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HomeMy WebLinkAboutSpecial 2009-12-14 Item 3E - Shoreline Master Program (SMP) - Cumulative Impacts AnalysisCITY OF TUKWILA SHORELINE MASTER PROGRAM UPDATE Cumulative Impacts Analysis Prepared for: City of Tukwila Revised December 2009 37 38 Introduction With the assistance of a grant from the Department of Ecology, the City of Tukwila is updating its Shoreline Master Program (SMP) consistent with state guidelines (WAC Chapter 173 -26). Under the shoreline guidelines, local jurisdictions are required to evaluate and consider cumulative impacts of reasonably foreseeable future development in the shorelines of the state (WAC 173- 26- 186(8)(d)). This report assesses the cumulative impacts of development and activities in the shoreline over time under the proposed amendments to the City of Tukwila SMP and was prepared as a grant deliverable (SMA Grant No. G0600234, Task 9). At this point in time, the proposed SMP has been reviewed by Department of Ecology (a staff draft and the Planning Commission Recommended Draft SMP), the Planning Commission, and the Tukwila City Council, and Tukwila staff has made revisions to the draft as a result of the comments received and discussions carried out with the review entities. Accordingly, this analysis should be considered the final version, evaluating the proposed SMP dated December 2009. This version of the SMP is expected to be locally adopted before the end of the year and forwarded to Ecology for formal review and approval in early 2010. For the City of Tukwila, shorelines of the state in the city limits and Potential Annexation Areas (PAAs) include approximately 13.6 river miles of the Green/Duwamish River, between approximately river mile (RM) 17.3 and RM 3.7. The Green/Duwamish River in Tukwila is designated as a "shoreline of statewide significance," having a mean annual flow greater than 1,000 cubic feet per second (cfs). The purpose of evaluating cumulative impacts is to insure that, when implemented over time, the proposed SMP goals, policies and regulations will achieve "no net loss" of shoreline ecological functions from current "baseline" conditions. Baseline conditions are identified and described in the Final Shoreline Inventory and Characterization Report (May 2007); Appendix A to the proposed SMP. The proposed SMP provides standards and procedures to evaluate individual uses or developments for their potential to impact shoreline resources on a case -by -case basis through the permitting process. The purpose of this memorandum is to determine if impacts to shoreline ecological functions are likely to result from the aggregate of activities and developments in the shoreline that take place over time. The state guidelines establish that, "to ensure no net loss of ecological functions and protection of other shoreline functions and/or uses, master programs shall contain policies, programs, and regulations that address adverse cumulative impacts and fairly allocate the burden of addressing cumulative impacts among development opportunities. Evaluation of such cumulative impacts should consider: Current circumstances affecting the shorelines and relevant natural processes; Reasonably foreseeable future development and use of the shoreline; and Beneficial effects of any established regulatory programs under other local, state, and federal laws. This cumulative impacts assessment uses these three considerations as a framework for evaluating the potential long -term impacts on shoreline ecological functions and processes that may result from development or activities under the proposed SMP over time. 1 WAC 173- 26- 286(8)(d) 1 39 40 Current Circumstances As part of the City's SMP update, an Inventory and Characterization Report and Map Folio was prepared in December 2006, and was finalized in the spring of 2007 following technical review by Ecology and King County. The final report and map folio is included as Appendix A to the proposed SMP. The inventory and characterization report identifies existing conditions and evaluates the ecological functions and processes in the City's shoreline jurisdiction. The inventory included a characterization of ecosystem processes functioning at a watershed scale, as well as an inventory and assessment of conditions in all shoreline areas within the City of Tukwila and its Potential Annexation Areas (PAAs) (shown below as the "shoreline planning area The term "shoreline planning area" refers to the approximate area within the City's shoreline jurisdiction, or areas subject to SMP regulations, as shown in Figure 1. The following sections summarize baseline conditions, or current circumstances, with regard to Tukwila's shorelines. Watershed Context and Shoreline Modifications The City of Tukwila is situated in the Puget Sound Lowlands at the transition from the fresh water Green River to the tidally influenced Duwamish estuary ecosystem. Tukwila includes approximately 12.5 miles of the Green/Duwamish River. The Green River basin is part of the Green/Duwamish Water Resource Inventory Area (WRIA 9). Historically, the Green/Duwamish River drained a significantly larger area than it does today. River course changes and major engineering projects in the early part of the 20 century resulted in both the White and Cedar Rivers being diverted to neighboring basins. As a result, the overall freshwater discharge in the Green/Duwamish River has been reduced to approximately one -third of the pre- diversion era. The Green/Duwamish has undergone extensive modifications as part of past river management with the intent of reducing channel migration and limiting the extent and duration of valley flooding. Levees and/or revetments have been constructed along the majority of the Green/Duwamish River through the City of Tukwila to increase bank strength and reduce flooding. In addition, flows within the Green/Duwamish River have been significantly modified by the construction of the Howard A. Hanson Dam and installation of water diversions. These modifications have significantly reduced the severity of floods that historically covered much of the valley bottom. The condition of the current system of levees and revetments is a growing source of concern for King County and the cities involved, as many of the levees are aging and would not meet current standards for either flood conveyance or stability. 2 SeaTac international Airport r �i f r i L .0 1 3 1 Map 2 Shoreline Planning Area Legend Tukwila City Limits River Miles Shoreline Planning Area Potentential Annexation Areas t_ Reach Areas L' 1 r 14ti I Figure 1. City of Tukwila Green Duwamish Shoreline Planning Area 41 42 Biological Resources and Shoreline Functions The Green/Duwamish River within the City of Tukwila provides important habitat for several species of salmonids and other listed fish, as well as a few wildlife species, such as osprey. The entire length of the GreenlDuwamish River within the City of Tukwila has been declared "critical habitat" for the Chinook salmon and bull trout and both species are listed as threatened under the Federal Endangered Species Act. The aquatic environment within the channel is an important corridor, particularly in the transition zone from the freshwater riverine environment to tidal estuarine environment of Elliot Bay. Almost every species of anadromous fish migrates through this transition zone, making it important for providing habitat functions. The transition area generally extends from the East Marginal Way South Bridge to the city's northern limits. The transition zone has effectively been pushed upstream from its historic location due to: (1) a significant reduction (70 of fresh water flowing into the Duwamish estuary (owing to the diversion of the White and Cedar/Black Rivers), (2) channel dredging, and (3) reduction of flows as a result of the Howard A. Hanson dam. The establishment of heavy industrial uses in the transition zone has replaced wetlands and natural riparian areas with impervious surfaces, and the river banks have been replaced by armoring, eliminating edge habitat which slows flows and creating unrestrained rapid downstream flows. Spatial structure, residence time, and the habitat available for fish refugia and rearing functions in the Duwamish estuary have therefore been reduced and constrained. High densities of fish have been observed utilizing what is left of this specific habitat. At the watershed scale, overall increases in salmonid survival rates are dependent on the availability of sufficient transition zone habitat to accommodate fish while they adjust from fresh to salt water (WRIA 9 Steering Committee, 2005). Modifications to the river system have resulted in reduced levels of ecosystem functioning in the other reaches of the river flowing through Tukwila, including hydrology, water quality, riparian habitat, and in- stream habitat. Changes to hydrology focus on modified flow regime due to dam construction, diversion, and urban development. River management and levees have reduced the connection between the rivers and their floodplains, changing the spatial extent of habitats, and increasing the potential for negative water quality impacts. Disturbances to the channel banks have resulted in areas that are dominated by non native invasive species. Wood, in the form of riparian trees and in- channel wood, is generally lacking throughout the system, which negatively impacts riparian and aquatic habitats. Land Use and Public Access The majority of the upper Green/Duwamish watershed, beyond the city limits, is in managed forestland, parkland, or designated wilderness areas. Agricultural land covers much of the upper watershed within the Green River gorge. The Kent -Auburn Valley is a transitional area between the forest and agricultural activities upstream to the highly developed residential, industrial and commercial development in the cities of Kent, Tukwila, and Seattle downstream in the Lower Green Duwamish River Valley. Within the valley, industrial, commercial, and residential land uses dominate the former Green River floodplain in the vicinity of Tukwila. South of the city, commercial and warehouse /industrial land uses dominate on the right bank in the City of Kent, with agricultural fields on the left bank within the Tukwila South potential annexation area. Commercial development is prevalent between the southern city boundary and I -405. Residential development dominates between 1 -405 and the I -5 Bridge. North of the I -5 Bridge to the Turning Basin, residential uses give way to commercial uses. The Turning Basin, located at river mile 5.8, is the approximate southern boundary of the predominantly industrial area that extends to the northern city limit. 4 There are significant public access opportunities for enjoyment and use of the Green/Duwamish River in Tukwila. A series of parks and open space areas provide recreational opportunities and the Green River Trail provides access along the river throughout much of the city, linking many shoreline parks. In addition, there are several unofficial recreational fishing sites and fishing shelters at various locations along the shoreline. Restoration Opportunities The inventory and characterization provides an assessment of shoreline functions and identifies potential conservation and restoration opportunities. As part of the SMP update process, the City also developed a Draft Shoreline Restoration Plan in February 2007. The plan report was revised in May following technical review by King County and Ecology. It was modified in 2009 to update the status of restoration projects and include some newly identified projects and is included as Appendix B to the proposed SMP. The Restoration Plan builds on the Inventory and Characterization Report and provides a framework to: Identify primary goals for ecological restoration of the Green/Duwamish ecosystem; Identify how restoration of ecological function can be accomplished; Suggest how the SMP update process may accomplish the restoration of impaired shoreline functions associated with the Green/Duwamish ecosystem; and Prioritize restoration projects so that the highest value restoration actions may be accomplished first. Past work which focused on the Green\Duwamish River (in Water Resource Inventory Area (WRIA) 9) has resulted in an important collection of data used to identify potential restoration opportunities. Significant restoration activities along the Green\Duwamish River are already underway in the form of the multi agency Green River Ecosystem Restoration Project. Several restoration opportunities have been identified as part of the WRIA 9 Final Salmon Habitat Plan and the recently adopted King County Flood Hazard Management Plan. Based on the key ecosystem functions that are currently altered, there appear to be two specific types of restoration actions that will most benefit the Green/Duwamish ecosystem in Tukwila. While these projects are intended to restore many ecosystem functions, the restoration activities will occur in the highly -urban valley bottom, and as a result, cannot fully achieve pre disturbance channel conditions. In addition, some restoration actions must occur at the watershed scale, which will restore ecosystem functions that cannot be addressed solely within Tukwila. Enlarging channel cross sectional area. This action will increase flood storage, allow for more stable Levees, restore floodplain area, provide a larger intertidal zone in the important transitional area, and provide a more natural transition from aquatic to upland habitats. This action could include the use of setback levees and revetments, and the excavation of historic fill or floodplain materials to create back channels. Enhance existing habitats. This action will improve the functioning of the existing aquatic, riverine wetland, and riparian habitats that currently exist along the Green/Duwamish River. These actions could include the removal of non native invasive vegetation, installation of native riparian vegetation, and installation of LWD below ordinary high water. The Restoration Plan identifies over 20 site specific projects that are in various stages of development. The projects generally address one or both of the types of actions described above. High priority projects will 5 43 44 typically address both hydrologic and habitat ecosystem functions; have opportunity for multiple funding sources; include freshwater tributary channels; and /or not require additional property acquisition. In the context of designating shoreline environments and developing management policies and regulations, the City wants to encourage and enable restoration projects throughout the city wherever possible, with a particular focus on projects in the transition zone. Potential Use Conflicts Two key issues illustrate potential use conflicts and constraints to implementing restoration in Tukwila: 1) levee maintenance and management; and 2) existing development patterns and anticipated redevelopment. Discussion of shoreline planning for the Green/Duwamish River in Tukwila must acknowledge the fact that, in light of the existing system of levees and revetments, the City cannot act alone. There are a variety of regulatory jurisdictions outside of the City with different responsibilities for maintenance and management of the levee system, including the U.S. Army Corps of Engineers (the Corps), the Federal Emergency Management Agency (FEMA), King County River and Floodplain Management Unit (acting as part of the Green River Flood Control Zone District), and private property owners. The City of Tukwila Public Works Department has overall responsibility for maintenance of all levees including the federally certified levee, which extends from about the I- 405 crossing to S. 180 The actual maintenance work on the levees is contracted by the City to King County. The restoration of native tree and shrub species along the levees would increase riparian habitat and ecological functioning of this reach of the Green/Duwamish River, benefiting salmonids as well as other species. However, along the federally certified levee the Corps of Engineers (responsible for certifying the federal levee) has been requiring removal of large trees to prevent what the Corps considers destabilization of the levee caused by the root systems, potential water piping (e.g., water infiltrating into and through levees along root pathways at higher rates than it could through root free soil) at high flows, and levee failure if trees fall. For the Vegetation Free Zone of the levee, current Corps guidance only allows grass as vegetative cover on the levees (USACOE, Engineering Manual 1110 -2 -301). Current guidance also specifies a root -free zone where plantings can occur, but roots will generally not penetrate this structural zone. Therefore, under current regulations, to meet the requirements for federal levee certification, some existing vegetation will continually have to be removed to maintain the levee certification. Under the SMA, removing trees and vegetation from the riparian zone of shorelines of the state is in conflict with policies for vegetation conservation and enhancement. A possible solution is to set back and re- slope the levees to create benches where vegetation can be planted that will not interfere with the levee prism as the levee system is reconstructed to improve its stability. This would require additional easement area beyond the existing maintenance easements that have been acquired along the length of the system. The existing development pattern also represents constraints to implementing restoration projects, including levee setbacks, off channel habitat restoration, wetland and stream restoration, and riparian zone enhancements. Most of Tukwila is fully developed with a dense, urbanized land use pattern along the river bank. The City's current SMP, in place since 1974, establishes a 40 -foot setback from the mean high water line. In areas where King County's SMP still applies, a 20 to 50 foot setback is established, depending on the type of use. In many places, there is little more than this 20 to 40 -foot zone that is not intensely developed. Some places have more open space and less development and thus have greater flexibility to accommodate potential habitat restoration actions. The City's vision for future land use includes maintenance of existing urban development and further development of its urban character, particularly its identity as a regionally significant center for manufacturing, industrial, and commercial development, as well as treating the river as more of an amenity than in the past. One challenge for the City is in determining how best to accommodate new development and redevelopment near the 6 shoreline in a manner consistent with the many competing goals of the GMA and SMA and their accompanying local documents, the Comprehensive Plan and the Shoreline Master Program. Reasonable Foreseeable Future Development and Use For the purposes of the cumulative impacts analysis, this section focuses on the effects of anticipated development and use of the shoreline as envisioned in the City's Comprehensive Plan and the proposed SMP. Since the existing development pattern in Tukwila is well established and highly urbanized, the focus of this discussion is on potential redevelopment throughout much of the city. That is, there are few vacant parcels along Tukwila's shorelines and virtually no potential for large areas of undeveloped land along the shoreline to be subdivided and newly developed. One exception is the Tukwila South Potential Annexation Area, which is currently agricultural and/or undeveloped land. While this section addresses anticipated future development and redevelopment, the subsequent sections address how such development would occur under the proposed SMP. Comprehensive Plan The Comprehensive Plan Land Use Element is divided into several elements, including three that specifically address different geographic areas of the City: the Manufacturing/Industrial Center, Tukwila Urban Center, and Tukwila South. Additional planning efforts for these areas include master plans, planned actions, and/or strategic implementation plans. From the upstream City boundary downstream to the Black River Green River confluence within the city limits (S. 204 Street to the north boundary of Ft. Dent Park), the Comprehensive Plan designates areas along the shoreline as Tukwila Urban Center and Commercial /Light Industrial (predominantly south of I -405). North of I- 405 in this reach, designations include a mix of Low Density Residential, Medium Density Residential, Regional Commercial Mixed Use, Commercial/Light Industrial, and Heavy Industrial. Significant portions of Low Density Residential areas within the reach's shoreline area are designated with a Public Recreation Overlay and are developed as Fort Dent Park, the Foster Golf Links and the Tukwila Community Center. Within the City's southern PAA, along the western Green River shoreline, all areas are designated as Tukwila Valley South. The Comprehensive Plan element generally envisions an extension of the commercial and industrial development on the valley floor for this area. From the Black River Green River confluence downstream to the northern city limits near the 16 Avenue S. bridge, the Comprehensive Plan designates areas along the shoreline as a mix of Manufacturing Industrial Center/Heavy and Low Density Residential. Other designations include Manufacturing Industrial Center/Light, Commercial/Light Industrial, and Residential Commercial Center. Tukwila Manufacturing /lndustrial Center The Tukwila Manufacturing/IndustriaI Center (MIC) is one of eight regionally significant industrial and employment centers in the Central Puget Sound region. Designated as such by the Puget Sound Regional Council, the City has developed a specific element in its Comprehensive Plan and an Implementation Plan to guide redevelopment in the area. The Implementation Plan is structured as a Planned Action under SEPA and was adopted in 1998. This element was developed consistent with the Comprehensive Plan and has been integrated as a component of the City -wide SMP Update. The element includes innovative approaches to combine shoreline redevelopment with environmental conservation, restoration, or enhancement actions. The plan also provides guidelines for integrating habitat enhancement with alternative bank stabilization designs, based in part on King County flood reduction policies and guidelines for bank stabilization. The MIC Plan will be reviewed for any needed amendments after the current SMP update is completed. 7 45 46 Redevelopment in the MIC is also subject to design guidelines developed in 1992 by the Boeing Corporation, in coordination with the City, and described in Duwamish Corridor Redevelopment Proposal /Design Guidelines (Sugio Kobayashi Ullman Inc., 1992). The document, which became part of the MIC Planned Action, establishes goals, objectives, and guidelines for redevelopment of Boeing properties in the Duwamish corridor. Objectives include enhancement of the shoreline environment by replacing old riprap bulkheads with new, more environmentally friendly retention structures and native riparian vegetation. The plan also promotes increased public access as redevelopment occurs, primarily as public and employee -only (semi public) access features and public shoreline access trails. Finally, the plan addresses remediation actions so that as redevelopment occurs, sites with contaminated soil and groundwater are identified and clean up plans are developed, consistent with state and federal laws. As this document is 14 years old, the City will be working with the Boeing Company to identify any needed amendments or revisions to the Redevelopment Proposal after approval by Ecology of the SMP update. Tukwila Urban Center Plan The Comprehensive Plan includes an element addressing the Tukwila Urban Center. The City is currently preparing a Tukwila Urban Center Plan. The Urban Center serves as a regionally significant shopping center (including Westfield Southcenter Mall) with light industrial, office park, and transportation oriented development. The center is generally bounded by I -405, I -5, South 180 Street, and the Green River. Policies and implementation strategies for the Urban Center promote mixed -use commercial and residential development near the Green River, with an integrated network of park, trail, and recreational facilities. Tukwila South The Comprehensive Plan includes an element addressing Tukwila South, an area bounded generally by South 180 Street, I -5, the Green River, and South 204 Street. This area is approximately 75 percent of the southern designated potential annexation area in unincorporated King County, which will be annexed by the City effective December 31, 2009. Currently the area is primarily a mix of agricultural and vacant lands, with a small amount of residential and industrial uses. The Comprehensive Plan element, prior to the adoption of the Tukwila South Master Plan, generally envisioned an extension of the commercial development on the valley floor for this area. As elsewhere in the City, the Comprehensive Plan promotes mixed -use densities for residential development near the river, and maintenance and enhancement of the open space network along the Green River. The Tukwila South Master Plan, required by the Comprehensive Plan prior to any significant development and annexation of the Tukwila South Area, was adopted by the City Council in June 2009. In July 2005, a Final EIS was issued for the 498 -acre Tukwila South Project. The adopted Tukwila South Development Agreement allows up to 10.3 million square feet of development. The development is envisioned to create a major new employment hub with campus -style office and research complexes with an array of commercial, retail, residential, hotel, and recreational uses included. The master plan, described in the Final EIS as being in accordance with the vision and policies of the Tukwila South component of the City's Comprehensive Plan, expects to develop over two phases: Infrastructure Development Stage (3 years) and Full Buildout Stage (horizon of 2030). The Infrastructure Development Stage would include the extension of major roadways (such as Southcenter Parkway) into the area, establishment of site grades throughout the area, installation of utilities and stormwater control facilities, and construction of sensitive areas mitigation as required for the master plan. 8 The Draft Sensitive Area Master Plan (SAMP) and the Fisheries and Wetland Mitigation Plans, included as an appendix to the Final EIS and required because the site was designated a Sensitive Areas Master Plan Overlay District, describe mitigation and restoration of sensitive areas within the Tukwila South Area. These components of the Tukwila South project will be located partially within shoreline jurisdiction and are proposed primarily as mitigation for wetland and stream fill impacts elsewhere on the project site. The plans propose to create 7 -acres of off channel habitat along the Green River, which is direct mitigation for filling of 7,127 feet of streams and ditches in the Tukwila South project area (Ecology "401" Water Quality Certification Permit, 11/7/2005). The habitat area would be designed to provide summer rearing, winter refuge, and upstream migrant holding habitats for fish. Eight- hundred lineal feet of the existing levee would be relocated in a curved fashion landward, between South 196 Street and South 200 Street. Approximately 4.5 acres on the river -side of the relocated levee would be excavated down to the bed elevation of the Green River to create open water habitat. The remaining 2.6 acres would be upland area with slopes ranging from 3:1 to 8:1 and would be planted with a mixture of palustrine emergent species and shrub scrub species. Woody debris snags would be anchored at the upper and lower ends of the restoration area to protect the downstream bank from erosion and to prevent sand bar formation from creating an isolated pool. The plans also propose to restore a perennial fish- bearing stream currently maintained as an agricultural ditch (Johnson Creek). The creek currently discharges to the Green River through a fish blocking floodgate. Around 1,350 feet of Johnson Creek would be relocated to a newly constructed meandering channel and associated floodplain parallel to and north of S 204 Street. A riparian area along the stream would be planted with a mixture of palustrine emergent species, shrub scrub species, and trees. Large woody debris would be anchored to the banks to provide in- stream structure and water velocity modification. A fish- passable flood gate would be installed at the confluence of the Green River to allow fish to migrate through the culvert in the levee and into the tributary under most flow conditions. In June 2009, the City of Tukwila and the Tukwila South Project property owner (La Pianta LLC) entered into a development agreement (Ordinance No. 2233). The development agreement stipulates that the property owner grant permanent easements to the City for maintenance access and improvements to the City's levee system on the west side of the Green River between South 196 Street and South 204 Street, as well as for public bicycle and pedestrian trail access. One of the main purposes of these easements is to make room for future levee improvements. The federally certified 205 levee (from South 180 Street to South 196 Street) is not expected to be altered. As part of the Tukwila South development, La Pianta is proposing to replace the King County- constructed levee system (from South 196 Street to South 204 Street), with a levee designed to meet criteria for federal certification. The existing east -west trending Cross Valley Levee would also be shifted southward from its existing location to the south end of the project area just north of and roughly parallel to South 204 Street. In the context of "reasonably foreseeable future development," the proposed changes at Tukwila South may improve riverine ecological functions by providing off channel habitat restoration along the Green River. However, it is important to note that the foreseeable changes in the Tukwila South project area will not result directly from provisions or regulations within the proposed SMP. The proposed changes will result primarily from the following: Mitigation required by Department of Ecology through the "401" Water Quality Certification and the US Army Corps of Engineers through the "404" Permit (to fill wetlands), 9 47 48 Identification of the Tukwila South area as a Sensitive Area Master Plan Overlay District with area -wide implementation of the sensitive areas ordinance, SEPA environmental review processes, and The development agreement between the City and the property owner. Summary of Conditions and Findings In summary, the City's shoreline planning areas are primarily designated for industrial/manufacturing and commercial/retail land uses. Other areas are primarily designated for low- density single- family uses. Public access and recreational uses along the shoreline are located throughout the city. These uses are not expected to change over time. Most of the City's shorelines are fully developed and future development activities on these properties would largely occur as redevelopment. The inventory and characterization and restoration planning elements of the SMP update should inform goals, policies, regulations, and environment designations. In this context, the key findings can be summarized as follows: The Green/Duwamish River throughout Tukwila is a critical resource, providing migratory habitat for numerous fish species, as well as riparian habitat for a variety of wildlife. The Green/Duwamish River changes from fresh to salt water within Tukwila, making it a unique and important section of the overall river system that deserves attention. Existing shoreline habitat is largely homogenous and degraded throughout the city. The variation that does exist is typically not significant enough to warrant different levels of protection or restoration focus along the shoreline with the exception of the transition zone. The flood protection system is made up of a mix of newer levees (e.g., the 205 levee), and older portions of levee (e.g., the northern portion of the city). The older levees may not meet current engineering standards in terms of slope angles and geotechnical stability, which may provide opportunities for different approaches to redevelopment. Restoration opportunities exist throughout Tukwila's shoreline environment. Activities that provide restoration of both floodplain functions and habitat functions should be prioritized. Policies should promote and regulations should enable the City to accomplish restoration goals and actions. Given the relative homogeneity of the resource condition and needs throughout the city, environment designations should reflect the distinction in current and planned land use and opportunities to expand or enhance restoration. Primarily this is a distinction between existing residential development, where banks may be armored with bulkheads or revetments, and commercial and industrial development elsewhere in the city, where banks are altered by flood control structures. It is important to acknowledge that future shoreline use patterns should not be driven solely by the Comprehensive Plan and zoning. As a result of the SMP update process, changes may be warranted in the Comprehensive Plan, zoning code, and floodplain management regulations to help facilitate long range planning objectives for shoreline management (such as implementation of levee setbacks). That is, since the proposed SMP amendments are informed by a body of technical and scientific shoreline analyses consistent with state guidelines, future amendments to other regulations may be necessary to successfully implement the SMP's vision. The following sections summarize the most significant proposed changes to the Tukwila's SMP and how these changes reflect the findings of the inventory and characterization and restoration planning efforts. 10 Summary of Proposed SMP Amendments Existing Regulatory Framework The City's current SMP designates all shorelines as "Urban." At the time the 1974 SMP was developed, all of the land in Tukwila's shoreline jurisdiction was either zoned industrial or was developed with urban uses. The SMP defines the Urban Environment as "areas to be managed in high intensive land uses, including residential, commercial, and industrial development and accessory uses, while providing for restoration and preservation to ensure long -term protection of natural and cultural resources within the shoreline" (Tukwila, 1974). The SMP further states that the management objectives for the shoreline "are directed at minimizing adverse impacts on the river and shoreline ecology, maximizing the aesthetic quality and recreational opportunities of the river shore, and recognizing the rights and privileges of property owners" (Tukwila, 1974). Within the Urban Environment, Tukwila's SMP employs a three tiered system of regulations based on the distance from the Green River mean high water mark (MHWM). These tiered management zones are generally described below and illustrated on Figure 2: River Environment/Zone: a 40 -foot wide zone extending landward from MHWM and having the most environmentally protective regulations; Low Impact Environment/Zone: the area between the River Environment and 100 feet from the MHWM; and High Impact Environment/Zone: the area between 100 and 200 feet from the MHWM. 200' LOW IMPACT ZONE Proposed Environment Designations RIVER ZONE 11 200' URBAN ENVIRONMENT 100' 4 a' RIVER ZONE c LOW IMPACT ZONE MEAN HIGH WATER LINE Figure 2. Tukwila SMP Shoreline Management Zones (1974 SMP; TMC 18.44) HIGH IMPACT ZONE The City also administers the King County Shoreline Master Program for the areas which have been annexed since the adoption of the City's SMP. These areas are designated Urban and the setbacks from Ordinary High Water Mark vary from 20 feet to 50 feet depending on whether the use is water dependent, single family or commerciaUindustrial. Tukwila's proposed shoreline designation system reflects the state's guidelines. The City's three proposed environment designations are: 49 50 Shoreline Residential Environment; Urban Conservancy Environment; and High Intensity Environment. The City proposes to designate river buffers to replace the current system of parallel shoreline management zones. Instead of the current River Environment, a minimum river buffer would be established for each shoreline environment. Allowed uses are proposed for the buffer area along the river and outside of the buffer in the remaining shoreline jurisdiction. This system is intended to facilitate the City's long -range objectives for land and shoreline management, including: 1. Ensuring no net loss of ecological shoreline functions; 2. Providing for habitat protection, enhancement, and restoration to improve degraded shoreline ecological functions over time and protection of already restored areas; 3. Allowing continued and increased urban development outside of the buffers in recognition of Tukwila's role as a regionally significant industrial and commercial center; and 4. Providing for improved flood control in coordination with King County and the Army Corps of Engineers. The proposed shoreline environment designations and their associated buffers are illustrated in Figures 3 through 5 and described briefly below. Designation criteria, management policies, use regulations, and development standards for each designation and management zone are in the proposed SMP. Shoreline Residential Environment This environment would be designated in the area between the ordinary high water mark and 200 feet landward for all properties zoned for single family use (see Map 3 of the proposed SMP). The purpose of the Shoreline Residential Environment is to accommodate urban density residential development, appurtenant structures, public access and recreational activities. In addition to general shoreline management objectives (above), the protective river buffer would limit development to accomplish the following objectives (not listed in order of priority): Ensure "no net loss" to shoreline ecological functions; Help protect water quality and habitat function by limiting allowed uses; Protect existing and new development from high river flows by ensuring sufficient setback of structures; Promote restoration of the natural character of the shoreline environment; and Allow room for reconstructing over steepened river banks to achieve a more stable slope and more natural shoreline bank conditions and avoid the need for shoreline armoring. The width of the buffer will be determined by identifying the location where the river bank would achieve an angle of 2.5:1 (the natural angle of repose to promote more stable banks) and then setting back 20 feet from that location. However, in no case shall the buffer be less than fifty (50) feet from the OHWM, measured on the horizontal. The river bank in the Shoreline Residential Environment is typically in a somewhat modified and degraded state but generally not stabilized with revetments or levees. This buffer width will protect shoreline functions, and allow for restoration by re- sloping and stabilization using bioengineering methods where possible and through planting with native vegetation. The buffer area and vegetation requirements established for the Shoreline Residential Environment will allow removing invasive plants; planting native vegetation; include other 12 features to improve shoreline habitat; and will prevent the placement of any structures in an area that could potentially prove instable. The proposed buffers are wider than those currently required under the existing SMP. A cross section illustrating the proposed Residential Shoreline Environment and buffer is provided in Figure 3. Urban Conservancy Environment 200' Shoreline Residential Environment Ordinary High Water Mark z Figure 3. Schematic of Proposed Shoreline Residential Environment The proposed Shoreline Residential environment would be applied to approximately 14 percent of the city's shoreline. Counting both banks, this represents approximately 3.5 miles of shoreline. This designation would apply to areas currently within the city limits, affecting approximately 200 residential parcels. Approximately 67 residential parcels have existing structures within 50 -feet of the OHWM. The proposed SMP provisions ensure that the "no net loss" standard will be met because: 1) much of the residential development already exists and is located within 50 to 100 feet of the OHWM; and 2) the banks are in a somewhat degraded and altered state (oversteepened; armored in places; and lack native vegetation). The provisions for bank restoration and vegetation enhancement or restoration will be triggered in the Shoreline Residential environment if development or redevelopment includes proposals for bank stabilization or overwater structures. Whether the actual buffer distance on individual parcels becomes the minimum 50 -feet, or something greater after bank reconfiguration, the proposed SMP provisions will ensure that vegetation and bank stability will be improved immediately adjacent to the river. These changes in the shoreline would occur incrementally over time and would not only meet the "no net loss" standard, but should improve ecological functions over time. This environment begins at the Ordinary High Water Mark and extends landward 200 feet along portions of the river not navigable to large water craft and that are not located in low- density residential areas (see Map 3 of the proposed SMP). The Urban Conservancy Environment areas are currently developed with high intensity urban multifamily, commercial, industrial and/or transportation uses or are designated for such uses in the proposed annexation areas. The Urban Conservancy Environment will also be established along Fort Dent Park as this site is bordered by a County constructed levee. However, uses will be restricted immediately adjacent to the river by establishment of a minimum protective buffer intended to protect and restore ecological functions where they exist in urban and developed settings while allowing a variety of compatible uses. 13 51 52 In addition to general shoreline management objectives, the river buffer would be established to accomplish the following objectives (not listed in order of priority): Protect existing and restore degraded ecological functions of the open space, flood plain and other sensitive lands in the developed urban settings; Ensure no net loss of shoreline function when new development or redevelopment is proposed; Provide opportunities for restoration and public access; Allow for adequate flood and channel management to ensure protection of property, while accommodating shoreline habitat enhancement and promoting restoration of the natural character of the shoreline environment, wherever possible; Avoid the need for new shoreline armoring; and Protect existing and new development from high river flows. The width of the buffer in the Urban Conservancy Environment is proposed as 125 feet, if the shoreline has an existing levee located south of I -405; or 100 feet, if there is no levee. The establishment of the 125 foot buffer along the shorelines with levees south of I -405 allows sufficient room for eventually setting back the levees to a 2.5:1 slope, and including a mid -slope bench that can be planted with native vegetation. This approach widens the channel somewhat to accommodate high flows and improves shoreline function by providing vegetation for habitat enhancement. As the Corps of Engineers does not permit planting on the levee prism, the only way to improve habitat along the 205 leveed portion of the river is to create a bench that can be vegetated that will not create a hazard for the stability of the levee. This levee configuration is the minimum levee profile under the proposed SMP and is the approach currently used by King County and the Corps of Engineers for levee repair /replacement projects. As an alternative to the 100 foot buffer, a buffer reduction of up to 50percent may be authorized if the property owner chooses to lay back the bank to achieve a more stable slope of 2.5:1 plus a 20 -foot wide area at the top of the bank and plant it with native vegetation in accordance with the buffer vegetation standards in the proposed SMP. A cross section illustrating the proposed Urban Conservancy Environment and buffer for leveed areas is provided in Figure 4. 14 200' Urban Conservancy Environment AJIow rotiO .:fur Levee repair replacement; 1_ Ordinary High Water Mark 15 125' Buffer I Figure 4. Schematic of Proposed Urban Conservancy Environment for Areas with Levees The proposed Urban Conservancy environment would be applied to the majority of the city's shoreline (approximately 73 percent). Counting both banks, this represents approximately 18.2 miles of shoreline. This designation would apply to areas currently within city limits and in the Tukwila South PAA, affecting approximately 277 parcels. The designation would apply to areas currently developed with commercial and light industrial uses, as well as less intense uses such as the Foster Golf Links course, Fort Dent Park, and the Tukwila Community Center property. The proposed SMP provisions ensure that the "no net loss" standard will be met because the buffer area (100 to 125 -feet from OHWM) will allow for bank reconfiguration and/or setback levees with vegetated benches. The provisions for bank restoration and vegetation enhancement or restoration will be triggered as development or redevelopment occurs in the Urban Conservancy environment. Whether the actual buffer distance on individual parcels becomes 100 or 125 feet, or something different after bank reconfiguration at a slope of 2.5:1, the proposed SMP provisions will ensure that vegetation and bank stability will be improved immediately adjacent to the river. Even with a buffer reduction in exchange for re- sloping/laying back the bank and planting with native vegetation, resulting buffer widths would be wider than those required under the current SMP. These changes in the shoreline would occur incrementally over time and would not only meet the "no net loss" standard, but should improve ecological functions over the long term. High Intensity Environment This environment will be designated in the area between the Ordinary High Water Mark and 200 feet landward for the area of the shoreline located from the southern end of the Turning Basin north to the City limit (including the City's North PAA) (see Map 3 of the proposed SMP). The High Intensity Shoreline Environment area is currently developed with industrial uses, a few of which are water dependent uses. Some areas of the shoreline in this environment are hardened with riprap or bulkheads, while other areas are more natural banks, such as those in the three restoration sites around the Turning Basin. The purpose of the Urban High Intensity Environment is to provide for high intensity, commercial, transportation and industrial uses while encouraging water dependent uses, protecting existing shoreline ecological functions and restoring ecological functions in areas that have been previously degraded. In addition to general shoreline management objectives (above), the river buffer would be established to accomplish the following objectives (not listed in order of priority): Protect existing and restore degraded ecological functions of the open space, flood plain and other sensitive lands in the developed urban settings; 53 function when new development or redevelopment occurs; Ensure no net loss of shoreline public access; while ortunities for restoration and p rotection of property, Provide opp management to ensure p adequate flood and channel manag and promoting restoration of the natural character oft the Allow for adeq p accommodating shoreline habitat enhancement shoreline environment, wherever possible; Avoid the need for new shoreline armoring; and h river flows• his consistent with ment from g This buffer width support salmonld Protect existing and new develop high water mark. Areas Ordinance for Type 2 streams that th is e City's Sensitive Ar river bank to improve shoreline function over The buffer will extend 100 feet landward from the ordinary the T re-vegetating t the buffer width ows established for setting back and re -veg fish use, back the bank to existing conditions. if the property owner chooses to lay percent may be authorized planted area lay n the to 50 p vegetation plus an additional p -feet wide A buffer reduction of up e and plant it with native veg no steeper than a 3:1 slop top of the new bank. rovided in Figure 5. t h e p High Intensity Environment and buffer is p A cross section illustrating t p ,I 1 1 200' I 1 High i ntensity Environment I I k 10C' Yw.,. `I Alto roam a 1:��i,, a�;.�. {.�,xra;- reconfigure 'h',. .1 Bu{ l -i ,y, R Shea l s bank to river 3 :1 slope Ordinary High Water Mark Figure 5. Schematic of Proposed High Intensity Environment F ►g 13 percent of eline• lied to approxima p t of would apply el areas High Intensity environment would be applied ercen the city's shoreline. miles of shoreline. This design designation The proposed Hig approximately 3.1 m arcon would design Counting both banks, this represents app ern PAA, affecting approximately 34 parcels. arcels. These properties are within the in limits and in the g Northern ro osed SMB Basin. The provisions ensure that the currently the Manufacturing and Industrial Center, north of the Turning for bank would apply e a in th will allow triggered ed primarily with industrial and commercial (1�0 feet from OHWNI) or restoration will be trigg currently develop P vegetation enhancement o ions for bank restoration and veg environment. nt. enhancement the actual on buffer distance on "no net loss" standard will be met because the buffer si slope of 3:1, the reconfiguration. The pro h Intensity reconfiguration at a p r 00f occurs in the different after bank improved immediately adjacent to individual development is or redevelop k stability will be imp rosed MP p r becomes will feet, that something ve getation visions will ensure that veg and ban proposed SMP pro percent buffer reduction, resulting buffer widths will be wider than those currently the river. Even with a 50 p 54 16 required under the existing SMP. These changes in the shoreline would occur incrementally over time and would not only meet the "no net loss" standard, but should improve ecological functions over the long term. Changes to Development Standards and Use Regulations The preference for water dependent or water related uses established in the Shoreline Management Act requires a body of water that is navigable and accessible both to businesses and the general public. The challenge for Tukwila's SMP is that very little of the Green/Duwamish River is navigable for commercial vessels. Of the 13.6 river miles in the City and its PAA, only approximately 1.5 river miles are accessible to deep draft vessels, from the Duwamish River Turning Basin north to the city limits. The vast majority of the river can only be accessed by kayaks, or small motorized boats and definitely not larger ships or barges. In addition, the presence of recently re- certified U.S. Army Corps of Engineers (COE) levees along a major portion of the river prevents direct access to the river, other than via visual access and pedestrian/bicycle trails, thus further limiting the possibility for establishment of water- dependent uses. Other portions of the shoreline are protected by King County constructed levees or over steepened banks armored with revetments, which also limit the possibility of water dependent uses. Nonetheless, water dependent uses are designated as priority uses north of the Turning Basin. The proposed SMP offers several changes to the development regulations that encourage shoreline conservation, facilitate shoreline restoration, and prohibit activities that would cause adverse impact to shoreline functions and processes. The most significant change is related to provisions within the proposed river buffer. The restoration plan identifies vegetation enhancement or restoration as one key priority for shoreline management in Tukwila and the development standards proposed in the SMP establishes vegetation protection and enhancement requirements in the High Intensity and Urban Conservancy Environments. The City will work with shoreline property owners to encourage re- vegetation of the shoreline buffer in the Shoreline Residential Environment (bank stabilization projects and projects for overwater structures must include revegetation of buffers as a condition of approval). The restoration plan also prioritizes actions that expand the active channel of the river and/or provide off channel habitat. The application of the new river buffer widths would facilitate projects such as levee setbacks and vegetated benches, as well as removal of shoreline armoring and setting back and re- sloping banks in non -levee areas to achieve a more natural, vegetated shoreline. These actions would occur either as project specific implementation of the WRIA 9 Salmon Habitat Plan (restoration plan) or the King County Flood Hazard Management Plan; or as part of redevelopment proposals in coordination with the City, King County, and other stakeholders. Consistent with state guideline requirements, the proposed SMP integrates environmentally sensitive areas regulations (Sensitive Areas Ordinance (SAO), TMC 18.45). Under the proposed SMP, standards and regulations for designated sensitive areas that are physically located in the shoreline jurisdiction would apply to all shoreline uses and development. The SAO standards provide many provisions to protect the shoreline, tributaries to the Green/Duwamish River, associated wetlands, and adjacent upland areas. Another change is the requirement of environmental impact mitigation where unavoidable impacts to shoreline ecological functions would occur as a result of allowed uses or development under the proposed SMP. Consistent with state guidelines (WAC 173- 26- 201(2)(c)), the proposed SMP requires mitigation measures where impacts are unavoidable to achieve the "no net loss" of ecological functions standard. This requirement is applied to any activity that would result in impacts to ecological functions, regardless if the action required a shoreline permit or not. 17 55 56 Other changes include limiting new shoreline modifications such as bulkheads and riprap revetments along much of the City's shoreline. New development would be required to be located and designed to avoid the need for shoreline stabilization measures. The proposed shoreline stabilization standards will limit any new shoreline stabilization, unless it can be shown through extensive studies to be necessary and will require the use of bioengineering techniques wherever feasible. Further, the conservation of native shoreline vegetation and removal of invasive vegetation has been emphasized in the new shoreline regulations for the City to further stabilize shorelands and increase habitat functions. Other changes related to development of specific uses in the shoreline are also designed to protect shoreline ecological functions and processes, while continuing to allow legal uses and development and encouraging public access to the shoreline for water oriented uses such as fishing. Under the proposed SMP, new standards have been developed for non conforming uses and structures. The existing SMP allows the expansion of a building containing a nonconforming use by 25 percent, provided the Planning Commission grants a special permit in cases of evident hardship. Under the proposed SMP, nonconforming uses cannot be enlarged or intensified to occupy additional land or expanded structure. A non- conforming use can be replaced by another non conforming use provided the new use meets certain criteria including avoidance of adverse impacts on shoreline ecological processes and/or functions; restoration of the entire shoreline buffer including paved areas no longer in use; and expansion of the use is limited to the minimum necessary to achieve the intended function. The existing SMP allows a non conforming structure that has been destroyed by not more than 75 percent to be re- built. Under the proposed SMP, such structures, regardless of the extent of destruction, may be rebuilt to their original dimensions. The proposed SMP also allows such structures to be altered or partially reconstructed provided that: 1) new construction does not further intrude into the buffer; 2) reconstruction will not create adverse impacts to shoreline ecological functions and/or processes; 3) the bank is re- sloped to a 2.5:1 or 3:1 angle in non leveed portions of the river and the entire shoreline buffer is restored (included paved areas no longer in use); or for properties along leveed portions of the river, the remaining buffer area is enhanced, invasive vegetation removed, and native vegetation planted on the levee prism, as allowed by the Corps of Engineers. Single family structures in residential zoning districts which have legally non conforming setbacks from the OHWM may expand the ground floor provided that: 1) expansion occurs along the existing building line(s); 2) the existing distance from the nearest point of the structure to the OHWM is not reduced; 3) the square footage of the new intrusion into the buffer does not exceed 50 percent of the square footage of the current intrusion; and 4) invasive plant species are replaced with native species within the entire shoreline buffer. Non conforming uses and structures that cease or are vacated for 24 consecutive months must be brought into conformance This time limitation may be extended by the City provided the shoreline buffer is restored or enhanced. The proposed changes to development standards and use regulations are, in general, more protective than the existing SMP. New development would be required to meet standards for environmentally sensitive areas within shoreline jurisdiction as well as the policy intent and development standards of the proposed SMP. Redevelopment would be allowed in all environments. As redevelopment occurs, the policies and regulations in the proposed SMP require that development be located and designed in a manner that avoids impacts to ecological functions and/or enhances functions where they have been degraded. For example, the vegetation conservation measures require that, as part of a redevelopment proposal, non native or invasive species be replaced with native vegetation appropriate for riverine riparian environments. Another example pertains to shoreline stabilization (for residential bulkheads or revetments). Policies and development standards establish a preference for alternative "soft- shore" erosion control or stabilization designs. Where shoreline stabilization is requested, project applicants would be required to demonstrate why a bioengineered design would not provide adequate protection of existing 18 development. Existing non conforming uses and structures are allowed to continue under the proposed SMP. However, when changes or expansions occur, shoreline ecological functions would be improved because of the requirements to restore or enhance the shoreline buffer with native vegetation and/or to re -slope non leveed river banks. Over time, as the proposed changes to the SMP are implemented, they will likely have a net beneficial effect on shoreline ecological processes as properties are redeveloped. Restoration Planning As described previously, the SMP Restoration Plan (Appendix B to the proposed SMP) represents the shoreline restoration element of the SMP. The plan includes goals and policies addressing restoration. The policies establish the City's intent is to meet the "no net loss" standard, and result in an overall improvement to the condition of the habitat and resources within the shoreline jurisdiction of the City over time. The plan identifies opportunities for restoration activities or efforts that include programmatic opportunities (e.g. surface water management; water quality improvement; public education), 28 site specific opportunities (some of which are already underway), regional plans and policies for Puget Sound restoration, and potential funding and partnership opportunities. The SMP's restoration planning is focused on areas where shoreline functions have been degraded by past development activities. The areas with impaired functions were identified in the City's Shoreline Inventory and Characterization. Recognizing that much impairment to shoreline processes and functions are the result of watershed scale activities beyond the City's control, the implementation of the Restoration Plan will improve shoreline ecological functions in the City over time. Beneficial Effects of Any Established Regulatory Programs under Other Local, State, and Federal Laws A variety of other regulatory programs, plans, and policies work in concert with the City's SMP to manage shoreline resources and regulate development near the shoreline. The City's Comprehensive Plan establishes the general land use pattern and vision of growth and development the City has adopted for areas both inside and outside the shoreline jurisdiction. Various sections of the Tukwila Municipal Code (TMC) are relevant to shoreline management, such as zoning (TMC Title 18), stormwater management (TMC 14.30), and floodplain management (TMC 16.52). The City's development standards and use regulations for environmentally sensitive areas (TMC 18.45) are particularly relevant to the City's SMP. Designated sensitive areas located in the shoreline may include areas of potential geologic instability, wetlands, watercourses, and fish and wildlife conservation areas. As noted above, standards and regulations in the critical areas regulations are now integrated in the proposed SMP. A number of state and federal agencies may have jurisdiction over land or natural elements in the City's shoreline jurisdiction. Local development proposals most commonly trigger requirements for state or federal permits when they impact wetlands or streams; potentially affect fish and wildlife listed under the federal Endangered Species Act (ESA); result in over one acre of clearing and grading; or affect the floodplain or floodway. As with local requirements, state and federal regulations may apply throughout the city, but regulated resources are common within the City's shoreline jurisdiction. The state and federal regulations affecting shoreline related resources include, but are not limited to: Endanzered Species Act: The federal ESA addresses the protection and recovery of federally listed species. The ESA is jointly administered by the National Oceanic and Atmospheric Administration (NOAA) Fisheries (formerly referred to as the National Marine Fisheries Service), and the United States Fish and Wildlife Service (USFWS). 19 57 58 Clean Water Act (CWA): The federal CWA requires states to set standards for the protection of water quality for various parameters, and it regulates excavation and dredging in waters of the U.S., including wetlands. Certain activities affecting wetlands in the City's shoreline jurisdiction or work in the adjacent rivers may require a permit from the U.S. Army Corps of Engineers and/or Washington State Department of Ecology under Section 404 and Section 401 of the CWA, respectively. Hydraulic Proiect Avvroval (HPA): The Washington Department of Fish and Wildlife (WDFW) regulates activities that use, divert, obstruct, or change the natural flow of the beds or banks of waters of the state and may affect fish habitat. Projects in the shoreline jurisdiction requiring construction below the ordinary high water mark of Puget Sound or streams in the city could require an HPA from WDFW. Projects creating new impervious surface that could substantially increase stormwater runoff to waters of the state may also require approval. National Pollutant Discharge Elimination System (NPDES): Ecology regulates activities that result in wastewater discharges to surface water from industrial facilities or municipal wastewater treatment plants. NPDES permits are also required for stormwater discharges from industrial facilities, construction sites of one or more acres, and municipal stormwater systems that serve populations of 100,000 or more. The City is in the process of revising its stormwater regulations to meet the new municipal NPDES permit requirements. There will be more stringent stormwater management requirements for control of stormwater volume and quality that should result in improvements in water quality and greater emphasis on the use of low impact development techniques throughout the City, which will also improve conditions in the Green/Duwamish River. State -owned Aauatic Lands: The Washington State Department of Natural Resources is the steward for the State owned bed of the Green/Duwamish River and would regulate any structures constructed in the bed of the river, such as piers. Current and Future Performance of Shoreline Ecological Functions The attached tables summarize the existing performance of shoreline ecological functions along the Green River as described in the Shoreline Inventory and Characterization Report (ESA Adolfson, 2007). Actions that would potentially cause a loss of shoreline function, and regulations from the proposed SMP that would protect or improve ecological functions are identified. The net impact expected from implementing the regulatory provisions of the proposed SMP is described along with opportunities for restoration of ecological functions. The tables below are focused on the effectiveness of the regulatory provisions in meeting the "no net loss" standard. Site specific restoration opportunities are outlined in the Restoration Plan (ESA Adolfson, 2007, updated in 2009) and are not directly evaluated as part of this assessment. The tables are organized by shoreline reach (as identified in the inventory and characterization report; see Figure 1 above), moving from the south to the north: G -1 PAA (Tukwila South Potential Annexation Area) G -1 (from upstream city limits to the Black River /Green River confluence) G -2 (from the Black River /Green River confluence to the downstream city limits) G -2 PAA (Tukwila North Potential Annexation Area) 20 Conclusion In large measure, the development and use patterns along Tukwila's shorelines are well established and there is little undeveloped land along the shoreline. Tukwila's identity as a regionally significant industrial, manufacturing, and commercial center will be maintained. Therefore, change within the shoreline will primarily be the result of redevelopment activities. The proposed SMP provides a new system of shoreline environment designations and river buffers that would protect shoreline resources and enable enhancement and restoration actions. The updated development standards and regulation of shoreline modifications provides more protection for shoreline processes. The updated standards and regulations are more restrictive of activities that would result in adverse impacts to the shoreline environment. The restoration planning effort outlined in the proposed SMP provides the City with opportunities to improve or restore ecological functions that have been impaired as a result of past development activities. In addition, the proposed SMP is meant to compliment several city, county, state and federal efforts to protect shoreline functions and values. Based on the assessment of these factors, the cumulative actions taken over time in accordance with the proposed SMP are not likely to result in a net loss of shoreline ecological functions from existing baseline conditions. Instead, it is expected that the regulatory provisions of the proposed SMP would result in an overall improvement of functions along the Green/Duwamish River. However, since most ecological functions along the Green River are heavily influenced by conditions and activities throughout the upper watershed, the improvements are not expected to be significant at the watershed scale. In concert with implementation of restoration actions in the city, the regulatory provisions of the proposed SMP would serve to improve the overall condition of shoreline resources in the city as redevelopment occurs. 21 59 60 t Net Loss, Reac► G1 'implementation of t �?reven ExPec tedfromimp aced standards loss het Impact ns of SMP F hods in Proposed SMp to prevent r Risks to Ecos _t ii1 minimize risk or minim na lySlS^ a net loss} paned an c hannel d and t1d� 1� Risk would cause 5.1 slope ew 5Mp CumulativeF A c� �ctions that uld levee recon trollmgn corn banks at i ees exile improvement t eermg• width would increase ll stabilized u nngb eA channel d p tovt Sects. to be constructe intertidal habitats. Ze for flood storage De ore natural �t< Ecosystem ened Shorelin OTmg on o ver steep ach an d Sh New hard shoreline arm signatioII bardcs leveereconstt°cnon �teracnon �Surf alogy –Ce,edu r reducing downstream 1 Surface storage, t for ng processes, Reach; GI Urban flooding, habitat form Designati hypox functions Desig trained and Conservan former f rodptain by Land Cw Ye ntsit situation: channel co (Current idly developed separa a nd Levee. Gilliam Creek has puny elopin tpote armoring redevelopment potential fopga which limits interaction. Commercial (office, warehouse, retail), park. (soccer fields), heavy and equ s tormwat er deten tion facility, major detention tie and highway iuterchan° o s over several vehicle bride r iver. Left bank– federally 405 certified levee from s outh. Rig a Hydrology Groundwater Recharge not a significant function Current valley is groundwater discharg raver valley is a slivery `fluvial tr Sediment D not asignifcantf Lion: ffeCjed atwatershed Current strut Process controlled 1s Novae. Sediment Delivery and Removal upland Level upriver articulate Sedum sediment generation and p fine oversteea d some levee slopes, inkier Blvd' in retention shoreline is south of M each along e vious surfaces (esP; north end ofx bank)• Current situation: o s eroding, For tDentPar k(right deveiop w hich disc hm8 on left ouch o a ter05) disc banks o Ciy's o f bank soutl+ s gem. k� p trail on rep s a ute f ne s edimen ts d ntribute likely most of reach e M m e s ban nts. along htbank contributin ark rt lower f 1 t on rig ed areas r bank of S 180th. u npaved Fort Dentdireet discharg d l v ee- out possible, on -site elevation behflt is not post Some conditions: nattO f j esedime n ondpr n o rth av d of red hullers. poorly h stornnvater detention hug enter river front Gilliam t rearm north end of reach, ru es e es sib f c ovet, p discharge, which receives oar quality tree tts quality unde n mid and storm water contributions (south er is of reach poo Quality –nutrient refs ftltrat and south pans derstory cover. W mo Q hosphorous through through Kee and removal (p removal and nitrogen f hoe} canopy 1 retention qtr wetland in shoreline denitt i tea large ire ht bank 115 One w not including on right jurisdiction, ratan fringe Current situation of reach and removed ba nd ed rip ha been in h oreli watercourses northern of each. Tree levee. n Po wetlands, tivee a11v certified Loss of wetlands due to filling m and reconstruction ew hard S uds for bench and standards con m id slope be 9.5, 9.6) armoring (Sects. back of banks in exchange 4o. Laying to 50% reduction of up SMP (Sett Sensitive areas protection provisions m 10) No significant risks �e sedimen significant impairment transpor r ve et atio n a l ong i (Sect. val of g Y 5 remo ened batiks for Ian SM t.and cle otn over -steep d cleating m control for projects, r vet, lauds t remove fine etoston (current secluding 125 ft (curt Inadequate stomttvatet treatment to rem ider buffets 100 with limits incre ent of w areas (Sect. 7 t. pe diment and particulate Establishm leveed d uses (sect. 8) buffer risk buffers 40 ft.) eveed an impervious surface in blow risk due to ble situ oval and vegetation on allowable plants Increased imps prohibiting native vegetation removal possible retention by enh ancement with native existing development) Standards (except e t w federally certified levee requiring w here in buffer 0) exists) (Sect 9. of riverltloodplain interface th rtherre duction oTmg on over h additional hard 01515 from eder Dec 200 shoreline jurisdiction Black f' f—"' sequencing, and tningau Creek and acts Analysis Gilliam "'y impacts, mitigation sea Cumulative Impacts t.. environmental imp Impacts/Final Cwn Ana lysis of potential en ulative Imp S3,1 waLongRangeProjects ,ShorelineiCum acing, unles hard Standards prohiba em new es (in that case mitigation studies show no and standards for levee a bench would be required) with a planted mid -slop re pair/repla cement (Sect. throng 9 5 9 and tree steepened banks With prohibiting native vegetation e uiringbuffer vegetation aeration and removal and r q f Kees and native station in the I Removalo eg reduction of fl oodplatn area. apply to all projects in the Shoreline jurisdiction on (Sect. 9.8 of SW) o/t es accepted, 12109/2009 l u lbnpact chang 1 No Ne Loss Table -Cum f 1 Opportun provided for in SM.? for restoration provisions o f function regulatory P Mitigationp j leveed areas set of replace lost vementi functions. 'Potential significant re coped to preferred 0500 profile to off- Pozen area. Potential ects, as they are re hat wider c e re slope expected Restoration Pgestotation improve f non levee ev id entified in No new °tease Plan, mostly m northern i loo bioenginee a t zone an de a part of mostly eg(1t n orthern create a larger aquatic to w wetland reto river) transition from b pr otected. 11IA 141A Wetlands will I No change No change ntiv for re due to ince a L ile_ vegetating ent (few existing ter re gulation s a ors in sloping and provide greater Slight s tovem d new stormw permit it t require stability at time of Slug ermit teat wilcl and In°°t more Po si t e treatment and new P during land redevelop t o City MPs respo t ides. d 8 more on site tte? vities. co nstructio n improvement when currently unpaved sites Slight redevelop due to wider buffer requirements and re vegetation requirements N totectio ion p ects, per due to vegetation p' the Restoration Plan uirements, wider buffers, new levee Improvement in some areas, ent req Voluntary laying back and and file with planted mid -slope bench. planting of banks in profde with plan g ,e for buffer reduction and buffer re- reduct teach an d Shoreline Designat River, and Stream "E, which is piped to stonnwater pump station). sw jcosy stem Fun ction es to the retention of eat and floodplain contnbng of sedim i n midi c f reach, but phosphorous Ro t� trapping the ve getation ce waters anderstary ve y eg¢tation in parts a generally groundwater and surface Boas overhanging k and ege tation that reach (willows). Functional 1 buffers and large trees Sc ding) narrow (largely restricted fbattk o bank Removal of e e overhangs water (elimination to shin narrow strip on rTemperatur a and Quality a�dwater discharg Water Q Reduction in temperature is a have mature trees b Current removed s ituation but certified levee roblYem ved fi federally been Engineers s requirements and per Corps of u a issue) r land is fully with of reach and upland with impervious surfaces (temperature buffet (i.e., no New incervious surfaces in ocontaminants) and m rent amioants filtering out watershed Quality c ontributing W ater Q Bible sources of Untreated stormwater runoff it land possible adjacent Currents n (unpaved areas where potential co pesticide out materials heavy e land uses sung maintenance, &e Use!siorage of ha heavy ¢qui o landscape m o Na nce, s (utilise*' use f snra!( quantities of Excessive use of pesticides storag m aterials Methods in p pp$ed SMP to prevent toss Minimize rfslc or min Risks Would cause a net loss) (actions that tv Sect 9,10). native plants 'LWDIOrganic inputs Large tree canoh bank.'" 1 Current situation- reach and on right removed northern of parts of rein have been rem much of reach, Tres from federally certified lev ration Riparian buffers and over -win Rip Patting in buffer or patting in (oils adequate stormwater treatment Large tree remOVal prohibit tree removal, w i t h m itigation Standards S 9 .10), (however tree removal required required mitigation for removed trees to be done WD placem r e on levee elsewhere in shoreline' Lent plane Standards requiring Te'veg buffers. buffer requiring mitigation (Sect. S, 9 Standards controlling structures m .2) Standards prohibiting increase to runoff and (Sect 9. airing requiring (Sect. 8 9 structures ibtting increase mitigation (Sect S. LID techniques Standards requiring stormw i ues (Sat 9 Stan n ttechn q low impact develop rue d coati without drips) runoff and requiring nt and use of inter treatment 4) agency plans, prohibiting prohibiti g spill prevention within 100 R of pl hibunng sensitive area (Sect 9.12) dons Standards that pCOhibition of (Sect fute waste facilities m shor controlling use of pesticides (Sect. requirement for managem plans for areas Standards etnent adjacent to river requiring large turf manag Le o rtDent tarfire facility). (port Deni 4arklS s for buffers Secr. 8 Uses�datd itingaanvevegera g,10)• Mitigation requirements that include addition of LWD in river r with planted Required profile forlevee 5 P� 100 or 125 ft mid -slope width from 'Wetted from Implements Net Impact DxP of SNIP regulatory provisions Slight improv ee t in win er t shade ture due to of trees retentionlp Potential improvement in water water regulatio e to SMcomplY and new p ety's fDESpermm with City's NP 1 ton 01 r provided for in SW for restoration of functions ve getation cnt due to strengthe tree protection with and future levee retorts removal, tree Improvement n memo te�ulations in SM Bch v egetation mi d slope rohib eats for planting n ative planted r Standards oval 4 re quireme nts ad trees $eCY. removal and also, requirement to leave Las l users vegetation, also, card to bwld'mgs place unless a hazer (Sect 91 1 le d of riparian buffers hacemen eat in quality and width 1 Improvem bench expected for sites that redevelop 40 R C° increase in Incre leYe Sect Z 7 vegetation removal, levee (if behind a led 12109(2004 Large tree and other g es accep 2 Cumul SmpaC. c hin °g ter v egetation maintenance 1 No NetbossT ImpaetsiVinal Cumulative Impacts Analysis Dec 2009 /G W :tl..ong Range FroJ eCt ShorelinelCumlative ---rte s for Education P shoreline proPettY L WD installation as part I of restoration projects m itigation projects that Restoration p include buffer Reach and Shoreline Ecosystem Function Designation Current situation— large tree canopy in northern parts ofreach and on right bank in much of reach. Trees have been removed _from federally certified levee. Poor understay vegetation in much of reach ,but some overhanging vegetation in some areas (willows). Functional buffers generally narrow (largely restricted to bank and top of bank only). In- stream habitat for fish and wildlife (especially for salmonids and bull trout) Current situation—generally poor in stream habitat due to channelization, levees and steep armored banks. Some pools and riffles from LWD in river and some beaches/mud flats exposed at low tide in northern part of reach. Risks ortun Methods in proposed SMP to prevent loss regulatory provided for in t provisions of SMP Implementation of PP ties i SMP for restoration (actions that would cause a net loss) or minimize risk° of functions improvements Buffer reductions Increased annoring on banks New over -water structures (bridges are most likely) Large tree removal (elimination of shade, source of future large woody debris, p erching and nesting locations for birds). Removal of native vegetation overhanging the river (shade, food supply, source of large woody debris) New hard shoreline amoring on over- steepened banks In/overwater structures with impacts on fish passage, shading, habitat disruption Filling of riparian wetland, off channel habitat reduction of up to 50% Standards that exchange for re-sloping bank d nkand enhancing buffer vegetation Standards protecting trees and native vegetation and re- vegetation requirements, and mitigation for unavoidable vegetation removal (Sect 9.10.) (Note: specific policy established for overhanging vegetation) Standards that require bioengineering techniques for bank stabilization (Sect. 9.6) Standards for overwater structures (Sect. 9.12) Standards prohibiting native vegetation and tree removal and requiring enhancement of buffers with native, overhanging vegetation (Sect 9 10). Standards controlling new hard armoring (Sect. 9.6), encouragement of reducing steep slopes of banks with native plantings (Sect. 7.7, in exch Inge for r2.5:1 buffer reduction) and design profile for slope with vegetated mid -slope bench. Standards for in -water and overwater structures, requirement for special studies to show no net loss, mitigation requirements (Sect. 9.12) Prohibition of wetland tilling, protection of Fish and Wildlife Habitat Conservation Areas (Sect. 10) 3 Ran e Projects /Shoreline /Cumulative hnpacts/Final Cumulative Impacts Analysis Dec 2009/G1 No Net Loss Table Cumul Impact changes accepted, 12/09/2009 S.W W. /Long g No change for width reduced buffers (maximum reduction would be 50% in non -levee areas, which is still wider than the current 40ft. Banks would be at natural angle of repose and buffer would be enhanced with native plantings resulting in a significant improvement ntover existing riparian conditions. No chang e for leveed areas, but levee mid -slope benches would provide improved riparian habitat. Improvement if banks are restabilized using bioengineering techniques No change if mitigation carried out and standards followed Improvement over existing in- stream habitat, few in or overwater structures expected, except for new pedestrian bridge in this reach Restoration projects to increase in- stream habitat esp. off- channel and near channel areas Voluntary laying back and vegetating riverbanks with native plants rn -NTukwila SMP Cu Impact Analysis Risks to Ecosystem Functions and Proposed Standards to Prevent Net L Reach and Shoreline Designation Reach: G2 (Black River /Green River confluence to north City limit) Designations: High Intensity, Urban Conservancy, Shoreline Residential Existing Land Use: High Intensity Environment: northernmost part of reach, includes the turning basin: industrial (truck parking, aircraft industry), transportation: private vehicle bridge. Several salmon habitat restoration sites in turning basin (left bank) off channel areas, mud flats, riparian wetland. Urban Conservancy- Industrial, office, commercial/warehousing, institutional (Federal Post office), recreational (Boeing employees facility), Foster Golf Course. Significant impervious surface existing except for open space. Recreational trail along river in much of reach. Southgate and Riverton Creeks are tributary to river. Ecosystem Function Risks (actions that would cause a net risk loss) New hard shoreline armoring on over steepened banks Hydrology Channel/Flood Plain Interaction: Surface storage, reducing downstream flooding, habitat forming processes, hyporheic functions Current situation: generally constrained due to channelization, .steep armored banks (some eroding). Hydrology Groundwater Recharge Current situation: not a significant fraction —valley is discharge area Sediment Delivery fluvial transport Current situation: not a significant function process controlled and affected at watershed level upriver from •om Tukwila Sediment Delivery and Removal upland fine sediment generation and particulate retention Current situation: nrostly impervious surface in Urban Conservancy; some unpaved area in High Intensity, unpaved areas in Shoreline Residential, fine sediment sources: unpaved parking lots, residential gardens, upland sources outside of Shoreline jurisdiction, which contribute sediment to tributaries; narrow, poorly vegetated buffers; general lack ofstormwater treatment. Water Quality nutrient retention and removal (phosphorous through filtration and retention and nitrogen removal through denitrification) Current situation: absence of large trees in High Intensity Env. and much of Urban Conservancy. Good tree cover in New overwater /in -water structures Loss of wetlands fish and wildlife habitat areas due to filling/bank armoring No significant risks No significant risks for coarse sediment transport impairment Land clearing, removal of vegetation along river, landslides from over steepened banks, increased impervious surface in buffer Inadequate stormwater treatment to remove fine sediment and particulates Further reduction of river floodplain interface through hard armoring on over steepened banks Removal of trees and native vegetation and reduction of floodplain area. Vegetation in the floodplain contributes to the retention of phosphorous from the Methods in proposed SMP to prevent loss or minimize Standards controlling new hard armoring requiring bioengineering techniques (Sect. 9.6). Voluntary lay back of banks in exchange for buffer reduction of up to 50% (excluding residential uses) (Sect. 7.6,7.7,7.8) Standards controlling extent and design of new over -water structures (Sec 9.12), mitigation required (Sect. 9.12) Sensitive areas protection provisions in SMP (Sect 10) N/A N/A r Analysis of potential environmental impacts, mitigation sequencing, and mitigation (Sect. 9.8 of SMP) apply to all projects in the Shoreline Jurisdiction 1 Adequate stormwater treatment (Sect. 9 4) and increase in buffer width from 50 ft to 100 ft in High Intensity and Urban Conservancy Environments and from 20 ft to 50 ft in residential areas.(Sections 7.6, 7 7, 7.8) Standards for land clearing in SMP (Sect. 9 11), including erosion sediment control for projects Standards prohibiting native vegetation removal and requiring vegetation enhancement in buffer (Sect 9.10). Restrictions on what structures can be built in buffer (Sect 8) Standards prohibiting new hard armoring, unless studies show no alternatives (in that case mitigation would be required) and standards for levee reconstruction (Sect. 9.5, 9.6) Standards prohibiting native vegetation and tree removal and requiring vegetation enhancement in buffer for new /re- development (except residential under 4 lots (Sect 9.10). SW W: /Long Range Projects/Shoreline /Cumulative Impacts/Final Cumulative Impacts Analysis Dec 2009/G2 No Net Loss Table Cumul Impact changes accepted oss, Reach G2 Net Impact Expected from Implementation of regulatory provisions of SMP Slight improvement as failing banks are stabilized with less steep slopes and bioengineering techniques, if property owners take advantage of incentive to re -slope steep banks in exchange for buffer reduction. Improvement in overwater structures as old structures are replaced. Increased channel width would increase flood storage, create a larger intertidal zone and provide a more natural transition from aquatic to upland habitats. Slight im __era in protection of sensitive areas No change No change Significant improvement in High Intensity area as area redevelops (where little stormwater treatment exists and many areas along river are unpaved) Improvement in High Intensity and Urban Conservancy due to wider buffers and enhanced buffers planted with dense native vegetation Slight improvement over time as buffer vegetation is enhanced through site redevelopment, voluntary planting, mitigation for over -water structures, bank stabilization. Opportunities provided for in SMP for restoration of functions Mitigation projects to off -set or replace lost functions Restoration projects including those that lay back banks and create shallow intertidal areas and off channel areas N/A N/A Incentive built in for re- sloping and re- vegetating banks to provide greater stability at time of redevelopment Restoration projects Voluntary riparian vegetation enhancement Reach and Shoreline Ecosystem Function Designation h reline Residential Single Family residential, parks open space (Tukwila Community Center, Codiga Park, future Duwamish River Bend Hill Park (partly in shoreline jurisdiction), North Wind Weir (both banks), Duwamish Park. Streets (42 "a Ave S S 155 s dacent to river, with gravel err[ situation: potential Risks (actions that would cause a net loss) trapping of sediment and denitrificarion Shoreline Residential and along Foster of citrate -N within the groundwater and Golf Course. surface waters Removal of large trees vegetation that overhangs water (elimination of shading) Current situation: high temperature is Increase in impervious surfaces larger trees n igh nl rva s n cy Good tree ty Env. And (stonnwater temperatures) large trees Urban H C o se oundwater discharge and much o cover in n SShorr Conservancy. Residential and along Reduction sm gr Foster Golf Course. New impervious sur in buffer (i.e., Water Quality contaminants no filtering out of contaminants) and in contributing watershed Water Quality Temperature a j Cw+ shoulders. contmnbtation f'onr ongoing industrial activities in High Intensity Environment (general lack of st onmvater treatment). Lower risk in Urban Conservancy and Shoreline Residential. Unheated stonnwater runoff Overwater structures (such as marinas or boat yards) with transport, use or storage of hazardous materials Some contamination of sediments due to Use/storage of hazardous materials previously contaminated sites Excessive use of pesticides /fertilizers LWD /Organic inputs Current situation absence of large trees in High Intensity Env. dd tree cover co er in Urban Conservancy Shoreline Residential and along Foster Golf Course. Riparian buffers and overwater vegetation Current situation: all buffers narrow, poor understo+y vegetation (mostly invasive plants), poor tree canopy except in Shoreline Residential and along Foster Golf Course Parking in buffer or parking in areas without adequate stonnwater treatment (oil drips) Large tree removal Removal of trees and native vegetation Methods in proposed SMP to risk' Buffers increased from 50 ft to 100 ft Conservancy Environments and from 2 prevent loss or minimize in High Intensity and Urban 20 ft to 50 ft in residential areas. Standards that prohibit tree removal with mitigation required (Sect 9.10) Standards controlling structures in buffer requiring mitigation (Sect. 8, 9.2), prohibiting increase in runoff and requiring LID techniques (Sect 9.4) Standards controlling structures in buffer requiring mitigation (Sect. 8, 9.2), prohibiting increase in runoff and requiring LID techniques (Sect 9 4) Standards requiring stonnwater treatment (Sect 9 4) ill prevention and contingency plans, prohibiting Standards requiring spill development within 100 ft of sensitive area (Sect 9.12) Standards that limit use of treated pilings (Sect 9 12). Prohibition of commercial hazardous waste facilities in shoreline jurisdiction (Sect 8). Standards controlling use of pesticides (Sect. 9,10.D), requirement for management plans for areas requiring large turf management adjacent to river (golf course). Use standards for buffers (Sect. 8), stonnwater treatment required (Sect. 9 4) Standards prohibiting native vegetation removal, tree removal and requirements for planting native vegetation (Sect 9 10). Mitigation requirements that include addition of LWD (Sect. 9.10) Standards prohibiting native vegetation and tree removal and requiring buffer vegetation enhancement when redevelopment occurs (Sect 9 10). and Buffers onservancy Envi orunents g and from 20 ft to 50 ft in Intensity residential Urban areas.(Sections 7.6, 7 7, 7.8) Buffer reductions in High Intensity Environment Urban Conservancy up to 50% (no buffer reductions allowed in Shoreline Residential Environment) in exchange for re- sloping bank and planting SW. W; /bong Range Projects /Shoreline /Cumulative Imp acts /Final Cumulative Impacts Analysis Dec 2009 /02 No Net Loss Table Curnul Impact changes accepted Net Impact Expected from Opportunities provided for Implementation of regulatory in SMP for restoration of provisions of SMP functions Some improvement expected tt s sites redevelop. Little chang e protected retention, as trees are already P under separate tree ordinance, however SMP tree protection is stronger. Significant improvement expected in High Intensity Environment as sites redevelop (buffer vegetation enhancement, stonnwater requirements in SMP, and new NPDES requirements. Also, improvements expected due to clean -up actions under Superfund in High Intensity Environment. Urban Slight improvements Conservancy and Shoreline Residential Cons Long -tent improvement in areas of reach which have no large trees currently (through requirements for re- vegetating buffers upon redevelopment) (source of LWD). Slight improvement through LWD replacement nrolects Improvement in quality and width of riparian buffers expected, for sites that redevelop No change for width reduced buffers (maximum reduction would be 50% in non -levee areas, which is still wider at natural angle of repose and buf er would be enhanced with native plantings resulting in a significant Voluntary tree planting, stewardship education for shoreline property owners (planned) Stewardship education for property owners and City maintenance crews. Restoration projects with riparian plantings, stewardship assistance voluntary buffer restoration by property owners rn C.)Reach and Shoreline Ecosystem Function Designation In -stream habitat for fish and wildlife (especially for salmonids and bull trout). Current situation: freshwater /saltwater transition zone in northern part of reach. Several new salmon habitat restoration sites in turning basin and at North Winds Weir (left bank) and Codiga Park have added in -stream habitat— riparian wetland mudflat/beaches, off channeUbackwater areas. Risks (actions that would cause a net loss) with native vegetation New bank armoring New overwater structures (docks in residential areas) Removal of large trees that could form in- stream habitat Filling/dredging of riparian wetland, off channel habitat Methods in proposed SMP to prevent loss or minimize risk' Standards controlling new hard armoring and bank stabilization (Sect. 9.6) Standards for in -water and overwater structures, requirement for special studies to show no net loss, mitigation requirements (Sect. 9.12) Buffers increased from 50 ft to 100 ft in High Intensity and Urban Conservancy Environments and from 20 ft to 50 ft in residential areas.(Sections 7.6, 7 7, 7.8) Buffer reduction to no less than 50% in exchange for re- sloping bank and stabilizing with bioengineering techniques including planting of native vegetation to overhang water (Section 7.6, 7 7, 7.8) Standards prohibiting native vegetation and tree removal and requiring buffer vegetation enhancement when redevelopment occurs (Sect 9.10). Standards controlling new hard armoring and bank stabilization (Sect. 9.6) Standards for in -water and overwater structures, requirement for special studies to show no net loss, mitigation requirements (Sect. 9.12) Prohibition of wetland filling, protection of Fish and Wildlife Habitat Conservation Areas (Sect. 10) 3 SW W:/Long Range Projects/Shoreline /Cumulative Impacts/Final Cumulative Impacts Analysis Dec 2009/G2 No Net Loss Table Cumul Impact changes accepted Net Impact Expected from Implementation of regulatory provisions of SMP improvement over existing riparian conditions. No change for reduced buffers in leveed areas, but levee mid slope benches would provide improved riparian habitat. Improvement if banks are restabilized using bioengineering techniques No change if mitigation carried out and standards followed Potential improvement Opportunities provided for in SMP for restoration of functions Restoration projects prioritized in transition zone esp. oft channel and back channel areas SAP Cumulative Fact and osystena "Function eac and Shoreline Designati retention pa)vsi5^ Vasks to Ecosystem cause a net I �inimitie risk would A gisks factions that loss) Channel/F plain Hydrology' storage, reducing 1 Interaction: Surfa habitat forming Reach; CT ban ream flooding, habitat f Designation/ Ur downstream hypotheic functions Conservancy actual interaction situation: little t k ith o ver d u e to s certi ied levee Ilse: a nd tributary watercourse LandU duero»an- (Curr ent uuture, rT s huctur flo d steepened bank lr levee into river t 1 e veethr e tha fl ¢charg Agra coon, t Fu's Shore m h emir Gtoun length (not h cross Cur v alley certifie 90 Ate discharge area �anspnrt valley m is in t oc ¢ss from S. oodplain f with small portion in Ne w cross valley Shoreline Jurisdiction develop m tributary and stream relocation t Johnson developm Creek 110 significant risks control levee throng H y drology n ot a significant ttndwaier Federally rent situation. is a tisks foz coarse sediment 'tin significant ens dlevee) w i t a function river ttimpatr e at S 1 fluvial transpor l90 south SednnentDelivery funcnon p el meet affected at 'watershed ley for site develop (duet mapped fl t a significa w roces f Grading and filling (due to non -certified levee)• Not and a lnvi a upland I M change will be i li Sediment t T an d Retention p w cross Delivery and particulate requeste furthe south. e stalled fin s e invent generation valley levee to be m fine sedimen further south. ntf of Lamds e leve used Standards toy prevent loss or t lv het Impact tcte y pe o SMP Standards for new and rebuilt levee const d px0 0£ regulatory provisions hods in Proposed SMp to prev -Functions an coon requiring ru less steep slope (Sect. 9.5) Sensitive areas provisions in SMp (Sect 10) N1A lidestfailures on over steepened banks of water treatment to %move fine N 1A n sediment Inadequate st Current situation: e¢ lower 1r adeq d articulates and behind levee sediment equ o s p oth top of activities s does no o to river dir o ftev¢¢1, but could flow than top small, interface via tributary strewn th has over- inadequate buf Further reduction of riverffl o nadeq through additional hard armoring nutrient through retention an teed banks of levee wa uality filtza steep ca l (phosp /ion a nit' gee Te oval through' i trees and native vegetation from removal and nittoge rebuilt levee Removal of h areas o[ from area. and retention newly restored o floodpla d tuat benc hes and d areas o con t le es to the of titde s o m e has Vegetation in the floodplam the trapping to thwithin Cu situation 9 r ith retentio of phosphorous fro ofnittat :11 vegetation present in evee main w en itriftcati on removed t° eat and d fact f nit been r ecently sedim f gngineef•s levee niaint¢nane the groundwater and sits Corps o standard ent (Sect. 9 4), and new water treatment implement new and 14P1DES ne Standards for storm to City stormwa' regulations T Standards for land clearing in construction erosion sediment control erosion sedim mid-slope b r equiremen ts (Sect. 9.11), including nSMp( n benches in re- built ((Sect) 10) required nd wider ivegetated buffers on Sect 9.1 I b ilt levees tream U restored ttibutary s with vegetated mid -slope Standards for levee construction hie removal Standards prohibiting native vegetation and (Sect 9 10). bench (S e ct 9 5) horeline Jurisdiction es accepted, 12109/2009 1 to all projects in the S h Cumul Impact chang 9.8 of NoNefLossTable d mitigation (Sect. 9. Dec 20091G1? AA anon sequencing, an acts Analysis D v ronmemtal impacts, m itigation Analysis of potential en Impacts/Final Cumulative Impacts SW lLo( gRzngeRroJecUShorelinelCumulative Reach Opportuni G tLosS d goer I provided for in SW for restoration of function meat: levee ent due to planned icfuture 1 provide slightly Tovem htl Improvement (lay back steep slope); prop o re construc tion eG OnstN and less acts to include off m chan fr development impacts 2 6 upland t 5 open te1 salmon habitat butary stream improvements, crease flood storage and open water) and Increased larger intertidal in width would c reate a large ut errtidal zone.. -trio change o change Two restoration ed future development projects identified in ent P with plaint this reach e t° identified Improvement expected permanent stortmwateT manage(' can out by Imp o f new stonnwat lea wily and p er of "f uk be due to temporary implementation develop staards f requirements an DES permit. South project awetland standards for NR mitigation for a (fun) and watercours impacts N Imprnv anent as levee is rebuilt and mid -slope benches d vegetation matures are planted O ff-channel r e,storation project as mentio above Water Quality Temperature Current situation: high temperature is problem for salmonids little to no riparian vegetation in this reach, no large trees Water Quality contaminants Current situation agricultural practices possible source of contamination (fertilizers, pesticides) LWD /Organic inputs Current situation: brier comprised of levee with little native riparian vegetation Riparian buffers and overwater vegetation Current situation: high temperature is problem for salnonids little to no riparian vegetation in this reach. Buffer largely taken up by levee) In -stream habitat for fish and wildlife (especially for salmonids and bull trout). Current condition: virtually no adequate in- stream habitat due to channelization and levee. Stream discharges via non- fish-friendly culvert and flap gate through levee Removal/topping of large trees vegetation that overhangs water (elimination of shading) Increase in impervious surfaces (stormwater temperatures) Reduction in groundwater discharge and base flows Untreated stormwater runoff Use/storage of hazardous materials Excessive use of pesticides for landscape maintenance Parking in buffer or parking in areas without adequate stormwater treatment (oil drips) (possible use prior to levee set -back) Minimal risks from site redevelopment little opportunity for LWD Increased buffer widths from 50" to 125 Buffer reduction after levee setback and installation of mid -slope planted bench (expected maximum reduction of 25 ft). Low risks due to non existence of in -stream habitat Standards that prohibit tree removal with mitigation required (Sect 9.10) Standards controlling structures in buffer requiring mitigation (Sect. 8, 9.2), prohibiting increase in runoff and requiring LID techniques and adequate stormwater treatment (Sect 9 4) Standards controlling structures in buffer requiring mitigation (Sect. 8, 9.2) Standards requiring stormwater treatment and use of low impact development techniques (Sect 9 4) Standards requiring spill prevention and contingency plans, prohibiting development within 100 ft of sensitive area (Sect 9.12) Prohibition of commercial hazardous waste facilities in shoreline jurisdiction (Sect. 8). Standards controlling use of pesticides (Sect. 9.10.D Use standards for buffers (Sect. 8), stormwater treatment required (Sect. 9.4) Mitigation requirements that include addition of LWD (Sect. 9.10) Section 7.7.C. Buffer designations Widening of buffer from 50ft currently to 125 ft to accommodate eventual levee setback (Section 7.6.C, and standards for flood hazard reduction (Section 9.5) requiring 2.5:1 slope, vegetated mid -slope bench, which will create shallow water areas along levee in high water. 2 S.W W: /Long Range Project/Shoreline /Cumulative Impacts /Final Cumulative Impacts Analysis Dec 2009 /GIPAA No Net Loss Table Cumul Impact changes accepted, 12/09/2009 Slight improvement when levee is rebuilt allowing for planting overhanging vegetation and trees on mid -slope bench. Improvement due to SMP standards and new stormwater regulations to comply with City's NPDES permit Improvement when site redevelops LWD will be incorporated into new off channel habitat area (see below) and trees will be planted on mid -slope bench when levee rebuilt. No change (due to levee maintenance to prevent large trees) Eventual improvement in over -water vegetation/shading when levee reconstruction completed and mid -slope bench is planted (including over hanging vegetation) and vegetation matures When levee is reconstructed, some fish and wildlife habitat will be created by planting on the mid -slope bench. Through mitigation for site development, owner will carry out off channel salmon habitat area of 8 acres (6 upland, 2 open water) and tributary stream improvements, including riparian vegetation and more fish friendly culvert and flap gate. Tukwila SMP Cumulative Impact Analysis Risks to Ecosystem Functions and Proposed Standards to Prevent Net Loss, G2 -PAA Reach and Shoreline Ecosystem Function Risks Methods in proposed SMP to prevent loss or minimize risk` Designation (actions that would cause a net loss) Current Land Use: water dependent (boat building, marina, marine industrial) and non -water dependent industrial (Seattle City Light substation) Reach: G2 -PAA Designation: High Intensity Possible redevelopment potential adjacent to Hamm Creek Restoration site on north). No levees, some bulkheads and armored banks. Two salmon habitat restoration projects in reach: Harem Creek and Seattle Fleets and Facilities mitigation site. Hydrology Channel/Flood Plain Interaction: Surface storage, reducing downstream flooding, habitat forming processes, hyporheic functions Current situation: channel constrained by armoring and bulkheads except where Hamm Creek was restored and flows into river and newly restored site on south side of Seattle City Light property Hydrology Groundwater Recharge Current situation: not a significant function, river valley is a groundwater discharge area Sediment Delivery fluvial transport Current situation: not a significant function process controlled and affected at watershed level upriver from Tukwila Sediment Delivery and Removal upland fine sediment generation and particulate retention Current situation: fine sediment could enter river from tributaries, unpaved parcels, and parking lots and very little riparian vegetation, and narrow buffers preclude retention of particulates New or rebuilt/maintained bulkheads, new shoreline armoring on over- steepened banks New overwater /in -water structures Filling loss of newly created wetlands fish and wildlife habitat areas No significant risks No significant risks for coarse sediment transport impairment Land clearing, removal of vegetation, landslides from over steepened banks, bank stabilization projects without adequate erosion controls Increased impervious surface in buffer w/o possible retention by vegetation Inadequate stormwater treatment to remove fine sediment and particulates Incentive for re- sloping and bioengineered bank to a 3:1 slope plus 20 ft setback (in exchange for buffer reduction maximum buffer reduction allowed is 50ft, which would still provide for a wider channel width). (Sect. 7.8.B.) Standards controlling new hard armoring (Sect. 9.5, 9.6) Analysis of potential environmental impacts, mitigation sequencing, and mitigation (Sect. 9.8 of SMP) apply to all projects in the Shoreline Jurisdiction 1 Standards controlling extent and design of new over -water structures (Sec 9.12), mitigation required (Sect. 9 12) Sensitive areas provisions in SMP to prevent filling, other impacts (Sect 10) N/A N /A- Standards requiring adequate stormwater treatment (Sect. 9 4) and increased minimum buffer width (Sect. 7). Also, new stormwater regulations under development to meet new NPDES requirements. Standards for land clearing in SMP (Sect. 9.11), including erosion sediment control for projects. Increased buffer width from 50 (current) to 100 R for new development (Sect 7.8.B). Restrictions on what structures can be built in buffer (Sect 8) Possible buffer reduction in exchange for re- sloping and vegetating bank no greater than 50 Standards prohibiting native vegetation removal and requiring planting of native vegetation (Sect 9 10). Standards for bank stabilization projects (Sect. 9.6) S. W W: /Long Range Projects /Shoreline/Cumulative Impacts/Final Cumulative Impacts Analysis Dec 2009 /G2PAA No Net Loss Table Cutnul Impact changes accepted 12/09/2009 Net Impact Expected from Implementation of regulatory provisions of SMP Slight improvement wider channel width on sites that re- slope bank and use bioengineering techniques, unless new water dependent uses go in. No change if existing water dependent uses stay. Increased channel width would increase flood storage, create a larger intertidal zone and provide a more natural transition from aquatic to upland habitats. No change to existing wetland and fish and wildlife habitat projects installed as restoration. No change No change Significant improvement in water Section 7.8.B. Establishment of quality mainly due to City's new River Buffer stormwater regulations (under Vegetation enhancement at time development now). of re- development as noted above Slight improvement in water quality due to new buffer width No change in buffer width over existing buffer requirements, but significantly improved riparian quality, if buffer reduction granted. Decrease in fine sediment from Opportunities provided for in SMP for restoration of functions Mitigation projects to off -set or replace lost functions Transition Zone is highest priority for restoration projects and to direct off -site mitigation efforts each and Shoreline Ecosystem Function Risks Designation (actions that would cause a net Loss) Water Quality nutrient retention and removal (phosphorous through filtration and retention and nitrogen removal through denitrification) Current situation —very little riparian vegetation present in reach Water Quality Temperature Current situation: high temperature is problem for salmonids little riparian vegetation in this reach, except for recent restoration projects and no large trees currently Water Quality contaminants Current situation: existing industrial uses, existing impervious surfaces many of which do not have stornnvater treatment and are not tied into the City's system,- buildings and parking (about 2/3 of Shoreline Jurisdiction and some vacant, unpaved land about I/3 ofjurisdiction; structures in buffer). Further reduction of river /floodplain interface through hard armoring on over steepened banks Removal of trees and native vegetation and reduction of floodplain area. Vegetation in the floodplain contributes to the retention of phosphorous from the trapping of sediment and denitrification of nitrate -N within the groundwater and surface waters Removal of large trees vegetation that overhangs water (elimination of shading) Increase in impervious surfaces (stormwater temperatures) Reduction in groundwater discharge and base flows New impervious surfaces in buffer (i.e., no filtering out of contaminants) and in contributing watershed Untreated stormwater runoff Overwater structures (such as marinas or boat yards) with transport, use or storage of hazardous materials Use/storage of hazardous materials Parking in buffer or parking in areas without adequate stormwater treatment (oil drips) Methods in proposed SMP to prevent loss or minimize risk' Standards prohibiting new hard armoring, unless studies show no alternatives (in that case mitigation would be required) (Sect. 9.5, 9.6) Standards prohibiting native vegetation and tree removal (Sect 9.10). Standards that prohibit tree removal with mitigation required (Sect 9.10) Standards controlling structures in buffer requiring mitigation (Sect. 8, 9.2), prohibiting increase in runoff and requiring LID techniques (Sect 9.4) Standards controlling structures in buffer requiring mitigation (Sect. 8, 9.2), prohibiting increase in runoff and requiring LID techniques (Sect 9.4) Standards requiring stormwater treatment and use of low impact development techniques (Sect 9.4). Also, new stormwater regulations under development responding to new NPDES permit requirements. Standards requiring spill prevention and contingency plans, prohibiting development within 100 ft of sensitive area (Sect 9.12). Also, new stormwater regulations under development responding to new NPDES permit requirements Standards that limit use of treated pilings (Sect 9.12). Prohibition of commercial hazardous waste facilities in shoreline jurisdiction (Sect. 8). Use standards for buffers (Sect. 8), stonnwater treatment required (Sect. 9.4). Also, new stormwater regulations under development responding to new NPDES permit requirements 2 S. W W: /Long Range Projects/Shoreline /Cumulative Impacts/Final Cumulative Impacts Analysis Dec 2009 /G2PAA No Net Loss Table Cumul Impact changes accepted 12/09/2009 Net Impact Expected from Implementation of regulatory provisions of SMP landslides if banks are re- sloped to 3:1. Improvement in riparian vegetation and in sediment and particulate retention Significant improvement in water quality mainly due to City's new stormwater regulations (under development now). Slight improvement in water quality due to new buffer widths and vegetation requirements (including replacement tree plantings in transition zone). Opportunities provided for in SMP for restoration of functions Restoration projects Laying back banks Installation of native vegetation that overhangs banks Reach and Shoreline Ecosystem Function Risks Methods in proposed SMP to prevent Toss or minimize risk' Designation (actions that would cause a net loss) LWD /Organic inputs Large tree removal (Current situation: no large trees, little overhanging vegetation in the reach) Riparian buffers and over- Insufficient width for adequate buffer function Requirements to increase current buffer of 50ft to 100 ft (Sect 7.8.B) water vegetation (Current situation: narrow to non existent buffers, little riparian vegetation except in restored sites)s In- stream habitat for fish and wildlife (especially for salmonids and bull trout). Freshwater /Saltwater Transition Zone with off channel habitat Current situation: little in- stream habitat except for two small restoration sites that created riparian wetland and shallow water habitat. This area contains the turning basin, which is regularly dredged by the Corps of Engineers thus opportunity to create in- stream habitat is limited. Bulkheads and impervious surface New in/overwater structures with impacts on fish passage, shading, habitat disruption Filling of riparian wetland, off channel habitat Standards prohibiting native vegetation removal, tree removal and requirements for planting native vegetation (Sect 9.10). Mitigation requirements that include addition of LWD to shoreline ecosystem (Sect. 9.10) Possible buffer reduction allowed in exchange for re- sloping and vegetating bank (no more than 50% reduction allowed, but significant improvement in riparian condition Standards for in -water and overwater structures, requirement for special studies to show no net loss, mitigation requirements (Sect. 9.12) Prohibition of wetland filling, protection of Fish and Wildlife Habitat Conservation Areas (Sect. 10) 3 S. W W: /Long Range Projects /Shoreline/Cumulative Impacts/Final Cumulative Impacts Analysis Dec 2009 /G2PAA No Net Loss Table Cumul Impact changes accepted 12/09/2009 Net Impact Expected from Implementation of regulatory provisions of SMP No change from current tree removal prohibition. Significant improved riparian vegetation and trees over long- term for properties that redevelop Significant improvement in riparian buffers if sites redevelop. Even with buffer reduction, there will be no change in buffer width but significant improvement in bank stability and riparian vegetation. Improved conditions for salmonids if new overwater structures built or old ones are upgraded. Fish and Wildlife habitat restoration areas protected Opportunities provided for in SMP for restoration of functions Adding LWD to reaches as mitigation and as part of development projects Restoration projects prioritized in transition zone esp. off channel and near channel areas Laying back and vegetating river banks with native plants