Northwest Regional Office, 3190 - 160th Ave S.E Bellevue, Washington 98008-5452 (425) 649-7000

October 3, 2000

Lara Thomas

City of Sultan

319 Main Street, Suite 200

PO Box 1199

Sultan, WA 98294

Dear Ms. Thomas:

Re: City of Sultan Industrial Park Non-Project Review Form

The purpose of this letter is to provide you with written comments regarding the above document as follow-up to comments that I have already provided the City during meetings that I have attended on this project.

Critical Areas/Wetlands/Steep Slopes, etc.: The NPRF needs to acknowledge that information regarding critical areas, including wetlands, is incomplete at this point in time. Prior wetland delineation work was done for only a small portion of the proposed Industrial Park as a part of the LID sewer corridor. Jones & Stokes, the wetland consulting firm that did the delineation work, made it clear in their January 16, 1998 Wetland Inventory Report that they evaluated critical areas, including wetlands and streams only within approximately I 00 feet along the pipeline corridor. The Wetland and Stream Delineation Report prepared for the sewer LID (dated December 23, 1998) delineated wetlands only within and a short distance beyond the 40-foot construction corridor for the pipeline. Although these reports provide the City with some baseline information regarding wetlands and streams along the sewer pipeline corridor, they are by no means sufficient for identifying other wetlands or streams/surface water drainage systems that exist within the proposed industrial park. Neither can they be considered as providing sufficient information for drawing conclusions regarding potential impacts of development to wetlands and streams within the Industrial Park (IP).

The Department of Ecology (Ecology) strongly recommends that additional wetland and stream inventory work be done within the proposed industrial park in order to get an accurate accounting of critical areas. Based a field visit that Sarah Suggs (Ecology's wetland specialist assigned to this area) and I made to the site in mid-April of this year, we believe that there are significant wetland resources that exist within the industrial park which need to be identified. We also noted the existence of several small tributaries to Wagley's Creek, which although they may seasonal in nature, need to be identified and accounted for. Until this fieldwork is done for the entire site it will be very difficult for the City to identify or evaluate potential impacts, whether direct or indirect, to critical areas within the industrial park.

Cumulative Impacts and disruption of wetland and creek hydrology: The NPRF should also address the cumulative impacts of development to Wagley's Creek and adjacent wetlands. Although specific projects have not yet been identified for construction within the IP, we can be certain that some of those projects will involve wetland fill and additional creek crossings. The proposed IP will also certainly result in increased impervious surfaces, will alter surface water flow and impact groundwater. During our field visit this May it was our observation that significant sheet flow of surface water occurs north of Wagley's Creek. This seasonal surface water provides hydrology to wetlands, Wagley's Creek and to the small tributaries that feed into Wagley's Creek. It is important that the hydrology of the site be studied and understood so that development at the site will not result in permanent disruption of surface water and shallow groundwater such that wetlands and Wagley's Creek and its tributaries are deprived of hydrology. We are concerned that the proposal to construct a road that runs parallel to Wagley's Creek (even though a buffer area is proposed) could permanently disrupt the flow of surface and ground water that provides hydrology to wetlands and to Wagley's Creek and its tributaries.

The Jones & Stokes Wetland and Stream Delineation Report states the following regarding wetland hydrology in the area:

Wetland functions may be impaired by the project: The analysis of impacts to wetlands also needs to address how the project may impact wetland functions. Wetlands perform different types of functions and to varying degrees. For example, a wetland may store a great amount of water during floods. This water storage capacity is a function the wetland performs. The functions that should be evaluated utilizing a wetland functional assessment method include, but are not limited to, water quality improvement, fisheries and wildlife habitat, flood and stream flow attenuation and recreation and aesthetics.

Wetland Mitigation and selection of alternatives: Several different land use and

transportation alternatives have been proposed for the project. Each alternative should be evaluated to determine its impacts to wetlands and other critical areas. Impacts to wetlands and critical must be compensated. It is important to note that wetland mitigation is usually defined in a series of steps that should be taken in sequential order. They are:

6) Monitoring the impacts and taking appropriate corrective measures.

Following this process is referred to as "sequencing". Ecology requires that an applicant demonstrate that they have followed this sequence in developing their project. The NPRF should discuss mitigation sequencing and should include it as a criterion for selecting a preferred alternative.

Buffers: The establishment of adequate buffers around wetlands and other sensitive areas will be important. At least one of the wetlands adjacent to Wagley's Creek is a Category 11 wetlands Ecology recommends buffers of at least 100 and up to 200 feet. Several of the other wetlands are Category III wetlands and would require buffers of 50 to 100 feet. Additionally, the National Marine Fisheries Service and the U.S. Fish and Wildlife Service may recommend larger buffers. I recommend that you consult with the federal services to get their advice regarding buffers for this project.

Floodplain issues/401 Water Quality Certification/water quality: The NPRF should address the fact that Wagley's Creek is apparently within the 100-year floodplain of the Skykomish River. This may have impacts in terms of what can be developed. I recommend that you consult with Dave Burdick of our office (415-649-7139) regarding this matter. Additionally, under the new Nationwide Permit Program (June 16, 2000) the Department of Ecology will require an individual water quality certification for any permanent above-grade fill within the 100-year floodplain.

Stormwater detention/treatment: The NPRF should discuss in more detail how stormwater will be managed. The NPRF on page 7 states that. "regional stormwater detention ponds will be integrated into this system [the Wagley's Creek corridor] using biofiltration to clean the water before it reaches the natural areas." This methodology may not be sufficient to manage stormwater. The Department of Ecology has just released its revised Stormwater Manual for Western Washington and anticipates adopting it by the end of December 2000. The Department of Ecology will require that projects meet the new standards for any individual water quality certifications that it issues for projects in the industrial park.

Stream corridor enhancement: The development of this area offers a unique opportunity to improve the habitat value of the corridor along Wagley's Creek. The Wetland and Stream Delineation Report prepared for the Sewer LID (December 23, 1998) provides a good baseline for evaluating impacts of the project to the creek. It discusses existing conditions and limiting factors along the creek. Such limiting factors include possible fish barriers, poor spawning habitat, lack of tree coverage in some areas, etc. Actions that could be taken to improve habitat along the corridor include removal of fish barriers, improvement of spawning habitat, reducing temperatures by planting shade producing trees, etc. The NPRF should discuss stream corridor enhancement and include it as a key priority of the project.

I hope the above comments are useful. As the project evolves I may submit more detailed comments on the project and its impacts.

If you have any questions regarding this letter I may be reached at 425-649-43 1 0 or at aken461@ecy.wa.gov..

Sincerely,

Ann E. Kenny

Senior Permit Specialist

Shorelands and Environmental Assistance Program

AEK:SA