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HomeMy WebLinkAboutSpecial 2013-09-09 Comprehensive Plan - Attachment B2 - Natural EnvironmentNATURAL ENVIRONMENT Comprehensive Plan Update Comments from July 2013 Work Sessions, Public testimony and written comments at 8/12/13 Public Hearing, and subsequent meetings with individual Council members Issue (highlighted in underline where possible Comment Date /Source Staff comment/analysis /options Concern /Issue Area /Policy Page 1 of 5 I It appears that the contracted editor did not ensure that the voice (passive vs active) in the sentence structure of the goal and policy language in this Element was consistent with other Comp Plan Elements. Recommend including an editor's note that explains why NE goal and policy structure is different from other elements and then make all Elements consistent in a year. 7/30/13 work session, CM Kruller Staff explanation: The goal and policy language structure was intentionally developed by the Tukwila Tree and Environment Advisory Committee goal statements are "end statements - i.e., where the City wants to be at some point in the future. Policies contain action verbs. Staff reviewed goal and policy language in the other Elements currently under consideration and they don't appear to be that different in the voice being used. Staff needs further direction from the Council on this issue. 2 SO /UL document. Staff should review all comment "balloons" to ensure they correctly cross reference revisions to goals and policies 7/30/13 work session; CM Kruller Staff has done this and prepared a memo (included in packet, dated August 28, 2013) with corrections or additional explanation on certain goals and policies. 3 The Natural Environment Element does a good job discussing the natural environment in Tukwila. Maps of slopes, streams (even channelized), wetlands, coal hazard areas, and any aquifer recharge areas would help residents and resident workers understand the natural features of the community, and would help identify the opportunities and challenges in development and redevelopment of your community. Dept of Commerce letter, 8/14/13 These resources are mapped on the City's Sensitive Areas map, which is too cumbersome to be inserted into the document. Instead, elcetronic links will be inserted in the document to take readers to the map on the City's website. 4 Pg. 3 of SO /UL, text, first paragraph, add "springs" after 08/21/2013, CM Robertson Staff concurs. "watercourses" on second line of paragraph. Sentence would read: "The Natural Environment Element sets forth goals and policies to guid the protection and management of wetlands, watercourses, springs, fish and wildlife areas 5 Pg. 5, of SO /UL, text, last paragraph, third line from bottom, add "snails" after "garter snakes" and before "amphibians ". Sentence to 8/21/13, CM Robertson Staff concurs. read: "Other wildlife species in Tukwila include coyotes, Eastern Grey squirrels, beaver, otter, nutria, turtules (mostly non- native red - eared sliders), garter snalkes, snails, amphibians (non- native bullfrogs, native Pacific Tree frogs, and salamanders), opossum, and raccoons." 6 Pg. 7, of SO /UL, under Climate Change. Comment: global warming will have other impacts besides sea level rises - add some discussion about temperature effects, such as the importance of trees to help mitigate heat island effects. 8/21/13, CM Robertson Staff concurs and can develop additional language to discuss increased temperature effects. 7 Pg. 8 of SO /UL, fourth paragraph - sentence referencing Corps of Engineers requirements to remove trees from levees. Clarify whether the Corps still has a role in determining what vegetation may grow on levees and on re- certification of levees. 8/21/13, CM Robertson The Corps of Engineers establishes standards for construction and maintenance of federally funded levees and also for locally funded levees to be eligible for federal assistance in the event there are repairs needed. One of the standards limits what vegetation may be planted or allowed to grow on the levees (current standard allows only grass, with provisions for variances on a case -by- case basis). The Corps does not certify levees nor does it require certification. Certification is a FEMA requirement related to mapping flood plains (i.e. if the levee is certified as meeting Corps standards it is presumed that the area served by the levee is no longer in a flood plain). 8 Pg. 11 of SO /UL, top of page, last sentence in paragraph carried over from page 10, add "and resources ", so sentence would read: 8/21/13, CM Robertson Staff concurs. "Tukwila also needs to improve the protection of watercourses and find mechanisms and resources to ensure that compensatory mitigation is successful for the long term." 9 pg. 11 of SO /UL, under Water Quality: add "springs" to the first 8/21/13, CM Robertson Staff concurs. sentence. Sentence would read: "More efforts are needed to improve and protect water quality in the City's wetlands, watercourses, springs and the Green /Duwamish River." 10 Pg. 11 of SO /UL, Water Quality, add to the last sentence in this paragraph: "therefore the City needs to make sure adequate 8/21/13, CM Robertson Staff concurs. resources are available." The sentence would read: "More efforts are needed to improve and protect water quality in the City's wetlands, watercourses, springs and the Green /Duwamish River, therefore the City needs to make sure adequate resources are available." 11 Pg. 13 of SO /UL, Policy 4.1.3, remove "existing" from second line of policy and add "fish" to the language. New policy language to read: 8/21/13, CM Robertson Staff concurs. "Identify impacts to wildlife from new development and ensure protection of existing priority fish and wildlife habitat, including Osprey and Bald Eagle nests and Chinook and Bull Trout habitat when issuing permits for development." Page 1 of 5 NATURAL ENVIRONMENT Comprehensive Plan Update Comments from July 2013 Work Sessions, Public testimony and written comments at 8/12/13 Public Hearing, and subsequent meetings with individual Council members Issue (highlighted in underline where possible Comment Date /Source Staff comment/analysis /options Concern /Issue Area /Policy 12 Pg. 16 of SO /UL, Concern that wildlife corridors have not been included in replacement policy 4.1.3. Existing Comp Plan Policy 4.2.4 reads: Protect and manage Tukwila's priority habitat areas, and habitat corridors within and between jurisdictions. 7/30/13 work session; CM Robertson A reference to wildlife habitat corridors was not included in proposed Policy 4.1.3 for several reasons: 1) Habitat corridors have not been defined or mapped. 2) the City has no means to protect habitat corridors within the city or between jurisdictions unless they are also part of a sensitive area, a park or the shoreline. The City's sensitive areas probably function as wildlife corridors for birds and small to medium sized mammals, amphibians, and other species. Examples include the riparian areas along streams and the river, large wetland complexes, and forested steep slopes such as those east of 1 -5 and along SR 518. 3) There is no regulatory authority to protect habitat corridors unless they are designated as priority habitat or provide habitat for a priority species as determined by the State. Direction is needed from the Council on whether to map wildlfe corridors and regulate them in some way. This type of mapping assessment would require hiring a wildlife biologist to identify and assess existing corridor conditions and their use by wildlife. 13 Pg. 16 of SO /UL, concern that the proposed policies under proposed Goal 4.11 (related to geological hazard areas) do not carry forward the language from existing Policy 4.3.2, particularly the issues related to costs being borne by the property owners" and requirements to implement measures to maintain slope stabiity. 8/21/13, CM Robertson Staff agrees that the new policies (4.11.1, 4.11.2, 4.11.3, 4.11.4, 4.11.5) do not completely address the current policy language. See staff comment below for Page 25 of the SO /UL document for proposed policy revision to Policy 4.11.3. 14 Pg. 16 of SO /UL, First Implementation Strategy bullet: delete "as needed" from the end of the sentence. New language would read: "Assign responsibilities for tracking climate change issues and develop recommendations for new City management policies as needed) " 8/21/13, CM Robertson Staff concurs. 15 Pg. 17 of SO /UL, sixth Implementation Strategy, remove "other ". New strategy would read (in part): " Team with other environmental organizations such as...." 8/21/13, CM Robertson Staff concurs. 16 Pg. 19, Policy 4.5.2 Add "springs" to policy. New language would read: "Recognize, protect and enhance the value of watercourse and river riparian zones, springs and other natural areas as wildlife 8/21/13, CM Robertson Staff concurs. corridors." 17 Pgs. 20 -21 of SO /UL, Policy 4.6.5, The policy needs to ensure that downstream and other drainage impacts do not occur from allowing off -site mitigation. Therefore revise the policy to read: "Allow off -site wetland mitigation only when there is greater functional benefit, no significant adverse impact to the drainage sub -basin adjacent property, 8/21/13, CM Robertson Staff concurs. and no signficant adverse impact to existing wetlands or watercourses. Preference shall be first to mitigation sites within given Tukwila's portion of the Green - Duwamish watershed, followed by sites located elsewhere in the watershed." 18 Pg. 21 of SO /UL, Policy 4.6.6: Delete this policy - we should not be allowing mitigation outside the City. "Consider allowing into 8/21/13, CM Robertson This policy and Policy 4.6.7 were included because Federal and State wetland guidance favor in -lieu fee programs to allow for larger & potentially more successful wetland mitigation sites instead of on -site mitigation at wetlands that are likely fragmented in the landscape. This policy was phrased "consider" so that the pros and cons of this approach could be fleshed out for further consideration by the Council. payment benefits will be than ecological of such actions significantly greater •• _. _ • _ - _ • • • ... .. 19 Pg. 21 of SO /UL, Policy 4.6.7: Delete this policy. "Consider creating - - - - - •• - 8/21/13, CM Robertson See explanation for policy 4.6.6 above - staff looking for guidance from Council on the issue of off -site and in -lieu fee issue. - _ _ _ _ _ _ .. _ _ _ - _ _ _ - _ _ - with King County to establish in lieu fee sites in Tukwila for wetland River shoreline." 20 Pg. 21 of SO /UL, Fifth Implementation Strategy bullet: delete "Encourage off -site wetland mitigation and "; new strategy would read: "Encourage off -site wetland mitigation and oOffer assistance to 8/21/13, CM Robertson Staff concurs property owners interestedin providing mitigation sites, where appropriate." 21 Pg. 21 of SO /UL, Sixth Implementation Strategy: Delete this strategy "Evaluate Federal State requirements for in lieu 8/21/13, CM Robertson If the Council deletes Policies 4.6.6 and 4.6.7, then deleting this implementation strategy would be appropriate. opportunities and and -- - •• • .:• :::.•• :: =• : • .•. .. .•:: -- - - County designated in Tukwila. Provide recommendations to sites decision makers." Page 2 of 5 NATURAL ENVIRONMENT Comprehensive Plan Update Comments from July 2013 Work Sessions, Public testimony and written comments at 8/12/13 Public Hearing, and subsequent meetings with individual Council members Issue (highlighted in underline where possible Comment Date /Source Staff comment/analysis /options Concern /Issue Area /Policy 22 23 24 25 26 27 28 29 30 31 32 33 34 Pg 21 and 22 SO /UL, add an implementation strategy to define and map springs. 8/27/13, CM Robertson Staff concurs and proposes placing the new implementation strategy under the heading on Page 21: "Wetlands /Watercourses /fish and Wildlife Habitat Implementation Strategies ". However, due to lack of resources, mapping will be done on the basis of information the City already has and on information that is submitted as part of development applications. Note that proposed Policy 4.8.2 requires all proposed development to identify hydrologic features on the site, including springs. Pg. 22 of SO /UL, Policy 4.7.6. Add "or fish and wildlife benefits" after 8/21/13, CM Robertson Staff concurs "water quality'. New Policy would read: Retrofit existing City surface water systems, including ditches conveying stormwater, to improve the water quality of discharges wehre there are significant water quality or fish and wildlife benefits. Pg. 23, of SO /UL, Policy 4.8.2, add "and prevent" to second sentence 8/21/13, CM Robertson Staff concurs of policy. New policy would read: "Require that all proposed development identifies hydrologic features both on- and off -site that could be impacted by the project. Evaluate and prevent project impacts on on -site and off -site watercourses, wetlands, drainage features and springs to avoid adverse impacts to existing sensitive area hydrology." Pg 23 SO /UL, Policy 4.8.3: Change "Continue" to "Perform ". New 7/30/13 work session; CM Robertson Staff concurs policy would read: Perform Continue inspection programs to ensure proper maintenance of public and private surface water management systems. pg. 24, SO /UL, Policy 4.9.4: Minimize adverse impacts to water resources by requiring the use of bioengineering and natural solutions for bank flood feasible 8/21/13, CM Robertson Staff concurs stabilization or control projects, wherever technically possible and not cost prohibitive." Pg. 24, SO /UL, Goal 4.10: The levee system south of 1 -405 is constructed, maintained and certified to meet the accreditation standards of the Federal Emergency Management Administration and 8/21/13 CM Robertson Staff concurs the City's Shoreline Master Program." Pg. 24, SO /UL, Policy 4.10.3: " Continue to wWork with the U.S. Army 8/21/13, CM Robertson Staff concurs. Addition of "Pacific NW conditions" helps emphasize that conditions and issues here differ from other areas of the country where Federal levees are located. Corps of Engineers to develop levee vegetation policies consistent with Pacific Northwest conditions that enhance habitat while at the same time protecting public safety." Pg.24 of SO /UL, Policy 4.10.4: Add to the end of the policy: "while 7/30/13 work session; CM Robertson Staff concurs. complying with Tukwila's Shoreline Master Program." New policy would read: "Coordinate with the City of Kent on flood control projects that affect both jurisdictions, while complying with Tukwila'as Shoreline Master Program." Pg. 24, SO /UL, Implementation Strategies. Change "federal" to "FEMA ". The proposed implementation strategy would read: 8/21/13, CM Robertson Staff does not concur. "Federal" does not just refer to FEMA but also to the Federal Endangered Species Act. "Regulate used, development and redevelopment, including essential facilities, in flood plains, consistent with federal FEMA regulations. Pg. 25 of SO /UL, Policy 4.11.1. Modify the policy to reflect that not all geotechnically hazardous areas are steep slopes. 7/30/13 work session and 8/21/13; CM Robertson Staff concurs. Recommended Policy 4.11.1 language would be: "Require geotechnical studies for any development proposal on slopes over 15% in areas where landslide potential is classified as Class 2, 3 or 4 to ensure that design takes into account geologic characteristics, surface and groundwater, and the presence of trees and native vegetation and their role in slope stabilization." Pg. 25 of SO /UL, Add language to the appropriate policy requiring that engineering measures identified in the studies be implemented by the applicant. 8/21/13; CM Robertson Staff concurs. Recommended proposed language in proposed Policy 4.11.3 would be: "Require that recommendations in geotechnical studies be implemented and require setbacks for buildings and other infrastructure where needed from the top and /or toe of steep slopes to reduce risks of slope failure and risks to public safety. Pg. 26 SO /UL, Second bullet, "Review and consider revising the SAO 8/21/13, CM Robertson Concur, but no code housekeeping amendments are currently in the DCD 2014 work plan. Amendments could be done in 2015. - ''e e_' Request deletion this implementation _ _ _ ." of strategy, just add to 2014 work program. Pg. 28 SO /UL, Goal 4.13: Revise goal wording to be consistent with other The would read: 8/21/13, CM Robertson Staff concurs and recommends additional modifications as follows: Change goal 4.13 to read "Overall city -wide tree canopy increased to a total of 29% by 2034. Change the "Goals for Increasing Canopy" to: "Canopy cover in goals. proposed goal Overall city -wide tree canopy for the zoning categories indicated below -has increased to 29% by 2034 e - _ _ _ _ _ wide for different land individual zoning categories increasedby 2034 as listed goals use categories: below" Page 3 of 5 NATURAL ENVIRONMENT Comprehensive Plan Update Comments from July 2013 Work Sessions, Public testimony and written comments at 8/12/13 Public Hearing, and subsequent meetings with individual Council members Issue (highlighted in underline where possible Comment Date /Source Staff comment /analysis /options Concern /Issue Area /Policy 35 Pg. 29 SO /UL, Policy 4.13.1.b. Modify paragraph 'b." as follows. Policy would read: "except for hazard trees or trees that interfere with underground or overhead utilties, prohibiting removal of any tree four inches or larger in diameter at breast height (dbh) on all undeveloped property without an approved development or other land use permit to the opportunity to some healthy trees during 8/21/13, CM Robertson Staff response: The language proposed for deletion was inserted by the Planning Commission to reflect concerns by some Tukwila property owners. Whether the policy includes this phrase or not, the goal is to work with project proponents to lay out development in a manner that allows for preserving mature, healthy trees while still permitting the allowed density to occur. provide preserve development, while the density for still accommodating allowed each site." 36 Pg. 29 of SO /UL, Policy 4.13.2: Shorten policy to end after "slopes" 7/30/13 work session; CM Robertson Staff agrees - new policy would read: Improve retention of trees on steep slopes. through modifications in regulations, the the role that trees and move remaining text of policy into implememtation strategies. ensuring evaluation of in slope stability during reviews, and by play geotechnical incentives. Two new implementation strategies providing would be added as follows: 1) Incorporate requirements in geotechnical studies to ensure evaluation of the role trees play in slope stability. 2) Develop incentives for increasing retention of trees on steep slopes. 37 Pg. 30 SO /UL, Policy 4.13.7: This policy allowing payment into a tree replacement fund may permit an "out" for not providing all required replacement trees. 8/21/13, CM Robertson Staff response: Current tree regulations (that apply only to sensitive areas and the shoreline) establish ratios for replacement of removed trees (for example in the shoreline a removed tree with a diameter of 4 -6 inches must be replaced by 3 trees). There are situations where not all the required trees should be planted on a site because it could affect the long term health of the trees, such as when space between trees or between trees and structures is inadequate. Both the current Tree Regulations and the Shoreline Regulations permit the payment into a special fund when all replacement trees cannot be accommodated on site. This proposed policy provides direction to support the existing regulations. The City has established a fund, which is utilized to purchase trees and related supplies for planting in sensitive areas and the shoreline. 38 Pg. 30 SO /UL, Policy 4.13.6. Tree topping is necessary in some cases when the trees are hazardous. Recommendation that when new regulations are developed, an exception be incorporated to allow for topping of hazardous trees. Balint. CC Hearing testimony 8/12/13 Policy 4.13.1 allows for the removal of hazardous trees (as do existing codes). It is well recognized in the industry that tree topping can actually turn healthy trees into hazardous trees. Topping is not an acceptable method of addressing hazardous trees or for lowering the height of healthy trees (lowering of tree height can be done by special methods - not topping - that will promote tree health, where there is interference with overhead utilities). Hazardous trees should be removed, or at a minimum, safety pruned by a knowledgeble arborist. Safety pruning does not encompass topping. 39 Pg. 29 SO /UL, Policy 4.13.1: SCL supports the proposed language "or trees that interfere with underground or overhead utilities" Brent Schmidt, SCL, letter to Council dated 8/9/13 Comment acknowledged 40 Pg. 30 SO /UL, Goal 4.14: Suggest adding a policy that recognizes the value of the "right tree -right place" concept. Brent Schmidt, SCL, letter dated 8/9/13 Staff concurs and proposes the following modifications to Policy 4.14.8: Develop an approved /recommended tree list for street trees, landscape perimeter planting and parking lots that recognizes the importance of the concept of "right tree, right place ", taking into account available planting space and infrastructure /utility conflicts and that considers takes into account the importance of diversity, species infrastructure conflicts,- climate conditions, canopy coverage goals, allergy issues, urban wildlife benefits, and tolerance of urban conditions. 41 Active intervention is required in some cases to make vegetation compatible with existing infrastructure...I support the development of rewards for the preservation of existing healthy trees balanced with recognition that not all existing trees are healthy or growing at locations that provide the highest benefit. Brent Schmidt, SCL, letter dated 8/9/13 Comment noted. 42 Pg. 27 SO /UL, Policy 4.12.1, PSE supports Tukwila's commitment to an urban forestry plan. Andy Padvorac, Puget Sound Energy, 8/12/13 Comment noted. 43 PSE is in full agreement that the provision of utility service needs to be balanced with environmental responsibility. PSE practices "right tree, right place" and has produced "Energy Landscaping" to guide the planting of appropriate vegetation near utility facilties. Andy Padvorac, Puget Sound Energy, 8/12/13 Staff will continue to work with stakeholders during the development of implementing regulations. Page 4 of 5 NATURAL ENVIRONMENT Comprehensive Plan Update Comments from July 2013 Work Sessions, Public testimony and written comments at 8/12/13 Public Hearing, and subsequent meetings with individual Council members Issue (highlighted in underline where possible Comment Date /Source Staff comment/analysis /options Concern /Issue Area /Policy 44 PSE would like to continue to work with the City as it moves forward with developing implementation measures Andy Padvorac, Puget Sound Energy, 8/12/13 Staff will continue to work with stakeholders during the development of implementing regulations. 45 Pg. 20 SO /UL,Policy 4.13.1.b.: PSE supports the language (originally requested by Seattle City Light) to allow removal of trees that interfere with underground or overhead utilities. PSE requests clarification of the term "interference ". Andy Padvorac, Puget Sound Energy, 8/12/13 In terms of Policy 4.13.1.b. ,examples of "interference" could be trees that have roots that are growing into sewer or water pipes, or overhead branches that are brushing up against utility wires. 46 Pg. 29 and 30 SO /UL, Policies 4.13.1.c and 4.13.7. PSE supports retaining significant trees in appropriate locations under the concept of "right tree, right place." PSE strongly supports incentives for off- site mitigation and fee -in -lieu and would like to see specific code language that applies this to trees under powerlines. Andy Padvorac, Puget Sound Energy, 8/12/13 Comment noted; staff will continue to work with stakeholders during the development of implementing regulations. 47 Pg. 20 SO /UL, Policy 4.13.4: add "utilities" to the Comprehensive Andy Padvorac, Puget Sound Energy, 8/12/13 Staff concurs with the request to add "utilities" to the definition of infrastructure. Plan definition of "infrastructure" so this policy applies to both city owned and non - city -owned infrastructure. 48 Move the following proposed implementation strategy for Policy 10.2.2 in the Southcenter Element into the Natural Environment Element as an implementation strategy. Suggested language: Develop street 8/27/13 CM Robertson Staff concurs and proposed adding this as a bulleted implementation strategy in the Urban Forestry Section of the Natural Environment Element (we propose it as the final bullet on page 33 of the SO /UL version). tree regulations that prioritize shade over ornamental needs. Page 5 of 5 September 4, 2013 City of Tukwila Jim Haggerton, Mayor Department of community Development Jack Pace, Director MEMORANDUM TO: Mayor Jim Haggerton Members of Tukwila City Council FM: Jack Pace, Director, Dept. of Community Development BY: Carol Lumb, Senior Plann ' ' Sandra Whiting, Urban Environmentalist RE: Staff Comments in Strikeout/Underline Natural Environment Element - References to Current Goals and Policies At the work session on July 30, 2013, Council asked staff to review the comments provided in the strike - out/underline (SO/UL) version of the Natural Environment Element to ensure that the revisions to Comprehensive Plan goals and policies have been explained and cross referenced correctly. Staff has reviewed all the comments and has concluded that in most cases the references in the comments are correct and that the new proposed wording accurately reflects the intent of the original policies referenced, and in some cases expands on them. This memo discusses only those comments for which staff thinks additional information or clarification is needed. Each comment in the strike - out/underline version of the Natural Environment Element is numbered, and is referenced accordingly below. g 13, SO/UL Comment CL6. Proposed language does not match exactly the existing policy language but meets the intent. Existing Policy 4.2.1 says the City will inventory, classify and designate fish and wildlife priority habitats. However, it is the Washington Department of Fish and Wildlife that designates priority species and habitat, not the City. The City has designated certain areas as "Fish and Wildlife Habitat Areas under the Sensitive Areas Ordinance (shown on the SAO Map) — they include the Green/Duwamish River, restoration areas on the river, and Tukwila Pond. Other areas that provide wildlife habitat are protected either as wetlands or watercourses and their buffers or are on public or private properties where there is existing tree canopy and little to no development. Pg. 13, SO/UL Comment CL7. Current goal related to water quality is in proposed Goal 4.7. See also proposed Policy 4.7.1 relative to maintaining water quality and proposed Policy 4.8.2 relative to downstream (i.e., "off- site ") impacts from runoff. CUSW. W: \\Long Range Projects\2014 Conip Plan Update \CITYCOUNCILWE Element - Council memo.docx 6300 Southcenter Boulevard, Suite #100 • Tukwila, Washington 98188 • Phone 206- 431 -3670 • Fax 206 - 431 -3665 September 4, 2013 Mayor Haggerton and Members of Tukwila City Council Annotated Strikeout/Underline Natural Environment Element Pg. 14, SO/UL Comment CL13. Correct references should be to proposed Policies 4.6.2, 4.6.3 and 4.6.4. Pg. 15, SO/UL Comment CL17. The proposed Policy 4.6.1 does not include any mention of projects for flood control and stormwater detention, as was stated in the existing Policy 4.1.9. Staff feels that, while ensuring that wetlands and watercourses are protected for their natural functions as stormwater and flood water retention and conveyance systems is important, carrying out flood control and stormwater detention projects in wetlands and water courses is not consistent with Best Available Science. The deletion of this aspect of the existing policy is consistent with current SAO regulations which only allow bioswales and dispersion outfalls in sensitive areas (with appropriate mitigation), as long as there are no adverse impacts to hydrology, habitat, or water quality. Creation of regional stormwater detention areas is no longer allowed in any streams or wetlands or their buffers. Pg. 15, SO/UL Comment CL25. Current policy intent is also found in proposed Policy 4.7.2 Pg. 16 SO/UL Comment CL26. The reference to protecting habitat corridors within Tukwila and between jurisdictions has not been carried over to proposed Policy 4.1.3. See discussion in Council Matrix of Comments. Pg. 18, SO/UL Comment CL 36. In addition to proposed Policies 4.2.1 and 4.2.3, part of former Policy 4.4.1 is also included in proposed Policy 4.3.1. Pg. 20, SO/UL Comment CL52. The proposed policy language does not include "development flexibility ", that was part of existing Policy 4.1.5. However, existing SAO provisions allow flexibility through buffer reductions and off -site mitigation, as well as reasonable use exceptions. Going beyond these current measures to allow even more flexibility would likely not meet Best Available Science. Therefore, this specific language was not carried over to the proposed policy. Pg. 23, SO/UL Comment CL69. Also see proposed Goal 4.10. CL/SW Page 2 of 2 09/04/2013 3:22 PM W: \\Long Range Projects \2014 Comp PlanUpdate \CITYCOUNCIL\NE Element - Council memo.doc