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HomeMy WebLinkAboutRenton-Walter followup response 12-3-19_final 1 PSE Follow-up Responses to Comments from Karen Walter – Muckleshoot Tribe 1. With a project of this magnitude involving Cedar River and other streams and wetlands with substantial documents to review, the City should have required a 30 day minimum comment period. PSE Response: PSE does not have an opinion as to the suggested comment period. However, the revised project does not result in impacts to the designated Shoreline of the Cedar River. The proposed project uses an existing transmission line corridor that was established in the late 1920s and early 1930s. PSE listened to public and agency input and revised the project design so that no impacts would occur near the Cedar River. The proposal was subject to an Environmental Impact Statement preparation process over several years that included multiple public comment periods and public meetings. PSE provided a revised Shoreline Exemption Project Narrative to the City dated January 25th 2018, which describes the revised proposal within the designated Shoreline of the Cedar River (see attached). 2. Per the Critical Areas Report for this project, “Two existing poles will be removed from and replaced outside of wetland and stream buffer resulting in a net increase of only 68 square feet of permanent impact. Vegetation community conversion impacts in wetland and stream buffers total 18,786 square feet and 20,064 square feet of temporary disturbance will occur.” The impacted areas are the Cedar River and Honey Creek (a May Creek tributary). The project proposes to mitigate for these impacts at Riverview Park near the Cedar River (see Appendix F of the CAR) and near Honey Dew Creek. More information is needed regarding the proposed mitigation, including how the project is sufficiently providing mitigation for a full suite of riparian functions, including future wood recruitment. The only proposed mitigation is planting new trees that are within the PSE corridor which means they are likely to be managed and not allowed to grow to their full heights. Further, there is no proposal to add removed trees back into the affected streams. Both the Cedar River and Honey Dew Creek (and May Creek) lack wood. The removed trees should be added back into these affected streams to partial mitigate for the tree removal (both temporary and permanently removed). PSE Response: The Revised January 2019 Renton Critical Areas Report provides additional information on mitigation. Specifically, no tree removal is proposed in the area of the Cedar River shoreline nor is mitigation. The proposed tree removal in the area of Honey Dew Creek will occur within the existing managed transmission line corridor where trees are trimmed or removed on a regular maintenance cycle to ensure compliance with electrical safety clearances. The existing trees would never be allowed to grow to their mature height as they would pose a safety risk to the existing transmission lines. However, mitigation plans for the Honey Dew Creek area include snags and hinge cut trees, which leaves all woody material in the area (see Appendix F). Replacement trees are provided for on PSE property located near wetland NR01 as shown on the plans. 2 It is also not clear how the proposed mitigation covers the same amount of buffer areas, in part because the mitigation area for the lower Cedar River area is not quantified on the sheets. PSE Response: Based on public and agency input, PSE revised the project design so that no impacts would occur near the Cedar River; thus, no mitigation is proposed along the Cedar River. For the Honey Dew Creek mitigation site, if trees are removed from the buffer, then native trees, not shrubs as proposed, should be restored. If trees cannot be planted in the any of the mitigation areas, then the applicant should find other mitigation sites to plant trees or contribute to King County’s ILF program. The amount of mitigation should equal as least 1:1 in square foot area to avoid a net loss of functions. Currently, the mitigation area for Honey Dew Creek is less than 1:1 to impact area. PSE Response: The proposed project is located within an existing transmission line corridor. Vegetation management occurs on regular intervals. PSE used Washington State Department of Ecology mitigation guidelines for vegetation conversion of buffers. Regarding tree replacement, PSE is proposing to plant at least 280 trees in Renton along the corridor, which exceeds the 212 regulated trees that are proposed for removal, a ratio of greater than 1:1 mitigation to impacts. This, along with a more detailed outline of how PSE is proposing to replace vegetation, is documented in the Vegetation Replacement Approach letter dated July 24, 2019 and submitted to the City of Renton as part of the Conditional Use Permit materials for this project.