LETTER FROM THE CITY OF MONROE RE COUNTY'S DRAFT EIS FOR THE COMPREHENSIVE MINERAL RESOURCE PLAN

January 7, 2002

Tom Niemann

Principal Planner

Snohomish County Department of Planning and Development Services

3000 Rockefeller Avenue, M/S 604

Everett, WA 98201

Re: DSEIS for Snohomish County Mineral lands designation

Dear Tom

The City of Monroe would like to submit the following comments on the Draft Supplemental EIS for the Mineral Lands Designation:

The summary memorandum by Huckell/Weinman Associates (dated 11/19/01, included with the DSEIS), proposes longer-term consideration of "broader policy options for incorporating potential traffic impacts into the designation/regulatory system" (pg. 2, subsection 3). It is the city’s position that such consideration cannot be put off to the longer term. It should take place now.

It is also recommended in the memorandum and DSEIS that mineral resources not be designated within Urban Growth Areas, as such designation would be inconsistent with the Growth Management Act. The designation criteria in the DSEIS (Summary, pg. 4) are intended to address proximity to residences. However, a large area immediately adjacent to the City limits on the west was identified as suitable for mineral extraction under all three alternatives. The area is located across a street (Fryelands Boulevard) from an extensive residential area containing several hundred homes, and in close proximity to a future elementary school (Monroe School District). This area has not been included in the City of Monroe’s UGA, and it is the City’s position that high-intensity development of this area, including mining operations, is incompatible with residential neighborhoods to the east and north. A second site identified in the northeast corner of the Monroe UGA is designated Residential (2-5 d.u./acre) under the Monroe Comprehensive Plan and is anticipated to develop with residences at that density upon annexation. This site also contains an area identified for park purposes.

City of Monroe representatives and residents provided extensive testimony in the Palmer Gravel Pit case regarding the impacts of mining activity on residential areas. The City is concerned that the Draft SEIS document will "set the stage" for mining operations to occur in the two areas identified above, leading to renewed conflicts between residents and mining operations. Should mining operations occur, there will be extensive truck traffic, particulate pollution, and noise impacts on neighboring residences.

On page 22 of the DSEIS (Transportation) it is stated that "based on the evaluation of impacts in this EIS, safety and traffic congestion impacts, which have a broad community-wide effect, could be relevant designation criteria. Trucks are often considered to have a higher impact on safety because of their size, weight and operational limitations. Congestion has an impact on all vehicular traffic and good operations are desired because the transportation network is regarded as the basis for the mobility of goods and services." Why are these factors not addressed in the DSEIS?

Although Snohomish County is conducting a phased SEPA process, it is appropriate

to include a "big picture" analysis of transportation impacts, particularly where the

SEIS will serve as the basis for consideration of policy alternatives for mitigation of transportation impacts associated with mineral extraction (see pg. 22-23 of DSEIS),

such as the timing of transportation improvements with mining activity. It would be appropriate to coordinate this and subsequent phases of SEPA with the preparation of a corridor plan for SR-2. We encourage and support the efforts by Snohomish County to promote funding of a corridor study for SR-2.

The City of Monroe is participating in and supports the coalition of cities that seek further dialogue with Snohomish County on the mineral lands designation process. At this time, the cities include Granite Falls, Sultan, Gold Bar, Index and Monroe. The Supplemental EIS should be withdrawn and a phased analysis of the safety and traffic congestion impacts associated with mining activity and transport should be prepared prior to re-issuance of the DSEIS. Because the initial comment period provided for the DSEIS has been insufficient to allow for a thorough analysis and response by the cities, we are requesting a 30-day extension of the comment period.

The City of Monroe requests that the Draft SEIS be withdrawn pending preparation of

a phased analysis of transportation and land use impacts associated with mineral activities. In the alternative, an Addendum should be prepared and issued for public and agency comment prior to issuance of a Final EIS. We recommend that the Mineral Lands Task Force serve in an advisory capacity for the preparation of the transportation analysis.

Should you have any questions concerning these comments, please contact Community Development Director Hiller West at (360) 863-4531 or myself.

Sincerely,

Donnetta Walser

Mayor

City of Monroe

C: City Council

Thom Myers, Interim City Administrator

City of Sultan

City of Granite Falls

City of Gold Bar

City of Index