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TACOMA
2215 North 30th Street
Suite 300
Tacoma, WA 98403-3350
253.383.2422 TEL
www.ahbl.com
February 11, 2020
Matt Herrera, AICP, Senior Planner
City of Renton
1055 South Grady Way
Renton, WA 98057
Project: Sunset Highlands Mixed Use, AHBL No. 2190210.10
Subject: Response to Muckleshoot Indian Tribe Comments dated January 22, 2020
LUA19-000290
Dear Mr. Herrera:
We are responding to your letter dated January 28, 2020, that contained comments from the
Muckleshoot Indian Tribe dated January 22, 2020, regarding the above referenced project.
The comments are included below (verbatim) for your reference. Our responses are shown in
bold after each comment.
1. Stream Typing.
Per the Critical Areas Report, the section of Honey Creek that flows along the southern
portion of the site is classified as a Type N (non-fish bearing). The report lacked
sufficient data to demonstrate this classification. In fact, based on the information
provided (i.e. bankfull width of 2 feet), at least one of the three physical criteria for
presumed fish habitat was met. The report lacks any information about any natural
barriers downstream and the streambed slope and the upstream basin area.
WDFW's current barrier map and fish distribution layer is showing fish use not far from
the site, below SR 900 and Union which is farther upstream than the City map in the
Critical Areas Report.
See https://geodataservices.wdfw.wa.gov/hp/fishpassage/index.html
The stream needs to be resurveyed to see if it meets the physical criteria for presumed
fish habitat under WAC 222-16-031 or demonstration of a natural physical barrier based
on WDFW's barrier assessment criteria.
Response: This will be addressed by the Wetland Ecologist.
2. Current stream buffer conditions.
The photos in the CAR suggests that the stream buffer on site has been totally cleared.
Is this correct? If so, isn't the project site in violation of the City's Critical Areas
Ordinance? It also seems that a buffer reduction and critical areas exemption should
not be allowed until any CAO violations are addressed including mitigation for any
temporal losses to riparian functions.
For any buffer reduction, the remaining stream buffer needs to be planted with native
trees and shrubs conducive to the soils on site. The landscape plan suggests that non-
native street trees will be planted in the buffer.
Response: We are not aware of any clearing activity or violations that have
occurred.
G+A Response: Please see attached technical memorandum.
Matt Herrera, AICP, Senior Planner
February 11, 2020
2190210.10
Page 2 of 2
3. Onsite culverts.
The site plans shows two existing 48" culverts crossing the stream. What is the purpose
of these culverts? Can they be removed as part of this project? If so, they could serve
as partial mitigation for the permanent reduction in the stream buffer and its functions. If
not, then additional mitigation will likely be needed.
Response: The existing 48-inch culverts are not within the subject property. We
have no rights to remove or alter them. We are not proposing any work inside the
existing stream. No mitigation should be required for areas outside of our control.
4. Tree removal.
How close to the stream are the two large Douglas fir trees on the western border that
will be removed (see the TIR)?
Response: One Douglas fir tree is 67 feet from the stream, and the other is
150 feet from the stream.
5. Technical Information Report.
With respect to the Technical Information Report, we offer these comments:
On page 5, there is an error. The site is within a salmon conservation plan as it is in
WRIA 8 which is a chapter of the larger Puget Sound Salmon Recovery Plan.
Response: We will update the report to note that our site is within the salmon
conservation plan area of WRIA 8.
The site's stormwater will ultimately drain to known salmon-bearing waters. The project
proposed to use enhanced water quality treatment methods for stormwater which is
good, but the project should also use oil control methods to minimize stormwater
pollutants known to adversely affect salmon.
Response: This is not a high-use site. Per the manual, oil controls are not
required/warranted. Enhanced treatment is adequate to protect the downstream
water quality.
If you have any questions, please call me at (253) 383-2422.
Sincerely,
Scott T. Kaul, PE, LEED AP
Project Manager
STK/lsk
c: Ed Sewell, Sewall Wetland Consulting, Inc.
Dale Fonk, Owner
Glenna Mahar, Graves + Associates
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