January 14, 2002

Mr. Tom Niemann, Principal Planner
Snohomish County Department of Planning and Development Services
300 Rockefeller Avenue, M/S 604
Everett, WA. 98201-4046

RE: Snohomish County Mineral Lands Designation Draft Supplemental Environmental Impact Statement

Dear Mr. Niemann:

The City of Gold Bar was incorporated in 1910 and is located 28 miles east of Everett, WA. Gold Bar is nestled within the scenic foothills of the Cascade Mountain Range and has a population of 2,028.

State Route-2 is the major highway linking the City with outside communities. This highway is designated a State Scenic Route and borders the southerly boundary of the Incorporated City Limits. May Creek Road is a designated City Arterial and is located within the northerly portion of the City. First Avenue is located within the westerly portion of the City Limits and is the only connection road between SR-2 and May Creek Road. The additional City roadway system is on a grid system.

Three major waterways are located within Incorporated Gold Bar. These waterways are the Skykomish River, Wallace River and May Creek. The Department of Ecology approved the City of Gold Bar Shoreline Master Program on November 7, 2001. The Shoreline Management Act of 1971 covers all shorelines of the state, including "shorelines" and "shorelines of state-wide significance" (SSWS). Provisions of the Act apply to the shorelines, streambeds and water of streams and rivers with a mean annual flow equal to or greater than 20 cubic feet per second or more. All three of the above-indicated waterways meet this criterion. Wetlands within hydraulic continuity and the floodplains of these three water bodies also fall under the Act.

Year around recreation located within a close proximity to the City includes snow skiing, hiking, fishing, hunting, river rafting, sightseeing and bird watching. Wallace Falls State Park has thousands of visitors each year and is located approximately 4 trail miles from the Incorporated City Limits.

The City of Gold Bar would like to submit the following comments on the Draft Supplemental Environmental Impact Statement (DSEIS) for the Mineral Lands designation:

Supplemental EIS Statement:

1. (pg. 51) "The quality of groundwater in an area is related to a number of factors, including the amount of unsaturated zone infiltration and direct saturated recharge to groundwater, the storage capacity of each geologic soil unit or bedrock unit, and the volume of individual aquifer units beneath the surface. Groundwater in an aquifer may receive recharge from or discharge into other adjacent aquifers. Consistent information is not available in all areas, so this discussion is qualitative."

City of Gold Bar Response:

The City is located within Mineral Resource Analysis Region 6. A total of 4,670

acres of land is designated for sand, gravel or bedrock extraction. A large portion

of the subject land is within close proximity to the City Limits or the Boundary

Reserve Area. These lands are located within the Skykomish Watershed and

the Wallace River Watershed.

The City of Gold Bar utilizes 4 well sites to provide potable drinking water to

persons residing or visiting within its water system boundary area. These wells

vary in depth between 28 feet and 680 feet. The City does hold Department of

Ecology issued "Water Rights" for the 4 well sites. The well sites rely upon

groundwater for recharge, quantity and quality.

Will the removal of timber and overburden, to get down to bedrock, effect

groundwater recharge? Will the fracturing of rock in blasting zones

effect groundwater and aquifers? Impacts to groundwater, created by the

The overall rating of the Skykomish River Watershed is identified as <1 percent

low Sensitivity, 13 percent intermediate sensitivity, and 86 percent is high

Supplemental ESI Statement:

1. (pg. 54) "On the designated mineral lands, vegetation and soil disturbances

during mining operations could cause erosion, sedimentation and increased turbidity to downstream water bodies, including wetlands."

2. (pg. 54) "Increased sediment loads in downstream water bodies could also

lead to an increase in nutrients and other contaminants associated with the eroded sediment. In addition, mining could result in runoff with elevated levels of contaminants, including suspended solids, nutrients, heavy metals and toxic organics from mining machinery."

3. (pg. 55) "Erosion, sedimentation and pollution could negatively affect water

City of Gold Bar Response:

Olney Creek and its related watershed are located within Mineral Resource

Analysis Region 6. The City has Department of Ecology issued water rights

to utilize the Olney Creek resource. Impacts to surfacewater, created by the

Will the removal of minerals from such a vast area change the watercourse of

Because of the large amount of land designated for mineral extraction,

Supplemental EIS Statement:

1. (pg. 58) "All of Western Washington is part of the Pacific Coast conifer forest which extends from the Gulf of Alaska to the Mendocino County coast of California. On a regional scale, the natural landscape has been described in terms of broad vegetation patterns called vegetation zones by Franklin and Dryness (1988). In Western Washington and Oregon, these zones tend to be related to altitude. Snohomish County is located in the western hemlock zone, which includes the majority of the Puget Lowlands and is the most extensive zone west of the Cascades."
2. (pg. 58) "Wildlife habitat in Snohomish County has been reduced in and

adjacent to urban and suburban areas. Increasing rates of development in the past two decades have accelerated habitat decline. However, important wildlife habitat exists where relatively undisturbed tracts of land remain in native vegetation. High quality habitat usually is generally associated with steep slopes (where trees and vegetation are usually retained), rivers, streams and accompanying riparian corridors, wetlands, and open space set aside for recreational use."

3. (pg. 58) "Snohomish County supports diverse and abundant wildlife."
4. (pg. 58) "Rivers and streams in the county provide spawning habitat for populations of anadromous fish. Approximately 50 percent of the fish populations are reported to be healthy, but 30 percent are considered to be depressed. Chinook salmon and bull trout/Dolly Varden are currently listed as federally threatened species. The status and occurrence of bull trout/Dolly Varden populations in Puget Sound are subject to some scientific debate. However, Bull trout/Dolly Varden are known to occur in waters of Snohomish County (Pentec, 2000). Other anadromous and resident fish populations have been affected by reduced shading, increased siltation and pollutants, and fragmentation of stream and river habitat caused by increased urbanization of the county."

City of Gold Bar Response:

The Supplemental DSEIS states "Increasing rates of development in the past

two decades have accelerated habitat decline." Would not the removal of such a

Because of the large amount of land designated for mineral extraction,

Supplemental EIS Statement:

1. (pg. F-22) "The presence of residential development within the site and

surrounding area, in addition to proximity to the Gold Bar UGA, could be

incompatible with mining activities."

2. (pg. F-23) "The Gold Bar and Sultan areas could be susceptible to cumulative impact resulting from a concentration of mineral extraction operations in the deposit areas closest to the UGA’s."

City of Gold Bar Response:

A portion of the land proposed to be designated Mineral Lands is within close

proximity to the existing City boundaries or the City designated UGA. Mineral

Lands are best compatible when surrounded by low density zoning (pg. 16). A

large portion of the City incorporated area and the City UGA is zoned R-9600.

Identifying land for mineral extraction adjacent to high density zoning is poor

planning. A larger distance needs to be incorporated between mining activities

and the City of Gold Bar. This would allow for a gradual decrease in density

through zoning, providing compatible land use between housing and mineral

extraction.

planning process between the City of Gold Bar and Snohomish County. It

establishes revised Urban Growth Area (UGA) boundaries for the City of Gold

Bar and refines the land uses in the unincorporated area, inside and outside the

UGA. It appears that some of the proposed mineral lands encroach within areas

identified in the Urban Growth Subarea Plan. Believing the plan to be of a joint

venture the City needs a voice to any changes to the Plan.

Because of the large amount of land designated for mineral extraction,

Supplemental EIS Statement:

1. (pg. 86) "Several factors contribute to the County’s existing visual character -

1. (pg. 86) "The visual character of these communities is strongly influenced by

natural/scenic amenities and resource based industries."

2. (pg. 88) "None of the alternatives specifically or directly include aesthetic

considerations in designation."

3. (pg. 89) "On a cumulative basis, designation and conservation of mineral

lands would not have any adverse impacts on the visual quality of the surrounding area. Mining activity, however, could have negative impacts on the visual quality of the area."

4. (pg. 89) "Under any of the alternatives, mining could result in a changed in

views resulting from vegetation clearing, exposed rock, gravel and soils and alteration of the local topography. These impacts would be present for the duration of mining activity."

5. (pg. 89) "The designation alternatives do not directly consider aesthetic factors, such as views. In general, such impacts are site specific and will depend on topography, vegetation, orientation, along with individual perceptions and other subjective considerations."

City of Gold Bar Response:

The City of Gold Bar is surrounded by timberland, scenic waterways, and the

Cascade Mountain range. Highway SR-2, the only major highway located in the

City is designated as a Scenic Highway.

When the timber industry cuts trees, reforestation measure provide for future

Wallace Falls is a State Park. The DSEIS and accompanying maps indicate that

mining activities will take place within a close proximity to Wallace Fall. This

State Park should not be designated for mineral extraction.

Because of the large amount of land designated for mineral extraction,

Supplemental EIS Statement:

1. (pg. 22) "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 operations are desired because the transportation network is regarded as the basis for the mobility of goods and services. Rail transport, instead of trucks, could also be considered."

2. (pg. 22) "Specific mitigation or improvements could be required as a

precondition for development. This could include improvements that would

be required to fix an existing problem or those associated with a project deficiency."

3. (pg. 90) "Access to/from the potential mineral resource lands would primarily involve travel on the existing state highway and Snohomish County arterial system. (See Figure 9) Collector and local access roads would be used between mineral resource sites and the arterial/highway system and between the arterial/highway system and the ultimate destination for mineral products."

City of Gold Bar Response:

ADMINISTRATIVE REVIEW:

1. The City of Gold Bar requests that the Draft Supplemental Environmental Impact Statement 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.
2. Due to potentially critical impacts on water resources, flood hazards and conflict with future urban development, the City requests that land located within the watershed areas of May Creek, Olney Creek and Wallace River not be included in land designated for future mining activity.

Should you have any questions concerning these comments, please contact Public Works Director John Light at (360) 793-1101 or myself.

Sincerely,

Kenneth O. Foster

Mayor

City of Gold Bar

Cc: City Council

Planning Commission

Phil Olbrechts / City Attorney