HomeMy WebLinkAboutD_Cedar_Falls_Transmission_Pole_Replacement_200625_FINALDEPARTMENT OF COMMUNITY
AND ECONOMIC DEVELOPMENT
PLANNING DIVISION
CERTIFICATE OF EXEMPTION
FROM SHORELINE SUBSTANTIAL DEVELOPMENT AND
CRITICAL AREAS REGULATIONS
DATE: June 24, 2020
PROJECT NUMBER: LUA19-000008, SME, CAE
PROJECT NAME: Cedar Falls Transmission Pole Replacement 3
PROJECT MANAGER: Alex Morganroth, Senior Planner
CONTACT: Seattle Public Utilities – SPU_WTR
Bob Gambill
PO BOX 34018
Seattle, WA 98124
APPLICANT: Seattle City Light
Maura Patterson
700 5th Ave
Seattle, WA 98124
LOCATION: Easements identified as APN3023059083, APN3023059066, APN2523049037,
and APN0886700160 adjacent to 1300 SW 27th St.
DESCRIPTION: The applicant, Seattle City Light, is requesting a Shoreline Exemption and Critical
Areas Exemption for utility pole replacement, which would be classified as normal
repair and maintenance. The work is located north of SW 27th Street, in the right -
of-way between Lind Avenue SW and Oaksdale Ave SW. All work will be
completed in a pipeline easement identified as APN3023059083,
APN3023059066, APN2523049037, and APN0886700160 in the Heavy Industrial
(IH) and Commercial Office (CO) zoning districts. The combined area of the sites
is approximately 4.96 acres, and they are located within a high seismic hazard
area, a 100-year flood hazard area (FEMA Zone – AE), mapped with wetlands and
within the Regulated Shoreline Overlay within Reach C of the Black
River/Springbrook Creek (BRSC-C). Eight (8) poles fall within critical areas only,
and one (1) pole falls within the Black River/Springbrook Creek regulated shoreline
and critical areas. Each existing pole will be replaced with a fiberglass/composite
material pole in approximately the same location it is today. The single pole within
the Black River/Springbrook Creek regulated shoreline will be moved 15 - 25 feet
to the west away from the Ordinary High Water Mark to increase safety and
minimize impact to the creek. Crews will follow all best management practices for
soil and erosion control when working near sensitive water bodies to prevent
material from entering the creek. Work will not further encroach outside the existing
right-of-way, nor will it alter any existing areas outside of the project footprint. All
proposed work would occur landward of the Ordinary High Water Mark and no
trees would be removed. No significant vegetation is anticipated to be removed as
part of the project except for approximately 18 square feet in the location of the
new poles. The old wood poles would be removed with a crane and their holes
DocuSign Envelope ID: 4439D059-4759-49E0-A658-1B78DA786FB2
City of Renton Department of Community & Economic Development Certification of Exemption
Cedar Falls Transmission Pole Replacement 3 LUA19-000008, SME, CAE
backfilled with clean crushed gravel. Any disturbed areas will be restored to their
original condition once maintenance is complete.
The applicant submitted a Habitat Assessment (Exhibit 2) prepared by Amberlynn
Pauley, a Strategic Environmental Advisor for Seattle City Light, that analyzes the
potential impacts of the project to the various flora and fauna at the project site.
The assessment specifically identifies the importance of floodplains to Endangered
and Threatened salmonids under the Endangered Species Act due to the large
wood debris, native vegetation, and support of water quality and food for salmon.
Salmonid species identified in the project area include Winter Steelhead/Rainbow
trout, Cutthroat trout, Coho salmon, Fall chinook salmon, and Bull trout. Vegetation
identified at the project site includes reed-canary grass, creeping buttercup,
Himalayan blackberry, and a stand of red alders mixed with black cottonwoods..
According to the assessment, the relocation of the polls further from the nearest
shoreline will reduce the potential impacts to the salmonids. In addition, the projec t
will result in the removal of the existing pesticide-laden wood poles that can leach
into the water as they degrade. The six new hollow fiberglass poles would increase
the flood storage capacity and allow for future co-location of other utilities due to
their strength and thereby lessening the environmental im pact of any future utility
project in the area. The assessment concludes that the project would result in
approximately 55 cubic feet of additional flood storage capacity, a reduction in
pesticide usage due to the use fiberglass poles, a reduction in the number of
lifetime trips needed to the site due to the lower maintenance requirements of the
new poles. The assessment makes a final effects determination of “may affect, not
likely to adversely affect”. The project is to be completed in summer of 2020.
SEC-TWN-R:
LEGAL DESCRIPTION:
(King County Assessor)
NE25 - 23 – 4
BOEING LONGACRES PROPERTY - BSP LOT 16 A RENTON
LLA# LUA15-000850-LLA REC# 20151224900008 SD LLA
BEING LOTS 10, 11, 15, 19 & TRACT C TGW POR
LOTS 9, 16 & 18 SD ADD
SEC-TWN-R:
LEGAL DESCRIPTION:
(King County Assessor)
NE25 - 23 – 4
MEADER HENRY-D C # 46 BOW LAKE PIPE LINE R/W ACROSS D C
SEC-TWN-R:
LEGAL DESCRIPTION:
(King County Assessor)
NE25 - 23 – 4
BOEING LONGACRES PROPERTY-BSP LOT X RENTON LOT COMBINATION #
LUA16-000070 REC #20160420000041 SD LOT COMBINATION DAF LOTS 10, 15,
19 & TRACT C OF SD ADD
SEC-TWN-R:
LEGAL DESCRIPTION:
(King County Assessor)
NW30 - 23 – 5
N 70 FT OF NE 1/4 OF NW 1/4 LESS ST HWY LESS ST SUBJ TO ESMT OVER
N 30 FT TCO 17-884
SEC-TWN-R:
LEGAL DESCRIPTION:
(King County Assessor)
NE25 - 23 – 4
BOEING LONGACRES PROPERTY - BSP LOT 18A RENTON LLA# LUA15-
000850-LLA REC# 20151224900008 SD LLA BEING LOTS 10, 11, 15, 19 &
TRACT C TGW POR LOTS 9, 16 & 18 SD ADD
DocuSign Envelope ID: 4439D059-4759-49E0-A658-1B78DA786FB2
City of Renton Department of Community & Economic Development Certification of Exemption
Cedar Falls Transmission Pole Replacement 3 LUA19-000008, SME, CAE
SEC-TWN-R:
LEGAL DESCRIPTION:
(King County Assessor)
NE25 - 23 – 4
POR OF GL 9 TAKEN FOR BOW LAKE PIPE LN 30 FT STRIP
SEC-TWN-R:
LEGAL DESCRIPTION:
(King County Assessor)
NW30 - 23 – 5
N 30 FT OF NW 1/4 OF NW 1/4
WATER BODY/REACH: Black Rvr/Springbrook Crk Reach C
CRITICAL AREA(S): High Seismic Hazard Area, 100-year Flood Hazard Area (FEMA Zone – AE),
Wetlands
CRITICAL AREAS EXEMPTON JUSTIFICATION/DECISION: An exemption from Critical Areas Regulations is
hereby APPROVED on the proposed project in accordance with RMC 4.3.050C.3 “Exempt, Prohibited and
Nonconforming Activities” and for the following reasons:
“Maintenance and Repair – Any Existing Public or Private Use” includes 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. The use of heavy construction equipment shall be limited to utilities and public
agencies that require this type of equipment for normal and routine maintenanc e and repair of existing utility or
public 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.
The applicant provided the actual elevation, in relation to mean sea level, the North American Vertical Datum of
1988 (NAVD 88), of the lowest floor (including basement) of all new or substantially improved structures, and
whether or not the structure contains a basement where base flood elevation data is provided through the flo od
insurance study or required (Exhibit 1).
SHORELINE EXEMPTION JUSTIFICATION/DECISION: An exemption from a Shoreline Management Substantial
Development Permit is hereby APPROVED on the proposed project in accordance with RMC 4.9.190C “Exemption
from Permit System” and for the following reasons:
“Normal Maintenance” includes those usual acts to prevent decline, lapse, or cessation from a lawfully established
condition.
“Normal Repair” means to restore a development to a state comparable to its original condition, including by not
limited to it 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.
Replacement of a structure or development may be authorized as repair where such replacement is the common
method of repair for the type of structure or development and the r eplacement structure or development is
comparable to the original structure or development including, but not limited to, its size, shape, configuration,
location and external appearance and the replacement does not cause substantial adverse effects to sho reline
resources or environment.
Normal and routine maintenance, operation and repair of existing parks and trails, or the construction of new 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 or to
construct new trails 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.
Within existing and improved public road rights -of-way or easements, installation, construction, replacement,
operation, overbuilding or alteration of all natural gas, cable, communication, telephone and electric facilities, lines,
pipes, mains, equipment or appurtenances, traffic control devices, illumination, walkways and bikeways. If activities
DocuSign Envelope ID: 4439D059-4759-49E0-A658-1B78DA786FB2
City of Renton Department of Community & Economic Development Certification of Exemption
Cedar Falls Transmission Pole Replacement 3 LUA19-000008, SME, CAE
exceed the existing improved area or the public right-of-way, this exemption does not apply. Where applicable,
restoration of disturbed areas shall be completed.
FINDINGS: The proposed development is consistent with the following findings pursuant to
RMC section 4-3-050C.2.d:
i. The activity is not prohibited by this or any other provision of the Renton
Municipal Code or State or Federal law or regulation;
ii. The activity will be conducted using best management practices as
specified by industry standards or applicable Federal agencies or scientific
principles;
iii. Impacts are minimized and, where applicable, disturbed areas are
immediately restored;
iv. Where water body or buffer disturbance has occurred in accordance with
an exemption during construction or other activities, revegetation with
native vegetation shall be required.
v. If a hazardous material, activity, and/or facility that is exempt pursuant to
this Section has a significant or substantial potential to degrade
groundwater quality, then the Administrator may require compliance with
the Wellhead Protection Area requirements of this Section oth erwise
relevant to that hazardous material, activity, and/or facility. Such
determinations will be based upon site and/or chemical-specific data.
The proposed development is:
Consistent with the policies of the Shoreline Management Act.
Not Applicable to the guidelines of the Department of Ecology where no Master Program has been finally approved
or adopted by the Department.
Consistent with the City of Renton Shoreline Master Program.
SIGNATURE & DATE OF DECISION:
Jennifer Henning, Planning Director Date
RECONSIDERATION: Within 14 days of the decision date, any party may request that the decision be reopened
by the approval body. The approval body may modify his decision if material evidence not readily discoverable prior
to the original decision is found or if he finds there was misrepresentation of fact. After review of the reconsideration
request, if the approval body finds sufficient evidence to amend the original decision, there will be no further
extension of the appeal period. Any person wis hing to take further action must file a formal appeal within the 14-
day appeal time frame.
APPEAL: Due to Governor Jay Inslee’s Proclamation 20-25 (“Stay Home, Stay Healthy”), the City Clerk’s Office is
working remotely. For that reason, appeals must be su bmitted electronically to the City Clerk at
cityclerk@rentonwa.gov. The appeal fee, normally due at the time an appeal is submitted, will be collected at a
future date. Appeals to the Hearing Examiner are governed by RMC 4 -8-110 and additional information regarding
the appeal process may be obtained from the City Clerk’s Office, cityclerk@rentonwa.gov. If the situation changes
such that the City Clerk’s Office is open when you file your appeal, you have the option of filing the appeal in person.
EXPIRATION: Two (2) years from the date of decision (date signed).
Attachments: Exhibit 1 and Exhibit 2
DocuSign Envelope ID: 4439D059-4759-49E0-A658-1B78DA786FB2
6/24/2020 | 1:11 PM PDT
700 5th Ave., Suite 3200 | P.O. Box 34023 | Seattle WA 98124-4023
TEL (206) 684-3000 TTY/TDD (206) 684-3225 FAX (206) 625-3709
seattle.gov/light
twitter.com/SEACityLight facebook.com/SeattleCityLight
An equal employment opportunity, affirmative action employer. Accommodations for people with disabilities provided upon request.
March 29, 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. Taylor:
Thank you for the letter dated March 6, 2019, as well as follow-up email communications, clarifying the
request for additional information to proceed with permits associated with the above referenced
Project. As communicated previously, Seattle City Light (SCL) needs to replace nine (9) transmission
poles that are reaching their end of useful life and that are present in the right-of-way within the
jurisdiction of the City of Renton. Eight (8) of the nine (9) poles fall within a critical area, and of those,
six (6) fall within a 100-year flood hazard area – the critical area for which additional information
has been requested.
I am pleased to provide the requested engineering drawings certified by an SCL Professional
Engineer with elevation data as a component of the application. The six (6) transmission poles within a
flood hazard area include (from West to East): 24/463, 24/404, 24/374, 24/337, 24/297, and 24/257 and
are labeled and highlighted in red text in the enclosures to distinguish them from poles not to be
replaced and/or not within a flood plain hazard area. Please feel free to call or email me if you need
clarification on any aspect of the project, as we are trying to complete this work as soon as possible.
Thank you very much for your assistance.
Sincerely,
Maura Patterson
Sr. Environmental Analyst
/Enclosures
Exhibit 1
DocuSign Envelope ID: 4439D059-4759-49E0-A658-1B78DA786FB2
APPROXIMATE UTILITY POLE
LOCATIONS SUPERIMPOSED ON CITY
OF RENTON CRITICAL AREA MAP
Renton, WA
Contact: Maura Patterson
Email: maura.patterson@seattle.gov
Phone: (206) 684-3687
= Approximate location of utility poles in Renton ECAs
Cedar Falls
24/463
Cedar Falls
24/404
Cedar Falls
24/374
Cedar Falls
24/337
Cedar Falls
24/257
Cedar Falls
24/297
DocuSign Envelope ID: 4439D059-4759-49E0-A658-1B78DA786FB2
PLS-CADD Drawing-50005001000150020002500050100150200250050100150200250PI 0°00'00"PI -40°57'45"PI -0°56'42"PI -0°26'03"PI 0°19'19"PI -0°18'50"PI 0°10'39"PI 0°42'20"PI -91°41'33"PI 69°28'08"GDI_0001GDI_0002GDI_0003GDI_0004GDI_0005GDI_0006GDI_0007GDI_0008GDI_0009Term sta=0.00X=1292019.01Y=170070.77ht=26.96 ele=26.9625/245 sta=61.44X=1292062.73Y=170027.60ht=71.27 ele=26.4225/216 sta=357.54X=1292358.21Y=170008.59ht=65.21 ele=23.1525/185 sta=664.75X=1292665.07Y=169993.93ht=60.84 ele=21.5725/155 sta=970.36X=1292970.44Y=169981.66ht=59.69 ele=21.3925/124 sta=1277.39X=1293277.15Y=169967.61ht=59.10 ele=22.0425/93 sta=1584.20X=1293583.71Y=169955.25ht=60.55 ele=23.8825/62 sta=1893.09X=1293892.31Y=169941.85ht=65.76 ele=22.3725/31 sta=2270.42X=1294269.05Y=169920.84ht=79.92 ele=20.3624/505 sta=2837.67X=1294283.89Y=170487.90ht=79.64 ele=17.9561 296307306307307309377 567Term25/24525/21625/18525/15525/12425/9325/6225/3124/50524/46324/43324/40424/37424/33724/297 24/281sub1sub224/27824/25724/217PI 0.000°00'00"PI 61.44-40°57'45"PI 357.54-0°56'42"PI 664.75-0°26'03"PI 970.360°19'19"PI 1277.39-0°18'50"PI 1584.200°10'39"PI 1893.090°42'20"PI 2270.42-91°41'33"PI 2837.6769°28'08"PI 21°PI 3486.31-0°12'17"PI 371°05PI 4080.50-2°43'47"PI 4451.36-0°40'47"PI 4850°02'35PI 5007.7591°17'01"PI 5308.840°00'00"PI 5608.840°00'00"PI 584486°55'2PI 60540°34'26PI 6452.75-0°06'04"Nelson Terminal to Fairwood Tap 115kV7/19/2012Page 1/5 Term - 25/245, 115kV, chickadee_acsr.wir, Displayed 90 Deg C Creep FE 25/245 - 25/31, 115kV, chickadee_acsr.wir, Displayed 90 Deg C Creep FE 25/31 - 24/505, 115kV, chickadee_acsr.wir, Displayed 90 Deg C Creep FE 24/505 - 24/281, 115kV, chickadee_acsr.wir, Displayed 90 Deg C Creep FEVert. ScaleHoriz. Scale20.0 ft.200.0 ft. NorthDocuSign Envelope ID: 4439D059-4759-49E0-A658-1B78DA786FB2
PLS-CADD Drawing250030003500400045005000550060006500700075008000050100150200250050100150200250PI 69°28'08"PI 21°36'25"PI -0°12'17"PI 1°05'51"PI -2°43'47"PI -0°40'47"PI 0°02'35"PI 91°17'01"PI 0°00'00"PI 0°00'00"PI 86°55'25"PI 0°34'26"PI -0°06'04"PI 0°03'08"PI 0°07'56"PI -0°29'17"PI 0°32'04"PI -0°19'17"PI 0°08'14"GDI_0010GDI_0011GDI_0012GDI_0013GDI_0014GDI_0015GDI_0016GDI_0017GDI_0020GDI_0019GDI_0018GDI_0019GDI_0017GDI_0020GDI_0021GDI_0021GDI_0022GDI_0023GDI_0024GDI_0026GDI_0027GDI_002824/505 sta=2837.67X=1294283.89Y=170487.90ht=79.64 ele=17.9524/463 sta=3191.66X=1294618.53Y=170603.33ht=80.33 ele=15.9824/433 sta=3486.31X=1294912.88Y=170590.09ht=68.88 ele=14.8224/404 sta=3783.53X=1295209.85Y=170577.80ht=69.44 ele=13.4424/374 sta=4080.50X=1295506.27Y=170559.83ht=73.84 ele=15.3224/337 sta=4451.36X=1295877.10Y=170555.05ht=73.90 ele=14.1524/297 sta=4850.26X=1296276.00Y=170554.64ht=74.53 ele=16.1424/281 sta=5007.75X=1296433.49Y=170554.36ht=74.18 ele=16.95sub1 sta=5308.85X=1296426.21Y=170253.35ht=36.06 ele=21.53sub1 sta=5308.85X=1296426.21Y=170253.35ht=36.06 ele=21.53sub2 sta=5608.84X=1296458.83Y=170317.35ht=35.93 ele=21.4524/278 sta=5844.88X=1296469.67Y=170553.13ht=77.05 ele=17.3424/257 sta=6054.20X=1296678.99Y=170554.75ht=72.27 ele=17.6224/217 sta=6452.75X=1297077.54Y=170553.85ht=74.26 ele=14.3224/177 sta=6853.51X=1297478.30Y=170553.65ht=74.78 ele=14.5724/140 sta=7213.64X=1297838.43Y=170553.14ht=74.36 ele=18.4724/127 sta=7350.64X=1297975.43Y=170552.63ht=68.47 ele=16.6124/103 sta=7602.90X=1298227.68Y=170553.84ht=74.88 ele=17.9524/79 sta=7832.52X=1298457.30Y=170552.80ht=85.62 ele=14.8724/24 sta=8379.96X=1299004.74Y=170553.39ht=67.66 ele=176.76567354295297297 371399157 301236 209399401360 137 25223054724/50524/46324/43324/40424/37424/33724/297 24/281sub1sub224/27824/25724/21724/17724/14024/12724/10324/7924/2423/52123/485PI 2837.6769°28'08"PI 3191.6621°36'25"PI 3486.31-0°12'17"PI 3783.531°05'51"PI 4080.50-2°43'47"PI 4451.36-0°40'47"PI 4850.260°02'35"PI 5007.7591°17'01"PI 5308.840°00'00"PI 5608.840°00'00"PI 5844.8886°55'25"PI 6054.200°34'26"PI 6452.75-0°06'04"PI 6853.510°03'08"PI 7213.640°07'56"PI 7350.64-0°29'17"PI 7602.900°32'04"PI 7832.52-0°19'17"PI 8379.960°08'14"PI 8691.58-0°08'38"PI 9050.300°24'15"Nelson Terminal to Fairwood Tap 115kV7/19/2012Page 2/5 25/31 - 24/505, 115kV, chickadee_acsr.wir, Displayed 90 Deg C Creep FE 24/505 - 24/281, 115kV, chickadee_acsr.wir, Displayed 90 Deg C Creep FE 24/281 - sub1, 115kV, chickadee_acsr.wir, Displayed 90 Deg C Creep FE sub2 - 24/278, 115kV, chickadee_acsr.wir, Displayed 90 Deg C Creep FE 24/278 - 24/127, 115kV, chickadee_acsr.wir, Displayed 90 Deg C Creep FE 24/127 - 24/79, 115kV, chickadee_acsr.wir, Displayed 90 Deg C Creep FE 24/79 - 23/394, 115kV, chickadee_acsr.wir, Displayed 90 Deg C Creep FEVert. ScaleHoriz. Scale20.0 ft.200.0 ft. NorthDocuSign Envelope ID: 4439D059-4759-49E0-A658-1B78DA786FB2
DocuSign Envelope ID: 4439D059-4759-49E0-A658-1B78DA786FB2
DocuSign Envelope ID: 4439D059-4759-49E0-A658-1B78DA786FB2
700 5th Ave. | P.O. Box 34023 | Seattle WA 98124 -4023 | TEL (206) 684 -3000 TTY/TDD (206) 684 -3225 | US WASHINGTON RELAY SERVICE 7 -1 -1
FLOODPLAINS HABITAT ASSESSMENT
Springbrook Creek Transmission Line Poles, Renton WA
SUBMITTED TO:
• City of Renton, Planning Division
• Attention: Alex Morganroth, AICP, Senior
Planner
Project Location:
2250 Lind Ave SW, Renton, WA; Parcel No.
3023059083 and
2251 Lind Ave SW, Renton, WA, Parcel No.
3023059066 and
Unaddressed parcel E. of Oakesdale Ave SW,
Parcel No 2523049037
Looking East from Pole # 2497877
MORE INFORMATION
Amberlynn Pauley
Environmental Strategic Advisor
(206)-735-1756
Amberlynn.pauley@seattle.gov
TRANSLATION SERVICES AVAILABLE
AT (206) 684-3800
• Información en español
• Impormasyon sa Tagalog
• 中文資訊
• Thông tin bằng tiếng Việt
• 한국어 정보
• Macluumaad Af-Soomaali ah
Exhibit 2
DocuSign Envelope ID: 4439D059-4759-49E0-A658-1B78DA786FB2
1
Springbrook Transmission Line Poles
Floodplains Habitat Assessment Seattle City Light
EXECUTIVE SUMMARY
The project proposes the removal of six (6) Seattle City Light (SCL) pentachlorophenol and copper
napthenate wood transmission utility poles and replacement with six (6) fiberglass poles along a co-
located utility right of way that follows the path of where SW 23rd Street would be, roughly between
Lind Ave SW and Oakesdale Ave SW.
The utility right of way co-locates the Olympic oil pipeline owned by BP, a Seattle Public Utilities (SPU)
water main, and Seattle City Light’s electric transmission line, the subject of this writing. The Olympic
pipeline and SPU are not proposing any changes. The one lane road in the ROW used by all utilities is
used as a community recreational trail as well.
Addresses of the three properties where these poles are located are, from east to west, at 2250 Lind Ave
SW, one pole; 2251 Lind Ave SW, two poles, and an unaddressed property, from the west bank of
Springbrook Creek west to Oakesdale Ave SW with three poles. This site is within the Green/Duwamish
Watershed, WRIA 9.
The right-of-way is in the large-scale floodplains, wetlands, and adjacent to fish bearing (Type F)
streams of Springbrook Creek watershed (City of Renton COR data, 2020). Floodplains are especially
important to Endangered and Threatened salmonids under the Endangered Species Act (ESA), providing
flood storage capacity, large woody debris & habitat features, native vegetation refugia, and the
support of water quality and food for salmon (NMFS Biological Opinion, 2008). At this location, five
salmonid species, with three Evolutionarily Significant Units (ESUs) threatened under the ESA are likely
present (StreamNet, 2019), though no Critical Habitat or spawning habitat is present:
• Winter Steelhead/ Rainbow trout (Oncorhynchus mykiss*) migration only
• Cutthroat trout (Oncorhynchus clarkii) migration
• Coho Salmon (Oncorhynchus kisutch) migration, rearing and migration
• Fall Chinook Salmon (Oncorhynchus tshawytscha*) rearing and migration
• Bull Trout (Salvelinus confluentus*), possible intermittent presence to hunt
Poles will be relocated up to 25 feet from their current locations, within the utility ROW, away from the
nearest shoreline and with fiberglass poles instead of wood. These measures reduce impacts by
removing pesticide impregnated wood poles from the floodplain, increasing the flood storage capacity
with hollow poles, reducing necessary vehicle maintenance trips, and maintaining co-location with
multiple utilities.
Allowing this project will result in fewer impacts to the floodplains of Springbrook Creek watershed than
maintaining the status quo, or placing them in an alternate location, as none exists that does not
require poles in the floodplain. The project has been designed to have the fewest possible impacts.
The project action determination is may affect, unlikely to adversely affect (NLAA) owing to the
negligible impacts, some of them positive, and the small scope and scale of the proposed project.
DocuSign Envelope ID: 4439D059-4759-49E0-A658-1B78DA786FB2
2
Springbrook Transmission Line Poles
Floodplains Habitat Assessment Seattle City Light
PROJECT PROPOSAL
The project consists of the replacement of six (6) wood transmission utility poles that are nearing the
end of their service life with six (6) fiberglass utility poles. Each of the four eastern most existing poles is
near to a creek, either Panther Creek, or Springbrook Creek in the western portion. The existing poles,
floodplains, and wetlands are exhibited in the map located in Appendix A. The area of project analysis is
the utility corridor parcels, and extends 25’ to the east of pole # 2497869 and 25’ to the west of pole
#2497877. No work in water is proposed.
The project proposes to replace each of the poles slightly further from the adjacent streambanks,
balancing direction from Seattle Public Utilities to maintain a minimum safe distance and minimize
impacts to their water main. The poles line up east-west along an established utility right-of-way
alignment, in the location where SW 23rd Street would be if it existed. The ROW corridor is designated
in its own parcels, and the specific pole numbers on each parcel are listed below:
• Parcel No. 3023059083; 2250 Lind Ave SW, One (1) Pole #2497869 CF24/257
• Parcel No. 3023059066; 2251 Lind Ave SW, Two (2) Poles #2497872 CF24/297, #2497873
CF24/337
• Parcel No 2523049037 Unaddressed property, utility right-of-way, perpendicular to Springbrook
Creek, Three (3) Poles # 2497874 CF24/374, # 2497875 CF24/404 and # 2497877 CF24/463
The project area map of existing floodplains, wetlands and approximate pole sites is located in
Appendix A. Mapping of the area shows that the Floodplains, the Protected Area, and the Special Flood
Hazard Area at this site are extensive, and there is a long history of levies, relocated rivers and streams,
agricultural activity and drainage ditches in this part of the Green River Valley (Anchor Environmental,
2004). Soils are Woodinville silt loam, Urban Land, Tukwila muck, Puget silty clay loam, and other hydric
and alluvial soils (NRCS, 2019). Most recently, there has been additional industrial development (King
County, 2011). For the purposes of this project, all of the above-named parcels and utility poles are
presumed to be entirely within the Special Flood Hazard Area and wetlands. For the sake of simplicity
within this report, the designated areas are referred to as the floodplains and wetlands. Site visits and a
brief analysis of the hydrology and plant species composition support this presumption. Dominant
vegetation across most pole sites is reed-canary grass (Phalaris arundinacea), creeping buttercup
(Ranunculus repens), Himalayan blackberry (Rubus armeniacus) and various forbs and mosses, though
the eastern most pole is near a stand of red alder, (Alnus rubra), black cottonwood (Populus trichocarpa)
and various willow species. No trees will be removed as part of the project proposal. Pictures of the site
in December 2019 are available in Appendix B.
Alternate locations for this project were briefly considered, but all potential locations must cross these
same floodplains & wetlands, avoid wetland mitigation lands to the south, and align with the remaining
transmission line to the east and west. Other locations result in a greater project area, more poles, and
as a result, greater impacts by avoiding the opportunity to co-locate with other utilities and share
access within the ROW corridor. Given these constraints, this site was determined to be the least
impactful location to floodplains, wetlands, and salmonids in the Springbrook Creek watershed.
DocuSign Envelope ID: 4439D059-4759-49E0-A658-1B78DA786FB2
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Site plans are appended to this permit application, and available as part of the permit package. Site
plans should be consulted for the precise location of the new poles.
PROJECT TIMING, METHODS AND WORK PLANS.
The project is scheduled to be completed over the Summer of 2020, beginning after June 1, and
completed before September 30, 2020. The work will be done during dry weather to avoid saturated
soils, and in all should be completed within 2-3 weeks. The fiberglass pole holes will be evacuated with
set with an eductor truck at a location further away from (perpendicular to) the stream shoreline,
potentially up to 25’ further away, in the least impactful area possible. A caisson will be installed in the
hole, and the pole will be set within the caisson. The area between the pole and caisson will be
backfilled with crushed, clean 5/8’s minus gravel. The eductor and caisson and pole setting trucks will
reach the location either by the single lane gravel road, or if possible, reach from a paved area, or, if
necessary, travel on large rubber mats and/or steel plates that allow the soil and vegetation structure to
remain. It is anticipated that all poles will be reached by the single lane road within the ROW footprint.
After the new poles are set, the energized lines and communication lines will move over to the new
poles, and the old poles will be cut, pulled up and removed from the site for appropriate disposal. The
void areas from the old poles will then be filled with clean crushed gravel without sediment. The
eductor truck method, and the pulling of the wood poles will result in reduced exposure of waters,
including floods and hyporheic flow, to pesticides and preservatives, and will result in negligible soil
exposure with immediate replanting, and no soil stockpiles over the course of the project. Exposed soils,
about 6 square feet at any one time during construction, will be re-vegetated immediately with a locally
adapted native grass mix.
No large woody debris, if present, will be removed. No vegetation will be removed except for the 18
square feet necessary for the new poles, and no changes to streambanks or streambank structures are
proposed. 80-120 cubic feet of caissons and crushed rock and fiberglass pole material will be added at
the site, however approximately 175 cubic feet of treated wood material will be removed from the site.
IMPACTS & EFFECTS DISCUSSION
The floodplains functions present on the project site are imperfect due to decades of changes to
hydrology and vegetation. That said, the proposed project, if allowed to proceed, would result in:
• Increased flood storage capacity of 55 cubic feet;
• Critical utility infrastructure moved further away from Springbrook and Panther Creeks;
protecting both the equipment and the creeks flooding events.
• Reduced pesticide usage and maintenance needs in the floodplain due to replacement of
pesticide-treated wood poles with inert fiberglass poles
• Continued co-location of critical utilities, minimizing the overall footprint and impact of
development from utility needs, including vehicle access and vegetation management
• Greater power reliability, with less risk of emergency access needs, due to timely upgrades
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Springbrook Transmission Line Poles
Floodplains Habitat Assessment Seattle City Light
Seattle City Light strives to apply the latest best management practices to protect the environment
throughout our projects and operation areas.
Removal, relocation and replacement of these poles will increase flood storage capacity because wood
poles are solid and require deeper depth to achieve the same strength as a shallower set, hollow
fiberglass pole. Flood storage quality is also improved by keeping more flood storage closer to the
stream. This will help contain more frequent and smaller storm & flooding events.
The change in pole type means that fewer pesticides, fungicides and wood preservatives are present
and available to travel in the floodplains and wetlands, and that fewer vehicle trips to re-treat wood
poles with these chemicals are necessary. Pentachlorophenol and Copper napthenate travel from the
pole into soil and water in very small leached amounts, though motility is affected by hydrology,
microclimate, soil acidity, wood species, length of time in service, and other factors not easily quantified
(Strid et. al. 2019). Removal of treated wood poles removes both direct and indirect impacts by
removing a source of possible pollution from the floodplains area completely.
Gravel fill will be brought in to stabilize the pole sets. Soils from the new poles will be placed in the old
pole holes. Vegetation removal is restricted to the circumference of the new fiberglass poles, further
from the streambank. The old pole holes will be revegetated. No effects, or negligible positive effects to
stormwater and vegetation cover are expected by the minor increase in vegetation cover and the
increased vegetation moved toward the stream banks.
Individual species and life stage effects for salmon species were not broken out because the habitat
available and species presence in the reaches of Panther and Springbrook Creeks adjacent to the
project do not have high intensity uses by the species (such as spawning or rearing), and because
project impacts are small, generally positive, and benefit all aquatic species that benefit from reduced
pesticides and greater flood storage.
PROJECT DETERMINATION
Because this is an existing transmission line, and these pole replacements are necessary to maintain the
line in good order, interrelated and interdependent effects are greatly minimized as a result of this
project. Doing nothing would likely result in emergency action due to broken poles or leaning poles in a
storm, due to these poles being at the end of their useful term. It’s foreseeable that the Puget Sound
area will continue to grow, and require additional electric power, and fiberglass poles is an upgrade to
how the infrastructure interacts with the local environment, while still fulfilling our mandate to provide
reliable, resilient power infrastructure for the local power grid.
Because of the positive project impacts of reducing pesticides, and the negligible stormwater effects
potential, the effects determination is may affect, not likely to adversely affect (NLAA).
There is no critical habitat within the scope or scale of expected effects, even cumulatively, from this
project.
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REFERENCES:
Anchor Environmental, L.L.C., 2004. Lower Green River Baseline Habitat Survey Report. Report prepared
for WRIA 9 Technical Committee and King County Department of Natural Resources.
City of Renton, 2020. COR Maps. Accessed multiple dates from January 1 through May 31, 2020 at
https://rp.rentonwa.gov/HTML5Public/Index.HTML?viewer=CORMaps
FEMA Region 10, 2013. Floodplain Habitat Assessment and Mitigation, Regional Guidance for the Puget
Sound Basin. Accessed online November 2019-May 2020 at https://www.fema.gov/media-library-
data/1383598118060-
e34756afe271d52a0498b3a00105c87b/Puget_Sound_R10_Habitat_Assess_guide.pdf
King County, 2011. Lower Green Duwamish River Watershed webpages, Accessed March 27th, 2020
https://www.govlink.org/watersheds/9/activities-partners/LowerGreen.aspx
NMFS 2008. Endangered Species Act Section 7 Formal Consultation and Magnuson-Stevens Fishery
Conservation and Management Act Essential Fish Habitat Consultation for the on-going National Flood
Insurance Program carried out in the Puget Sound area in Washington State. HUC 17110020 Puget
Sound. Available online at: https://www.fema.gov/media-library-data/20130726-1900-25045-
9907/nfip_biological_opinion_puget_sound.pdf
StreamNet, 2019. GIS data for Pacific Northwest Salmonid distribution spatial data set (all Puget Sound
Species.) Portland (OR): StreamNet, May 2003. Data update: January 31, 2019.
http://www.streamnet.org/online-data/GISData.html
Strid, A.; Hanson, W.; Cross, A.; Jenkins, J. 2019. Treated Wood Fact Sheet; National Pesticide Information
Center, Oregon State University Extension Services. http://npic.orst.edu/factsheets/treatedwood.html.
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Appendix A: Approximate Pole Locations on City of Renton Critical Areas Map.
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Appendix B: Site Photos
Clockwise from top left: Pole 2497873 very close to Panther Creek; Pole 2497877 near
Oakesdale Ave SW, Road looking toward pole 2497875, Springbrook Creek, looking south from
pole 2497874.
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