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September 17, 2019
CITY OF RENTON
DEPARTMENT OF COMMUNITY & ECONOMIC DEVELOPMENT
1055 S. GRADY WAY
RENTON, WA 98057
RE: Cedar Falls Transmission Pole Replacement 3, LUA19-000008, CAE, SME
Dear Mr. Morganroth:
Thank you for the email dated July 3, 2019, requesting a Habitat Assessment waiver from the Department
of Ecology (DOE). Since that time, City Light has had several conversations and email exchanges with the
Department of Ecology and FEMA to seek clarification on the definition of “maintenance” and the
interpretation that poles not installed in the exact same location do not qualify as exempt as “normal
maintenance of above ground utilities and facilities, such as replacing power lines and utility poles” per
FEMA guidance on compliance with the Biological Opinion (BiOp) for the National Flood Insurance
Program (NFIP) in Puget Sound. Here is a summary of those communications:
08/05/2019 Telephone conversation with NFIP Coordinator at DOE. They requested an
email with more detailed information, but it was indicated on the call that any
movement of utility poles during replacement was not considered
maintenance.
08/05/2019 City Light sent an email with the requested information to DOE.
08/07/2019 City Light sent an email with additional clarifying information to DOE.
8/07/2019 Second telephone conversation with NFIP Coordinator at DOE to seek
clarification of the above interpretation of utility maintenance. It was
recommended that City Light speak with FEMA for any formal definitions of
utility maintenance. It was re-iterated that a floodplain permit and Habitat
Assessment (HA) are required if poles are not replaced in the exact same
locations, even if the movement is beneficial.
8/15/2019 Telephone conversation with FEMA – Region X Mitigation Division. A request
for an email with more detailed information was made. City Light sent an
email to FEMA with the requested information.
8/16/2019 FEMA responded via email to City Light that DOE’s interpretation for this
project was in alignment with the BiOp for Puget Sound. FEMA indicated that
the project was not exempt from the HA due to “the placement of poles in
new locations” (i.e., moving the poles is to be considered new development).
While City Light disagrees with this interpretation, we will proceed with the HA to document the impacts
of the project, which are beneficial to the floodplain as follows: composite versus wood-treated material
to diminish impacts to water quality from wood preservative materials; hollow poles of smaller diameter
to increase flood plain storage; and the movement of poles away from salmonid-bearing streams to
minimize impacts from the utility infrastructure (further distance from the stream resources ensures that
storm or high-water related damage to the poles may be lessened due to increased distance, and
therefore long-term maintenance and potential emergency repair and reconstruction needs are reduced).
Given the interpretation and guidance from DOE and FEMA against a waiver, as well as the long lead time
to receive clear guidance, City Light respectfully requests an extension to complete and submit the HA.
Please let me know if you have any questions regarding our request. Thank you very much for your
assistance.
Sincerely,
Maura Patterson
Sr. Environmental Analyst