Review Team
for Washington State 2009) and Springbrook Creek Wetland and Habitat Mitigation Bank:
Mitigation Banking Instrument (WSDOT and City of Renton 2006).
1. Project Description
Thunder Hills Sanitary Sewer Interceptor was installed in 1965 and, like many sewer
projects of that time, was installed in a stream valley to take advantage of favorable
gravity-flow conditions. It consists of approximately 3,600 lineal feet of 10-inch to 18-
inch concrete pipe that runs beneath or adjacent to Thunder Hills Creek. The depth of
the pipe varies, and may be greater than 30 feet in some areas. Currently, access to the
existing sewer is poor. Erosion along the creek has compromised the sewer interceptor
in the past; portions of the stream bank were stabilized with gabion baskets in the early
1980s, and more repairs that used large quantities of rip-rap armoring were done in 2008
and 2009.
The City proposes to improve system components and access for the sanitary sewer
interceptor through a combination of Cured-In-Place-Pipe (CIPP) technologies and
construction of replacement sewer line segments. From the northern end of the project
area south, proposed improvements include adding an equipment turnaround at Station
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6+50,1 building a new access road across PSE property at Station 15+00, and rebuilding
the entrance road at Station 30+00. A new parallel sewer will be installed from
approximately Station 3+28 to 11+20 and 13+08 to 15+44 underneath the new/improved
access roads. The remaining portion of the existing sewer will be rehabilitated in place
using CIPP technology. Existing rock buttresses and rockeries south of Station 6+00 will
be rebuilt to protect the existing/new sewer and access road.
Construction associated with proposed sewer interceptor rehabilitation will result in
some disturbance to on-site wetlands and their associated buffers. Impacts from
proposed project activities include temporary impacts (vegetation clearing) from
construction, direct wetland impacts (vegetation clearing and wetland fill) from new
access roads, and impacts to wetland buffers (vegetation clearing) from new access
roads. The sewer interceptor rehabilitation work itself will not result in permanent
impacts to wetlands or wetland buffers. Impact areas are shown on project site plan
drawings submitted with this memorandum.
2. Existing Conditions of Wetlands and Buffers
Six small wetlands were delineated in the project area. The wetlands were named
alphabetically based on location along the creek, from upstream to downstream.
Wetland A was categorized as a Category III slope/depressional wetland with a habitat
score of four and a total score of 17. Wetland B was categorized as a Category III riverine
wetland with a habitat score of six and a total score of 19. Wetland C was categorized as
a Category IV slope wetland with a habitat score of five and a total score of 14. Wetland
D was categorized as a Category III riverine wetland with a habitat score of five and a
total score of 18. Wetland E was categorized as a Category III depressional wetland with
a habitat score of five and a total score of 17. Wetland F was categorized as a Category III
slope wetland with a habitat score of five and a total score of 16. All wetlands are located
adjacent to Thunder Hills Creek, with the exception of Wetland A, which is collocated
with the tributary stream (Stream E) at the upstream end of the project area.
A summary of existing wetlands is provided in Table 1. Detailed information on
wetlands delineated in the project area, and a map of all delineated features, are
provided in the Stream & Wetland Delineation Report (The Watershed Company 2015).
1 Station numbers refer to location markers found on project site plan drawings.
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Table 1: Existing Conditions of Wetlands
Feature Ecology
Rating Habitat Score HGM classification Standard Buffer
Width (ft)
Wetland A III 4 Slope/Depressional 75
Wetland B III 6 Riverine 100
Wetland C IV 5 Slope/Depressional 50
Wetland D III 5 Riverine 100
Wetland E III 5 Depressional 100
Wetland F III 5 Slope 100
Non-wetland areas are dominated mainly by a native deciduous forest with a few
coniferous trees. The forest has an understory that includes typical shade-tolerant native
shrubs and groundcovers. Patches of locally-dominant invasive weeds such as
Himalayan blackberry and English ivy are also present throughout the forest (Figure 5).
Dense monoculture of Himalayan blackberry and Japanese knotweed predominate
where powerlines cross the stream and along forested edges.
Thunder Hills Creek is a perennial stream that flows north-northwest through the entire
project area. Bed and bank armoring have been placed along significant portions of the
stream channel in an effort to prevent erosion. Large, loose riprap occurs throughout the
channel, and gabion baskets armor sections in the northern (downstream) portion of the
project area (Figure 3). As described in the Critical Areas Report (The Watershed
Company 2017), multiple barriers downstream prevent salmonid fish use on-site in
Thunder Hills Creek. Seven presumed seasonal tributary streams join Thunder Hills
Creek along its course through the project area.
3. Wetland Impacts
3.1 Avoidance and Minimization of Wetland Impacts
The entire project would be located within stream and wetland buffers designated by
the City of Renton; therefore, strict avoidance of buffer impacts is not feasible.
Nevertheless, several project elements minimize the area of wetland and wetland buffer
impacted. These minimization measures are described below:
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• CIPP technologies are used to repair the existing sewer interceptor where it
crosses Thunder Hills Creek;
• Where replacement pipe segments are proposed, construction those segments
under the access road to minimize the footprint of construction and maintenance
impacts;
• Locating the improved/new access roads over the existing unmaintained
trail/roads to minimize impacts to vegetation in the combined wetland and
stream buffer;
• Using a narrower width path (seven feet compared to 12-foot road) for
specialized equipment on the northern portion of the project area;
• Implementing a Temporary Erosion and Sediment Control plan, provided with
the project site plan drawings; and
• Timing construction to avoid the wet season when sedimentation and erosion
would be anticipated.
3.2 Unavoidable Wetland Impacts
The project will result in unavoidable wetland impacts. Temporary impacts to wetlands
and wetland buffers (20,703 square feet) will be restored to their pre-existing conditions
following construction. Permanent wetland buffer and stream buffer impacts (41,000
square feet) will be mitigated on-site.
Direct wetland impacts include placement of a new gravel access road within Wetland F,
and construction of a new gravel turnaround that extends partially into Wetland E at the
southernmost extent of the project area. These direct wetland impacts total 1,332 square
feet (0.03 acres) (Table 2).
Wetland Category Area of Impact Credits Required
F III Slope 1,315 square feet
(0.029 acres)
0.025
E III Depressional 17 square feet
(0.001 acres)
0.001
Total III 1,332 square feet
(0.03 acres)
0.026
3.3. Impacted Wetland Functions
Wetland E
Wetland E was classified as a Category III depressional wetland with a habitat score of
five and a total score of 17. Only a small area of Wetland E will be directly affected by
the project. Wetland E is a disturbed wetland that has formed on top of fill material and
is located on what once was likely the stream channel of Thunder Hills Creek. The
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culvert that carries Thunder Hills Creek under I-405 is under Wetland E; the culvert inlet
is located just south of the wetland.
Scrub-shrub and emergent vegetation in the wetland may filter runoff from adjacent
development before it reaches Thunder Hills Creek and downstream impaired waters of
the Black River.
Due to the limited area of impact, this project is not expected to affect water storage
potential of the wetland significantly. Similarly, the small area of impact will not
significantly affect diversity of habitat structures within the wetland.
Wetland F
Wetland F was categorized as a Category III slope wetland with a habitat score of five
and a total score of 16. The project will fill the majority of Wetland F, effectively
eliminating its current functions, described below.
Because the average slope of the wetland is greater than five percent and the vegetation
has a limited potential for trapping sediments and pollutants from adjacent
development before it reaches Thunder Hills Creek and downstream impaired waters of
the Black River.
The nearby residential development may generate flashy runoff associated with
impervious surface coverage. The wetland position and vegetative composition would
have limited potential to slow or store floodwaters. However, and flood reduction
potential would be beneficial to downstream development, which encompasses the
urban core of the City of Renton.
The wetland itself has limited site complexity in terms of vegetation, hydroperiods, and
special habitat features. Similarly, given the proximity of adjacent high-intensity
development, there is limited potential to support habitat in the surrounding landscape.
However, the adjacent Thunder Hills Creek provides instream, riparian, and downed
wood habitats, which increase the habitat value of the wetland.
4. Springbrook Creek Mitigation Bank Use
4.1 Wetland Mitigation Site Selection Rationale
The project applicant considered several alternatives for mitigating for permanent
wetland impacts. Given the steep nature of the project site and the lack of public
ownership, on-site wetland mitigation outside of existing wetland areas was not a
feasible option. Additionally, The Environmental Protection Agency (EPA) and the U.S.
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Army Corps of Engineers (Corps) have established a preference for use of mitigation
banks or in-lieu-fee programs over on-site, permittee-responsible mitigation (33 CFR
§325 and 332, 40 CFR §230). The City of Renton has an approved wetland mitigation
bank on Springbrook Creek and King County operates an in lieu fee program through
its Mitigation Reserves Program.
The applicant proposes to purchase wetland credits at the Springbrook Mitigation Bank
(Springbrook Bank) to offset permanent wetland impacts. The Springbrook Bank is
owned by the City of Renton, and its Service Area includes portions of the Green-
Duwamish Watershed (WRIA 9) including the project site. The Springbrook Bank was
selected over the King County Mitigation Reserves Program because of its proximity to
the impact site and location within the City of Renton and WRIA 9.
4.2 Wetland Functions Provided at Wetland Mitigation Bank
The Springbrook Bank created approximately 18 acres of new wetland area, and
rehabilitated or enhanced approximately 85 acres of wetlands. The proximity of the
Springbrook Bank to the lower reaches of Springbrook Creek and the Lower Green River
provides an opportunity for the wetland mitigation bank to improve water quality,
hydrologic, and riparian functions.
Dense native vegetation will help filter water quality. In addition to water quality,
riparian vegetation supports detritus and shading, which supports instream habitat for
salmonids.
Springbrook Creek floodwater is captured by the bank wetlands during high water
events because parts of the manmade levees were removed. This additional flood
storage capacity reduces downstream flood elevations.
Additionally, because the Springbrook Bank is located within an otherwise densely
developed area, similar to the impact site, the mitigation bank protects and enhances the
remaining area available for wildlife populations.
4.3 Wetland Functions Not Mitigated at Wetland Mitigation Bank
Temporary impacts to wetlands and wetland buffers will be mitigated on-site rather
than at the mitigation bank. This on-site restoration is warranted, as it will help to
maintain existing functions present at the site to the maximum extent feasible.
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Additionally, permanent impacts to wetland buffers will be mitigated on-site. The on-
site wetland mitigation is warranted to maintain buffering functions for the stream and
existing wetland areas that will remain.
4.4 Proposed Mitigation Credits
The project proposes to mitigate for unavoidable permanent impacts to Wetland E and
Wetland F using the Springbrook Creek Mitigation Bank. Because Wetland and Wetland
F are Category III wetlands, 0.85 credits at the Springbrook Creek Mitigation Bank are
required per impact acre (WSDOT and City of Renton 2006). Therefore, permanent
impact to 0.03 acres to Wetland E and Wetland F requires 0.026 mitigation credits.
4.5 Credit Purchase or Transfer Timing
Credits will be purchased immediately upon receiving permit approvals from
regulatory agencies.
References
Interagency Review Team for Washington State. 2009. Using Credits from Wetland
Mitigation Banks: Guidance to Applicants on Submittal Contents for Bank Use
Plans.
The Watershed Company. 2015. Stream & Wetland Delineation Report Thunder Hills
Sanitary Sewer Interceptor Alternatives Analysis, Renton, WA. Prepared for City
of Renton.
The Watershed Company. 2017. Critical Areas Report Thunder Hills Sanitary Sewer
Line- Renton, WA. Prepared for Stantec Consulting Services, Inc.
Washington State Department of Transportation (WSDOT). 2006. Springbrook Creek
Wetland and Habitat Mitigation Bank Prospectus.
Washington State Department of Transportation (WSDOT) and City of Renton. 2006.
Springbrook Creek Wetland and Habitat Mitigation Bank: Mitigation Banking
Instrument.