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HomeMy WebLinkAboutC_KC_Second_Response_Letter_to_MIT_181022.pdfL-9 King County Department of Natural Resources and Parks Parks and Recreation Division King Street Center 201 South Jackson Street, Suite 700 Seattle, WA 98104 October 22, 2018 Clark H. Close Senior Planner City of Renton Subject: LUA18-000421, ECF, SMC County Response to Muckleshoot Concerns (additional comments) Dear Mr. Close: Thank you for the opportunity to respond to additional comments regarding the County's permit application to improve the trestle over May Creek for non -motorized use. We provide some brief responses to the individual comments below. However, our overall response is focused on the limited scope of the proposed decking project. General response: As described in our prior response, decking the bridge is a minor change to existing conditions that would have minimal effect on stream habitat. In itself, the decking does not constitute a significant impact that would indicate anything beyond a DNS finding under SEPA. Given the limited scope and cost of the project, which does not extend the overall life the trestle, the proposed work would not reasonably trigger the removal and replacement of the entire trestle. Responses to revised comments: Creosote and aquatic habitat: Creosote has a negative impact on aquatic habitat, which tends to decrease over time. The proposed project, while not removing the impact, would likely reduce the transport of PAH's to the stream due to the reduction in runoff traveling along the treated members during rainfall events. The suggested mitigation for creosote impact — complete removal of the structure is not in proportion to the scope and scale of the project. It is not the case that minor updates to existing structures with creosote piers throughout the Puget Sound basin result in a requirement to remove the entire structure to mitigate creosote impacts. Scour: The current project does not include armoring, and we have no indication that scour is a problem that would require future armoring. ■ Large woody debris: The upstream elements described in the County's previous response are likely to be in place for the foreseeable future, and limit the likelihood that large woody debris would be transported to the trestle. It is not within the scope of the project to consider the removal or modification of these elements. • Shading: Quantity of shading was addressed previously. The new issue raised in the comments is the character of the shading. Note that the trestle currently has one continuous edge where the pedestrian walkway is located. The height of the trestle above the creek, the presence of existing large trees that filter and break up sunlight, the presence of proposed fencing that breaks up sunlight, and the complexity of the substructure all mitigate the concern that the new decking will create a cleanly defined sun/shade line. Solar access to the creek is filtered and varied by the several levels and complexity of shading elements adjacent to and above the trestle and we do not believe that impacts are significant enough to warrant a SEPA DS or a requirement for substantial mitigation. Sincerely, William (Chris) Erickson Project Manager King County Parks