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HomeMy WebLinkAboutSEPA EPIC-294-85 - CITY OF TUKWILA - SOUTH 168TH STREETSOUTH 168T" ST PROJECT SOUTHCENTER PARKWAY & ANDOVER PARK WEST FILLING PORTION OF TUKWILA POND EPIC - 294 -85 • City of Tukwila PLANNING DEPARTMENT 6200 Southcenter Boulevard Tukwila, Washington 98188 (206) 433 -1849 To: From: L. Date: M E M O R A All Interested Parties March 14, 1989 U M SEPA Responsible Official Subject: SOUTH 168TH STREET ENVIRONMENTAL IMPACT STATEMENT The City determined that a final decision on road alignment is premature at this point. Therefore, the environmental review process for this project was terminated. A new environmental review process will be instituted when SEPA actionable project decisions are proposed. _ 1908 City of Tukwila 6200 Southcenter Boulevard Tukwila Washington 98188 (206) 433 -1800 Gary L. VanDusen, Mayor MEMORANDUM TO: Ross Earnst and Rick Beeler FROM: Ron Cameron, City Engineer ,f' >■ DATE: March 7, 1989 SUBJECT: South 168th Street Design Report Project No. 84 -RWO8 111 MAR 7 1989 Brian, Vernon, you and I discussed the South 168th Street design report on January 20. The most effective action for the report would be to put it on the Transportation Committee agenda to ACCEPT the report. Accept would be defined in the agenda item as meaning the report is accepted only, not adopted as a specific plan. It is a report that describes design alternatives and hearing findings. The report identifies alternative widths and alignments that could be constructed. A number of changes have occurred since the report work was done the pond development is about 200,000 feet instead of 1,200,000 square feet, the Bon is considering addition, and the area is identified as a wetland. Actual design width and alignment will be determined when development initiates the need for the additional access and capacity. Work on a ped corridor and combined Bon, pond, Godfather's /Toys R Us access will continue. Pursuing a final EIS at this time would be inappropriate. The CH2M Hill Transportation Plan work is evaluating east /west connection alternatives; that information will supercede the 168th findings. There are no funds budgeted to update the 168th report incorporating the CH2M Hill work. "Accepting" the report will allow completion of the contract with Entranco, formally recognize the design alternatives presented, and not create a public outcry of "adopting" the report that a specific street is to be built. At this time, there are several alternatives, it is not known what east /west improvement(s) is needed. Development and the additional studies will determine those recommendations. This report does not mandate a specific east /west choice for the CBD. Therefore, "accepting" it as advisory information is the appropriate action. RC /kjr Attachment: January 18, 1989 Jim Wiley Memorandum CC: Brian Shelton File: 84 -RWO8 Memo To Brian Shelton From: Dale Anderson & Jim Wiley Subject: South 18Bth - EIS input for Brian 1. The FEIS is in production for final review - If we assume the reteininq wall i� feasible - and I get that deci- sion by Friday 1/20, - � ecz- - , ' we could have it to the City for final by 1/31/89. rzna re- RECEIVED .�&`~ � u. � � � ��'^ ~� mp^� TUKVMA PUfaUC WORKS If we need to wait for further geotech input on the wall - we could have it to the City for final review within two weeks of recei i the input, v ng 2. Vern feels we should produce a supplemental EIS due to three reasons: 1) the 3onq delay in producing the FEIS; 2) the pending Bon plans; 3) the City's prelimnary OK for the Tmk Pon �t d*���pment. Vern thought that we would have to re-issue y � for comment at a minimum. re- ssue the DEIS From our perspective, we're not sure, based on SEpArequXa.ion re- view, why we have to do a supplemental EIS. It probably won't re- duce our chances ...of a project challenge by A d~b ~" u - ' e^nqe y u u on - it will cer- tainly add to the cost / the process. H- '' ~ ~ - Beeler's policy deci��io"' es , ow ever this will be Rick 3. Budget status - as Dale mentioned to Vern, the EIS project budget was expended a year ago. We are now on the 3rd or 4th re- view of the Final. ,The delays and start/stopsare costly to the- butoet. If the document undergoes more than one more review w'th changes, Entrarnco reeds additional funds. This is certainly ` |/e case ife we prepare a supplemental EIS., AF�DAVIT [[ Notice of Public Hearing Q Notice of Public Meeting [� Board of Adjustment Agenda Packet Q Board of Appeals Agenda Packet Q Planning Commission Agenda Packet Short Subdivision Agenda Packet [[ Notice of Application for Shoreline Management Permit [] Shoreline Management Permit OF D ISTRI UTI0N hereby declare that: 1 Determination of Nonsignificance [] Mitigated Determination of Non - significance [[ Determination of Significance and Scoping Notice [� Notice of Action [] Official Notice 1,1 Other • (48) S 0 Other was mailed to each of the following addresses on Name of Project File Number , 19 . DISTRIBUTION LIST Allied Stores X633 Southcenter Mall Tukwila, Washington 98188 Andover & Associates 854 East Mercer Way Mercer Island, Washington 98040 Attn: Mr. Thomas Yedor Auduhon Society Room 619 - Joshua Green Building Seattle, Washington 98101 Attn: Dyanne Sheldon 'Bon Marche c/o L. V. Miller 3rd & Pine Seattle, Washington 98111 Bon Marche Distribution Center 17000 Southcenter Parkway Tukwila, Washington 98188 Attn: Mr. William Hicks Buck & Gordon 1011 Western Avenue Seattle, Washington 98104 Attn: Mr. Jay P. Derr ,Chamber of Commerce 950 Andover Park East Tukwila, Washington 98188 Attn: Mr. Terry Anderson ,Chevron USA, Inc. P.O. Box 7611 San Francisco, California 94120 .Chevron USA 220 Strander Boulevard Tukwila, Washington 98188 ,City of Kent Public Works Department P.O. Box 310 Kent, Washington 98031 Attn: Mr. Don Wickstrom, Director I FROM I.lY 2 1987] rm7 l)T :. AV LA City of Renton P�El�- 7,1 ®,m Public Works Department 200 Mill Avenue South Renton, Washington 98055 Attn: Mr. Dick Houghton, Director City of Tukwila Mayor 6200 Southcenter Boulevard Tukwila, Washington 98188 Attn: Mr. Gary L. Van Dusen City of Tukwila City Clerk 6200 Southcenter Boulevard Tukwila, Washington 98188 Attn: Ms. Maxine Anderson ,City of Tukwila City Council 6200 Southcenter Boulevard Tukwila, Washington 98188 Attn: Ms. Wendy A. Morgan, Chair :City of Tukwila City Council 6200 Southcenter Boulevard Tukwila, Washington 98188 Attn: Mr. Edgar D. Bauch --City of Tukwila City Council 6200 Southcenter Boulevard Tukwila, Washington 98188 Attn: Mr. Joe H. Duffie -City of Tukwila City Council 6200 Southcenter Boulevard Tukwila, Washington 98188 Attn: Ms. Mabel J. Harris -City of Tukwila City Council 6200 Southcenter Boulevard Tukwila, Washington 98188 Attn: Mr. Charles E. Simpson City of Tukwila City Council 6200 Southcenter Boulevard Tukwila, Washington 98188 Attn: Ms. Marilyn G. Stoknes City of Tukwila City Council 6200 Southcenter Boulevard Tukwila, Washington 98188 Attn:. Mr. James J. McKenna Collins & Associats ' Suite 600, Merrill Place 411 First Avenue South Seattle, Washington 98104 Attn: Mr. Brad Collins J Commercial Design Associates 4230 - 198th Street S.W. Lynnwood, Washington 98036 Attn: Mr. Scott Shanks Davis Wright Todd Riese & Jones 110 - 110th Avenue N.E., #700 Bellevue, Washington 98004 Attn: Ms. Linda M. Youngs Delco Group 2219 Second Avenue Seattle, Washington 98121 Attn: Mr. Peter Orser Doubletree Plaza 1600 Southcenter Parkway Tukwila, Washington. 98188 Attn: Mr. George J. Neumann Doubletree Inc. 622.5 North 24th Street, #200 Phoenix, Arizona 85016 Attn: Mr. James R. Smith Firestone 215 Andover Park West Tukwila, Washington 98188 Attn: Mr. Dennis McGriff Mr. Larry Hanson Firestone Zone Marking Office P.O. Box 68907 Seattle, Washington 98168 Attn: Mr. Russ Paris First Western Development 4230 - 198th Street Lynnwood, Washington 98036 Attn: Mr. Mike Hess ',Foster, Pepper & Riviera 1111 Third Avenue Seattle, Washington 98101 Attn: Mr. John C. McCullough, Jr. Hayden Island Corporation 909 North Tomahawk Island Drive Portland, Oregon 97217 , J. C. Penny Company Regional Tax Office . #4015 Buena Park, California 90624 King County Surface Water Management Division Room 976 King County Administration Building Seattle, Washington 98104 Attn: Mr. Joe Simmler, Manager King County Traffic & Planning Division 9th Floor King County Administration Building Seattle, Washington 98104 Attn: Mr. John Logan, Manager King County Department of Planning 811 Alaska Building 618 - 2nd Avenue Seattle, Washington 98104 Attn: Environmental Coordinator ✓MacAulay Nicolls Maitland International SeaFirst 5th Avenue Plaza Suite 3900 Seattle, Washington 98124 Attn: Mr. Frank J. Agostino Metro 821 Second Avenue Seattle, Washington 98104 Attn: Mr. Dick Sandaas Metro ✓ Environmental Planning Division 821 Second Avenue South. Seattle, Washington 98104 i,01 � Matt Mikami 16813 Southcenter Parkway Seattle, Washington 98188 Office of Archaeology and Historic ✓ Preservation 111 West 21st Avenue, KL -11 Olympia, Washington 98504 Attn: Mr. Robert G. Whitlam z Puget Sound Air Pollution Control Agency P.O. Box 9863 Seattle, Washington 98109 Attn: Mr. Arthur Dammkoehler Puget Sound Council of Governments 216 First Avenue South Seattle, Washington 98104 Attn: Mr. Jim Williams Puget Sound Power and Light / 620 South Grady Way Renton, Washington 98055 Attn: Mr. Wayne Harris /Rainier National Bank Controllers Department 086 P.O. Box 3966 T14 -1 Seattle, Washington 98124 /Real Property West 44 Montomery Street, #4230 San Francisco, California 94104 Rosse Inc. c/o Samuel & Hazel Rosse 808 Howell Street Seattle, Washington 98010 M.A. Segale, Inc. "P.O. Box 88050 Tukwila, Washington 98188 Shidler McBroom & Gates 3500 First Interstate Center Seattle, Washington 98104 Attn: Mr. Gary D. Huff Shidler, McBroom, Gates & Lucas %/ Suite 505, Honeywell Center 600 - 108th Avenue N.E. Bellevue, Washington 98004 Attn: Mr. Dennis J. McLerran v Special Products Company P.O. Box 66314 Seattle, Washington 98166 Attn: Mr. Scott A. Salzer r Springridge Investment, Inc. c/o Jones & Grey & Bayley, P.S. 36th Floor One Union Square Seattle, Washington 98101 Springridge Investment Ltd. 1021 Island Road Victoria, British Columbia V8S 2V2 Canada Attn.: Mr! < Bruce Smith Stepan & Associates, Inc. 33505 - 13th Place South Federal Way, Washington 98335 Attn: Mr. Kent Stepan Trammell Crow Company P.O. Box 80326 Seattle, Washington 98108 Attn: Mr. Don Jefferson, Project Manager T.C.W. Realty Holding Company 400 South Hope Street Los Angeles, California 90071 Union Pacific Corporation Tax Office P.O. Box 2500 Broomfield, Colorado 80020 Union .Pacific Railroad v/1515 Building S.W. Fifth Avenue Portland, Oregon 97201 Attn: Mr. A.L. Shoener, General Manager Union Pacific System 1015 Andover Park West Tukwila, Washington 98188 Attn: Mr. Craig Schuler ,/Upland Drive Business Park 8815 38th Avenue N.E. Seattle, Washington 98115 U.S. Army Corps of Engineers Seattle District Environmental Resource Section P.O. Box C -3755 Seattle, Washington 98124 ✓ U.S. Department of HUD Valuation Department 1321 Second Avenue Seattle, Washington 98101 y U.S. Department of Interior Bureau of Land Management Regional Office East 4217 Main Street Spokane, Washington 99202 U.S. Postal Service Tukwila Branch 225 Andover Park West Tukwila, Washington 98188 Washington State Department of Game Program Manager. Environmental Affairs Team 600 North Capitol Way Olympia, Washington 98504 Washington State Department of Ecology Mail Stop PV -11 Olympia, Washington 98504 Washington State Department of Transportation District Design /Engineer/ Environmental Review 9611 S.E. 36th Street Mercer Island, Washington 98040 Washington State Department of Transportation 6431 Corson Avenue South Seattle, Washington 98104 Attn: Mr. Jerry Schutz Planning and Research Coord Washington State Office of the Attorney General Dexter Horton Building Seattle, Washington 98104 City of Tukwila 6200 Southcenter Boulevard Tukwila Washington 981,88 (206) 433 -1800 Gary L. VanDusen, Mayor MEMORANDUM TO: All I��sted Parties FROM: /I'j,/ Beeler, SEPA Responsible Official DATE. une 3, 1987 SUBJECT: SOUTH 168TH STREET DRAFT ENVIRONMENTAL IMPACT STATEMENT (DEIS) This DEIS was prepared pursuant to Chapter 197 -11, Washington Administra- tive Code, and is herewith being distributed for public review and comment. The key issues are wetlands, traffic circulation, and land use parking impacts. Alternatives to the proposal range from no action and a continued deterioration of traffic circulation characteristics (Figures 23 and 24) to a four -lane alternative with maximum loss of 2.8 acres of wetland and land use impacts (Table 1). The engineering basis for this DEIS is provided in a separate document entitled "South 168th Street - Design Report ", on file at the City of Tukwila Public Works Department. This DEIS includes the relevant informa- tion from that report. Written comments on this DEIS are due by July 3, 1987. VU /sjn attachment DRAFT ENVIRONMENTAL IMPACT STATEMENT FOR SOUTH 168TH STREET City of Tukwila Department of Public Works King County, Washington Prepared pursuant to The State Environmental Policy Act of 1971 Revised Code of Washington 43.21c and SEPA Rules, Effective April 4, 1984 Chapter 197 -11, Washington Administrative Code Date of Issue: nate Comments Due: and City of Tukwila Ordinance #1331 As amended by Ordinance #1344 June 3, 1987 July 3, 1987 Responsible Official • • MEMORANDUM To: 168th Street DEIS Reviewers From: Vernon Umetsu RE: 404 Permit Requirement Date: 5/13/87 1. Jim Green of the COE said that filling of more than one (1.0) acres of wetland would require a 404 permit. A Nation-wide permit would not be applicable in such a situation. the 168th Connector, requiring the filling of 2.8 wetland acres, would need a specific 404 permit. 2. A 404 permit requires that the applicant first show no other practical alternatives to the action. Green suggests that we contact Karen Northrup of his office to determine what level of project justification (if any) is necessary to meet this criteria. 3. The Traffic Circulation section of the 168th DEIS does not demonstrate a high level of project justification in 1990. 4. The Public Works Department may want to review again the DEIS to ensure that this is the document they want the COE to rely upon in their analysis of the City's 404 permit application. 5 Planning will await a specifit instruction to proceed with the DEIS before any further work. April 16, 1987 City of Tukwila 6200 Southcenter Blvd. Tukwila, WA 98188 Attention: Mr. Jack Pace Re: 168th St. Extension EIS Report Dear Mr. Pace: 1P)11- [APR 17 1987 L—_ T WO:VILA PLANNING DEPT. To confirm our conversation, I would like to receive a copy of the EIS. for the -168th St. Extension. Please forward this information to: Scott Salzer P. 0. Box 66314 Seattle, WA 98166 In addition I would appreciate any formal presentation, proposal or additional EIS documents that pertain to the "Tukwila" pond site and its development. Regards, Scott Salzer RE: • • TELEPHONE MEMO Renton - Tukwila Boundary Adjustment PERSON CONTACTED: Vernon Umetsu, Tukwila Ping. L` PERSON CALLING: Jim Matza, Union Pacific Railroad, Rea1:,Estate Dept. (402- 271 -3194) DATE: 3/27/87 INFORMATION ITEMS: 1. Send all further land use communications to: A.O. , Meyer, Dir. of Real Estate, Western Division 1416 Dodge Street Room 300 Omaha, Nebraska 68179 2. UPRR has no objection to the proposed Tukwila Zoning; especially the R =A (AG.) zoning between the tracks. 3. Questions regarding moving UPRR tracks to the west „to mate with BNSF Burlington Northern Railroad tracks,should be directed to the following: E. C. May General Manager UPRR Salt Lake District Office Building 406 W. -- 1st South Salt Lake City, Utah 84101 Atten.: Norm Si1er, Dir. of Engineering Svcs. (801 - 350 -3442) c r oiy (PC /VG • • September 29, 1986 City of Tukwila Planning Dept. 6200 Southcenter Blvd. Tukwila, WA 98188 Attention: Mr. Jack Pace Re: Tukwila Pond Site Design Report S. 168th S Dear Mr. Pace: SEP u 0 1986 CITY OF IUKVViLA PLANNING DEPT. As an individual concerned with the "proper "" development of the Tukwila Pond site, I would like to make the following comments relative to the above referenced project. As in previous correspondence, I would like to point out that I am not a resident of Tukwila. In spite of this, I have spent considerable time at the pond since 1974 and have followed proposed uses and impacts with great interest. I have had the opportunity to briefly review the Design Report S. 168th St.. and have the following comments. Recommendations were made as early as 1979 for cross streets in the "superblock ". This was at a time prior to alot of the extensive development that now exists. Before the superblock was completed, it seems that it would have been prudent to provide cross streets while the opportunity existed. This gross oversight shows a lack of planning for the ultimate use of the area. While extensive development was allowed, little consideration was given to the results on traffic flow. Now to correct the problem, the S. 168th St. proposal touches the most sensitive environment that has existed and does exist in the superblock. I would like to refer to a previous Draft EIS, dated Dec. 1979, "Tukwila Center - Chartwell Development Corp. ", page 50 para. 2, which states "The variety and productivity of the site are unmatched on any comparably sized site in the Green River Valley or greater Seattle area ". As I mentioned in 1980, this observation should not be taken lightly. Further comments on this will be reserved until the current Draft EIS is finalized. Admittedly I am not a traffic engineer, nor do I pretend to be, but I cannot see how this extension will solve or reduce the traffic problems in this superblock area. This is particularly true since traffic lights are propsed at the intersections of S. 168th St. on Southcenter Parkway and Andover Park W.. Rather • • than two intersections at Strander Blvd. /Andover Park W. and Strander Blvd. /Southcenter Parkway subject to back -ups, there would now be four. This proposed project is not a safety related issue, as the design report states, but appears to be an attempt to say "we are trying to do something ". Also, this proposed extention does nothing for the remainder of the superblock, which is the ultimate destination for most of the traffic. Further this project cannot be related to future development of the Tukwila Pond site, as there currently is no proposal being presented. In conclusion, to-sacz-ifice 1/2 acre of an extremely sensitive and diverse system to provide a band -aid solution , does not seem to be in the best interest of the area. This proposal is to make up for the lack of planning and foresight on th part of the city planners. I do not feel that the extension will provide the relief for which it is intended and the City of Tukwila should consider other alternatives. Regards, Scott Salz P. 0. Box 66314 Seattle, WA 98166 (206) 243 -4412 P. S. - Please include my name on the list for receipt of the final EIS cc: Mr. Joe Duffie President - Tukwila City Council SHI,LER McBROOM GATES &LUCAS Seattle ATTORNEYS AT LAW • A PROFESSIONAL SERVICE CORPORATION Bellevue 'Respond to: 3500 First Interstate Center Seattle, Washington 98104 Telephone (206) 223 -4600 Telecopier (206) 622 -5110 Telex: 29 -2988 CRAIG V. WENTZ Seattle Office February 5, 1987 Vernon M. Umetsu, Associate Planner Planning Department City of Tukwila 6200 Southcenter Boulevard Tukwila, WA 98188 Re: Proposed 168th Street Extension Dear Mr. Umetsu: 505 Honeywell Center 600108th Ave. N.E. Bellevue, Washington 98004 Telephone (206) 453 -0300 166 FEB 0 0 1987 CITY OF TUKWILA PLANNING DEPT. Confirming our earlier conversations, please ensure that I am included on the mailing list for the D.E.I.S. for the above - captioned project. I have always appreciated your willingness to keep us advised on the project and will look forward to visiting you some time in the future. cc: William Hicks, P.E. CVW:jg 29 -042 9263 -1 Sincerely, SHIDLER McBROOM GATES & LUCAS Craig V. Wentz JACK S. WAYLAND Director STATE OF WASHINGTON DEPARTMENT OF GAME 'Region Four Office, 16018 Mill Creek Boulevard, Mill Creek 98012 - Tele March 25, 1987 Rick Beeler Planning Director City of Tukwila 6200 South Center Blvd. Tukwila, Washington 98188 1.-81M[TNE.--1 MAR 27 19871 CITY f ;. ! . Kv t I LA !b.o. 0Vg i1 PT. Re: Proposed street construction through the bed of Tukwila Pond Dear Mr. Beeler: I have been contacted by Entranco Engineers regarding whether a Hydraulic Project Approval (HPA) will be required for that part of the project which will encroach within the ordinary high water line of the pond. (As required under RCW 75.20.100). Our verbal response to them was that an HPA will be required. This letter is to document our response, so that those entities involved in the project can complete their planning. If you have any questions regarding this letter, please contact me at (206) 775 -1311. Sincerely, THE DEPARTMENT OF GAME TAM:cj a,f4de4.1 Theodore A. Muller Regional Habitat Program Manager cc: Phil Schneider Habitat - Olympia Dale Anderson - Entranco Engineering • • DEPARTMENT OF THE ARMY SEATTLE DISTRICT, CORPS OF ENGINEERS P.O. BOX C-3755 SEATTLE, WASHINGTON 98124-2255 REDLY TO ATTENTION OF Regulatory Branch MAR 2 198T Mr. Ralph C. Colby King County Building and Land Development Division 450 Ring County Administration Building 500 Fourth Avenue Seattle, Washington 98104 Reference: Tukwila Pond Dear Mr. Colby: This is in response to your letter of February 2, 1987, concerning the Corps of Engineers jurisdiction in Tukwila Pond at Tukwila, Washington. You requested that the Corps make a jurisdictional determination in light of a proposed development that would eliminate Tukwila Pond. In late 1986, the Corps of Engineers published new permit regulations which became effective January 12, 1987. These regulations provide clarification by the Environmental Protection Agency of the definition of waters of the United States and now include waters: (1) which are or would be used as habitat by birds protected by Migratory Bird Treaties or (2) which are or would be used as habitat by other migratory birds which cross state lines. This clarification is significant because it expands the Corps Sectioh 404 jurisdiction. Tukwila Pond is now considered to be a water of the United States and subject to Department of the Army permit requirements under Section 404 of the Clean Water Act. Under Section 404, authorization is required for the discharge of dredged or fill material into waters of the United States, including wetlands. If you have any questions concerning this determination, please contact Mr. Jim Green, telephone (206) 764 -3495. Sincerely, Samuel R. Casne Chief, Environmental and Processing Section King County Building & land Development Division Parks, Planning and Resources Department 450 King County Administration Bldg. 500 Fourth Avenue Seattle, Washington 98104 February 2, 1987 Mr. Mike Bowlus U. S. Army Corps of Engineers Post Office Box C -3755 Seattle, WA 98125 -2255 RE: Tukwila Pond: Jurisdiction Dear Mr. Bowlus: • ,R4 -1987 J This agency has recently received an EIS Scoping Notice for a project involving the potential elimination of Tukwila Pond in the City of Tukwila, Washington. The site is located immediately south of Strander Boulevard, between Southcenter Parkway and Andover Parkway. We would request that the Corps make a determination as to whether this waterbody is under your jurisdiction in light of the pending EIS and potential development of the site. Please contact Dyanne Sheldon at 344 -5287 if you have further questions. Ralph C. Colby Interim Supervisor Technical Services Section RCC:DS:klc cc: Dyanne Sheldon, Environmental Planner ANDREA BEATTY RINIKER Director STATE OF WASHINGTON . DEPARTMENT OF ECOLOGY 4350 - 150th Ave. N.E. • Redmond, Washington 98052-5301 • (206) 885 -1900 RECEIVED FE B 4 1987 TUI;VJ;LA PLL:IC WORKS January 30, 1987 Mr. Byron Sneva Public Works Director - City of Tukwila 6200 Southcenter Boulevard Tukwila, WA 98188 Dear Mr. Sneva: To further clarify the Department of Ecology's role in flood plains as it relates to the city of Tukwila and to provide a degree of certainty to applicants proposing developments within the Green River Flood Control Zone No. 2 in King County, we recommend you use the following steps: 1. Verify if the site is within the Green River Flood Control Zone. _ v0,,lh 2. Verify the type of zone the site is within on the Flood Insurance Rate Map (FIRM) prepared by The Federal Emergency Management Agency (FEMA). Zones A, B, C and D. 3. If the site is within Flood Control Zone 2 of the Green River and within an A Zorie on the FEMA FIEM, have the applicant file a Flood Control Zone Application with King County Surface Water Management Division. King County Surface Water Management Division will review the application and request additional information if needed for evaluation in terms of chapter 508 -60 WAC, Administration of Flood Control Zones. Upon completion of their review and evaluation, the county will transmit the application to the Department of Ecology, Northwest Regional Office, together with recommendations. The Department of Ecology will issue a permit based on the recommendations and in accordance with Flood Control Zone regulations. W. Byron Sneva January 30, 1987 Page 2 4. If the site is within Flood Control Zone 2 of the Green River and within a B, C or D Zone on the FEMA FIRM, notify the applicant by letter that a state Flood Control Zone Permit is not required and send a copy to the Department of Ecology, Northwest Regional Office. We look forward to hearing from you soon. Sincerely, Herm H. Huggins Resource Management HH:cd cc: Nancy Ellison Dave Clark, King Co. Roy Bishop Janet Jorg Ed Hammersmith ' �~^/� ��� -ces^' �J��� Memo NOV - -~"o To: Jim Wiley 7 From: Dale Anderso ~p« Subject: Finaliza of South 168th DEIS - Issue of -~ Wetlands and Mitgation Text 1. I'd like to summarize my perception of activity to date and provide some recommendations. We provided a pre-draft to the City with some definitive recommendations for wetland mitigation. The City's predraft comments directed us to delete most of the detail with mitigation plans, although it still had a clear committment to mitigation. Difference of opinion on the mitigation issue between Public Works and Planning resulted in Brian's requestion we use a less definitive statement (in Rex & my opinion) concerning mitigation. (These different text versions are attached). Rex and I have discussed this on Saturday and have the following recommendations: Our first recommendation is to go with the depth of mitigation stated in the pre-draft. We think the project record is clear that this was the consultants' recommendation (Do we have a file copy of the transmittal letter and copy to Brian?). If this project gets into a lawsuit, I think we should document these changes are the City's preference. If they don't prefer the mitigation detail, then we offer the verbage stated in the attached Insert M. We feel that is provides a clear committment to mitigation. Even though it lacks detail, we think it will be an adequate DEIS statement. The disadvantage to the City is that it will open the door for the resource agencies to define mitigation for the City. Or it will result in a request by the client for the consultant to prepare such a mitgation plan in the final DEIS. If this occurs, I'd recommend the client be prepared for a change order. This change order would involve preparation of a mitigation plan (for Rex and EEI). We think use of the City's preferred insert M verbage may result in the agencies feeling the DEIS is not adequate. This could lead to permit denials down the road. I'm trying to avoid any more iterations on the DEIS from a budget perspective. I hope you can convince the client to accept our text. Rex indicated he would like his name off the document if mitigation is not a committment - I tend to agree. Please let me know the outcome so we can finalize the DEIS. cc: Morency & Van Wormer City's comments to Pre-draft Insert M * Dense riparian and deciduous trees will be planted on the slope easement as shonw in Figure 11. This will discourage casual pedistrian intrusion into the pond area, minimize spillover from street lights and provide replacement resting/nesting. (This is OK with us) Insert M continued * Wetland meadow, treed area of snag swamp and riparian border areas within the wetland border of Figure 10 will be replaced at other sites in the general area. Replacement will occur within years after construction. Possible sites for off-site options include expansion of the P-17 channel and/or P-1 drainage retention pond(s) and replanting with riparian vegetation along portions the Green River, and combining City mitigation with other off-site mitigation projects of unnamed projects. Brian asked Jim to delete the above verbage and replace with * Wetlands will be replaced on site or off site • depending on available properties or development related activities. Vern ok'd this change via phone to Dale Rex and Dale's recommendation is to be more specific on mitigation and follow our pre-draft recommendation. However, in light of the City's desired DEIS strategy, we suggest to use this for insert M: * Wetlands (including the wet meadow, riparian edges, and pond) will be replaced on site and/or off site. The location and type of mitigation will be dependent on the present availability and capability of sites that can be enhanced to sufficiently offset losses associated wit impacts of the South 168th project. Insert K Biological data suggests the likelyhood that the Tukwila Pond site may be a valuable, significant wildlife habitat area for its wetland values to migratory waterfowl. These birds use it as a stop-over resting area and long-term wintering and nesting ground. This site has not been designated as a significant wetland habitat by any federal, state or local agency with jurisdiction. However the City will recognize the site's wetland habitat valuse and mitigate for them. A more detailed discussion of plants and animals at the Tukwila Pond property is presented below and in Appendix B. (continued) Insert K - We suggest to use this instead: Biological data suggest that the Tukwila Pond site is a highly used waterfowl area which is integrated with the Green River to the east. These birds use it as a stop-over resting area and long-term wintering and nesting ground. This site has not been designated as a significant wetland habitat by any federal, state or local agency with jurisdiction. However the City will recognize the site's wetland habitat valuse and mitigate for them. A more detailed discussion of plants and animals at the Tukwila Pond property is presented below and in Appendix B. ;1909 City of Tukwila 6200 Southcenter Boulevard Tukwila Washington 98188 (206) 433 -1800 Gary L. VanDusen, Mayor MEMORANDUM TO: Gary Van Dusen FROM Vernon Umetsu (/1. DATE: August 21, 1986 SUBJECT: 168th Street Extension 1) The Transportation Committee met to consider design alternatives for the 168th Street Connector (between Southcenter Parkway and A.P.E.). 2) The Committee strongly supported alternative A (4- lanes, 70 ft. intrusion along entire south end of Pond Property). 3) The Committee forwarded item to COW and unanimously wanted to take action concurring with the consultant recommendation that alternative A be selected for construction. 4) I pointed out to the Committee that Council action indicating preference for one alternative prior to completion of the E.I.S. process would probable violate SEPA regulations. The Committee did not agree. 5) Jim Haney feels that it would be all right for Council to indicate a preference in in context of a COW discussion if it was clearly identified as a preliminary finding and subject to the findings of the E.I.S. process. Haney would defineitely advise against adoption of any resolution on this matter. 6) I would recommend that Council members be appraised of these findings. cc: Planning Director City Attorney . � � » - •AK®>® . . ._. 4 • \ 2 _. -e y K� / .� ..y /�, \� , on • TELEPHONE MEMO RE: 57 'FO S /682"61 S7 87 PERSON CONTACTED: T/M &) / G �S�" — 0 6 83 rowribitivco> PERSON CALLING: �,��, � Goc ��..�.., DATE: 2 -72s'/ INFORMATION ITEMS: 675 3/* 78 . �.. �. / Ll_ WOW - T.2 � ,ir RE: TELEPHONE MEMO Cam- gere,,,4_e_ PERSON CONTACTED: E,c�Ci( ) C , PERSON CALLING: DATE: Z %U /B INFORMATION ITEMS: C - — (044, 6,;(.1,4"-ze. 7:Z4),t-e. d,L;"9--&-e-ed: S-F37- -f6 136 TO: FROM: DATE: SUBJECT: City of Tukwila 6200 Southcenter Boulevard Tukwila Washington 98188 (206) 433 -1800 Gary L. VanDusen, Mayor MEMORANDUM South 168th EIS File Vernon Umetsu iJ February 10, 1986 Comments of Dyanne Sheldon, King County Planning (344- 5287), on the Tukwila Pond Site development as reported in the Record Chronicle of February 9, 1986 and other general comments on pond development Information Items 1. King County has not rated Tukwila Pond on its 3 -tier wetlands value scale since it is outside King County's direct administrative jurisdic- tion. However, it is not unreasonable to expect that the pond would receive a #2 rating on such a scale. In evaluating the importance of a "2" rating, it is essential to understand the way in which a "2" is arrived at. A "1" rating would be given to unique and outstanding wetland areas. The criteria for such wetland areas are as follows: a. Areas containing species given state or federal rare and endangered or threatened status; b. Wetlands with a near or equal proportion of open water and terrestrial areas, terrestrial areas being in patches, and such areas having a high diversity of species; c. Areas greater than 10 acres, with 3 or more wetland classification areas, one of which must be open water; or d. Presence of environments which are infrequently found in King County. Any one of these criteria could be reason for designation of a Class 1 (unique and outstanding) wetland area. A Class 3 wetland area is characterized as having less than one acre of open water with low species diversity. Also, they would be those 'South 168th ConnectoW Comments February 10, 1986 Page 2 • wetland areas below the tenth percentile in three or more of the characteristics by which King County rated wetland areas. These would include such characteristics as low species diversity, low plant or habitat diversity and so forth. Class 2 wetlands would be all those wetlands not rated as Class 1 or Class 3. For example, Angle Lake would be a Class 2 wetland area. Based on the rating system above, it is clear that Class 2 wetlands are fairly wide spread and, while they do indicate the need for environmen- tal sensitivity in any proposed developments adjacent or on such areas, they do not constitute a unique and outstanding environment to be given especially strong protections and /or preservation. 2. Sheldon states that the value of Tukwila Pond lies in its relative uni- queness in the City of Tukwila and that the Green River does provide a much more valuable overall habitat for waterfowl and water associated species. However, Tukwila Pond provides an important resting habitat for such species as babbling ducks which use still ponds rather than areas with flowing waters. Please note that babbling ducks are not rare and endangered or threatened on either the federal or state species list. 3. The development of a road would not affect any of the species currently known to be on the Pond. However, human intrusion, as defined as "people walking to and from along the road" will affect certain species of ducks, such as widgens and gadwalls, which are very shy. These species can easily tolerate automobile traffic, but not human intru- sion. Other species such as mallards are highly tolerant to human intrusion. Sheldon maintains that any mitigation measure, even one which goes to the extent of duplicating habitat further to the north of the proposed roadway, would be speculative in its effectiveness. This is because the existing complexity of the affected habitat area could not be immediately achieved with the newly created areas and that the uses which would be established in this relatively immature habitat area may affect the ultimate complexity which the new habitat area could achieve. 4. The King County response to the 168th Scoping Notice, identifies the Tukwila Pond site as "...providing excellent and rare habitat." Sheldon states that the rare habitat provision should be viewed only in the context of being rare within the City of Tukwila; it is not rare within the overall context of King County. (POND1) (1B) 5. Sheldon is Conservation Chair of the Seattle Audobon Society. City of Tukwila 6200 Southcenter Boulevard Tukwila Washington 98188 433 -1800 , Gary L VanDusen, Mayor February 6, 1986 Dale Anderson Entranco Engineers 1515 116th Ave. NE Suite 200 Bellevue, WA 98004 Re: South 168th DEIS Scoping Dear Dale: In response to your letter of January 27, 1986, the Planning and Public Works departments concur that the DEIS scoping process is complete. It is now my understanding that the existing scope represents the consensus of city representatives and Entranco as to what analyses are necessary to pro- duce a substantively adequate EIS for the proposed South 168th Street improvement. I must emphasize that Part A.4 of our contract with Entranco calls for your firm to prepare an EIS sufficient to satisfy the procedural and substantive requirements of SEPA. This city expectation was fully communicated to Entranco during contract negotiations by Phil Fraser. The City will con- tinue to assist Entranco in focusing the work for elements of the environ- ment which are central to the impact analysis, but Entranco will continue to bear full responsibility for all necessary analyses to meet SEPA requirements. With regard to the substantive DEIS content, Entranco recommended addi- tional wildlife studies in paragraph six of your letter dated January 10, 1986. The Planning Department does not feel it is necessary, but does not prohibit Entranco from conducting such a study if Entranco now feels this is required to satisfy SEPA requirements. However, no additional funding will be allowed, since analysis of wetland impacts were specifically iden- tified as critical to a substantively complete EIS during contract nego- tiations and is considered to be part of the original scope of work. Additional comments to your letter of January 27, 1986, are listed below: 1. Land use impacts of the road should be assessed and landowners /tenants may be contacted. 2. It is very appropriate to evaluate road impacts on the pond property. However, it is not necessary to discuss the impacts of pond property Dale Anderson February 10, 1986 Page 2 development on the environment, except for a general discussion of cumulative impacts associated with the road improvement. 3. A summary of pond parcel development history is not necessary since it does not focus on the direct and indirect impacts of road development. 4. The positive and negative secondary environmental impacts of the road on all affected parcels should be qualitatively discussed. The pond parcel should not be singled out for detailed analysis of secondary impacts except as the number and scope of secondary impacts may be greater on this parcel. 5. Vernon Umetsu will conduct a building setback analysis in place of Rick Beeler. Please contact me immediately if there are any misunderstandings which we must still clear up._ Sincerely, Vernon M. Umetsu Associate Planner cc: Mayor Planning Director City Engineer City Attorney File /ks (POND) (1B) • ENTRANCO ENGINEERS, INC. January 27, 1986 Mr. Brad Collins Planning Department City of Tukwila 6200 Southcenter Boulevard Tukwila, Washington 98188 Attention: Vern Umetsu 1515.110TH AVENUE NE, SURE 200. BELLEVUE. WASHINGTON 98004 1208) 454 -0883 01E- ∎ lE- ilitli=j 1 FEB Re: Meeting Conclusions S. 168th Street EIS City's Response to Scoping Recommendations Entranco Project 86042 -66 Dear Brad: JAN 28 �86 CITY OF TUKWILA PLANNING DEPT. Thank you for taking time to meet with us on January 17, 1986. This letter summarizes the decisions made at that meeting concerning the EIS portion of the S. 168th Street contract. Those attending the meeting included Phil Fraser, Brad Collins, and Vern Umetsu from Tukwila; Jim Wiley, David Morency, and Dale Anderson of Entranco. I have keyed the following information to the meeting agenda. Background - Rick's Request for Scoping Comment Summary Dale mentioned that the scoping summary and Entranco's recommendations (January 10th letter to Rick) were requested by Rick on January 2, 1986. Jim provided a summary of alternatives: The-project will involve a 50-foot/ roadway width from edge of property line to the north. In addition, a- normal:f.il l slope (2:1) would extend farther north into the pond. Further- analytttrOf,.= al ter a1tf-vesAszptanned: Summary of Entranco Recommendations to Scoping Comments p ), 15 A.e,€4e { +Y.• re.:. Wildlife Change in Scope. Dale escribed the reco nded change which would respond to. the Audubon S iety's scoping c ment. Brad indicated/ that n o c l i g rr g e " ' i n ' "scope will be' al l owed: The. y's preference i s to keep the impact analysis focused- on the direct roadway impacts to wetland' habitat: Dale described Entranco's intent to map only the habitat along the southern boundary of the pond .and provide a more general map of the entire pond in the EIS. Possible mitigation measures for the pond will be' focused:_on 'the- pond area. directly affected: It. should be noted that the, t w absence of fish: sampling data could be the cause for the Department of Game= to deny a hydraulics permit approval-: of 'fuZ. Sc.r, fit, I(.4 be EVERETT OFFICE: 519 SEATTLE-FIRST NATIONAL BANK BULGING, EVERETT. WASHINGTON 98201 1208) 258.6202 Mr. Brad Collins Planning Department City of Tukwila January 27, 1986 Page 2 Pond Policy. Brad recommended that we reference the Comprehensive Land Use Plan and the pond's designation as a parcel for special _development -6`"`A. considerations due to environmental constraints. IRMEEtiedfie!n1414'4lig sl- ikagepttataes04W00416STCHWWiiitt4MWTEOFAMMTOWWW, No additional clarification of the City's pond policy is possible at this time. It is possible that the mitigation identified in the EIS may eventually become the "special development considerations" for the road project. Economic Impacts City Input. konOmit-9 etementjinfOrliation: in the EIL:*. •Thi.s.informatlow Is. to .be 17tontrideredAtlfrr Utiem3StigeOtftttiMprojtetV No attempt should be made in requesting economic impact estimates from landowners, evert re,Wf-e, 45 Change in Scope. The City does not desire any proposals for adding an economic element. Any impacts to adjacent property owners should be addressed as land use issues. North-South Connector kits Ittlftilotappropriate to discuss potential impacts of this-tproject to the' ' 15 Offefft■Ociperty.74,14w-the!..-ELSV The'CitVprefers- we identify- that they nortiv=south connector is on the TIP and that we qualitatively discuss'itsf relationship with South 168thffr The primary purpose of the north-south, connector is to service the pond parcel when developed,. Secondary Impacts The secondary impacts discussion, as it relates to the pond parcel, will be addressed as follows. Ar-summary will be provided of the parcel's, developmentzthi5tork; the primary purpose of South 168th will be stated, (eaW4limMitgtonnector), and both thetiivt_ALLO negative impacts South' 1680:4421WhiiCowthe parcel will be qualitatively discussed. Other pond) parce523MPactifrom undefined future development would be entirely speculative:at'this time and will not be mentioned for this EIS: -tht Traffic Analysis - Areawide Analysis e.-.4.t.-P) e 7.t^-4- The slifeettkffboOditleVof our traffic analysis are adequate. 4e-c,4 J;rect - Aska P& /4",•-eZ- P. 141— 13)/A-• I 5.±. 4-11 vw Mr. Brad Collins Planning Department City of Tukwila January 27, 1986 Page 3 /ASS Approach to Draft EIS Comment Response veli I s y, asdefeFmi ned'.by,, the7 City' basedk' on `:Draft' EIS:-comments i (c't wirF beecovered "•by= contract'•. amendment. Ccry ors- Legal Liabilities /Appeal Process Review fi!tshould consult the City's adopted SEPA ordinance for further insight o the SEPA appeals process. Annle..gahaestimonys;retiufire4las urresult of 000/70Wbe:COVered7bY contract: amendments. Minkler Experience - City Suggestions and Land Use /Wildlife Issues 7 Vern needs the EIS to include an 11 x 17 photo (1" = with property lines, right -of -way, and edge of slope easement ma Tre dge° of stopei easement_canabe•considered part of -the 'setback: A tabular summary of the -/ acreage of land area affected, number of parking spaces eliminated, building setbacks (R�i ck Beeler-win not provide a . special setback analysis/-- Ywhe indtcated), and operational impacts. Schedule Jiiii iS'ndieated' the EI'S is about' two. months behind the scheduler'. The EIS team is waiting for .a project description, including definition of alternatives. Phil wants the EIS to proceed. Thank you for your direction and the opportunity to focus our approach. This letter and the previous one to Rick Beeler satisfy provisions. in our ' contract to evaluate the EIS scoping implications relative to our scope of' work: Sincerely, ENTRANCO IN Dale E. Anderson Senior Environmental Scientist cc: Phil Fraser Jim Wiley Vrw w A4' 5-1Y ENTRANCO ENGINEERS, INC. 1515 -116TH AVENUE N.E., SUITE 200, BELLEVUE, WASHINGTON 98004 (206) 454 -0683 January 27, 1986 Mr. Brad Collins Planning Department City of Tukwila 6200 Southcenter Boulevard Tukwila, Washington 98188 Attention: Vern Umetsu Re: Meeting Conclusions S. 168th Street EIS City's Response to Scoping Recommendations Entranco Project 86042 -66 Dear Brad: bE@..DWG® JAN 28 1986 CITY OF TUKWILA PLANNING DEPT. Thank you for taking time to meet with us on January 17, 1986. This letter summarizes the decisions made at that meeting concerning the EIS portion of the S. 168th Street contract. Those attending the meeting included Phil Fraser, Brad Collins, and Vern Umetsu from Tukwila; ,Jim Wiley, David Morency, and Dale Anderson of Entranco. I have keyed the following information to the meeting agenda. Background - Rick's Request for Scoping Comment Summary Dale mentioned that the scoping summary and Entranco's recommendations (January 10th letter to Rick) were requested by Rick on January 2, 1986. Jim provided a summary of alternatives: The project will involve a 50 -foot roadway width from edge of property line to the north. In addition, a normal fill slope (2:1) would extend farther north into the pond. Further analysis of alternatives is planned. Summary of Entranco Recommendations to Scoping Comments Wildlife Change in Scope. Dale described the recommended change which would respond to the Audubon Society's scoping comment. Brad indicated that no change in scope will be allowed. The City's preference is to keep the impact analysis focused on the direct roadway impacts to wetland habitat. Dale described Entranco's intent to map only the habitat along the southern boundary of the pond and provide a more general map of the entire pond in the EIS. Possible mitigation measures for the pond will be focused on the pond area directly affected. It should be noted that the absence of fish sampling data could be the cause for the Department of Game to deny a hydraulics permit approval. EVERETT OFFICE: 516 SEATTLE -FIRST NATIONAL BANK BUILDING, EVERETT, WASHINGTON 98201 (206) 258-6202 • • Mr. Brad Collins Planning Department City of Tukwila January 27, 1986 Page 2 Pond Policy. Brad recommended that we reference the Comprehensive Land Use Plan and the pond's designation as a parcel for special development considerations due to environmental constraints. No reference should be made that Resolution 736 (Chartwell) is current City policy. No additional clarification of the City's pond policy is possible at this time. It is possible that the mitigation identified in the EIS may eventually become the "special development considerations" for the road project. Economic Impacts City Input. The City prefers to not include any economic element /information in the EIS. This information is to be considered at a later stage in the project. No attempt should be made in requesting economic impact estimates from landowners. Change in Scope. The City does not desire any proposals for adding an economic element. Any impacts to adjacent property owners should be addressed as land use issues. North -South Connector It is not appropriate to discuss potential impacts of this project to the pond property in the EIS. The City prefers we identify that the north -south connector is on the TIP and that we qualitatively discuss its relationship with South 168th. The primary purpose of the north -south connector is to service the pond parcel when developed. Secondary Impacts The secondary impacts discussion, as it relates to the pond parcel, will be addressed as follows. A summary will be provided of the parcel's development history, the primary purpose of South 168th will be stated (east -west connector), and both the positive and negative impacts South 168th will have on the parcel will be qualitatively discussed. Other pond parcel impacts from undefined future development would be entirely speculative at this time and will not be mentioned for this EIS. Traffic Analysis - Areawide Analysis The superblock boundaries of our traffic analysis are adequate. Mr. Brad Collins Planning Department City of Tukwila January 27, 1986 Page 3 Approach to Draft EIS Comment Response Any further study, as determined by the City based on Draft EIS comments, will be covered by contract amendment. Legal Liabilities /Appeal Process Review We should consult the City's adopted SEPA ordinance for further insight into the SEPA appeals process. Any legal testimony required as a result of appeals will be covered by contract amendment. Minkler Experience - City Suggestions and Land Use /Wildlife Issues Vern needs the EIS to include an 11 x 17 photo (1" = 200') with property lines, right -of -way, and edge of slope easement marked. The edge of slope easement can be considered part of the setback. A tabular summary of the acreage of land area affected, number of parking spaces eliminated, building setbacks (Rick Beeler will not provide a special setback analysis as he indicated), and operational impacts. Schedule Jim indicated the EIS is about two months behind the schedule. The EIS team is waiting for a project description, including definition of alternatives. Phil wants the EIS to proceed. Thank you for your direction and the opportunity to focus our approach. This letter and the previous one to Rick Beeler satisfy provisions in our contract to evaluate the EIS scoping implications relative to our scope of work. Sincerely, ENTRANCO IEGINE� NC. Dale E. Anderson Senior Environmental Scientist cc: Phil Fraser Jim Wiley SOUTH 1681TREET - EIS MEETING AGENDA • DATE: 1/17/86 PLACE /TIME: TUKWILA CITY HALL - 3:00 P.M. eg_eSerr PERSONS I : PHIL FRASER, BRAD COLLINS, VERN UMETSU, , JIM WILEY, DAVID MORENCY (ENTRANCO) REQUESTED BY: DALE ANDERSON (ENTRANCO) AGENDA ITEMS: BACKGROUND - RICK'S REQEST FOR SCOPING COMMENT SUMMARY SUMMARY OF ENTRANCO RECOMMENDATIONS TO SCOPING COMMENTS WILDLIFE CHANGE IN SCOPE- POND POLICY ECONOMIC IMPACTS CITY INPUT CHANGE IN SCOPE TUKWILA POND PARCEL DEVELOPMENT POLICY NORTH / SOUTH CONNECTOR SECONDARY IMPACTS TRAFFIC ANALYSIS AREAWIDE ANALYSIS NORTH / SOUTH CONNECTOR APPROACH TO DRAFT EIS COMMENT RESPONSE LEGAL LIABILITIES / APPEAL PROCESS REVIEW MINKLER EXPERIENCE - CITY SUGGESTIONS LAND USE / WILDLIFE ISSUES - VERN MEETING RESULTS / ACTION NEEDED: ENTRANCO ENGINEERS, INC. January 10, 1986 Mr. Rick Beeler Planning Department City of Tukwila 6200 Southcenter Boulevard Tukwila, Washington 98188 Dear Rick: 1515 -116TH AVENUE N.E., SUITE 200, BELLEVUE, WASHINGTON 98004 (206) 454-0683 RORIE JAN 131886 CITY OF TUKWILA PLANNIN DEPT. This letter is in response to your January 2, 1986 request for a summary of the scoping implications to the EIS portion of the South 168th Street contract. Attached is a summary of the scoping comments received. They are keyed to the environmental categories we established as a result of our November 7, 1985 project meeting and are found in the scoping notice. We believe the degree of controversy generated so far is greater than anticipated. As a result, I have communicated our approach on select environmental elements (see summary), so you know the level of effort and what will be produced. I have also made specific recommendations below. Of primary concern are the Water, Plants, Animals, Land and Shoreline Use, Transportation, and Economics elements. Key issues which need attention include: (1) define the City's policy for the Tukwila Pond parcel, (2) decide on the need to expand the scope to address the pond's regional importance as wildlife habitat, (3) decide on the extent of secondary impact analysis to the Tukwila Pond parcel, (4) decide on the need to expand the traffic study, (5) decide on the need to add an economic impacts element, and (6) define a strategy for possible environmental appeals and how to address liabilities. The following recommendations are based, in part, on discussions with Jim Wiley, David Morency, and Dennis Neuzil of Entranco Engineers; our wetlands /wildife subconsultant, Rex Van Wormer; and Phil Fraser and Brad Collins of the City of Tukwila. Entranco recommends expanding the contract scope for item 2 (wildlife) to address the concerns of the Bon, Seattle Audubon, Metro, and King County, at an estimated cost not to exceed $6,000. The scope would include a study of the entire pond, a study of the wildlife interaction with adjacent habitats (the Green River and I -5 corridor areas), and coordination aspects. The liability in proceeding this way is that it would change the DEIS task schedule by extending it three months. This affects remaining tasks and results in a Final EIS publication in November. We also request that the City's policy for Tukwila Pond be clearly stated at this time (itern 1), especially as it relates to wildlife use. EVERETT OFFICE: 516 SEATTLE -FIRST NATIONAL BANK BUILDING, EVERE1T WASHINGTON 98201 (206) 258 -6202 Mr. Rick Beeler Planning Department City of Tukwila January 10, 1986 Page 2 Entranco recommends that the City provide a brief discussion for EIS inclusion on project funding options to partially address the economic issues (item 5) raised by the Bon. This is the preferred economics approach based on feedback from Phil Fraser. We can respond with an economics element which would not exceed $5,000 if the City prefers. I suggest we all discuss it at our next meeting. Entranco also recommends limiting item 3 (secondary impacts) to a qualitative discussion and not increasing the budget. I believe Brad Collins preferred this approach based on a December 16, 1985 phone discussion. We recommend not expanding the traffic analysis scope (item 4) and believe addressing the superblock area is adequate to project need determination. Since no alignment exists for the north -south connector of Strander to South 168th, we do not plan to address impacts of that project, other than to mention it may be built at some future time. As you know, our contract includes addressing the Draft EIS comments for Final EIS production. We are not budgeted for conducting additional studies which may be requested by EIS commenters and plan on using the City's response to this letter as a basis for EIS response. In summary, we are recommending not expanding the EIS scope in most areas. We do suggest an addition to the wildlife analysis. Other issues (transportation, economics, secondary impacts) are more of a judgment call based on legal liabilities. We agree with your suggestion to meet and discuss our strategy for the project (item 6). We will contact you to arrange a meeting the week of January 13th to discuss these issues. Sincerely, ENTRA /1/ NVGINEERS, INC. Dale E. Anderson Encl. DEA:lbc cc: Phil Fraser • • SUMMARY OF SOUTH 168TH STREET SCOPING COMMENTS IMPLICATIONS TO EIS CONTRACT SCOPE The City of Tukwila received nine scoping comments from the 59 notices sent to those on the on the mailing list. Entranco Engineers has reviewed these comments and has prepared this summary. The degree of controversy generated so far is greater than anticipated at the time of contracting. All comments expressed concern over potential negative project impacts. These comments are discussed below as they relate to the EIS product. Areas of special concern are emphasized. Earth The Bon noted concern about soil conditions on the project site and engineering costs for structural mitigation. We intend to base the EIS work on the design report information. Water The Bon, Seattle Audubon, Metro, and King County expressed concern. Seattle Audubon and King County want the long -range management plans for the pond defined. It would help to have the City's policy on this clarified. We plan to use the hydraulic information generated in the design report to address water quality issues and the Chartwell EIS information on water quality conditions. No new water quality monitoring is intended. Plants The Bon, Seattle Audubon, Metro, and King County noted concern about Tukwila Pond wildlife habitat impacts. The Corps of Engineers indicated possible 404 permit jurisdiction. After we contacted the Corps of Engineers, a subsequent letter (January 7, 1986) said a permit will not be required. Animals The Bon, Seattle Audubon, Metro, and King County noted concern about Tukwila Pond wildlife habitat impacts. We need to know the Game Department's stance on this relative to game fish. Our contact with them this week indicates they will want to know whether game fish are present in the pond for Hydraulic Permit Approval. We are requesting that they document their concerns in writing at this time. Land and Shoreline Use Adjacent land use concerns were noted by the Bon, Hayden Corp., TCW Realty Advisors, and Bruce Smith. The Bon wants cumulative land use impacts to its property and to 'potential" building tenants addressed. We think the Bon's comments are unclear as to who are "potential" building tenants. The Bon also wants these impacts to owners of the Tukwila Pond parcel addressed. It would help to have the City's policy on Special Development Considerations for the pond property clarified. We need clarification of the Department of Game's stance on this relative to shoreline jurisdic- tion. Our contact with them this week indicates that they plan to not act now and will observe the City's response to dealing with the pond. We also need the City's zoning setback determination requested on November 8, 1985, as input to the discussion. Transportation The Bon, Metro, UPRR, the Hayden Corp., and King County noted concern. Particular concerns include truck loading, parking space, railroad spur, and access impacts to existing businesses. The Bon wants a new, complete traffic study which includes the prior City proposal for a north -south connection of Strander to South 168th (across the pond property). Our intent is to analyze the superblock traffic issues. We believe that limiting it to this area is sufficient to define the project need and necessary improvements. We do not intend to address the north -south connection, since no alignment exits and it opens up the entire issue of expanding the EIS to cover the future Tukwila Pond property use and resultant impacts. Utilities The Bon noted concern on the power utilities and relocation costs. Again, we intend to base the EIS work on the design report information. • • Environmental Health No specific comments concerning noise. Our plan is to provide a qualitative description of possible noise impacts to waterfowl. As requested by Phil Fraser on November 7, 1985, we will try to include references on noise impacts to the waterfowl. No noise monitoring or modeling is intended. Air No specific comments concerning air. Our plan is to provide a qualitative description of possible air impacts based on traffic information. No air monitoring or modeling is intended. Aesthetics The Hayden Corp. expressed concern that the roadway might produce a visual barrier, although it is unclear what they mean. Again, a qualitative analysis is intended, with one or two figures depicting visual impacts. Objectives of the Proposed Project Several scoping comments (King County, the Bon, and Seattle Audubon) asked for clarification /justification of the project need. We believe that the intended traffic analysis will provide this information. Economic Impacts Although not included in our scope of work and not usually required by SEPA, the Bon has recommended a study be conducted which includes cost ranges, types and sources of financing, and other reliable financial information. The UPRR has asked that the EIS include an estimate of the loss of business due to track relocation. Hayden Corp. has stated that the project cost cannot be absorbed by local businesses. DEPARTMENT OF THE ARMY SEATTLE DISTRICT. CORPS OF ENGINEERS P.O. BOX C -3755 SEATTLE, WASHINGTON 98124 -2255 REPLY TO ATTENTION OF Regulatory Branch JAN 7 1986 Bradley J. Collins, Director Department of Planning City of Tukwila 6200 Southcenter Boulevard Tukwila, Washington 98188 Dear Mr. Collins: Reference the Corps of Engineers letter of December 12, 1985, advising you that a Department of the Army permit may be required for the placement of fill material into Tukwila Pond or in adjacent wetlands at Tukwila, Washington. We have reviewed all available information about the site and determined that the existing pond and adjacent wetlands are not waters of the United States. A Department of the Army permit will not be required for the discharge of dredged or fill material at this site. Nothing in this letter should be construed as excusing you from compliance with other existing Federal, state, and local statutes, ordinances, or regulations which might affect this work. 401-- c c eGruitc.T v6tck, /2,(g7 Sincerely, z Warren E. Baxter Chief, Regulatory Branch • TO: Mt\ L.-- FROM: OSF"1 C E MEMO CITY OF T-U KW I LA DATE: 112 - -815- SUBJECT: tx-j9-c; i ���-1 � C c("-KS 6-`#i c. u,. 76 t - 3 ` -? King County Executive Randy Revelle Department of Planning and Community Development Holly Miller, Director December 17, 1985 Mr. Brad Collins Planning Director City of Tukwila 6200 Southcenter Boulevard Tukwila, WA 98188 RE: Scoping Notice for South 168th Street Dear Mr. Collins: FT)) D E C 1 9 1985 PL DEPT. The Department of Planning and Community Development has reviewed the above scoping notice and concurs with the City of Tukwila's Determination of Significance. We believe the Environmental Impact Statement (EIS) should cover the following concerns. Environmental and Resource Issues Tukwila Pond is noted as a valuable stopover for migrating waterfowl. The pond is used throughout the year by a large number of diverse waterfowl species. It provides critical habitat for resident and migratory waterfowl. While portions of the pond have been affected by human actions in the past, the southern portion (currently proposed for fill) is presently the least disturbed area and has the highest diversity of vegetation. This is the portion of the site that would be destroyed by the development proposal. We believe the potential for "enhancement" on the rest of the site is not justification for eliminating an area that is already stable and providing excellent and rare habitat. If possible, Tukwila Pond should remain undisturbed. The EIS should also address what, if any, long -term management plans exist or are under development for Tukwila Pond. Transportation Issues The EIS should identify the need for the project, consistency with local plans, alternative alignments considered, and the future function of the new road. 811 Alaska Building 618 Second Avenue Seattle, Washington 98104 (206) 344-7503 Mr. Brad Collins December 17, 1985 Page Two Any impacts to King County roads as a result of this project should also be addressed. Traffic volumes and distribution should be discussed on roadways which would experience a significant change from existing traffic patterns. Should you have any questions concerning these comments, please call Bill Hoffman at 587 -4693. Sincerely, HOLL MILLER Director HM:LG:ds TPLG37 cc: Ralph Colby, Supervisor, Plan Implementation, Building and Land Development Division ATTN: Dyanne Sheldon, Environmental Planner Lou Haff, County Road Engineer Harold Robertson, Manager, Planning Division ATTN: Bill Jolly, Chief, Resource Planning Section David Masters, Resource Planner Bill Hoffman, Chief, Transportation Planning Section David Mark, Transportation Planner Lisa Grote, Transportation Planning Assistant Lois Schwennesen, Chief, Community Planning Section HAYDEN CORPORATION Mr. Brad Collins Planning Director City of Tukwila 6200 Southcenter Blvd. Tukwila, Washington 98188 RE: Scope of E.I.S. South 168th Street Dear Brad: • 900 N. TOMAHAWK ISLAND DRIVE PORTLAND, OREGON 97217 PHONE (503) 283 -4111 December 16, 1985 FEDERAL EXPRESS The purpose of this letter is to identify the probable adverse impacts upon Parkway Square Shopping Center located adjacent to the proposed South 168th Street. 1. Loss of Service Driveway: The Sanitation and building service areas are now designated in the south property line boundary of the shopping center. This access is essential to the daily operations and management of the shopping center and would be eliminated with the proposed roadway. 2. Building Setback: The roadway proposal would create a ten (10) foot setback from the sidewalk curb to the building wall. Tenants and customers would not have adequate access area for efficient retail use. 3. Grade Variation: The roadway proposal creates a three (3) to four (4) foot grade level variation between the roadway /sidewalk (lower) and building level (higher). This would result in severe access, design and foundation problems. 4. Public Identification & Physical Barrier: As a retail location it is essential that street traffic identify and obtain easy access to the shopping center. The proposed roadway would create a traffic problem and potential hazard for left turn access from Southcenter Parkway and in,addition produce a visual and physical barrier from the proposed roadway. 5. Project Cost and Construction: The considerable cost of development of a roadway cannot be absorbed in any proportion by the property owner. Given existing economic conditions any construction interference with the daily operation of the shopping center tenants is unacceptable. Best.. regards, Larry Summerton Contr ct Property Manager for Real Property West, Inc. LWS:mm M39D11 cc: Real Property West, Inc. • • SHIDLER McBROOM GATES & LUCAS Seattle ATTORNEYS AT LAW • A PROFESSIONAL SERVICE CORPORATION Bellevue 3500 First Interstate Center Seattle, Washington 98104 Telephone (206) 223 -4600 Telecopier (206) 622 -5110 Telex: 29 -2988 • December 16, 1985 DENNIS J. McLERRAN Bellevue Office Hand Delivered Mr. Brad Collins, Planning Director City of Tukwila 6200 Southcenter Boulevard Tukwila, Washington 98188 Re: Scoping Notice - South 168th Street EIS File No. EPIC 294-75 Dear Mr. Collins: 505 Honeywell Center 600 108th Ave. N.E. Bellevue, Washington 98004 Telephone (206) 453 -0300 Telecopier (206) 455 -9166 DEC 1 6 1985 J CITY 'i L ,.:'rdjLA, Pl. !`.NN!N i DEPT. We represent The Bon with regard to their Distribution Center located at 17000 Southcenter Parkway in Tukwila. Our client has asked that we provide comments on the City's recently issued Scoping Notice for the South 168th Street Environmental Impact Statement. We would request that the Draft EIS for the proposal fully address the issues and concerns identified below. I. LAND USE. A. Impacts on The Bon Distribution Center. The Bon Distribution Center is a major facility which receives and ships the merchandise for all forty Bon stores located in the Western United States. The proposed South 168th Street project will have major impacts upon the existing use made by The Bon of its Distribution Center. The tentative plans presented by the City and its consultants would severely disrupt the operations of the Distribution Center and could even require its relocation. Because there is no right -of -way currently existing through the Distribution Center site, at least thirty feet of The Bon's property would have to be taken to accommodate the proposed street. The area which would be taken is currently developed with improvements essential to the proper functioning of the Distribution Center. A truck loading area, a rail spur, and refueling area with underground tanks and pumps would all be severely disrupted or eliminated by the proposed street. The northwestern access to the Distribution Center would also be eliminated. Mr. Brad Collins December 16, 1985 Page Two The most severe impact on the existing use would be disruption of truck loading on the north side of the building. All or substantially all of the existing property is necessary for trucks to back into the eighteen loading bays where incoming merchandise is offloaded. The internal systems of the Distribution Center building have been designed in a manner which requires incoming goods to be unloaded on the north side of the building. A complex system of automated tracks and conveyors takes the incoming merchandise to central receiving and processing areas where the merchandise is repacked or separated for outbound shipment to retail stores from twenty loading docks on the south side of the building. The internal systems within the building are not easily or inexpensively modified. If loading on the northern side of the building is eliminated, there is insufficient space on the current property and inside the building to accommodate such a change in operations. All alternative loading areas around the building are already dedicated to other essential operations. Rail unloading also occurs on the north side of the building. The proposed street would likely eliminate one of two rail spurs currently used by The Bon for offloading and car stacking. The two spurs are necessary at peak periods to allow greater numbers of rail cars to be unloaded. It is not likely that the spurs can be relocated and to do so would also disrupt the internal organization of the Distribution Center building. Elimination of the northern access would also be potentially disruptive to the retail operation conducted in the northwestern portion of the building, as customer parking is primarily accessed through the northern driveway. Truck traffic flow would also be disrupted, as The Bon currently routes inbound delivery trucks around the building in a clockwise manner and out the northern access. This clockwise flow allows monitoring of entry for security purposes and prevents overflows of trucks at the northern loading area. An open curb system for truck loading would eliminate the truck traffic control currently exercised by The Bon's security personnel. The cumulative impact of the problems created by construction of South 168th Street may be great enough that The Bon's current use of the property would have to be discontinued. It is quite certain that a substantial amount of damage would be caused to the existing land use and probably to other potential users of the existing building. These impacts should be fully identified and explored in the EIS. B. Impacts on Other Land Uses. Several other properties and uses could be substantially affected by the proposal. The shopping center located just north of The Bon Distribution Center owned by Real Properties West would suffer several major impacts. The users located in the center have their merchandise loading and service doors on the south side of the building. Construction of a street would eliminate the existing access drive serving the loading doors. Trucks serving these shops would have to park on the street if South 168th is constructed. Garbage / • Mr. Brad Collins December 16, 1985 Page Three loading areas would also be affected. Additionally, because of a grade differential problem, the loading and service doors would probably be three to five feet higher than the street grade. This would create further difficulties with use of the existing doors. The TCW Realty Advisor's property located directly east of The Bon Distribution Center contains Boeing Computer Service offices. One of the alternatives discussed by City consultants has been relocation of the rail'line located along the northern boundary of the TCW property to a location further south because of soils problems on the Tukwila Pond parcel. Movement of the rail line would eliminate existing parking for the offices located on the TCW property. The impact on available parking for the office use should be evaluated. Also, the EIS should address the impacts of the proposal on land uses planned for the Tukwila Pond parcel. At a minimum, a portion of the developable area of this property will be lost to street construction under the proposal. II. TRANSPORTATION. As discussed in the Land Use section above, the proposed street would have a number of impacts on existing transportation systems. The Bon's existing traffic flows would be disrupted by closing the northwest access to the property, by possible prevention of counterclockwise truck flows around The Bon Building and by disruption of truck loading. The railroad operations within the location of the proposed right -of -way could also be severely impacted. A letter from The Transpo Group is attached which identifies the nature of the proposal's impact upon The Bon's truck offloading operations. The letter also indicates that the truck loading operations cannot be moved and, therefore, would have a severe impact upon the functioning of the proposed roadway as well. These impacts should be fully explored in the EIS. Additionally, the existing railroad service is likely to be modified or lost due to the proposal. The exact nature of the proposal and any alternatives with respect to rail service should be presented in the EIS. The cost of relocation of rail facilities should also be fully identified. With respect to traffic analysis in the EIS in general, there is a need for a complete area traffic study to determine whether the proposed street is really necessary or will actually solve any perceived problems with traffic flow. Because the City is proceeding with other major improvements in the area such as Minkler Boulevard, any traffic study should consider whether other proposed traffic improvements will resolve problems with traffic flows on Strander Boulevard. Based upon discussions with various staff members, it is apparent that no area -wide traffic study has been done for a number of years. Without preparing such a study, the need for the proposed street cannot be fully explored. Mr. Brad Collins December 16, 1985 Page Four As a general comment, the preliminary design and location of the proposed street need to be further defined before an adequate analysis of the environmental impacts can be prepared. In early meetings with the staff and design consultants, it has been apparent that many issues will remain unresolved until a proposal with more specific location and design features is presented. Also, prior plans prepared by the City have identified a north /south connection between Strander Boulevard and South 168th Street. The impacts of such a connector on The Bon's truckloading should be further explored in the EIS. If the north /south street would intersect in the area of The Bon's truckloading operations, there could be additional traffic concerns. If there is any possibility that such a link will be created in the future it should be discussed as the South 168th Street proposal is an essential preprequisite to such a link. III. UTILITIES. Puget Power has a 115 Kv. underground electrical vault and line located within the alignment of the proposed street. Puget Power has indicated that the line should not be placed within the actual roadway area and should be relocated. The costs of relocating the line should be identified, as well as the exact relocation alignment. Puget Power has tentatively estimated that relocation costs could be as much as half a million dollars. IV. EARTH. At early meetings, the staff and design consultants have identified a problem with unsuitable soils in the proposed road alignment. The extent of the problem should be defined in the EIS, and the specific construction measures which are proposed to deal with the problem should be stated. Also, the cost of special construction techniques necessary because of unsuitable soils should be identified. Any alignment adjustments made to deal with soils problems should also be identified. V. WATER, PLANTS, AND ANIMALS. Because the proposed street will occupy a portion of the Tukwila Pond site, a designated environmentally sensitive area, a full assessment of the impacts of the proposal with respect to wildlife usage of the pond and upon the pond in general should be made. VI. FINANCIAL IMPACTS. The proposal appears to be a potentially very expensive project and may even be cost prohibitive. Because of the need to acquire right -of -way, deal with unsuitable soils, relocate the existing 115 Kv. underground power line, relocate rail lines and possibly pay damages to users who will have existing uses disrupted, the City should make a good faith estimate of the range of costs involved in proceeding with the project and the alternatives. While the State Environmental Policy Act Guidelines discourage a cost /benefit analysis in an EIS, it will be highly desirable for decision - makers and the public to have reliable financial information available when decisions must be made on the project. Mr. Brad Collins December 16, 1985 Page Five Additionally, although the SEPA Guidelines do not require that the method of financing a project be investigated, it would be helpful if the types and sources of financing which could be used are identified. It is certain that this will be a major issue in later hearings. In preliminary discussions with staff, it has been indicated that an LID may be proposed for the project. The alternative financing methods which the City may use should be identified to allow full consideration of financing options by the public and the ultimate decision- makers. VII. ALTERNATIVES. The majority of surrounding property owners have expressed opposition to the project in early meetings. Certainly a discussion of the alternative of not building the street should be contained in the EIS. Also, since Tukwila is currently evaluating other east /west street improvements such as Minkler Boulevard, discussion of the alternative of building Minkler and /or other streets without South 168th Street should be evaluated. Alternative locations for the South 168th Street alignment should also be evaluated. An evaluation of whether the westerly end of the street can be relocated from between The Bon and Real Properties West sites to another location should be made. VIII. OBJECTIVES OF THE PROJECT. To clearly evaluate whether the objectives of the project will be met, a full area traffic study should be completed as part of the environmental analysis. The Bon questions whether there is a need for the proposed street if Minkler Boulevard is built and, therefore, questions whether the City's objective of lessening congestion on Strander Boulevard will be met. IX: CONCLUSION. The Bon invites the appropriate City officials and the consultants involved in the preliminary design study and EIS preparation for the project to take a tour of The Bon's affected facilities at an early date. The environmental impacts identified above can only be fully appreciated by viewing The Bon's operations. Please have the appropriate individual contact the undersigned to arrange a site tour. Additionally, please notify this office of any meetings or hearings and of the availability of any draft and final documents. Thank you for your anticipated consideration of the above. Very truly yours, SHIDLER McBROOM GATES & LUCAS -1r\AE4e's^45 Dennis J. McLerran DJM /13 -14 Attachment cc: Bill Hicks, The Bon Jim Maclsaac, The Transpo Group Transportation Planning & Traffic Engineering Consultants December 3, 1985 Mr. Dennis McLerran & Lucas Shidler, McBroom, Gates 505 Honeywell Center 600 108th Avenue NE Bellevue, WA 98004 SUBJECT: SOUTH 168TH STREET DEVELOPMENT PROPOSAL C� The TRANSPO DEC - 31985 D$El "B Off GATES. & LUCAS [N,C 16 1985 Dear Mr. McLerran: n'. ..Yb`; LA We understand that the City of Tukwila istweenoSouthcenterUParkway ands AnaYver and construct a new 3or 4 -lane street be the south edge of the Park West. The new street would be located along "Tukwila Pond" property, and along the north edge of the Bon Marche northwest regional distribution facility property. There are a number of physical and environmental thatbyour brief willucoverd by this proposed street alignment. I am confident those issues. The purpose of this letter is to point out and discuss one major issue: • Impact of the proposed street on the Bon's north truck access and docking operations (or vice versa). Facilit Access and Internal Function Mr. Bill Hicks was kind enough to give us an in- epthitour ofTth the iinteraal functions of the Bon warehousing and distribution processing is all engineered to receivico incoming merchandiseifr rom ofvendors via 17 or 18 large truck docks plus rail docks building, and to ship out the regrouped and tob40ldifferent The store destinations via 28 truck docks on east face of the building is committed to truck docking for all furniture delivery operations in the Puget Sound area. As a result of this tour, we conclude the following: • There is no way to consolidate the north side truck docking facilities with those on the maximumginternal all three building faces have been functioning capacity. � Any attempt to relocate the side ofkthe result in a need for major entire internal operations of the facility. The TRANSPO Group, Inc. • 23 - 148th Avenue SE, Bellevue, Washington 98007 • (206) 641 -3881 'TitANSPO @rove Mr. Dennis McLerran December 3, 1985 Page 2 • Hence, we view the north side truck docks and docking activity as an unchangeable given that the street project must be designed around. Receiving Dock Operations The large tractor /trailer rigs that deliver to the north side receiving docks require all of the space now available between the building face and the north property line. It would be impossible to maneuver the large rigs around parked rigs with loss of 30 feet of right of way (ROW) -- or any substantial portion thereof. In addition to truck maneuvering space, there is also need to "stack" incoming trucks while awaiting preceeding trucks to dock and undock. This stacking occurs along the north side of the rail spur line, and into the east side docking area. The dock access must be served by a counter - clockwise truck circulation pattern (westbound along the north building face). This is to orient the driver's view of the docking facilities as he backs into the dock. The facility manager was able to supply incoming truck counts for the months of October and November for the north side receiving docks. During October there were an average of 63 incoming trucks per day, or 126 docking and undocking movements per day. During November the averages were 54 and 108 respectively. The docking maneuvers generally occur between 7 AM and 4 PM. A docking maneuver can take from 2 to 4 minutes, depending upon the size of the truck and the number of trucks docked at the time. On occasion, a less experienced truck driver can take more than 5 minutes to dock. The undocking maneuver takes about one minute. In general only one docking or undocking movement can occur at a time. Given these statistics, and assuming 60 incoming trucks per day for purposes of easy calculation, incoming trucks currently use 3 x 60 = 180 minutes of docking time, plus 60 minutes of undocking time. This represents up to 4 hours of the 9 -hour operating day when all space along the north side of the facility is preempted by truck docking maneuvers. Future Street Operations If a new public street is to utilize 30 feet of the north docking area, truck docking operations must of necessity utilize a portion of the public street. The street would have to be designed with no curb on its south side along the entire docking area. By paving the rail spur track area, it may be possible to provide incoming (westbound) truck access over the rail area south of the future public street ROW. However, when rail cars are present, truck ingress would have to circulate via the westbound lane(s) of the new street. No matter which way truck ingress occurs, the trucks must preempt the future street eastbound Mr. Dennis McLerran December 3, 1985 Page 3 Y Y h "MANSPO Grove lanes to make their docking maneuvers. Undocking maneuvers would need to penetrate both directions of travel on the proposed street. When rail cars are present, incoming trucks would also block a westbound lane of the street while awaiting for prior docking movements to be completed. In summary, if 30 feet were to be removed from the north docking area, the street design would need to provide unrestricted truck access across its south "curbline ". Truck docking and undocking operations would block eastbound traffic operation on the street for up to 4 hours over a 9 -hour business day. Eastbound traffic flow would be subjected to one hour of delay time plus any delays associated with stacking of incoming trucks. Such delays would be intolerable to the general street traffic. The safety implications are quite apparent. Conclusions We do not believe that the existing north receiving dock operations of the Bon warehouse and distribution facility can co -exist with a new public street, if any significant portion of the docking zone is removed by the street. If trucks cannot penetrate the south half of the street in making docking maneuvers, the docking operations would be eliminated. Conversely, if the south half of the street were to be used during truck docking operations, street operation and safety would be unacceptable. We would strongly urge City staff, and its consultant to observe the truck loading operations, and to tour the internal functions of the facility. We believe they would concur with our conclusions. Very truly yours, The TRANSPO Group, Inc. James W. Maclsaac, P.E. Principal Engineer cc: Bill Hicks MACAULAY NICOLLS MAITLAND 1 INTERNAnONAL Real Estate Brokers, Consultants, Managers Established 1898 Officers: Frank 1. Agostino Frank L. Friedman Michael K. McKernan Arthur L. Wahl Mr. Brad Collins Director, Planning Department City of Tukwila 6200 Southcenter Blvd Tukwila, WA 98188 Dear Brad: Associated with COLLIERS International Property Consultants December 9, 1985 It has been requested of me by the owners to relate the desires and opinions that the Spring Ridge property be viewed as a developmental site and not merely vacant land in reference to the addition of 168th Street. Although Spring Ridge does not have buildings and other obvious physical obstructions, it would appear very apparent that the Spring Ridge property is available to solve any problem. Unfortunately, said property has enough problems at this time and further restrictions, conditions, setbacks, and encumberances that would force building development further into lower site coverages will further endanger the development of said site. We certainly appreciate the opportunity to voice the concerns of the owners, as well as your concerned understanding of the overall scope in regard to the City. Respectfully yours, MACAULAY NICOLLS MAITLAND I;s ATIONAL FJA:bjg cc: Bruce Smith },I� DEC L 0 1985 _. PLANNING DEPT. Suite 3900 Seafirst Fifth Avenue Plaza, 800 Fifth Avenue, Seattle, WA 98104 Telephone (206) 223 -0866 Seattle Vancouver Calgary Edmonton Australia Brunei Singapore Malaysia Hong Kong Macau United Kingdom United States REPLY TO ATTENTION OF Planning Branch DEPARTMENT OF THE ARMY SEATTLE DISTRICT, CORPS OF ENGINEERS P.O. BOX C -3755 SEATTLE, WASHINGTON 98124-2255 Bradley J. Collins, Director Department of Planning City of Tukwila 6200 Southcenter Boulevard Tukwila, Washington 98188 Dear Mr. Collins: DEC 12. 1985 DEC 16 1985 CiT;: C; T! ,;\AILA PLA.NNIP!;G DEPT. 1 We have reviewed the determination of significance for the construction of the proposed new arterial, South 168th Street, Tukwila, Washington, with respect to the U.S. Army Corps of Engineers' areas of'special expertise and jurisdiction by law as designated by the President's Council on Environmental Quality on December 21, 1984. In response to your request for comments on the scope of the environmental impact statement, we have the following comment. The placement of fill material in Tukwila Pond or in adjacent wetlands may require a Department of the Army permit in accordance with Section 404 of the Clean Water Act. Information about the permitting process can be obtained by contacting the Seattle District Regulatory Functions Branch at the above address, or by telephone (206) 764-3495. Thank you for the opportunity to comment on this proposed project. Sincerely, Copy Furnished: George W. Ploudre, P.E. Acting Chief, Engineering Division Commander, North Pacific Division ATTN: NPDPL -ER Seattle Audubon 0,3acietp Washington Nonprofit Corporation 619 Joshua Green Building • Seattle, WA 98101 • 206/622 -6695 December 12, 1985 Mr. Brad Collins Planning Director, City of Tukwila 6200 Southcenter Boulevard Tukwila, WA 98188 Re: Tukwila Pond; File: EPIC 294 -75 Dear Mr. Collins: . E l.i 1 f 1985 PtA\Nl1 G DEPT. Seattle Audubon Society has received notice of the declaration of significance for the proposal to construct south 168th St. accross the south end of Tukwila Pond. We agree with the determination of significance and request that we become a party of record for this project. In addition to those items listed in the narrative of the scoping notice we would request that a detailed study be conducted on the aspect of habitat provided by this pond in its current condition. How does the pond function in the environmental system comprised of the openspace associated with the freeway right -of- way, Tukwila Pond; and the Green River, especially relating to resident and migratory birds. Industrial, commercial; and multifamily developments have maximized land use in the Tukwila area and the open waters of Tukwila Pond, the associated wetland vegetation; and the open space surrounding it provide excellent habitat in stark contrast to the surrounding land use. The southern margin of the pond contains the highest diversity of wetland vegetation and it is the area least impacted by human intrusions; for these reasons it receives the highest use by wildlife, especially more reclusive waterfowl species. The placement of the road alignment in this area would destroy the most intricate aspect of this wetland system. Enhancement of wetlands is a possibility in certain situations, however it is not a desirable or ethical attitude to assume that destruction of the most productive area of this wetland could be justified by an enhancement proposal on the remains of the wetland. The question arises as to the intent of such a road alignment: what property is proposed to be accessed which could not be accessed with existing thoroughfares? Could not the parcel to the west of the pond be accessed with a cul -de -sac from Southcenter Parkway? This should be considered as an alternative to the proposal. a. page 2: Collins What are the long range plans of the City of Tukwila for Tukwila Pond and its surrounding openspace? Will it continue to be submitted to repeated development proposals or will the City make an effort to preserve this wetland and a significant area of openspace surrounding it as a visual, biological, educational and open space amenity to the City of Tukwila? Seattle Audubon is opposed to the project as it is pre- liminarily proposed. We anticipate the opportunity to comment on the technical documents for this proposal, and if possible, to comment at public hearings which may be held in conjunction with the project. Thank you for this opportunity to comment on this proposal. DS: lws Sincerely; Dyanrie Sheldon; Conservation Chair 11 • .. „ mETRD Municipality of Metropolitan Seattle Exchange Bldg. • 821 Second Ave., Seattle, Washington 98104 December 13, 1985 Bradley J. Collins, Planning Director City of Tukwila Planning Department 6200 Southcenter Blvd. Tukwila, Washington 98188 Determination of Significance EPIC - 294 -75: South 168th Street Dear Mr. Collins: • i t re, 711 kyFc E 7 1985 A Pt• 61: ;,' 1 DEPT. Metro staff has reviewed this proposal and offers the following comments. Water Quality Metro anticipates no significant adverse impacts to wastewater facilities. We anticipate no significant degradation of surface water quality provided all mitigating measures both during and after construction are implemented in a timely manner. The proposal includes fill in Tukwila Pond and adjacent wetlands. Metro recognizes wetlands as environmentally sensitive areas with unique characteristics for wildlife habitat and water quality protection. Wetlands, such as Tukwila Pond, are important ecological systems which can improve water quality in varying degrees by temporarily or permanently retaining suspended materials, excess nutrients, toxic chemicals and disease - causing micro - organisms. Additionally, Tukwila Pond may now function as a migratory route for waterfowl. Potential adverse impacts on the water quality of the pond and adjacent wetlands caused by the proposal can be expected to impact wildlife habitat. In 1983, Metro evaluated the Tukwila Pond area as a possible site for the Tukwila Transit Center. After an in -depth analysis of the site ,which included a wetlands inventory report by a consulting wildlife biologist, Metro eliminated the site from further consideration. Metro's investigation and the wetlands report found, among other things, that : • • Bradley J. Collins December 13, 1985 Page Two 1. Any development within the Tukwila Pond area would adversely affect wildlife and result in a reduction in both the numbers of individuals and diversity of wildlife species; 2. If development does occur, the least impact on wildlife would occur from projects focusing on the northern boundary of the site; 3. Increased runoff from additional impervious surface should be directed away from the pond to prevent degradation of water quality. Because of the value of the wetland habitat and Metro's other activities aimed at protecting water resources, Metro rejected the pond area as a site for the Tukwila Transit Center. Metro acknowledges that King County has included wetlands in its Sensitive Areas Program. While recognizing that the proposed project is within the corporate limits of the City of Tukwila, we encourage the proponent to consider the Sensitive Areas Program guidelines and mitigating measures to avoid adverse impacts which may arise from the construction and implementation of the proposed project in Tukwila Pond and adjacent wetlands. In addition, Metro recommends that any construction activity related to the project be prohibited in Tukwila Pond and adjacent wetlands unless no other feasible, less environmentally - damaging alternative exists and that a buffer zone between the proposed project and the wetland be established. Metro recommends that this zone extend at least 50 feet away from the wetlands boundary. Should the proponent find that no other feasible, less environmentally - damaging alternative exist, measures to prevent any degradation of water quality should be taken. These measures should include, but not be limited to: o use of sediment curtains or containment fabrics to prevent sedimentation into the pond; o identification of runoff discharge points into surface waters through King County's drainage planning process; o methods to prevent toxic materials, petro - chemicals and other pollutants from entering surface water during and after construction; o provisions for maintaining adequate setbacks and wetland vegetation; o revegetation of affected areas. • • Bradley J. Collins December 13, 1985 Page Three Public Transportation Pedestrian access and the pedestrian environment are concerns of Metro since they affect the ability of potential transit riders to get to and from bus zones. The environmental impact statement should include a discussion of pedestrian access amenities. Another factor which affects transit and transit ridership is the type of development associated with the proposed access road. What other types of development are planned in and adjacent to the Tukwila Pond? Also, does the proponent envision any additional roadways or traffic control measures for the area which may affect public transportation? The EIS should also specify the extent and degree of traffic impacts in the area which may arise from the proposed project. Thank you for the opportunity to review and comment. Very truly yours, Gregory M. Bush, Manager Environmental Planning Division GMB:dww KEITH T. BORMAN General Solicitor (503) 249-2505 JOHN F. WEISSER Assistant General Solicitor (503) 249-2507 • • UNION PACIFIC RAILROAD COMPANY LAW DEPARTMENT 1515 S.W. Fifth Avenue, Suite 400 Portland, Oregon 97201 -5465 (503) 249-2660 UNION PACIFIC December 13, 1985 Mr. Brad Collins Planning Director City of Tukwila 6200 Southcenter Blvd. Tukwila, Washington 98188 JEFF S. ASAY General Attorney (503)249.2315 ROY P. FARWELL General Attorney (503) 249-2881 CAROLYN L. LARSON General Attorney (503) 249 -2317 BARRY L. GROCE Assistant General Attorney (503) 249-2382 Our File: 9208 -32 -2 Re: EPIC - 294 -75 - Proposed Construction of South 168th Street between Southcenter Parkway and Andover Park West Dear Mr. Collins: In response to your November 18, 1985 scoping notice, Union Pacific Railroad Company requests that the City include the following issues in its analysis of the environmental impact of constructing a new arterial street (South 168th Street) between Southcenter Parkway and Andover Park West. 1. Removal of the Northerly Spur Track Serving The Bon. If street construction necessitates removal of the northerly spur track, the EIS should address the impact on The Bon of cutting its car holding capacity in half and the resulting impact on the Railroad, e.g., increased switching time and costs and /or possible loss of business. In addition, the cost of removing the track should be included as a project cost. 2. Loss of Ability to Extend Lead Track. The spur tracks serving The Bon were aligned so as to leave room to the north for a future westerly extension of the Railroad's lead track. The EIS should consider the loss of rail service potential to properties north and west of The Bon and the need to compensate the Railroad for taking its right of way and damaging its remaining property. (tiler, ��� --• Lilo :I 1985 ';r1' . . t.'i v; !LA Pi ANNV. G DEPT. • • Mr. Brad Collins December 13, 1985 Page Two 3. Shifting Lead Track. If the street alignment requires that the Railroad's lead track east of The Bon's switch be shifted to the south, the EIS should consider the following issues: (a) Right of Way Acquisition. If the lead track is shifted more than a few feet, it will not fit within the limits of the Railroad's existing easement, necessitating acquisition of additional right of way for the Railroad. (b) Design Limitations. Any realignment of trackage must meet railroad engineering standards. For example, the maximum allowable curvature for trackage is a curve with a radius of 459.27 feet. Where reversed curves are used, 100 feet of tangent (straight) track must be introduced between curves. Curves must end 50 feet before paralleling a building that is 8' 6" from the track centerline. Clearances between the track and the street or other structures must meet WUTC and Railroad requirements. These factors must be taken into consideration when determining the location and amount of right of way needed to realign the lead track. (c) Cost of Shifting Track. The cost of shifting the lead track from the turnout east of Andover Park West to The Bon's trackage, including crossing work in Andover Park West, should be included as a project expense. When the Draft EIS is prepared, I request that you notify me of its availability for review. Very truly yours, CLL:gh Puget Souna Air Pollution C on tro SERVING: KING COUNTY 200 West Mercer St. P.O. Box 9863 Seattle. 98109 (206) 344 -7330 KITSAP COUNTY Dial Operator for Toll Free Number Zenith 8385 Bainbridge Island Residents Dial 344-7330 PIERCE COUNTY 901 Tacoma Avenue South 213 Hess Building Tacoma. 98402 (206) 383-5851 SNOHOMISH COUNTY 1 -800 -552 -3565 200 West Mercer Street, Room 205, P.O. Box 9863 Seattle, Washington 98109 (206) 344 -7330 imis , Planning Director -City of Tukwila 6200 Southcenter Blvd. Tukwila, 61A 98188 Dear Mr. Collins: November 26, 1985 South 168th St, - New Link Arterial In response to your request for scoping on the above - titled p al this Agency submits the following comments pursuant to RAC 197-11-408: Areas of Probable Significant Adverse Air Quality Impact: O Point source or stack emissions O Other: Motor vehicle emissions ❑ Fugitive emissions O Odors ❑ Toxic air pollutant emissions Recommended Impact Analysis: O Atmospheric dispersion modeling ❑ Receptor modeling ❑ Emission ratio /rollback O Physical modeling ❑ Ambient monitoring ® Discussion ❑ Other: Recommended Mitigation: ❑ Size reduction ❑ Limit on operating hours ❑ Special air pollution controls: ❑ Offset Emissions Additional Comments: 7 - • • - • - e ement ; thi BOARD OF DIRECTORS CHAIRMAN: Doug Sutherland. Mayor Tacoma ■ - - • —• 11 Licenses Needed: O Notice of Construction & Application for Approval (new source permit) ❑ Comments: ❑ Carpools, vanpools, or increased transit service ❑ Deny license Rl Other: P.ecornend selection and implementation leis ntation of appro- priate mitigation 11 orm is submitted in confirmation. Ray Aardal. Commissioner Kitsap County Bruce Agnew. Councilman Snohomish County Charles Royer. Mayor Seattle Joe Stortini. Pierce County Executive Agency Contact: Telephone: times R. Pearson 344 -7336 William E. Moore. Mayor Everett Linda Tanz. Member at Large VICE CHAIRMAN: Morrie Dawkins. Mayor Bremerton Randy Revelle, King County Executive A.R. Dammkoehler, Air Pollution Control Officer Transportation Planning & Traffic Engineering Consultants December 3, 1985 Mr. Dennis McLerran Shidler, McBroom, Gates & Lucas 505 Honeywell Center 600 108th Avenue NE Bellevue, WA 98004 SUBJECT: SOUTH 168TH STREET DEVELOPMENT PROPOSAL Dear Mr. McLerran: Hayden Co ation • Hayden Isla vision Larry W. Summe Commercial Proper t= nagement 900 North Tomahawk Island Drive Portland, Oregon 97217 (503) 283 -4111 DEC -31985 IRE i:i GATES & LUCAS We understand that the City of Tukwila is proposing to acquire right of way and construct a new 3 or 4 -lane street between Southcenter Parkway and Andover Park West. The new street would be located along the south edge of the "Tukwila Pond" property, and along the north edge of the Bon Marche northwest regional distribution facility property. There are a number of physical and environmental problems to be encountered by this proposed street alignment. I am confident that your brief will cover those issues. The purpose of this letter is to point out and discuss one major issue: • Impact of the proposed street on the Bon's north truck access and docking operations (or vice versa). Facility Access and Internal Function Mr. Bill Hicks was kind enough to give us an in -depth tour of the internal functions of the Bon warehousing and distribution facility. The internal processing is all engineered to receive incoming merchandise from vendors via 17 or 18 large truck docks plus rail docks along the north side of the , building, and to ship out the regrouped and repackaged goods to 40 different store destinations via 28 truck docks on the south side of the building. The east face of the building is committed to truck docking for all furniture delivery operations in the Puget Sound area. As a result of this tour, we conclude the following: • There is no way to consolidate the north side truck docking facilities with those on the east and south building faces -- all three building faces have been developed to maximum internal functioning capacity. Any attempt to relocate the north side truck docks would likely result in a need for major (if not total) reconstruction of the entire internal operations of the facility. The TRANSPO Group, Inc. • 23 - 148th Avenue SE, Bellevue, Washington 98007 • (206) 641 -3881 Mr. Dennis McLerran December 3, 1985 Page 2 • • The TRANSPO Cr ovp Hence, we view the north side truck docks and docking activity as an unchangeable given that the street project must be designed around. Receiving Dock Operations The large tractor /trailer rigs that deliver to the north side receiving docks require all of the space now available between the building face and the north property line. It would be impossible to maneuver the large rigs around parked rigs with loss of 30 feet of right of way (ROW) -- or any substantial portion thereof. In addition to truck maneuvering space, there is also need to "stack" incoming trucks while awaiting preceeding trucks to dock and undock. This stacking occurs along the north side of the rail spur line, and into the east side docking area. The dock access must be served by a counter - clockwise truck circulation pattern (westbound along the north building face). This is to orient the driver's view of the docking facilities as he backs into the dock. The facility manager was able to supply incoming truck counts for the months of October and November for the north side receiving docks. During October there were an average of 63 incoming trucks per day, or 126 docking and undocking movements per day. During November the averages were 54 and 108 respectively. The docking maneuvers generally occur between 7 AM and 4 PM. A docking maneuver can take from 2 to 4 minutes, depending upon the size of the truck and the number of trucks docked at the time. On occasion, a less experienced truck driver can take more than 5 minutes to dock. The undocking maneuver takes about one minute. In general only one docking or undocking movement can occur at a time. Given these statistics, and assuming 60 incoming trucks per day for purposes of easy calculation, incoming trucks currently use 3 x 60 = 180 minutes of docking time, plus 60 minutes of undocking time. This represents up to 4 hours of the 9 -hour operating day when all space along the north side of the facility is preempted by truck docking maneuvers. Future Street Operations If a new public street is to utilize 30 feet of the north docking area, truck docking operations must of necessity utilize a portion of the public street. The street would have to be designed with no curb on its south side along the entire docking area. By paving the rail spur track area, it may be possible to provide incoming (westbound) truck access over the rail area south of the future public street ROW. However, when rail cars are present, truck ingress would have to circulate via the westbound lane(s) of the new street. No matter which way truck ingress occurs, the trucks must preempt the future street eastbound ;- Mr. Dennis McLerran December 3, 1985 Page 3 • • 111ANSP Group lanes to make their docking maneuvers. Undocking maneuvers would need to penetrate both directions of travel on the proposed street. When rail cars are present, incoming trucks would also block a westbound lane of the street while awaiting for prior docking movements to be completed. In summary, if 30 feet were to be removed from the north docking area, the street design would need to provide unrestricted truck access across its south "curbline ". Truck docking and undocking operations would block eastbound traffic operation on the street for up to 4 hours over a 9 -hour business day. Eastbound traffic flow would be subjected to one hour of delay time plus any delays associated with stacking of incoming trucks. Such delays would be intolerable to the general street traffic. The safety implications are quite apparent. Conclusions We do not believe that the existing north receiving dock operations of the Bon warehouse and distribution facility can co -exist with a new public street, if any significant portion of the docking zone is removed by the street. If trucks cannot penetrate the south half of the street in making docking maneuvers, the docking operations would be eliminated. Conversely, if the south half of the street were to be used during truck docking operations, street operation and safety would be unacceptable. We would strongly urge City staff and its consultant to observe the truck loading operations, and to tour the internal functions of the facility. We believe they would concur with our conclusions. Very truly yours, The TRANSPO Group, Inc. James W. Maclsaac, P.E. Principal Engineer cc: Bill Hicks l ; IN co (L/Y)A-T/ 1a /3 /9r 17V ° 1' LAW OFFICES OF DAVIS, WRIGHT, TODD, RIESE & JONES A PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS 110 11OTH AVENUE N.E. SUITE 700 BELLEVUE. WASHINGTON 98004 42061 •51.8686 TELECOPIER: (206) 451.9397 December 2, 1985 Transportation Committee City Council City of Tukwila 6200 Southcenter Blvd. Tukwila, Washington 98188 Re: Extension of South 168th Street Dear City Council Members: •200 SEATTLE•FIRST NATIONAL BANK BUILDING SEATTLE. WASHINGTON 98154 (2061 622.3150 TELEX: 328919 TELECOPIER: 1206) 622.•322 550 WEST 7714 AVENUE SUITE (•50 ANCHORAGE. ALASKA 99501 19071 276.44813 TELECOPIER: (907) 279.1761 1752 N STREET N.W. SUITE 800 WASHINGTON. D.C. 20036 (202) 822-9775 T E LE C O P I E R: 12021 296-3196 PLEASE REPLY TO BELLEVUE OFFICE We have been informed that the Transportation Committee will be meeting December 3, 1985 to hear concerns of various property owners on the proposed extension of South 168th Street between Southcenter Parkway and Andover Park West. We represent TCW Realty Advisors which owns property on the south side of the proposed street extension and fronting on Andover Park West. Based upon the information provided at the briefing by Entranco Engineers on November 20, 1985, we would like to express cautious support for the extension of the street. There are some areas of concern, however. The present design proposes to take 30 feet of right -of -way from the properties to the north and south of the roadway. The TCW Realty Advisors' property is encumbered on the north by a railroad spur and an underground electrical transmission line. The present design would require relocation of both of these improvements at sub- stantial cost to the City. We recommend that the street be located to the north of the existing TCW property line placing it entirely on undeveloped property. This location would eliminate the cost of relocating the railway line and utility line and will reduce land acquisition costs. We are concerned that if the railway line is relocated, it will be relocated farther to the south and will result in a substantially greater taking of TCW Realty Advisors' property than presently proposed. Our client's property is developed and any taking will be costly and will create a hardship. 1 Transportation Committee City Council City of Tukwila December 2, 1985 Page 2 We ask that the location of the street and the land acqui- sition costs and utility and railroad relocation costs be clearly analyzed in the Environmental Impact Statement. Please also consider this letter to constitute a comment on the Scope of EIS. If you have any further questions, please do not hesitate to contact me or Thomas Herta at TCW Realty Advisors, 400 South Hope Street, Los Angeles, California, 90071 -2899. LMY /kg Very truly yours, DAVIS, WRIGHT ,,TODD, RIESE & JONES / / Linda M. Young, cc: Mr. Thomas Herta Mr. Brad Collins, Planning Director Hall Baetz, Esq: HAYDEN CORPORATION December 2, 1985 FEDERAL EXPRESS Mr. Phillip Fraser Senior Engineer City of Tukwila 6200 Southcenter Blvd. Tukwila, Washington 98188 RE: Proposed 168th Street Development Impact upon Parkway Square Shopping Center • 900 N. TOMAHAWK ISLAND DRIVE PORTLAND, OREGON 97217 PHONE (503) 283 -4111 Dear Mr. Fraser: The purpose of this letter is to formally establish the concerns of property owner, Real Property West, Inc., for the proposed development of 168th Street between Andover Park West and Southcenter Parkway. As outlined in the November 20, 1985, meeting with Entranco Engineering and the City of Tukwila Engineering Department, a feasibility study is now being prepared to be presented to the City of Tukwila Transportation Committee on the development of 168th Street. At that time, Hayden Corporation, representing Real Property West, Inc., expressed several key concerns and their possible adverse affect to the property known as Parkway Square Shopping Center. As now appropriate, I will restate these concerns by the property owner: 1. Loss of Service Driveway: The Sanitation and building service areas are now designated in the south property line boundary of the shopping center. This access is essential to the daily operations and management of the shopping center and would be eliminated with the proposed roadway. 2. Building Setback: The roadway proposal would create a ten (10) foot setback from the sidewalk curb to the building wall. Tenants and customers would not have adequate access area for efficient retail use. 3. Grade Variation: The roadway proposal creates a three (3) to four (4) foot grade level variation between the roadway /sidewalk (lower) and building level (higher). This would result in severe access, design and foundation problems. 4. Public Identification & Physical Barrier: As a retail location it is essential that street traffic identify and obtain easy access to the shopping center. The proposed roadway would create a traffic problem and potential hazard for left turn access from Southcenter Parkway and in addition produce a visual and physical barrier from the proposed roadway. or Phillip Fraser December 2, 1985 page .2:; • Project Cost and Construction: The considerable cost of development of a roadway cannot be absorbed in any proportion by the property owner. Given existing ecomonic conditions any construction interference with the daily operation of the shopping center tenants is unacceptable. It is the conclusion of Real Property West, Inc., that the present proposed 168th Street) Development would have a major negative impact on Parkway Square Shopping Center. Real Property West proposes the feasibility study by Entranco Engineers for the City of. Tukwila Transportation Department be terminated before an additional and unnecessary expenditure of additional public funds. Best regards, Larry W. Summerton Contract Property Manager for Real Property West, Inc. LWS:mm M39D11 cc: Real Property West, Inc. WAC 197- 11 -00 • DETERMINATION OF SIGNIFICANCE AND REQUEST FOR COMMENTS ON SCOPE OF EIS Description of Proposal South 168th Street - Constru'ction of a new link arterial street between Southcenter Parkway and Andover Park West; right of way will involve filling a portion of Tukwila Pond and modification of railway service to properties along route. Proponent City of Tukwila Location of Proposal, including street address, if any Immediately south of Southcenter; bracketed between Strander, Andover Park West, Southcenter Parkway, and the railroad spur to the north, east, west, and south respectively - see attached Figure. Lead Agency: City of Tukwila File No. EPIC - 294-75 EIS Required. The lead agency has determined this proposal is likely to have a significant adverse impact on the environment. An environmental impact statement (EIS) is required under RCW 43.21C.030(2)(c) and will be prepared. An environmental checklist or other materials indicating likely environmental impacts can be reviewed at our offices. The lead agency has identified the following areas for discussion in the EIS:Earth, Water, Plants, Animals, Land & Shoreline Use, Transportation, Utilities, Environmental Health - Noise, Air, and Aesthetics - see attached narrative. Scoping. Agencies, affected tribes, and members of the public are invited to comment on the scope of the EIS. You may comment on alternatives, mitigation measures, pro- bable significant adverse impacts, and licenses or other approvals that may be required. The method and deadline for giving us your comments is: Submitted in writing and received on or before Uecember16, 1985. Responsible Official Brad Collins Position /Title Planning Director Phone 433 -1845 Address 6200 Southcenter Boulevard, Tukwila, WA 98188 Date November 18, 1985 Signature You may appeal this determination to the City Clerk at`lrity Hall, 6200 Southcenter Boulevard, Tukwila, WA 98188 no later than 10 days from the above date by written appeal stating the basis of the appeal for specific factual objections. You may be required to bear some of the expenses for an appeal. Copies of the procedures for SEPA appeals are available . with the City Clerk and Planning Department. rt NARRATIVE • • Earth - Includes topography, soil types, soil stability, filling and grading, erosion potential, impervious surfaces, and appropriate mitigative measures. Water Includes work within 200 feet of surface water (Tukwila Pond), filling of portions of pond, possible diversion of surface water, work within 100 year flood plain, street surface water runoff, and appropriate mitigative measures Plants - Includes wetland and upland plants, wetland inventory, consideration of threatened or endangered plants, and landscaping. Animals - Includes birds and other wildlife using Tukwila Pond, consideration of threatened or endangered species, migratory implications, and measures to preserve or enhance wetland habitat. Land & Shoreline User Includes site and adjacent land use characterization, existing structures, structures to be demolished, current zoning, comprehensive plan designation, current shoreline designation, classification: for environmental sensitivity, appropriate measures to ensure land use compatibility. Transportation - Includes identification of existing streets and highways, public transit, parking space issues, new streets, railroad access issues, projected traffic volumes, and appropriate mitigation measures. Utilities - Includes identification of existing utilities and possible impacts, new utility needs, and appropriate mitigation measures. Environmental Health - Includes existing noise, types and levels of noise associated with project and appropriate measures to reduce or control noise impacts. Air - Includes types of emissions and appropriate measures to reduce or control impacts. Aesthetics - Includes description of possible impacts to aesthetics of natural environment of Tukwila Pond. The EIS will also address the objectives of the proposed project, alternatives, comparison of alternatives, any proposal conflicts with policies of the Tukwila Comprehensive Land Use Policy Plan and appropriate mitigation measures. ,11 1 LIMITS 144th ST TUK W ILA PON• 81188TH uuuuuuI e ENTRANCO Engineers FIGURE 1. VICINITY MAP- PROPOSED NEW ARTERIAL SOUTH 168TH ST' 1 Rosse nc. c/o 'Samuel & Hazel Rosse 808 Howell Street Seattle, Washington 98010 M.A. Segale, Inc. P.O. Box 88050 Tukwila, Washington 98188 Shilder McBroom & Gates 3500 First Interstate Center Seattle, Washington 98104 Attn: Mr. Gary D. Huff Spring Ridge Investment, Inc. c/o Jones & Grey .& Bayley, P.S. One Union Square 36th Floor Seattle, Washington 98101 Springridge Investment Ltd. 1021 Island Road Victoria, British Columbia Canada V8S 2VS Attn: Mr. Bruce Smith Trammell Crow Company P.O. Box 80326 Seattle, Washington 98108 Attn: Don Jefferson, Proj. T.C.W. Realty Holding mpan 400 South Hope Street 11,0e, Los Angeles, California 900 artment of HUD n Department econd Avenue Seattle, Washington 98101 U.S. Department of Interior Bureau of Land Management East 4217 Main Street Spokane, - Washington 99202 U.S. Postal Service 34301 Ninth Avenue South U.PA-t -shMI W 1CKS Federal Way, Washington 98103 +. T' 'eOW p11� /1/ i1eeo go�ar++croass � u tu► WIc w 4% tSt VI /NsIn) to yyz 26 PUC>ET Pc►-JF/L 62.0. s Uk.a—OY k e.,J Tb .J W A , / 48 firs- MAc4.0141114 ly,(4.1.4.•= M16.L1(d4• 0 1 /s( 1 'V U111414..0 :5;4.41eot rPUI A.16 l 12-9-4104 elf,rz* kA-1 C>z a e.a reb/LAT-i 0.40 ,� o N. T1.1./7 tr ?.,L tD /Lri.4..1 tom, U11tCxa cr7u7 1 nn;s 7. McLerrar *Ns Shaer Mc Swk so+to .o, rogue, Ave ue. IWIel ti¢..) WA . q'gooq U.S. Postal Service Tukwila Branch 225 Andover Park West Tukwila, Washington 98188 Washington State Department of Game Environmental Affairs Team 600 North Capitol Way Olympia, Washington 98504 Washington State Department of Ecology Mgr. Mail Stop PV -11 Olympia, Washington 98504 Union Pacific Corporation Tax Office P.O. Box 2500 Broomfield, Colorado 80020 Pacji-d- S15/ 7"-" Union Pacific Railroad 1515 Building S.W. Fifth Avenue Portland, Oregon 97201 Attn: A. L. Shoener, Gnl. Mgr. Upland Drive Business Park 8815 - 38th Avenue N.E. Seattle, Washington 98115 U.S. Army Corps of Engineers Environmental Resource Section P.O. Box C -3755 Seattle, Washington 98124 (J .rte r u v lut c )-' i s iY/ t re'1 W.S.D.O.T. 1 w�, of y� t-5 Dist. Design Engineer /Env. Review i 5ek 0 -i`/ 9611 S E 36th Street 4 • • Mercer Island, Washington 98040 W.S.D.O.T. 6431 Corson Avenue South Seattle, Washington 98104 Attn: Mr. Jerry Schutz Washington State Office of the Attorney General Dexter Horton Building Seattle, Washington 98104 (/t 4 co- in Pet i t Sy57"£ S.w. g"' `/¢r.a7rw:to yva P2i4,vp o,q 972.o/ 1.cl {Ar-4 c IGUCS _rQ P�cv Ua11W 14,11 dal i i e-S e. I/o //0 -• 41e It!e. -F , l& i1O D5 • ENTRANCO ENGINEERS, INC. To: LETTER OF /TRANSMITTAL O MEMORANDUM Ricx 1515 -118th AVENUE N.E.. SUITE 200 (206)454-0683 BELLEVUE, WASHINGTON 98004 o 518 SEATTLE -FIRST NATIONAL. BANK BUILDING (206)258 -6202 EVERETT, WASHINGTON 98201 Date. 11 -l�f- sr (lir/ o 7-Lrikati Project No Ir615 ' Z la(e too Title: f48 tEIS Re• 5- -o/J(77 goilla Attention: if ATTACHED 0 ORIGINALS a UNDER SEPARATE COVER 0 PRINTS o OTHER FOR YOUR: NFORMATION /USE AS REQUESTED a OTHER OUR ACTION: a REVIEWED o APPROVED 0 NOT APPROVED o SEE REMARKS a OTHER REOUESTED ACTION: p4PROVAL a REVIEW 8 COMMENT a MAKE CORRECTIONS NOTED a REVISE & RESUBMIT SigrTH ER� NO. OF COPIES DRAWING NUMBER DESCRIPTION rtd 4-ra717 V 4CA ell 814)4. c/Lfer� C'(7 Di, li •,y Ifs Re%arks: uK h 4>z 4144,F die e( c ycC%Sed j 5ketAiix Pik- Al /e �cr 1/pt e n a 4 -,/7// - //J , Srna 1e 141e /441,t 5l " /144 ZO '- e Z: OD d es w 74. e , "ve/aer Owe ers s t also 6116.415d d /s cy% / 5 By: L4L qi/t JI tag. 67 Ii fizollo )0i4f. 4,4,-0,014f w' "iced 1 4 wLic. sae Dr /'4..r 7-.L4'd " cc• lre61 1/0e./ 6 014e,a1 DISTRIBUTION: White It Addressee - Canary to Project File - Pink to Day File A -02.2 (1 -85) ENTRANCO ENGINEERS, INC. November 6, 1985 Mr. Rick Beeler City of Tukwila 6200 Southcenter Boulevard Tukwila, Washington 98188 Dear Mr. Beeler: 1515 -116TH AVENUE N.E., SUITE 200, BELLEVUE, WASHINGTON 98004 (206) 454-0683 We have been retained by the City of Tukwila to study the feasibility of developing a new arterial street. The proposed street is South 168th Street between Southcenter Parkway and Andover Park West (see enclosed vicinity map). Currently we are gathering data and identifying the issues affecting the proposed road. To aid us in this effort and better acquaint you with the proposed project, we have scheduled a meeting of adjacent and nearby property owners. You are welcome to bring any of your tenants to the meeting. The meeting is scheduled for: 2:00 P.M. Wednesday November 20, 1985 Tukwila City Hall 6200 Southcenter Boulevard Conference Room 3 An environmental impact statement will be prepared for the project. A scoping notice for the Draft EIS will be published in the near future. The November 20th meeting is an information and data gathering meeting. Environmental information gathered at this meeting will be used for the EIS process. If you or a representative are unable to attend the meeting, please advise either Phil Fraser, Senior Engineer, City of Tukwila (206) 433 -1856 or Jim Wiley, Project Manager, Entranco Engineers (206) 454 -0683. Sincerely, ENTRANCO ENGINEERS, INC. ,O James D. Wiley, P.E. Project Manager Encl. Nov 7 1985 Pt �:(���:it�ik� DEPT' :LA 1 EVERETT OFFICE: 518 SEATTLE -FIRST NATIONAL BANK BUILDING, EVERETT, WASHINGTON 98201 (206) 258-6202 ♦ LIMITS TUKWILA POND S.188TH Y 111111111111111 a KLER.ELV NORTH S 180th ST ENTRANCO , Engineers FIGURE 1 VICINITY MAP — PROPOSED NEW ARTERIAL SOUTH 168TH ST. J TASK % TOTAL % ITEM COMPL. % TOTAL COMPL. OCT 14 21 28 1985 NOV 411 18 25 DEC 2 9 16 23 10 JAN 613 20 27 FEB 3 10 17 24 MAR 3 10 17 24 31 APR 7 14 21 28 1986 MAY 5 1219 26 JUN 2 9 16 2) 30 4JUL 7 14 21 28 AUG 4 11 18 25 SEP 1 e 15 22 w OCT a 11 DESIGN REPORT Survey 10.5 Data Collection 1.0 Soils Investigation 20.0 Design Report 34.0 • • 1 i Right -Of -Way 3.0 ENVIRONMENTAL. IMPACT STATEMENT Scoping 2.5 DEIS 22.0 4 City Review Imo, Issue DEIS Hearing DEIS A Final EIS 7.0 Issue Final EIS - TOTAL 100 • Public Meeting South 168th Street City of Tukwila October 31. 1985 PROGRESS REPORT NO. 1 SCHEDULE project: 168th street DEIS - Tukwila prepared by dea date: 10 -14 -85 task months from notice to proceed 1 - SCOPIN6 DEIS(1) 2 - DEIS PREP 3 - FINAL EIS(2) 4 - HEARING DRAFT EIS(3) 5 - PRINT & CIRCULATE(4) 6 - CONTRACT SCOPE PREP(5) 1 2 3 4 5 6 7 8 9 10 11 12 ifftf }fff }fffff }ffffffffffffffffffff fffiffffffff footnotes: fff fffffffffffff***** (1) 21 day wait for response (2) assumes no major changes required; after feis issused wait 7 days minimum before action (3) no sooner than 15 days after deis issuance (41 includes city's review, then a 30 day comment period (5) subject to revision from scoping results - 85-3Lia ENTRANCO ENGINEERS, INC. To: LETTER OF r TRANSMITTAL 0 MEMORANDUM 6 z 1515 -116th AVENUE N.E.. SUITE 200 (206)454-0683 BELLEVUE. WASHINGTON 98004 ❑ 516 SEATTLE -FIRST NATIONAL BANK BUILDING EVERETT, WASHINGTON 98201 (206)258 -6202 Date' /49- R 8— e'3 • 4, wG 7 t31 Project No' 660': —d 6 Title' Se /6 Ap7-4 Z74-X Re' Attention: �fj -/ F /e4-.1 ATTACHED ❑ ORIGINALS ❑ UNDER SEPARATE COVER SGPRINTS ❑ OTHER FOR YOUR: NFORMATION /USE ❑ AS REQUESTED ❑ OTHER OUR ❑ REVIEWED ❑ NOT APPROVED ACTION: ❑ APPROVED ❑ SEE REMARKS ❑ OTHER REQUESTED APPROVAL ❑ MAKE CORRECTIONS NOTED ACTION: ❑ REVIEW & COMMENT ❑ REVISE & RESUBMIT ❑ OTHER NO. OF DRAWING COPIES NUMBER _L %Q. 1T Ge or o I S4 mev j, M % 7 c e L • - ,b--z-,J. __(_ 3 5 j� r� Ted Ala./h.-if .e.17'- - S'� o�_ . /1, r: e_ Q DESCRIPTION Remarks' P./ ek 1 G /•e d. -P c.c/ a .✓o��O� f1 On �o ,L1 l /v C IvED CITY Or Tt.!KWItJ NOV PJSL:C WORKS 0E°' CC' DISTRIBUTION: White to Addressee - Canary to Project Fite - Pink to Day File A -02.2 (1 -85) '. Responsible official Brad Col 1 ins Position /title Planning Director Phone433 -1845 Addiess 6220 Southrenter Route ton 9R1R8 Date Signature (OPTIONAL) You may appeal this determination of significance • to (name) City Clerk at City Hall at (location) 6200 Southcenter Boulevard, Tukwila, Washington 98138 no later than (date) 10 days from the above by (method) Written appeal You should be prepared to make specific factual objections. YOu may be required to bear some of the Contact City Clerk to read or ask about the procedures expenses for an appeal. for SEPA appeals. There. is no agency appeal. [Ch. 197 -11 RCW —p 541 Published. (1983 Laws) (attach Affidavit of Distributic V„ 1 LIMITS TUK W IL A PONO - 3.188TH uuuuunu � 11 A. RAIL OA ,PL BAR IBO NORTH S 180th ST ErTwwco Engineers FIGURE 1 VICINITY MAP - PROPOSED NEW ARTERIAL SOUTH 168TH ST. J SOUTH 168TH STREET - CITY OF TUKWILA SCOPING NOTICE MAILING LIST Allied Stores • 633 Southcenter Mall Tukwila, Washington 98188 Andover & Associates 854 East Mercer Way Mercer Island, Washington 98040 Attn: Mr. Thomas Yedor Audubon. Society Room 619 Seattle, Washington 98101 Attn: Joshua Green Building Bon Marche c/o L. V. Miller 3rd & Pine Seattle, Washington 98111 Bon Marche Distribution Center 17000 Southcenter Parkway Tukwila, Washington 98188 Attn: Mr. William Hicks Buck & Gordon 1011 Western Avenue Seattle, Washington 98104 Attn: Mr. Jay P. Derr Chamber of Commerce 950 Andover Park East Tukwila, Washington 98188 Attn: Mr. Terry Anderson Chevron USA, Inc. P.O. Box 7611 San Francisco, California 94120 Chevron USA 220 Strander Boulevard Tukwila, Washington 98188 City of Kent Public Works Department P.O. Box 310 Kent, Washington 98031 Attn: Mr. Don Wickstrom, Director FT City of Renton Public Works Department 200 Mill Avenue South Renton, Washington 98055 Attn: Mr. Dick Houghton, Director City of Tukwila City Council 6200 Southcenter Boulevard Tukwila, Washington 98188 Attn: Ms. Mabel Harris, Chairwoman City of Tukwila Transportation Committee 6200 Southcenter Boulevard Tukwila, Washington 98188 Attn: Mr. Bud Bohrer City of Tukwila Transportation Committee 6200 Southcenter Boulevard Tukwila, Washington 98188 Attn: Ms. Wendy Morgan Commercial Design Associates 4230 - 198th Street S.W. Lynnwood, Washington 98036 Attn: Mr. Scott Shanks Doubletree Plaza 1600 Southcenter Parkway Tukwila, Washington 98188 Attn: Mr. George J. Neumann Doubletree Inc. 6225 North 24th Street, #200 Phoenix, Arizona 85016 Attn: Mr. James R. Smith Emerson GM Diesel, Inc. 6851 East Marginal Way South Seattle, Washington 98108 Firestone 215 Andover Park West Tukwila, Washington 98188 Attn: Mr. Dennis McGriff Mr. Larry Hanson Firestone Zone Marking Office P.O. Box 68907 Seattle, Washington 98168 Attn: Mr. Russ Paris First Western Development 4230 - 198th Street Lynnwood, Washington 98036 Attn: Mr. Mike Hess Hayden Island Corporation 909 Norht Tomahawk Island Drive Portland, Oregon 97217 J. C. Penny Company Regional Tax Office #4015 Buena Park, California 90624 King County Surface Water Management Division Room 976 King County Administration Building Seattle, Washington 98104 Attn: Mr. Joe Simmler, Manager King County Traffic & Planning Division 9th Floor King County Administration Building Seattle, Washington 98104 Attn: Mr. John Logan, Manager Metro 821 Second Avenue Seattle, Washington 98104 Attn: Mr. Dick Sandaas Metro Environmental Planning Division 821 Second Avenue South Seattle, Washington 98104 Office of Archaeology and Historic Preservation 111 West 21st Avenue, KL -11 Olympia, Washington 98504 Attn: Mr. Robert G. Whittam Puget Sound Air Pollution Control Agency P.O. Box 9863 Seattle, Washington 98109 Attn: Mr. Arthur Dammkoehler Puget Sound Council of Governments 216 First Avenue South Seattle, Washington 98104 Attn: Mr. Jim Williams Rainier National Bank Controllers Department 086 P.O. Box 3966 T14 -1 Seattle, Washington 98124 Real Property West 44 Montomery Street, #4230 San Francisco, California 94104 Rosse Inc. c/o Samuel & Hazel Rosse 808 Howell Street Seattle, Washington 98010 M.A. Segale, Inc. P.O. Box 88050 Tukwila, Washington 98188 Shidler McBroom & Gates 3500 First Interstate Center Seattle, Washington 98104 Attn: Mr. Gary D. Huff Spring Ridge Investment, Inc. c/o Jones & Grey & Bayley, P.S 36th Floor One Union Square Seattle, Washington 98101 Springridge Investment Ltd. 1021 Island Road Victoria, British Columbia V8S 2V2 Canada Attn: Mr. Bruce Smith Trammell Crow Company P.O. Box 80326 Seattle, Washington 98108 Attn: Mr. Don Jefferson Project Manager T.C.W. Realty Holding Company 400 South Hope Street Los Angeles, California 90071 Union Pacific Corporation Tax Office P.O. Box 2500 Broomfield, Colorado 80020 Union Pacific Railroad 1515 Building S.W. Fifth Avenue Portland, Oregon 97201 Attn: Mr. A. L. Shoener General Manager Upland Drive Business Park 8815 - 38th Avenue N.E. Seattle, Washington 98115 U.S. Army Corps of Engineers Seattle District Environmental Resource Section P.O. Box C -3755 Seattle, Washington 98124 U.S. Department of HUD Valuation Department 1321 Second Avenue Seattle, Washington 98101 U.S. Department of Interior Bureau of Land Management Regional Office East 4217 Main Street Spokane, Washington 99202 U.S. Postal Service 34301 Ninth Avenue South Federal Way, Washington 98103 U.S. Postal Service Tukwila Branch 225 Andover Park West Tukwila, Washington 98188 Washington State Department of Game Program Manager Environmental Affairs Team 600 North Capitol Way Olympia, Washington 98504 Washington State Department of Ecology Mail Stop PV -11 Olympia, Washington 98504 Washington State Department of Transportation District Design Engineer/ Environmental Review 9611 S.E. 36th Street Mercer Island, Washington 98040 Washington State Department of Transportation 6431 Corson Avenue South Seattle, Washington 98104 Attn: Mr. Jerry Schutz Planning & Research Coord. Washington State Office of the Attorney General Dexter Horton Building Seattle, Washington 98104 • City of Tukwila 6200 Southcenter Boulevard Tukwila Washington 98188 433-1800 Gary L VanDusen, Mayor October 9, 1985 .John Bannon Entranco Engineers 1515 116th Ave. NE Suite 200 Bellevue, WA 98004 RE: Notice to Proceed for S. 168th Street Preliminary Design Report, Environmental and Right -of -Way Services Project No.: 84 -RWO8 Contract No.: 85 -062 City Budget Line Item No.: 103/02.541.101.41.78 Dear Mr. Bannon: Enclosed you will find your copy of Contract #85 -062 for $132,650. Per section #3 of the enclosed agreement, 366 calendar days are provided to complete the awarded scope of work. The effective date of this notice to proceed is October 10, 1985. Within the next 10 calendar days please submit your schedule for our review and approval. Your insurance cer- tificate shall be delivered to the City in order for this Notice to Proceed to be in effect. To expedite the City's vouchering process, it is requested that your billing include the contract name, number, and the City's Budget Line Item number. The Project Engineer for this project is Phil Fraser. If you have any questions, do not hesitate to call at 433 -1856. Sin l y illip R. Fraser Senior Engineer cc: Cei Finance Department City Engineer File: 84- RW08 -2 Enclosure (1) /ks /KPW.2(168TH.NTP) SOUTH 168th STREET -. A2C FILE #. DATE /0 - 9- g5 CO. Entra, cc) En9,n errs CONSULTANT AGREEMENT FOR jJ1' / of 3 ENGINEERING SERVICES This Agreement is entered into between the City of Tukwila, Washington, hereinafter referred to-as the "CITY," and Entranco Engineers, Inc., hereinafter referred to as the "CONSULTANT," in consideration of the mutual benefits, terms, and conditions hereinafter specified. 1. Project Designation The CONSULTANT is retained by the CITY to perform engineering services in connection with the project designated South 168th Street - New Link Arterial Street. 2. Scope of Services CONSULTANT agrees to perform the services, identified in Exhibit "A" attached hereto, including the provision of all labor, materials, equipment, and supplies. 3. Time of Performance Work under this contract shall commence upon the giving of written notice by the CITY to the CONSULTANT to proceed. CONSULTANT shall perform all services and provide all work product required pursuant to this Agreement in accordance with the following: Preliminary Design and Environmental Impact Statement - 366 calendar days 1 9/16/85 • Final Design, Bidding Phase, Construction Inspection and Staking Services - to be established at time of work Post - Construction Phase - two months after acceptance of construction Established completion time shall not be extended because of any unwarranted delays attributable to the CONSULTANT, but will be extended by the CITY in the event of a delay caused by Extra Work requested by the CITY, or because of unavoidable delays caused by an act of God, or governmental actions, or other conditions beyond the control of the CONSULTANT. 4. Payment The CONSULTANT shall be paid by the CITY for completed work for services rendered under this Agreement as follows: a. Payment for the work provided by CONSULTANT shall be made on an hourly basis plus expenses as provided in Exhibit "B" attached hereto, provided that the total amount of payment to CONSULTANT shall not exceed One Hundred Thirty -Two Thousand Six Hundred Fifty Dollars ($132,650) without express written modification of this Agreement signed by the CITY. b. The CONSULTANT may submit vouchers to the CITY once per month during the progress of the project for partial payment for work completed to date. Such vouchers will be checked by the CITY and upon approval thereof, payment will be made to the CONSULTANT in the amount approved. 2 • c. Final payment of any balance due the CONSULTANT of the total Agreement amount will be made promptly upon its ascertainment and verification by the CITY after the completion of the work under this Agreement and its acceptance by the CITY. d. Payment as provided in this section shall be full compensation for work performed, services rendered, and for all materials, supplies, equipment, and incidentals necessary to complete the work. e. The CONSULTANT's records -and accounts pertaining to this Agreement are to be kept available for inspection by representatives of the CITY and State for a period of three (3) years after final payments. Copies shall be made available upon request. 5. Ownership and Use of Documents All documents, drawings, specifications, and other materials produced by the CONSULTANT in connection with the services rendered under this Agreement shall be the property of the CITY whether the project for which they are made is executed or not. The CONSULTANT shall be permitted to retain copies, including reproducible copies, of drawings and specifications for information, reference, and use in connection with CONSULTANT's endeavors. The CITY will not hold the CONSULTANT liable for any re -use of such documents, drawings, specifications, and other materials produced by the CONSULTANT in connection with the services rendered under this Agreement. 3 6. Compliance with Laws CONSULTANT shall, in performing the services contemplated by this Agreement, faithfully observe and comply with all federal, state, and local laws, ordinances, and regulations applicable to the services to be rendered under this Agreement. 7. Indemnification CONSULTANT shall indemnify and hold harmless the CITY, its officers, agents, and employees from and against any and all claims, losses, or liability, or any portion thereof, including attorney fees and costs arising from injury or death to persons, including injuries, sick- nesses, disease, or death to CONSULTANT's own employees, or damage to property occasioned by negligent act, omission, or failure of the CONSULTANT, its officers, agents, or employees, in connection with services rendered pursuant to this Agreement. CONSULTANT shall not be required to indemnify, defend, or hold harmless the CITY with respect to any portion of any settlements or judgments arising from the negligence or other fault of the CITY, and not arising from the negligent act, omission, or other failure of the CONSULTANT, its agents, servants, or employees. With respect to the City, the CONSULTANT specifically waives its immunity under Title 51 of the Revised Code of Washington, the Industrial Insurance Act, for injuries to its employees, and agrees that the obligation to indemnify and hold harmless the CITY and any of its agents and employees extends to any claim, demand, or cause of action brought by or on behalf of any employee of the CONSULTANT against the CITY, its officers, agents, and employees, and includes any judgment, award, and cost arising therefrom, including attorney's fees. 4 8. Insurance The CONSULTANT shall secure and maintain in force throughout the duration of this Agreement comprehensive general liability insurance with a minimum coverage of $500,000 per occurrence and $1,000,000 aggregate for personal injury; $500,000 per occurrence /aggregate for property damage; and professional liability insurance in the amount of $1,000,000. Said general liability policy shall name the City of Tukwila as an additional named insured and shall include a provision prohibiting cancellation of said policy except upon thirty (30) days' prior written notice to the CITY. Certificates of coverage as required by this section shall be delivered to the CITY within fifteen (15) days of execution of this Agreement. 9. Independent Contractor The CONSULTANT and the CITY agree that the CONSULTANT is an independent contractor with respect to the services provided pursuant to this Agreement. Nothing in this Agreement shall be considered to create the relationship of employer and employee between the parties hereto. Neither CONSULTANT nor any employee of CONSULTANT shall be entitled to any benefits accorded CITY employees by virtue of the services provided under this Agreement. The CITY shall not be responsible for withholding or otherwise deducting federal income tax or Social Security or for contributing to the state industrial insurance program, or otherwise assuming the duties of an employer with respect to CONSULTANT, or any employees of CONSULTANT. 10. Covenant Against Contingent Fees The CONSULTANT warrants that he has not employed or retained any company or person, other than a bona fide employee working solely for the CONSULTANT, to solicit or secure this Agreement, and that he has 5 not paid or agreed to pay any company or person, other than a bona fide employee working solely for the CONSULTANT, any fee, commission, percentage, broker fee, gifts, or any other consideration contingent upon or resulting from the award or making of this Agreement. For breach or violation of this warranty, the CITY shall have the right to annul this Agreement without liability or, in its discretion, to deduct from the Agreement amount, or otherwise recover, the full amount of such fee, commission, percentage, brokerage fee, gift, or contingent fee. 11. Discrimination Prohibited The CONSULTANT, with regard to the work performed by it under this Agreement, will not discriminate on the grounds of race, color, national origin, religion, creed, age, sex, or the presence of any physical or sensory handicap in the selection and retention of employees or procurement of materials or supplies. 12. Assignment The CONSULTANT shall not sublet or assign any of the services covered by this Agreement without the express written consent of the CITY. The subconsultants that the CONSULTANT-intends to use on this project are: Hart - Crowser & Associates - geotechnical Colie Hough Associates - landscape architecture Rex Van Wormer - biological. consultant 13. Non - Waiver Waiver by the CITY of any provision of this Agreement or any time limitation provided for in this Agreement shall not constitute a waiver of any other provision. 6 14. Termination a. The CITY reserves the right to terminate this Agreement at any time upon not less than ten (10) days' .written notice to the CONSULTANT. b. In the event of the death of a member, partner, or officer of the CONSULTANT, or any of its supervisory personnel assigned to the project, the surviving members of the CONSULTANT hereby agree to complete the work under the terms of this Agreement, if requested to do so by the CITY. This section shall not be a bar to renegotiation of this Agreement between surviving members of the CONSULTANT and the CITY, if the CITY so chooses. c. In the event this Agreement is terminated under any of its terms prior to completion of the work, a final payment shall be made to the CONSULTANT for work satisfactorily completed which, when added to any payments previously made, shall total the same percentage of the amount which would have been due if the work had been fully completed as the work completed at the time of termination bears to the total work required under this Agreement. 15. Notices Notices to the City of Tukwila shall be sent to the following address: City of Tukwila Department of Public Works 6200 Southcenter Boulevard Tukwila, Washington 98188 7 Notices to CONSULTANT shall be sent to the following address: Entranco Engineers, Inc. 1515 - 116th Avenue N.E., #200 Bellevue, Washington 98004 16. Integrated Agreement This Agreement, together with attachments or addendums, represents the entire and integrated Agreement between the CITY and the CONSULTANT and supersedes all prior negotiations, representations, or agreements written or oral. This Agreement may be amended only by written instrument signed by both the CITY and the CONSULTANT. 17. Extra Work The CITY may desire to have the CONSULTANT perform work or render services in connection with this project other than provided for by the expressed statements of this Agreement. This will be considered as Extra Work, subject to change .order, supplemental to this Agreement, setting forth the nature and scope thereof. Work under such supplements shall not proceed unless and until so authorized in writing by the CITY. Payment for all Extra Work performed under this Agreement shall be negotiated at the time the Extra Work is authorized. It is anticipated that the CITY may desire the CONSULTANT to prepare presentation materials for and participate in additional public meetings. This work shall not require a Supplemental Agreement and the CONSULTANT shall be compensated for such work at the rate of Five Hundred Dollars ($500) per meeting. 8 1• 18. Changes in Work The CONSULTANT shall make such revisions in the work included in this Agreement as are necessary to correct errors or omissions appearing therein, when required to do so by the CITY, without additional compensation therefor. Should the CITY find it desirable for its own purposes to have previously satisfactorily completed work or parts thereof revised, other than minor revisions within the scope of the work, the CONSULTANT shall make such revisions, if requested and as directed by the CITY, in writing. This work shall be considered as Extra Work and will be paid for as provided in Item 17. All extra work shall be submitted as a supplement to this Agreement and approved by the CITY before the work is undertaken. CITY OF TUKWILA ENTRANCO ENGINEERS, Mayor, Gary L. Van Dusen Attest: City Clerk, Maxine Anderson Approved as to form: Office of the City Attorney: President 9°-/t- Date EXHIBIT "A" SOUTH 168TH STREET - NEW LINK ARTERIAL STREET Between Southcenter Parkway and Andover Park West SCOPE OF SERVICES During the term of this Agreement, the CONSULTANT shall provide design services in connection with the following project: South 168th Street - New Link Arterial Street Between Southcenter Parkway and Andover Park West The scope of work shall include the furnishing of all services and labor, materials, equipment, supplies, and incidentals to conduct and complete the work as follows: Phase I a. Preliminary design surveys. b. Design reports. c. SEPA environmental impact statement d. Right -of -way. Phase II a. Design street paving; curb and gutter, sidewalks, driveways. b. Design storm drainage. c. Design utilities. Phase III a. Construction support services. The CONSULTANT shall prepare construction plans in conformance with standard practice of City for plans prepared by its own staff. Procedures shall be consistent with the provisions of the current edition of the Department of Transportation "Highways Design Manual" and amendments thereto. The CONSULTANT shall provide the following basic engineering services for the project, consisting of the preparation of detailed construction drawings and specifications, estimate and other relative information including, but not limited to, the following items: A. PRELIMINARY DESIGN PHASE - PHASE I 1. Survey The field work shall consist of the following items: a. Research. b. Field survey and mapping. c. Field surveying work for right -of -way computations, staking of right -of -way, and title reports. 9/16/85 1 of 8 Exhibit "A" 2. Soils Investigations The geotechnical work under this contract shall consist of: a. Geologic reconnaissance. b. Subsurface exploration. c. Engineering analysis and consultation. d. Report preparation. 3. Preparation of Preliminary Design Report This task shall consist of the following items: Vicinity map Executive summary Project narrative Description of existing conditions, deficiencies in existing street network, design parameters to be used, design restraints Discussion of alternatives, including number of lanes, vertical and horizontal alignment, sidewalk location, and private access Recommendation of an alternative and discussion Preliminary cost estimate for recommended alternative, including land acquisition costs. Land costs to be based upon current County assessed valuation. No appraisals will . be performed. Traffic analysis (superblock only). Traffic analysis and design year is for 1990 for the superblock defined by Southcenter Parkway, Strander Boulevard, Andover Park West, and S. 180th Street. Existing data, planning studies, and other project reports to be basis for traffic projections and analysis. No major new routes, except Minkler Boulevard extension, are assumed to be in place for design year. Level of service /capacity, accident, and signal warrant studies will be conducted, with attention also given to pedestrian and transit movement. Railroad spur lines impact. This item of work shall include data collection from railroad company and businesses served by the railroad, evaluation of possible relocation, evaluation of possible abandonment, evaluation of design restraints. Discussion of utilities involvement. This item shall consist of review of utility comprehensive plans, location and identi- fication of existing utilities, identification of utilities 2 of 8 Exhibit "A" requiring relocation, discussion of relocation alternatives, including utilities required to support comprehensive plan, discussion of power underground for illumination. Identification of permit needs'and discussion. Roadway cross - sections, including curb, gutter, sidewalk, and preliminary pavement section. Preliminary horizontal alignment drawing. Preliminary vertical alignment drawing. Preliminary storm drainage analysis. ,Preliminary commercial access improvement analysis. Commercial parking disruption discussion. Landscaping and restoration design adjacent to the roadway. Pond landscape enhancement. Bar chart schedule for improvements, including final design engineering and construction. Final report. Public meetings. This item shall also include preparation for meetings, attendance at three (3) meetings, and exhibit preparation. • Client coordination and review meetings, as needed. At the completion of this engineering analysis work, a Preliminary Design Report with 20 copies shall be submitted to the City. 4. Preparation of SEPA EIS A SEPA environmental impact statement will be prepared for the proposed street improvement. This task shall consist of the following items: Scoping process Draft EIS - traffic and wetlands will be major impacts to be addressed Final EIS Assist with hearings for Draft EIS Print and circulate draft and final EIS documents Scope of work, subject to revision following scoping hearing 3 of 8 Exhibit "A" 5. Right -of -Way for Selected Alternative a. Determination of centerline for selected alternative. b. Preparation of right -of -way plans. c. Preparation of legal descriptions for the right -of -way takes and easements. B. FINAL DESIGN - PHASE II Preparation of detailed construction plans and specifications, including the following: 1. Plans shall be prepared with such provision and in such detail as to permit the convenient layout in the field for construction and other purposes within a degree of accuracy acceptable to the City. 2. Plans shall include complete details for the construction of the proposed improvements, including details for paving, concrete curb and gutter, and concrete sidewalks, and the installation of storm drainage, sanitary side sewers, undergrounding, utility adjust- ments, traffic signals, illumination, and landscaping. 3. Plans will consist of a title sheet; plan and profile sheet(s) cross - sections, typical sections; special details and special layouts. 4. Plans shall be in such detail as to permit the development of an accurate estimate of quantities for several pertinent items of work . to be performed in the construction of the project. 5. Plans shall be prepared in ink or equivalent on 36" x 24" mylar sheets. 6. The title sheet shall include the following: a. Project title and number b. Vicinity map c. Sheet index 7. The plan and profile sheet(s) will include the following: a. All rights -of -way, easements, and property lines. b. All storm drainage catch basins with their corresponding invert and rim elevations, all connecting lengths of pipe with their lengths, slopes, and diameters noted. All storm drainage catch basins shall be numbered in both the plan and profile. c. All new sanitary sewer main extension, showing manholes with their corresponding invert and rim elevations; all connecting lengths of pipe with their lengths, slopes, and diameters noted. All manholes shall be numbered in both the plan and profile. 4 of 8 Exhibit "A" d. All new watermain extensions. e. Profile of existing roadway and proposed roadway centerlines. 8. The scales to be used, the lettering, and general delineation of the plans shall be such as will provide legible reproduction when the plans are reduced to one - fourth of their original size (50 percent reduction). 9. The minimum horizontal scale for the plan and profile plans shall be "one inch equals 20 feet." 10. Plans shall include details for pavement marking, signing, and city streets revisions (paving, curb and gutter, storm drainage), as necessary. Plans shall show all the existing physical features, surface and subsurface facilities, as determined by field survey or indicated on City or utility company records for each area included in the right -of -way, or greater, if necessary, outside the right -of -way to include pertinent details adjacent to the right -of -way. 11. Special Provisions shall be included in the contract plans for items of work which are not covered by the APWA and State Standard Specifications, as may be required, to properly cover the work contemplated by the plans. 12. The Consultant shall furnish such pertinent information and data with respect to the plans and design as the City may request, including, but not limited to, one (1) copy of the quantity and design computations. 13. Field surveys required to complete the plans in the Agreement shall be furnished by the Consultant. The field surveys shall include sufficient referencing to permit the re- establishment of all necessary points to the satisfaction of the City. 14. Plotting of street sections and profile, calculation of earthwork quantities. 15. The Consultant shall review all plans and specifications with the City to check for any omissions, duplications, unnecessary requirements, and conformance with City standards. The Consultant shall finalize the plans and specifications in accordance with any City comments. The Consultant shall make such minor changes, amendments, or revisions in the detail of the work as may be required by the, City. This item does not constitute an "Extra Work" item. The Consultant will be held .responsible for the accuracy of the work even though the work has been reviewed and accepted by the City. 16. Preparation of the bid items and quantities for the contract proposal and detailed special provisions will be prepared by the Consultant. The City will furnish examples of the standard 5'of 8 Exhibit "A" • • specifications and contract documents to the Consultant. The Consultant will put together and retype the standard specifications as required. 17. The Consultant shall assemble the plans and specifications in a form approved by the City that can be used by suppliers and /or contractors as a basis for formal bids. 18. Supervise any subconsultants used in connection with preparing design services (as required). 19. Prepare estimate of construction costs based upon the approved construction plans, bid item quantities, and current unit bid prices. 20. Coordinate with the utility companies in connection with the design phase of this project and any utility adjustments /undergrounding necessary. The contemplated utility companies are enumerated as follows: a. Puget Power and Light b. Pacific Northwest Bell c. Group W Cable d. Washington Natural Gas Company 21. Prepare and bind contract documents. 22. Coordinate with the City on all phases of work. C. BIDDING PHASE 1. Assist in obtaining bids. 2. Prepare tabulation of bids. 3. Assist in evaluating bids and awarding contract. D. CONSTRUCTION INSPECTION AND STAKING SERVICES (To be negotiated at time of work.) E. POST- CONSTRUCTION PHASE 1. Prepare record drawings from information provided by contractors, record drawings, and other inspection reports. 2. Provide City with one (1) set of aperture cards reproduced from the record construction drawings. F. DESIGN CRITERIA The City will designate the basic premises and criteria for the design. Plans and specifications, to the extent feasible, shall be developed in accordance with , the latest edition and amendments at the time of Notice to Proceed of the following: 6 of 8 Exhibit "A" 1. APWA WSDOT 1984 standard specifications for road, bridge, and P 9, municipal construction. 2. City of Tukwila design standards. 3. Manual on Uniform Traffic Control Devices for Streets and Highways. 4. Washington State Department of Transportation, "Highway Design Mannual" and "Construction Manual." G. DOCUMENTS TO BE FURNISHED BY THE CONSULTANT The following documents, exhibits, or other presentations for the work covered by the Agreement shall be furnished by the Consultant to the City upon completion of the various phases of the work. All such material used in the project shall become and remain the property of the City and may be used by it without restriction. 1. Three (3) sets of Preliminary Plans for review. 2. Five (5) sets of Final Plans and Specifications for review. 3. Thirty (30) sets of contract plans. 4. Thirty (30) sets of Contract Documents and Specifications prepared from the work performed under this Agreement. 5. Two (2) copies of the detailed estimate of cost of the work to be constructed. 6.. One (1) set of all sheets comprising the set of contract plans and permanent scale mylar reproducibles, together with one (1) copy of all reports, drawings, etc., appertaining thereto, plus an equal ' number of revised copies, if review discloses that revisions are necessary. 7. One (1) copy of all survey notes taken by the Consultant. 8. One (1) copy of the quantity and design computations for the work performed under this Agreement. 9. Seventy -five (75) copies of Draft Environmental. Impact Statement. 10. Seventy -five (75) copies of Final Environmental Impact Statement. 11. One (1) copy of each license to construct agreements with plan street profile and cross - section for each property. (City to provide executed license to construct.) 12. One (1) set of aperture cards reproduced from the record construction drawings. 13. All drawings, plans, data, and other materials produced by the Consultant shall be deemed to be the property of the City and shall be delivered to the City upon its request. 7 of 8 Exhibit "A" H.� RESPONSIBILITIES AND DOCUMENTS TO BE FURNISHED BY CITY 1. The City shall provide all criteria and full information as to the City's requirements for the project, including design objectives and constraints, space, capacity and permanent requirements, flexibility and expandability, and any budgetary limitations; and furnish copies of all design and construction standards which City will require to be included in the Drawings and Specifications. 2. Assist Consultant by placing at his disposal all information pertinent to the project, including previous reports, as -built drawings, and any other data relative to design and construction of the project. 3. Average weekday traffic counts, traffic projection rates, and recent accident data. 4. Arrange for access to and make all provisions for CONSULTANT to enter upon public and private property as required for CONSULTANT to perform his services. 5. Examine all studies, reports, sketches, drawings, specifications, proposals, and other documents presented by CONSULTANT; obtain advice of CITY attorney, insurance counselor, and other consultants as CITY deems appropriate for such examination; and render in writing decisions pertaining thereto within a reasonable time so as not to delay the services of CONSULTANT. 8 of 8 Exhibit "A" EXHIBIT "8" SOUTH 168TH STREET COST BREAKDOWN A. PHASE I - PRELIMINARY DESIGN PHASE 1. and 5. Survey and Right -of -Way Maps $ 17,750 2. Soils Investigations. Hart Crowser 26,300 3. Design Report and Preliminary Design Entranco Engineers 39,330 Colie Hough Associates - 4,470 Walker & Associates - Aerial Photo 1,100 ' Report Reproduction 2,000 4. SEPA EIS - Draft and Final Entranco Engineers 36,700 Rex Van Wormer 3,000 EIS Reproduction 2,000 Fees to be negotiated for the following at time of work: B. PHASE II - FINAL DESIGN C. BIDDING PHASE D. CONSTRUCTION INSPECTION AND STAKING SERVICES E. POST- CONSTRUCTION PHASE 1 of 1 $132,650 Exhibit "B" NPSOP -RF DEPARTMENT OF THE ARMY S TTLE DISTRICT. CORPS OF ENGINEERS P.O. BOX C -3755 SEATTLE. WASHINGTON 98124 Mr. David Morency Entranco Engineers 1515 - 116th Avenue Northeast, Suite 200 Bellevue, Washington 98004 _ r• - 22 DEC 1981 - D Dear Mr. Morency: This is in response to your letter of 4 December 1981, inquiring about Department of the Army permit requirements for proposed development of a 40 -acre site in Tukwila, Washington. We have carefully reviewed all available information about the site, with approximately 22 acres being occupied by an existing pond and associated wet- land vegetation. We have determined that the existing pond and its associated wetlands are not waters of the United States. Individual Department of the Army permit would not be required for discharge of dredged or fill material at the project site. Nothing in this letter should be construed as excusing you from compliance with other existing Federal, state and local statutes, ordinances or regulations which might affect this work. Sincerely, /i , 4 - 77. /1:„., GERALD A. KELLER Chief, Regulatory Functions Branch Vet( -pcTC Mln{A -(onw cS - co PerZCeDe J? % 3 (Z/ 7 w flr c K eS7;4TclSlI Z 4-0et. P MiY To: I ANSMITTAL 0 MEMORANDUM ❑ 516 SEATTLE -FIRST NATIONAL BANK BUILDING (206)258 -6202 EVERETT, WASHINGTON 98201 LETTER OF lE@MOWEE, JAN 2 ENTRANCO EN INEk ►° na (1 1515 -116th AVENUE N.E., SUITE 200 BELLEVUE, WASHINGTON 98004 (206)454 -0683 £-,' L gL C'i d ew�� Date. Project No ir669Z ^6 6 Title' �//48 ° E S �i Attention: Re' 666 7x4' ATTACHED ❑ UNDER SEPARATE COVER ❑ ORIGINALS o PRINTS ❑ OTHER FOR YOUR: INFORMATION /USE ❑ AS REQUESTED ❑ OTHER OUR ❑ REVIEWED ❑ _NOT APPROVED ACTION: ❑ APPROVED PEE REMARKS ❑ OTHER REOUESTED ❑ APPROVAL ❑ MAKE CORRECTIONS NOTED ACTION: ❑ REVIEW & COMMENT ❑ REVISE & RESUBMIT ❑ OTHER NO. OF DRAWING COPIES NUMBER DESCRIPTION 71/9/ /46) -4444 Remarks. ei1s 477e- e - r te- ate- 6,4 cilia, ;"t6 >Ow_ eweireo 4ficc c CC' DISTRIBUTION: White to Addressee - Canary td Project File - Pink to Day File A -02.2 (1 -85) ro1, ro'1 ect threatens Tukwila Pond waterfowl . p trees under alternatives A, B or C plans to incorporate a number of leaving or rebuilding another water By ROBERT JONES "would have significant impacts on mitigating measures, including feature, and, to offset the Toss of Staff Reporter wildlife," the draft EIS said. "Fill- replacement .of the lost wetland the wildlife habitat, establishing A ,proposed east -west arterial ing and encroaching into the pond area either at the Tukwila Pond site similar habitat at another location. along the south side of Tukwila . would eliminate the shallow mud- or at another location. That proposal has numerous hur- Pond, would .,destroy- "prime water 1,10 flats used by migrating shorebirds, Other mitigating measures pro- dies to overcome, however, includ fowl .habitat, according to a draft N fish and amphibians. Loss of the posed by the city include the plant- ing U.S. Army Corps of Engineers environmental impact statement $ mudflats would also reduce insect ing of trees and shrubs on the slope regulations protecting wetlands prepared by the city of Tukwila. ©'� production, which is necessary for below the arterial adjacent to the inhabited by migratory waterfowl. The city's proposal for a three- juvenile ducks during their first pond to discourage casual human The corps has determined that Tuk- or four -lane road would fill 1.8 to strands. seven to 10 days of life," the intrusion into the pond area and to wile Pond comes under its jurisdic- ta. re rt said. provide replacement resting /nesting tion, which means any developer 2.8 acres of the 19.5 acre pond and Po marsh where environmentalists and Loss of a smaller pond in the areas. who wants to fill in a wetland must developers have clashed for a Tukwila southeast corner under Alternatives The draft EIS also said road con- get permits. To get a permit, a decade, just south of the Southcen Pond A, B or C would eliminate a duck struction would increase the poten- developer must prove that the proj- ter Mall. [Proposed road nesting and brood rearing site and tial for future development of the ect is water - dependent, such as a Mi" At least one citizen group, the `�er Blvd habitat for migrating birds. The Tukwila Pond property because of marina, or that it would be too Seattle Audubon Society, says that it. o Ions of large trees would remove improved property access. ex ensive or technical) or to isti much filling of the environmentally ' ; nesting and perching habitat fora The Tukwila Pond property is calllly impossible to build the project sensitive wetland isn't necessary to variety of smaller birds; the report zoned C -P, which is the designa- build the road. said. tion for Planned Business Center.' Audubon spokesman Joe Miles Under Alternative D, the wildlife Improved site access resulting from Said his group agrees an east -west reduce traffic congestion on Strand- impacts also would be significant (road construction) will increase the arterial is needed between Andover er Boulevard to the north and to but somewhat less because of less likelihood of such a development to Park West and Southcenter Park- improve traffic flows in the mile- encroachment by the roadway, the some degree," it said. way. long "super- block" between report said. • This type of development, "What we are against is a route Strander and South 180th Street. Arterial construction and the • depending upon _what is approved, that crosses the wetlands and the Each of the alternatives includes resulting traffic noise and light could have significant plant and pond: Tukwila Pond is used heavily filling along the southern shore of glare -would have an impact on animal impacts, the report "said. by waterfowl, especially during the the pond. They are: wildlife use of the Tukwila Pond, The latest such proposal has come winter, and the best wetland habitat • Alternatives A, C and D each depending on the species, the from the Ohio -based shopping cen- shorec exactly southern oosed with a 6-foot foot, lk 4-lane the south humansaid. ivityep obablypwouldpno Youngstown, which has proposed a Y P P with a 6 -foot sidewalk on the south roadway is to be constructed," he side. .The alignment of each alter- longer inhabit the'pond. shopping center and office complex said. , native varies slightly. However, the report said the city at the pond site, filling the pond but "We feel there is a feasible alter- M Alternative B calls for a -40- videi impacts that would minimize the foot, 3 -lane roadway (one lane in Tukwila backs commuter rail "line atr ad the pond and still pro each direction and a center left -turn vide a roadway." The Audubon Society would like lane). with 6 -foot sidewalk on the to see a three-lane roadway narrow- south side. The Tukwila City Council has the line as the first link in a region - er than the city proposes and an According to the draft EIS, approved a resolution urging the al rail system. alignment farther south, away from Alternatives A, B and C would " development of a commuter rail A rail system is of special inter - the pond, Miles said. eliminate. about 2.8 acres of reed system between Seattle and the est to Tukwila, which has a resi- dent little filling would be canarygrass marsh and „pone;, a .Green.River Valley, population under 5,000 and a needed under our proposal, " he stand of young alder, mature larger commuting population of more than Said, although it would eliminate a alder and willow trees, and a Tukwila joins Kent and Auburn 20,000 people employed in the handful of parking spaces and 1.200-foot -long vine -shrub bramble in the move to encourage the city. require moving utilities, including a between the edge of the wet mead- Municipality of Metropolitan Seat - railroad line. ow and a railroad track that runs tle (Metro) to study the possibility Tukwila officials couldn't be along the south side of the pond. of using existing Burlington North - reached Wednesday for a comment Alternative D would eliminate ern tracks to establish a commuter On the EIS. about 1.8 acres of wetlands and line between Pacific- Algona and The city's draft EIS outlines four pond. the King Street Station in down - alternatives for South 168th Street, Removal of 2.8 acres of wet- town Seattle. The Tukwila resolu- which the city says is needed to lands, pond, •and large riparian tion, passed unanimously. envisions bAtic- y Alez<4-. SOUTH 168T" STREET FINAL ENVIRONMENTAL IMPACT STATEMENT EPIC - 294 -85 Memo 1-18-89 To Brian Shelton From: Dale Anderson & Jim Wiley Subject: South 168th - EIS input for Brian 1. The FEIS is in production for final review - If we assume the retaining wall is feasible - and I get that deci- sion by Friday - 1/20, we could have it to the City for final re- view by 1/31/89. ��U�������N��� ��������0q���N�" �K� �� 1�&�| w�vr�� m�� muisue WORKS If we need to wait for further geotech input on the wall - we could have it to the City for final review within two weeks of receiving the input. 2. Vern feels we should produce a supplemental EIS due to three reasons: 1) the long delay in producing the FEIS; 2) the pending Bon plans; 3) the City's prelimnary OK for the Tuk Pond property development. Vern thought that we would have to re-issue the DEIS for comment at a minimum. From our perspective, we're not sure, based or SEPA regulation re- view, why we have to do a supplemental EIS. It probably won't re- duce our chances of a project challenge by Audubon - it will cer- tainly add to the cost of the process. How ever this will be Rick Peeler's policy decision. 3. Budget status - as Dale mentioned to Vern, the EIB projcct budget was expended a year ago. We are now on the 3rd or 4th re- view of the Final. The dela/s and start/stops are costly to the budget. If the document undergoes more than one more review with changes, Entranco needs additional funds. This is certainly the case if we prepare a supplemental EIS. City of Tukwila 6200 Southcenter Boulevard Tukwila Washington 98188 (206) 433 -1800 Gary L. VanDusen, Mayor ji{ DEC 221988 TO: FROM: DATE: SUBJECT: MEMORANDUM Rick Beeler, Planning Director Brian Shelton, Senior Engineer December 21, 1988 South 168th Street FEIS Work on the South 168th Street FEIS and design report were temporarily suspended earlier this year in consideration of the current development proposal for the Tukwila Pond property. Please advise me sometime this week of the status of the pond property proposal as it relates to the South 168th Street project. BLS /kjr File: 84- RW06 -6 11400 S.E. 8th Street Bellevue. W198004 206-453-1600 January 25, 1988 Mr. Jack Pace Planning Department City of Tukwila 6200 Southcenter Blvd. Tukwila, WA 98188 Re: Easement rights Dear Jack: P� IANN ;1: ] �.., •I:. ?� SP1HER Pursuant to our telephone conversation, I am enclosing a copy of the Parkway Square Binding Site Improvement Plan (recorded December 5, 1979) showing a 30 -foot easement in favor of The City over the south 30 -feet of The Parkway Square development. I've also enclosed a copy of the deed affecting The Bon's adjacent site south of Parkway Square. The deed reflects the 16 -foot easement in my favor, running over the north 16- feet of The Bon warehouse property, to the west line of my property. Please let me know if you have any further questions. Sincerely, PIEKER PARTNERS oel Benoliel Partner JB:db PARKWAY SQUARE BINDING SITE IMPROVEMENT PLAN SECTION -26, TOWNSHIP 23 NORTH, RANGE 4 EAST, W.M. CITY OF TUKWILA, KING COUNTY, WASHINGTON -7,01 ',_.. NI M:•Is Parcels Its se: IV of Shuns., . 60'ustnenr 90. 816.1 -79 recorded nter Rr•ordir; ho. •934i40f1. Leine a revision of Snort Plat No. recor.:r3 under o,0'; "11r'30634, Records of King County. 0 *i'; . snor' r1,• of that ;v,r•.ion ',' the Southeast 1/4 of Inc Northwest I'4 r' Saturn 26, - ownsnip 7i 0orrn, Range 4 East, W.M.. In ring Canty. .asntngton, .I,nC'InO as follows: 9 ,snnin9 at the -.nutented lntersectinr of Inc centerlines of Soutncenter oare.ay (S/tr avenue S d 7tno=,er Foe tegrd „5. 164th Street), thence South 69'45•SL Cest along the 'onu.erted centerline of said Strander Boulevard. a 1l stance of 325.3; fret, trance Soutt 0 "25'58" East parallel with the -yhunente0 Cast 11ne of said subdivision, a distance of 30.00 • feet to an Intersection with 24. South margin of Said Strander Bou1e•ar0, and the true point of beginning of the herein described tract: thence con- tinuing South 0 "25'08' East. a distance of 200.00 feet: thence South 89"45'50' Ent parallel with said centerlIne of Strander Boulevard. a distance of. 350.00 feet to the monlraented East line of said suedieisloni thence South 0"25'58' Cast a10ng said Cast 1ine, a distance of 1093.20 feet td the soft- rented Southeast corner of said subdivision. thence North 69043'19" West along the monumented South line of said subdivision. a distance of 626181 feet to the Cast merlin of said 5outnc.nter Partway; thence North 0 "57 44' ' West 810,8 Said Cast earytn, a distance Of 1241.PS feet t0 a poimt'of curvet- thence NOrtnerly and Easterly along the arc of a curve to the right. salt " tune hav609 a radius of 50.00 feet through a central angle of 91"11'50 ". a distance . o / 79.58 feat.to the South .ar910 of sell Strander Boulevard:''' thence South 80 -45'58 East along said South marg/n, a dllgncs 0 ^237.72 feet to the true point of beglnnlr9;. The eforimenitoned lonllaentetion est4Dlifhed by the C1 . • Of. Tue.114 udder 1.6.0. No. 13. Centrect'NO. 7.68. Sht. 1 of 19. Street PI •n4.9090631, otMRihtd • • • Rneei ail men by these presents that we, the un4ersl4sod. ides is fee simple of the lard herein described de hereby estiblisn a 81ed8.n., Stte•tlgNevegent 901e for the purpose of leas. of portions theetot.•punua0t teCbaptar.38.17,.' 8.0.11. and Title 17. 7ye.11a Municipal Code a0d that Amid plan d00p.400. r " constitutes aubdlvlslep'of the Sind herein de6tet0ed forme piepre Of • ^ sale or other treesfee af. portions thereof and. further, Chet .the .0400sigfed declares that development of the property herein described shall gesture to • all Inscriptions contained hereon.. "t. - . _ INSCRIPTIONS andergrnund ut111ty eaienont a'd 11.0 terns an0 40ndt l'nns " - favor of •uget found Po..• t lent :wipe ^y as No. 6329973, are ^m0,'..' .'der 1rr0r1ino 40. ' 2) Casenent and the :eon, and rnnol tlons.theneo'. in fa, ,f d' ' 't7 ',sonde,: for .tilliy 'Sint and line• es conde': .'prr Per,r^.^hr, 0. 6355525. • 3) "'derground utility easement and tar tern; and :irdit'ons :here.'. 'n favor n/ Bon Servlcentee corporation as r•TOrdef .horn an.urci n', N0. 6640297. 4) Casements and otter Conditions contained in Boundary Line +ds,ttncnt N0. 814-3 -79 recorded under Recording No, 79041,0161 101,4 . revtlon Of Short Plat No. 77 -51 recorded under Recording so. 7110136614. 0) Restrictions imposed by instrument recorded On fe:r.ary 23, 1919, under Retarding-No. 7902231098. , . 6) Sebject to 40- easement over the south 30 feet of Parte It of Boundary tine Adjpstpot No. 616.3 -79. recorded under Recording No. 79041180861', being a elvlsleaa of Short Plat No. 77.51 recorded under Becorotng No. 7710130634, to favor of the City of Tukwila for access. utilities and -ills right to coolt•,ct related improvements by the City. If the City does not male use of this easement .itntn 10 years of the effective date Of the Binding Site Improvement Plan accompanying this Certificate . -. Of Segregation, tie easement will be void and all rignts will revert to the miner 'of Parcel C. , 7) EKtappt the Nest 7 feet of Parcels 111 1 IV of Boundary Line 64j,steent • ..NO. 11A -3 -79. recorded under Recording No. 7904180861, being a revision of Street Plat N0. 77.51 recorded under Recording No. 7710130E34. dedt- toted. to tie City 0f Tukwila. .. • OEOICA ON know all mem by these presents. t7et we the endersf,nedr mnlers in fee stptq 0f the lone nereln described do hereby dedicate to the City-p7. 11N,rll. for- ever the Pelt seven feet of Parcels III and IV of Boundary line Adjustment N0. 819 -3 -79 recorded under Recording N0. 7904180861, being o revision of Snort Plat No. 77 -51 recorded under Recording No. 7710130634. Words of King County. situated In the City of Tu0.1le, King Cdumty, Washington,. being 4 portion of the Southeast 1/4 of the Northwest 1/4 of Section /A. Tmnshlp 23 North, Range 4 East. N.M. . . : 'the sage/OB.5 CERTIFICATE r y,r -'E 0r y'certlfy that this 61rd1ng Site Improvement Plan for eart.a9 S0,are. the teretofon described tract of lend. 1s based upon en 444011 t 0 r40, and that•all the 1e0r3ee and distances shown thereon are correct: and that I Aare fully.commlled with tie provisions of the statutes and platting ., reglalatlon }. . • s, Robert 11: Veelaer • State of Callfarmta County of S . f.....wM Profess1on.l led Surveyor Certificate Ito. 7100 • SNORT SIBOTVISIdt cow. TTVU twined and epprewed this • / day of 1 /evr/ js� . 1570 impatient to.R.,.8. 54.17 and T4 (1e T7 TeieMla 16nn1noal ode. TMs 1s to certify that en Mks 24, eta - day of th t/L ra .t*.' -y. 1979, before ma, e undersigned. le Notary T4b141, portent' appeared- LL).a..Am 1 P40.-0 .40 - • :and Do9rAio &June • • rwpectleely, pow 1188 ,. er..a the. Peuaoreer Pima tat umaihatenseis, �Z<6 - SLCf64fMAe- TRRAL.4004' %IL/9a ftedde4T (4.51'. a_. s. V to t loom .60 ere. the individuals rho executed 101. .4191n dttlarsstoh, and,' 'cane.iedged tp me that they signed and sealed the sale .8 0041lr rpluntary i act add deed for the vies and curp0ses thereini menttoted aid on heath 'toted + that they were .authortie41 to 1,0tpte 1614 tmetgmatelt And tim7.tme Seal affixed -• - e,' -'. ∎ .is the'corporete feel of solo covporotten. Wtnefs rl, b1O and pffMal seal • . the day pro year Melt above written. . -' 1 • Z •_.. .;1; . ., , i t s t , n + r + 1 _ 7. arY Dub11t 4 and far the eP _ . .. 6,•4.4Fe4aeA• ar�Sa�dL . felsion Ce.el tree KIN6 0014141 DEPT, 00 63sEis1ElfiO Eaa lned aid approved this day of -1 •. CFA:.. ., +2-- :i.�.. (i019 A,f0e3801 . Deputy Klq Canty blesser - «• ass= 166 OE111Rf C g Of i f f it. 7.972050781 RCSD.61D QLCT , - . ;•:.: iltw'rM pet bi .it "o4e req..,( o* t6 City of Tukwila tntt . • .f ate Pa , tfji. at -11 ' ' minytea oust l• .Ar. .:•;a54 4.0604.4 In Vetre * l . N Br,.J♦rnm J,rie • . P69E4 s,:7Q 13 :. . Awards Of 8908 Lo17mt7. ltestl 79 ar • c'L}jtr'.6.4rLip ' ( IABOIS S W1t'LA ,/ co Menegtf - Supt. of Retard% F • M)' Caylsion etplree is4 3*.al \`fie► /�e�al Eti.'et ... saaAApw Ta,pm 1ANE5 s'• ., .si.: }N Petheolin Engineering r c ....r Co. a� • . • win A I� 7,0 -!6 • S • ?/ f 7• 45 SE..N' z ti _ jcaO2_ _ . F N' 89• 4s'58 /V , '/Y ICAO 09• h .341Ti IMINr IN FA VOX Or TN,- Car Oi rot rra • ilk. Aeeett, (/�trrtr, ANe 1Nr Afivs. , nt 1;.:40Ap;:file 'F(auo i44 f➢Lf4WA' S, er lie Air. J' 4.17r.11,11 11AMi•, }iA' a 7we` Z■LMtw Ayiitlr Tfv.)ta7: j Le hrternii Alt iir Tau Arms Sir rraiMrtrwr /Zaty. j 1,I4eAawr hit. fit *V Arm AtL A'AtNAr Mir ,4'erroi . eN.. k Mew, DV #1Avzi G;• • • N'89• 4T • /9 / Y 6/9 8/ sot;,, !ME S.+o•r .°c. No .77 31817" 7 O/ I FOL/ND Co //em Pi., IN CNtrt /n 4" /Nov P,••c -4 A O Pettiolin Engineering Eh.rra Plainer. end •u.eyttt • o eo..3w 4101 t• GWy BMd Po4tltnd Q eVe. 972 3 T Mtoha+ X5001 207-00, 1000 1SSP AN•.,t ` [ ltu..ut *Ml,rngIon 01007 TtlAl,ent 110111 101340 790 - 3 }r CCP PARKWAY SQUARE BINDING SITE IMPROVEMENT PLAN SECTION 26, TOWNSHIP 23 NORTH, RANGE 4 EAST, W.M. CITY OF TUKWILA, KING COUNTY, WASHINGTON :O•:JO 1 N.YOR /�I 36 0 0 Sr 44'DEe SIVD (3 /f4° Sr) N09.45 58 A7 67505' 11' 45. II IV •0• S.o� t..r 0.1.•.6 • •1...Vr 17 S. fM 37 fosno C .0 MONUrtNr ` t N � ` 1 /S V oeACAOUno I ntrt N7 /N FA rote Or PAO,.n 12 f= 1'+01..4 Ai No 77 -S/ .PfCDRO,•5. No 7901231098 140 00 PARCEL A N 09. 45. 50' IV —325 f/M.r1 0/ •(/ra irr E•u.nrN7.r. R,colo/As Abu. 6320873, 6 376 /89, '6355525,6640297. Jf4 J7' PARCEL B • 15 ORArnA6t AND U runt E.ut.rtnr, R,co#O.NS No 77/0/3Q634\ OtarA7te 4 for 04 lator,4 :. .D -• 0.0 . 1 /.... w•.r.. .:N 21 45 50 • J2 /.35• ' , . � . _ N I!• 45 °•$$ '.. • • • 0 N f SCA(f+ / • 60 f1ARCL7. C CASCO MONO... 47' /5 N -.f1). d/ 4.11e• ..Ar S.o.7 0•,- A■ n -r/ N Leff e Z Caron weni./w4'IRO. P -v Engineering •0 r •no •••••••••• 1fir •• - '•l r.. : 1 mTiri• 770 - ;< name SI /I CWMcB:he 10/28:68 STATUTORY WARRANTY DEED THE GRANTOR, RON SERVICENTER CORPORATION, a Washington corporation, fur and in consideration of Fen and !'o-'100 r:ollars (S10.00) , in hand paid, coneys and warrants to CHATILLW: REALTY CORPORATION, a Washington corporation, the following described real estate, situated in.the County of King, State of Washi:Igton: That portion of the Nur,thwest 1 of the Southeast 1 AND the Northeast 1 of the Southwest r'f Section 26, Township 23 North, Range 4 East, W.,., io King County, Washington, described as follows: Beginning at the Nortneast coiner of the Southeai., > 4 of said Section 26; thence North 88°03'42" West along '...„17,..".4 the North line of said Southeast 1 a .:Istance feet to the West line of the East 659.34 feet at sac Northwest i of the Southeast 1, and the true point of ,..,. ,,...- 7,-..7... c---- , beginning: thence South 01'4729" West along said V,est line a distan"e of 658.25 feet: thence North 8800'36- West a distance of 1305.23 feet to the Easterly margin of the Mess Brothers Road No. 972: Thence North 01'0835" East along said Easterly margin a distance of 647.97 feet: thence continuing along said Easterly margin North 01°05' 14" East a distance of 8.39 feet to the North Line of Northeast 1 of the ,Southwest 1: 6430287 thence South 830542" E-_, said North line a distanct' of 632.65 feet to the center of said Section 26: thence South 88°05'42" East along the North line of the Northwest 1 of the Southeast 1 of said SA,tion 2t; a distance of 680.00 feet tc the true point of beginning: AND EXCEPT the West 6 feet of said portion of the Northeast 1 of the Southwest 1 as conveyed to the City of Tukwila by deed under Auditor's File No. 6343850, records oi King County: Situate in tie City of Tukwila, County of King, State of Washington. SUBJECT TO: (a) Easement recorded July 22, 1929 under Auditor's File No. 2554742, at Volome 1445 of Deeds, page 219 for telephone poles. (h) Easements as granted by inst:uments recorded November 9, 1932 under Auditor's File No. 2740675 at Volume 1535 of Deeds, page FO'biUari 28, 1958 under Auditor's File no, 4877985 at Volume 3781'.of Tlesde, luxe 477 for ingress and egress over the North 20 feet NOV 6- 1961 ���rppp (..� Easement recorded May 29, 1968 under Auditor's File No, 6355532 for utility :rains and lines with appurtenances over the East 15 feet of the West 21 feet of the above - described property. -IN WITNESS WHEREOF, said corporation ha= pd this.ins.t4ument to be executed by its proper officers this -,7-"Pm-day of (:,r , 1968. of the West 20 feet of the Northwest } of the Southeast } of said Section 26 and over the North 16 feet of that portion of the Northeast } of the Southwest } of said Section 26 lying oat cf Mess Brothers County Road (57th Avenue South), (c) Easement recorded July 12, 1968 under Auditor's Ft1e No. 6376188, Volume 5114 of Deeds, page 555 for undergrounu electric system and appurtenances over the east 3 feet of the West 56 feet of the above - described property. BON SERVICENTER CORPORATION By By resident • Secretary STATE OF WASHINGTON ) COUNTY OF KING ) On this Zgiti day of October 1968, before me the undersigned, a Notary Public in and for the State of Washington, duly commissioned and sworn, personally appeared JAMES A. WALSH to me :sown and W. J. FIX to be the Vice President and Ass't,Secretary, respectively of BON SERVICENTER ,,,nruRATION, a Washington corpnration, the corporation that executed the foregoing instrument, and acknowledged the said instrument to be the free and voluntary act and deed of said corporation, for the uses and purposes there-n mentioned, and on oath stated that they were authorized to e:tecute the said instrument and that the seal affixed is the corporate seal of said corporation. WITNESS my and and official seal hereto affixed the day and year first above written. NOV 6 -1968 l Fib_ar a •u• tc'in nd -iortnee of Wa= hington, residing at Seattle. -2- UM513 1,(67.---c- ,(67 5 o a c oM M T PUGET G -rr PON'E17 S y62-r' E p4N11 60 1987 Mr. Vernon M. Umetsu Associate Planner City of Tukwila 6200 Southcenter Boulevard Tukwila, WA 98188 Dear Mr. Umetsu: We have reviewed the South 168th Street Draft Environmental Impact Statement and'submit the following comments for your consideration. Puget Power previously provided comments on the impacts of the proposed ' 168th Street arterial on our electrical system to Entranco Engineers, Inc., in a letter dated February 13, 1986. At this time, we would like to reiterate those concerns. The underground 115 kV transmission line and the underground 15 kV distribution cable located between Southcenter Parkway and Andover Park West would be difficult to maintain and repair within the existing alignment if paving is placed over the power trench containing these electrical lines. Repairing portions of these lines would require removal of a considerable amount of street surfacing. If it ever became necessary to replace the cable rather than repair it, the full length of the power trench would have to be excavated. Because the 115 kV line installa- tion uses a cable which is experimental in nature, its life expectancy is not known. This may mean that repair will be required before its planned life expectancy. Therefore, we do not consider paving over the existing power trench as a viable alternative. Possible alternatives to paving over the existing power trench include: 1. A conduit system which utilizes PVC pipe could be installed under the new street system. This would require large underground vaults every 1000 feet of conduit run and the installation of new cables. Existing easements would also have to be renegotiated. 2. The sidewalk power trench could be relocated. This could prove to be difficult due to existing improvements on adjacent property and because new easements would need to be acquired. 3. Overhead lines could be installed adjacent to the proposed street. This may require a new cable station or a pole mounted cable termination. In lieu of this, overhead lines would have to be extended to the nearest cable station which is located just east of the West Valley Highway. Overhead lines, it should be noted, are in conflict with a City of Tukwila ordinance. This option would also require the acquisition of new easements. 54 -DC -3956 Puget Sound Power & Light Company P.O. Box 0868 Bellevue, Washington 98009 -0868 (206) 454 -6363 Mr. Vernon M. Umetsu -2- July 10, 1987 As mentioned above, all three alternatives would require either renegotiation of existing easements or securing new easements. Easements secured to provide operating rights for the existing 115 kV and 15 kV lines between Southcenter Parkway and Andover Park contain language specific to the original installation of these facilities. Any work proposed within the existing easement area will require renegotiation of these rights. If the existing improvements to the adjacent property (i.e., railroads and buildings) allow for the relocation of our power lines, the acquisition of new easements will also involve considerable expense. The process of design, survey, appraisal and negotiations could take at least one year. Another concern that Puget Power has is that undergrounding a 115 kV cable is not the usual practice. The cable used in our current line is experimental in nature. Installing a conduit system or relocating the line will require new 115 kV underground cable. At this time, we have not investigated the availability of such cable. The cable Puget is currently using is no longer available from the manufacturer. Based on a preliminary review, the estimated cost for relocating the lines or installing a conduit system could exceed $600,000 if alternative D in the Draft EIS is implemented. This does not include the cost of securing additional easements. One final comment is that installing the new line may take a month or longer during which time there will be reduced electrical reliability to surrounding areas. To minimize impacts to our electrical system, we suggest that the Project Engineer meet with Puget Power's Division Engineer early in the planning process. We also recommend that, whenever possible, our power line relocations be included in any state or local permit applications you may file. Thank you for the opportunity to review and comment on this Draft Environmental Impact Statement. If you have any questions regarding our response, please let me know. Very truly yours, M. V. Stimac, Manager Licensing R Regulation MVS:BML /bl 54 -DC -3956 Ll''}I iijJJ JUL 0 1987! 8) 19 87 -4 .1 Oj (.1-05-1\c_P_Jur_q_ fkk pie Lo-f_ta. ;a.) ._inyyL, • 1, LArt--6c, cn.d. 1.41, QLLL4,114.1-4, 7,111,1\2.&t.cd ry,siLza_ J (_,4 1-4-) Jaiuf (Th ni j=c1) it . EYE 11-f3 dc A -CiLJ a - I a CI-CL C5 J2 - irr_d it■ ZJWj • ("Iva_ -ON ( 7,C c 1,041C11 L'A), A_s_ car cL, cti_L (1,41_,41/3-MC ) (,k- 1.4 C2i L 479 ?,rcynzsi-3-r,_ cam, / tIJCJSL Rainier Audubon Society P.O. Box 778 Mr. Vernon Umetsu Associate Planner Department of Planning City of Tukwila 6200 Southcenter Boulevard Tukwila, WA 98188 Subject: South 168th Street Draft EIS Dear Mr. Umetsu: Auburn, Washington 980472 n C c ( `•_" July 8, 1987 0 19871 ' L A ' ' _ 01:PT Rainier Audubon Society has reviewed the South 168th Street Draft EIS and is concerned about the loss of valuable wetlands. Tukwila Pond is a valuable wildlife area. The southern end of the pond contains the highest diversity of wetland habitats, which support the greatest number of wildlife. It is listed as a site to visit in the book Girding in King County by Hunn. On page 40, it states "Tukwila Pond has not been designated as a significant wetland habitat by the U.S. Army Corps of Engineers and King County. ". The only reason Tukwila Pond has not been designated as a significant wetland by King County is because it's within Tukwila's city limits. Using King County's rating system, Tukwila Pond would be assigned a Unique /Outstanding wetland rating because the wetland is greater than 10 acres in size and has 3 of more wetland classes, of which one is open water. In King County, Unique /Outstanding rated wetlands and their 100 foot buffers can not be altered. This valuable wetland system would be protected if it was placed under their jurisdiction. The U.S. Army Corps of Engineers does not rate wetlands. However, for this project the U.S. Army Corps of Engineers will require a 404 permit to fill wetlands at Tukwila Pond based on their letter written March 2, 1987. This Draft EIS has not addressed the basic requirements of that permit process. The Corps requires an evaluation of every application concerning the practicability of using reasonable alternative locations and methods to accomplish the proposed action. This Draft EIS only considers roadway alternatives within the corridor adjacent to Tukwila Pond. T!ainier Audubon Society a1, P.O. Box 778 Auburn, Washington 98002 The justification of this roadway appears to be to improve access to the property. This would only increase the potential for development of the remaining portion of the Tukwila Pond property. According to the traffic studies, the level of service benefited from this roadway being - constructed in mimimal. Why is there not a traffic analysis or comparison of the traffic situation with and without the proposed Minkler Boulevard to the south? Construction of the Minkler roadway would have miminal impacts on natural resources, and should benefit the traffic flow pattern and emergency vehicle response. Rainier Audubon believes a wetland mitigation plan needs to be discussed in detail, to determine if it is possible to compansate for the proposed wetland loss. It is not justified to destruct the most productive area of this wetland, without completing a comprehensive mitigation plan before the roadway is built. Waiting up to 5 years before mitigation occurs at some as yet undetermined location is not valid mitigation. Sincerely, Tina Miller Conservation Chairman Rainier Audubon Society King County Parks, Planning . and Resources Department 1108 Smith lbwer 506 Second Avenue Seattle, Washington 98104 (206) 344-7503 Mr. Vernon M. rimetsu, Associate Planner Department of Planning City of Tukwila 6200 Southcenter Boulevard Tukwila, WA 98188. RE: South 168th Street Draft EIS Dear Mr. Umetsu: July 8, 1987 Thank you for the opportunity to comment on the Draft Environmental Impact Statement (dEIS) for the construction of South 168th Street. After reviewing the document, we offer the folowing comments which should be addressed in the Final EIS to fully evaluate the environmental impacts of the proposed project. 1. The Final EIS should discuss an alternative which minimizes the impacts on Tukwila Pond and the loss of wildlife habitat. Alternatives A,B, and C will result in the loss of at least 2.8 acres of wetland habitat, and Alternative D will eliminate 1.8 acres of habitat. All of these alternatives are designed to "achieve the necessary improvements in traffic circulation, safety and property access." (p.4). Development of a new Alternative (Alternative F), which could minimize filling of the wetland, could have a 3 -lane roadway similar to Alternative B, but with the alignment of Alternative D. The width of these lanes could be reduced to 12 feet, which is the general county and national standard. The north - facing roadway edge, which would extend into the wetland, could be supported by a rock or concrete retaining wall. This would eliminate the 2:1 side slope of fill as proposed. Minimizing the width of the road and accompanying fill will reduce encroachment into the wetland and subsequent costs of mitigation. 2. The Final EIS should include a detailed mitigation plan for the loss of wetland habitat. Mitigation is a mandated requirement under Section 404 of the Federal Clean Water Act, and is not an option as suggested on page 54 of the dEIS. A complete mitigation plan should be developed and include discussion of the location, goal, timing, methodology, monitoring procedure, and contingency plan for the Mr. Vernon Umetsu page two mitigation. The plan should be developed by a consultant with proven experience and success in wetlands mitigation, and should be reviewed by the_federal resource agencies with jurisdiction (particularly EPA,- COE, and USFWS) prior to inclusion in,the final document. The cost of the mitigation must be included in the cost. of construction of the roadway, and not tied to future development proposals on the property. 3. Discussion of the wetland habitat types should be consistent throughout the document. The determination of the wetland edge as shown in figure 18 should be based on an established delineation procedure. The U.S. Army Corps of Engineers recently published a Delineation Manual (Technical Report Y -87 -1) which outlines a process to delineate a wetland edge based on soils, vegetation, and hydrological indicators. The term "palustrine scrub - shrub" is a wetland habitat definition according to the U.S. Fish and Wildlife's Classification of Wetlands and Deepwater Habitats of the United States (1979). Therefore, the " palustrine scrub - shrub" area, shown in figure 18 as a "Riparian Border ", should be included inside the wetland area. The four vegetative habitat zones, shown on page B-2, have no regulatory significance and should be replaced with definitions utilized in the U.S. Fish and Wildlife classification system. This classification system has been adopted nation -wide, and should be adhered to for consistency. Page 33 should be corrected to note that 2.8 acres of wetland will be filled (not 0.5 acres) under Alternatives A,B, & C, and 1.8 acres (not 0.25 acres) will be filled under Alternative D. Once again, we appreciate the opportunity to comment on the dEIS. We hope that these comments will assist you in producing a final EIS which addresses the probable adverse impacts of the proposed development, and discusses all feasible alternatives. Sincerely, Tracy Deputy Director cc. Derek Poon, Chief, Resource Planning Section ATTN: Erik Stockdale, Resource Planner nziPT 71-L. 04,11_,>„ CA.'; cLi sP/ /2e So a' 7=-4-- DS /ie ke t, ,f1 , ( 4 . ^ - 4! 1 744L 11 - gL4— P4L414-.-4 Pa-dt - , A4>.JZ L4 iz7 ALI - D&L do-6c- .-->uo-4- 6. 6-$., 721 j 4L4L4J-el gt- 4<-4-4- /v tI- (tree bt-k, .A.4-a4" et-cch...t,„ • Pc-td ctu-eA. .t)-( 1 " , 1r 4J E 2L A242.ae7L- a-14-y ct-Lt. "Pc-K_d csea-ttic Audubon 3ociep Washington Nonprofit Corporation 619 Joshua Green Building • Seattle. WA 98101 • 206/622 -6695 6 July 1987 Mr. Vernon M. Umetsu, Associate Planner Department of Planning City of Tukwila 6200 Southcenter Boulevard Tukwila WA 98188 Dear Mr. Umetsu: Re: Tukwila Pond and S. 168th St. DEIS We have reviewed the Draft Environmental Impact State - statement (DEIS) for the proposed construction of South 168th Street. Although many and diverse impacts may result from the proposed project, our concerns are primarily related to the potential impacts of the project on Tukwila Pond, its wetlands, and its wildlife. During our review we identified a number of what we see as shortcomings in the project and the DEIS. To permit full evaluation of the environmental impacts of the proposed project, the Final Environmental Impact Statement must address these concerns: 1.. Failure to Provide for a Project Alternative Which Protects Tukwila Pond. a. All of the alternatives (A, B, C, and D) pre - presented in the DEIS appear adversely to impact the pond and its associated wetlands. Alternatives A, B, and C result in the loss of 2.8 acres of habitat (Table 1, pg. 7, pg. 50) and alternative D would eliminate 1.8 acres of habitat (pg. 50). Although not presented in the DEIS, a feasible alter- native appears to exist which would allow construction of the roadway, while minimizing the impacts on Tukwila Pond. This alternative must be presented in the Final EIS and should include the following design elements: (1) A 3 -lane roadway section similar to that used in "Alternative B ". A 3 -lane roadway would easily carry twice the daily traffic volume projected for the -2- year 1990 (LOS =C). With a high volume of turning vehicles, especially trucks, a 4 -lane roadway is essentially reduced to two lanes of through- traffic. The use of a center, two - way left -turn lane provides the same capacity, and with increased safety. (2) Two 11 -foot through -lanes with a 12 -foot center turning -lane. Even under traffic conditions containing a high percentage of trucks this configuration will provide ample lane width for lateral vehicular clearance (WSDOT Design Manual, WSDOT Local Agency Guidelines). Interstate freeways require only a 12 -foot lane width (WSDOT Design Manual). The proposal by the DEIS to use 13 and 14 -foot lane widths in "Alternative B" appears excessive. Beyond minimizing the impacts to Tukwila Pond and its associated wetlands the 3 -lane alternative described above may reduce the overall cost of the project by reducing the road width and the amount of fill needed to support the roadway. b. The proposed 6 -foot sidewalks should be eliminated or reduced to five feet. In any case the Final EIS must investigate the need for a pedestrian corridor along South 168th Street. The investigation should include a review of the projected pedestrian use of South 168th Street and the consideration of alternative pedestrian corridors. Sidewalks along the existing roadways in the vicinity of the project are, at most, five feet in width. Given the sensitivity of the site and the lack of data showing extensive pedestrian use, the proposal to use 6 -foot side- walks appears unwarranted. c. Whatever the design selected, the north side of the roadway, along Tukwila Pond, should be supported by a rock or concrete retaining wall, as suggested on pg. 33 of the DEIS. The 2:1 side slope proposed by the DEIS requires additional fill material and unnecessary encroachment upon the wetlands of Tukwila Pond. Whatever the lane design, the roadway alignment along Tukwila Pond should be shifted to the south with a southern shoulder alignment similar to "Alternative D ". 2. Failure of the Project to Provide for Definitive Wetland Mitigation. The discussion of wetland mitigation in the DEIS (pg. 43, 43, 54, 55, and 95) is vague, deceptive, and otherwise inadequate. Mitigation is a requirement, not an option, as -3- suggested in the DEIS (pg. 54). With such adverse impacts as the elimination of habitat, the Project and the Final EIS must include a detailed mitigation proposal. How can the City and the public assess the impact of the project unless a detailed plan is presented which shows how and where the habitat will be replaced? The following issues regarding mitigation must be addressed in the Final EIS: a. On page 42 of the DEIS the following statement is made describing the southern wetlands of Tukwila Pond: "The variety and productivity of the proposed 168th Street project site is the highest per unit area of the pond property since it encompasses the wetlands, pond edge, tree canopy and the shallow islands in the southwest corner of the pond." We do not believe that mitigation can duplicate or replace the complex natural system currently existing along the southern portion of Tukwila Pond. The Final EIS must address how each component of this complex southern shoreline is to be replicated. b. Photo 10 in the DEIS shows the "Snag Swamp" located in the southwest corner of Tukwila Pond. The caption reads, "Area heavily used by canvasback, pintail, green winged teal, shoveler and ruddy ducks, great blue heron and crows." Page 43, Figure 18 shows the elimination of a portion of the snag swamp by Alternatives A, B, and C. We do not believe that this valuable snag habitat can be easily duplicated. The Project and the Final EIS must detail how the "Snag Swamp" would be duplicated in the mitigation process. c. Page 55, Figure 19 shows the "Proposal for Wetland Mitigation ". The figure depicts wetland shrubs and trees growing on a steep 2:1 side slope. Wetland vegetation, by definition, grows in damp soil where water has accumulated. It is unrealistic to assume that enough water will.accumulate on the 2:1 side slopes to sustain the tall dense wetland vegetation illustrated in Figure 19. The Final EIS must present a more realistic proposal for wetland mitigation. d. Recognizing the integral importance of the southern wetlands to the natural function of Tukwila Pond as a whole, how can mitigation occur if wetland replacement is located offsite, as suggested by the DEIS (pg. 54)? We do not consider partial offsite mitigation to be acceptable. Existing wetlands eliminated by the project must be replaced on site. Therefore, condemnation of land for the project must include condemnation for wetland mitigation. The precise location of wetland mitigation must be presented. -4- e. Under Mitigating Measures on page 53, it states that the vegetation plantings to be placed between the north side of the roadway and Tukwila Pond are to "discourage casual pedestrian intrusion into the pond area" and to "minimize spillover from street lights ". Yet under Mitigating Measures on page 95 the following statement is made, "The North side of the road is intended to be visually accessible to the roadway traveler, so that with time and additional growth, the trees will direct views across the pond." This apparent inconsistency should be corrected in the Final EIS. f. On page 54 the DEIS indicates that mitigation would be scheduled within one year of road construction, depending upon area and in any case within five years after completion of the project. Scheduling of the mitigation with respect to the filling of the wetland must be reevaluated. To guarantee equivalent wetland replacement, mitigation must occur prior to filling of the existing wetland. All mitigation must be included in the construction plans for the roadway and funded as part of the project. 3. Failure to Provide an Adequate Biological Evaluation of Tukwila Pond. Review of DEIS Appendix B (pgs. B1 -B14), and "Plants and Animals" (pgs. 40 -56), revealed several inaccurate statements and procedural errors in the biological evaluation of Tukwila Pond. The following issues must be addressed in the Final EIS: a. general the biological evaluation in the DEIS attempts to dissect Tukwila Pond into many artificial components. By so dividing Tukwila Pond an attempt is made to minimize the biological importance of each component. The ability of the Tukwila Pond properly to function as high quality wildlife habitat is dependent upon the interaction of its various component parts. The elimination or reduction of individual components such as the small breeding pond in the southwest corner, the "wet meadow ", or the "snag swamp" may significantly impact the entire Tukwila Pond system. The environmental value of Tukwila Pond lies in the interrelationship of its component parts, not in one or another of the parts standing alone. b. In the DEIS the following statements are made (pg. 40 -41): "Tukwila Pond has not been designated as a significant wetland by the U. S. Army Corps of Engineers and King County. However, no determination of significance has been made by any agency with jurisdiction." (Appendix B, Page 1): "This site has not been designated as significant wetland habitat by any Federal, State or local agency with jurisdiction." -5- All of the foregoing statements are misleading. Tukwila Pond can not be designated by the Federal Government, the State of Washington, or King County as significant, because the property is under the jurisdiction of the City of Tukwila. However, the Army Corps of Engineers has the authority to clarify Section 404 jurisdiction over waters of the United States which are used as habitat by migratory waterfowl and other migratory birds which cross state lines. The March 1, 1987 letter from the Corps, presented in the appendix, clarifies Section 404 jurisdiction over Tukwila Pond. The three sentences quoted above from the DEIS are misleading and should not appear in the Final EIS. The DEIS fails to mention that on May 19, 1980, the Tukwila City Council passed Resolution No. 736 which proposes guidelines for the protection of Tukwila Pond. Guideline 2c of the Resolution reads, "Encourage the wetlands environment to be used by wildlife, particularly waterfowl. In order to accomplish this objective, the following policies should be implemented:...c) Provide sufficient setback from the edge of the wetland area to minimize the harmful effects of encroachment by buildings, access roads and parking areas." c. On p. 42 the DEIS lists three classes of wetland found on the Tukwila Pond property, under the U. S. Fish and Wildlife Service (USFWS) classification system. However in the DEIS, portions of the "Palustrine scrub - shrub" class are eliminated from the wetland designation it uses. On Figure 18, major portions of the "Riparian Border" (i.e. Palustrine, scrub -shrub class) are excluded from the wetland designation. At the northeast corner of Tukwila Pond the "Riparian Border" is included within the wetland designation, yet major portions of the "Riparian Border" along the north, south, east, and west shorelines are excluded. The discussion on page 45 describing the "Riparian Border" gives no explanation of why major areas were excluded from the wetland designation. The Final EIS must clearly explain the line designating "Wetlands" in Figure 18, and why all classes of wetlands are not consistently included. d. On photo 10 in the DEIS Appendix Section on "Biological Evaluation of Tukwila Pond" it is noted that the "Snag Swamp" is heavily used by wildlife yet, on pages 40 -48, no discussion about nor description of is given for the "Snag Swamp" (photo 10). To fairly assess the impacts of the project, the Final EIS must discuss this important area. Special mention should be made of the use of the snags by raptors and cormorants. -6- e. On page 2, Appendix B, Tukwila Pond is subdivided into Four habitat zones. One of these zones is titled "Transitional vegetation." Nowhere in the DEIS is there a description of the "Transitional vegetation" zone. Likewise, nowhere on Figure 18 is the "Transitional vegetation" zone shown. To assess the impacts of the project the Final EIS must show the location of and discuss this zone. f. On page 47, "two small unidentified species of fish" are briefly mentioned. Considering the importance of fish as a food source for waterfowl and marsh birds, further evaluation of the fish within Tukwila Pond must be presented in the Final EIS. The evaluation must identify the species of fish and assess the potential impact of increased turbidity caused by the project on their life cycles. g. On page 14, Appendix B, Table 5 presents the Habitat Suitability Index for the Habitat Evaluation Procedure (HEP). The Wetland habitat (4) appears to have been left out of the analysis for the project site. After recognizing the existence of wetland habitat on the project site it is unclear why it was not included in the analysis. The Final EIS must correct or explain this apparent inconsistency. h. On page 11, Appendix B, the DEIS portrays the southwestern flooded bush area and the open ponds as temporary and changing. Minimal information is presented to support portrayal of a temporary or changing condition. The Chartwell Corporation DEIS description of the site in 1979, nearly eight years ago, reflects Tukwila Pond as it is seen today. Any undocumented insinuation that the habitat at Tukwila Pond is temporary is misleading and must not be included in the Final EIS. i. On page 7, Table 2, Appendix B, the name yellow -green swallow appears. This should be Violet -green swallow. 4. Failure to Provide an Adequate Hydraulic Analysis of Tukwila Pond. Review of the section of the DEIS entitled "Water ", pages 37 -40, disclosed the following inadequacies in the hydraulic analyses. (These issues must be addressed in the Final EIS): a. Under Existing Conditions, page 37, the DEIS indicates that the source of water for Tukwila Pond is surface runoff from adjacent paved properties. Field investigations of the site indicate that the surface waters from the adjacent properties are collected by several storm -7- sewers, none of which outfall to Tukwila Pond. Also, no documentation is presented which supports the statement on page 37 that more water leaves the pond by evaporation and transpiration than by the existing storm drain outfall from the pond. Considering the proposal described in the DEIS to divert water away from Tukwila Pond to the P -17 Channel, the Final EIS must present a detailed evaluation of the water budget of Tukwila Pond. The evaluation must include a study of potential groundwater sources and recharge points. b. The DEIS, on page 37, mentions a 48 -inch storm drain outfall along the eastern boundary of Tukwila Pond. Drainage plans from the Tukwila Department of Public Works show the outfall to be only 15 inches. This discrepancy must be corrected in the Final EIS. c. The DEIS, on page 37, states that "Recent revisions to the regional system include the construction of an overflow line to the P -17 drainage channel from Tukwila Pond, constructed in 1985 ". The drainage plans from the Tukwila Department of Public Works indicate that the overflow would be from the Andover Park West Storm Sewer System, not Tukwila Pond. This possible discrepancy must be resolved in the Final EIS. d. Pages 40 and 54 of the DEIS briefly mention that a temporary erosion control plan "could" be developed for the construction site. To assess the potentially serious impacts of sediment -laden water entering Tukwila Pond, the Final EIS must include a detailed erosion control proposal for the project, considering the several alternatives. We at Seattle Audubon continue to be sincerely concerned about the serious impact this project would have on Tukwila Pond with its associated wetlands and wildlife. To permit appropriate evaluation of these impacts, the issues raised in this letter must be adequately addressed in the Final EIS. ncerely yours, RICHARD L BUTLER President BELLEVUE OFFICE RAINIER BANK PLAZA 15TH FLOOR 777 108TH AVENUE N.E. BELLEVUE. WASHINGTON 98004 TELECOPIER: (206) 455.5487 • TELEX: 32.8024 TELEPHONE: (206) 451.0500 JOHN C. McCULLOUGH July 9, 1987 FOSTER, PEPPER & RIVIERA A LAW PARTNERSHIP INCLUDING PROFESSIONAL SERVICE CORPORATIONS 1111 THIRD AVENUE SEATTLE. WASHINGTON 98101 (208) 447.4400 Mr. Rick Beeler City of Tukwila 6200 Southcenter Blvd. Tukwila, Washington 98188 Dear Rick: T E L E C O P I E R: 120614479700 TELEX: 32.8024 ANSBK: FOSTER LAW SEA OF COUNSEL ANCHORAGE. ALASKA 550 WEST 7TH AVE.. SUITE (660 19071 276.4833 PL South 168th Street Draft Environmental Impact Statement We represent Toronto Dominion Bank (the "Bank "), which owns the property commonly known as the Tukwila Pond Property (the "Property "). We are writing to provide comments on the Draft Environmental Impact Statement ( "DEIS ") prepared by the City of Tukwila for its proposed South 168th Street Extension. As a preliminary matter, we must note that three of the four action alternatives described in the DEIS have a disproportionate impact on the Property. Any proposal finally adopted should attempt to distribute the burden of the proposal more equitably among affected property owners. 1. Special Development Considerations. The DEIS (at page 67 -68) discusses in general fashion the special development considerations applicable to the Tukwila Pond Property. In this discussion, the DEIS asserts that the special development considerations do not "preclude development." As a basis for this assertion, the DEIS refers to a document identified as "City of Tukwila, 1977." No such document is listed in the references to the DEIS, and therefore the accuracy of this statement is difficult to assess. Even if documentary reference were provided, however, it is inappropriate for the City to assert, in its own EIS, that the special development considerations applicable to the Tukwila Pond Property would in no case preclude development of that Property. The effect of the special development considerations in practice must be determined by an environmental and zoning review process before the City, a process that is highly discretionary. As such, it is not possible for the City to predict with authority Mr. Rick Beeler July 9, 1987 Page Two the outcome of such a discretionary process. In fact, the special development considerations may work in a given case effectively to preclude development, whether that proposed development is a road extension or a commercial project on the property. This assertion in the DEIS is self- serving and unsupportable, and should be stricken. In addition, this discussion in the DEIS further asserts that "previous site development conditions, as defined in City Council Resolutions 656 and 736, are not applicable to this project." For this claim, the DEIS refers to a personal communication with Brad Collins, former Planning Director for the City of Tukwila. No rationale is given, however, for this assertion, and it is unclear how the former Planning Director may dictate the application of environmental and development policies adopted by the City Council. Resolution 656 and 736 deserve fuller discussion in this EIS, and their applicability to the 168th Street Extension project should be seriously reviewed. 2. Right of Way Acquisition. The DEIS identifies that up to approximately 75,000 square feet of the Tukwila Pond Property will be required for acquisition by the City in connection with the 168th Street Extension project. The zoning for the Tukwila Pond Property, as discussed in the DEIS, envisions a "high intensity commercial use" for the site. DEIS at 61. As such, this Property represents some of the most expensive real estate in the entire City. Because of these considerations, the cost of acquiring the necessary portion of the Tukwila Pond Property may be considerable. The DEIS, however, includes no discussion of the fiscal impact on the City of Tukwila of such right -of -way acquisition costs and associated relocation expenditures. This is an omission that should be corrected in the final EIS. For the purposes of the discussion the EIS should, of course, examine a "worst case" impact analysis. For the purposes of right -of -way acquisition, we suggest that a figure of $16.00 per square foot would be appropriate, bringing the cost of right -of -way acquisition for the Tukwila Pond Property itself to as much as $1.2 million. The DEIS also notes in passing and without discussion that additional property may be required from the Tukwila Pond parcel. Such additional property may be necessary to provide for wetland habitat replacement or to mitigate parking loss on adjacent properties. DEIS at 74. It is impossible to evaluate such comments, however, in the absence of more specific information relating to which portions of the Tukwila Pond Property the City may additionally seek to acquire. Obviously, the taking of portions of this Property may have a serious impact upon its developability, depending upon the size and location of Mr. Rick Beeler July 9, 1987 Page Three the portions of the Property taken. The final EIS should contain a full discussion of these alternatives. 3. Transportation. The DEIS should discuss potential access from the Tukwila Pond Property onto the 168th Street Extension. 4. Fill Activities. The DEIS notes that several acres of pond and-wetland area on the Property may be filled in connection with the project. Such fill may further require the creation of replacement habitat, possibly also on the Property. But the DEIS contains no discussion of what impact such fill and possible replacement may have, from a regulatory viewpoint, on development of the remainder of the Property. If, for example, the fill associated with the 168th Street project could effectively preclude filling of other areas on the Property, this possibility must be discussed and evaluated in the DEIS. 5. Restoration. The DEIS indicates that restoration of wetland and buffer areas may be a part of the 168th Street project. Yet such restoration may be inconsistent with the position taken by the City with respect to the Property which calls for fill and development of the entire site. Such an approach has been encouraged by the City in dealings with at least one prospective developer of the Property, and the inconsistency between this position and the restoration plans described in the DEIS must be discussed. These represent the Bank's comments on the DEIS. We will be happy to discuss these issues with you at greater length if you desire. Thank you for the opportunity to comment, and we look forward to publication of the final EIS for this project. Additionally, since the Bank has received no prior notice of the environmental review process for this project, we ask that you send copies of the Final EIS and all other notices to Mr. Michael LeFevre, Toronto Dominion Bank, Pacific Division, Toronto Dominion Tower, P.O. Box 10001, Pacific Centre, Vancouver, British Columbia, Canada V7Y 1A2. Sincerely, CGS Joljn C. McCullough JCM /mw cc: Mr. M. LeFevre Mr. Dave Tysoe Vernon Umetsu Director of Planning City of Tukwilla Dear Sir, I am writing to you to express my concern for the preservation of the Tukwilla Pond and my strong opposition to the proposed road construction through that area. As a nearby resident, shopper and spouse of a worker of the Southcenter area I am aware of the traffic conges- tion.. However I do not believe that construction of yet another road through this environmentally sensitive area is the answer. The Tukwilla Pond is an oasis of wildlife in what is fast becomming an urban jungle. We do not need more asphalt. We need relief, relief provide by the viewing of the wildlife at the Tukwilla Pond. I urge you to put aside your plans for road building and preserve this valuable asset for the community. Sincerly a/).WX Carol L. Potter cc: Gary L. Van Dusen, Mayor Wendy A. Morgan, City Council Edgar D. Bauch, City Council Joe H. Duffle, City Council Mable J. Harris, City Council Charles Simpson, City Council Marilyn Stoknes, City Council James Mc Kenna, City Council V12/14.,•-, ' 1*) U2,7 i `` PLANNIND DEPT. O \JUL - 21987 a „Av2i, J12; -,diz-e-e, 8".) e/t4 OW-d Z," - _//_57/5 fly' J&7-‘0, ,/,/.7 JUN 8 0 1987 PLANNING* DEPT. _ECG /31 %- 'J fia G Qi �,, -rte Jrx�' 2 &,‘ t6 7.-4e/46 a4a 7/"Iai 77,/j/37/' y�r ,„„ AIN 3 0 1987 CITY OF TUYK4ViLA PLANNING DEPT. Vernon Umetsu Department of Planning City of Tukwila 6200 Southcenter Boulevard Tukwila, Wa. 98188 Dear Mr. Umetsu, 15130 65th Ave S. Tukwila, Wa. 98188 June 26, 1987 As avid birdwatchers and nature lovers, we would like to protest the destruction of any part of Tukwila Pond for construction of a road. This pond is an important part of the migration of birds each year. To destroy any part of it would be a real loss to the community. It is one of our real pleasures of living in Tukwila to be close enough to drop in often to see the birds, especially during the season when the young hatch. Please consider other answers to any traffic problems in this area. Yours truly, szadec-4-. /77 Robert D Buckingham Billie M Buckingham , awvy ,�.. a �_* 3�. "�qG -- 'S5 n_e. "''•e ,,,,f , cc: Mayor of Tukwila 4,--"'-- � - ''° N t.- _ .,- z. «:- -- ., ti'- - .� --- _ -., , by 1 X73 Tukwila City Counci]� KZ r, .� i. _ .���3 a :'•w -AMP ti. w«�fr. June 25, 1987 Vernon Umetsu Dept. of Planning City of Tukwila 6200 Southcenter Blvd. Tukwila, WA 98188 Dear Mr. Umetsu: RECEIVED JUN 2 9 1987 Adrienne ?fteophilus 15110 Sunwx ( Blvd. Tul wi%a. ?1bsfiingvn 98188 I understand that the City of Tukwila Department of Public Works is proposing to construct a multilane roadway, South 168th Street, across the southern margin of Tukwila Pond. I would like to register my strong opposition to this infringement on a rare area where we can still see waterfowl, shorebirds, and songbirds at almost any time of the year. As you must know, the small area of Tukwila Pond is one of the few 'watering holes' for hundreds of migratory water birds in this area. It is used for resting, breeding and feeding. If we continue to take over the areas of wildlife, it will be a much sorrier place in the years to come - for us and for our descendents. One of the many beauties of the Seattle area is the 'wild places' where we can still go, so close to home, to enjoy wildlife. Let's not ruin any more. I hope that you and the others involved will re -think this and leave Tukwila Pond wild. Thank you. / cc: Gary L. Van Dusen, Mayor Wendy A. Morgan, City Council Edgar D. Bauch, Joe H., Duf f i e Sincerely, Adrienne Theophilus rILF1j-) L.— JUN '" 9 ‘± ' 1987 _ A CITY 444 PLAN^v*i.n.-t-1-•:---- • , REC- /E0 JUN 23 087 ,,644-61 /lay .eey C.ZZ:7■7 c-12-z.11620- d-vn ( /&l'!4. 7zzt-7 MS. AGNES M. WILDER 815 S MOTH ST WESLEY GA DES moons, WA. 981911 7/11teze& z Oc cro-teMc444L- "514,- ritheala., GOT 9/'/ it&il- -ey/ 177- /tie, / / itrIX7 /417- Zil\l\fir,!-Ili [ - L.I JUN 25 1987 CITY OF —TuK•visi.A. PLANNI;',W: DEPT. -Nfirx-/ -Na .-7-1A-141-1r-ervr 4174r492 117 --p-r-orvi --17V/ • S' -,7-711,1 7 r'/r -14r/rPal rved..' 4.) 5t/ -N$1:;(-vi Tr, vol Ar - p rud -127:9i. • irpci yptirwilo Tvwd 1.74-11-G, 72(1_03 -t)q •Pli/r1(1 ar YIP:A(1Yr) 31"rrir "17 CI ?-y,74 7fr Ci`r dryiS 111/P71,777V ri/rirri 7767-,3-77-rbvv!' W- Y1 P2172( ‘7-3-7tni/ prcro tvIt-trrviorv-yry rv-27 5/92 12,,-ectrs,d 4 q44,-,,,x, •pnror2r7g/ 74? 7tra 1l ntorvry-ica -V9areSid t/ €7.,1„ - 0.9 —va?-v(4 / !--76 • vwxdp-o-v Arm4771-)z,o2 WQ1l 1 CY1 17"W P;) ?-47-vp alp/ ?Tv ri40.4-r. (-?prfEcN/ n47746.rrr 49'rv-rt', 7T 772/ psuciitIreK) 1457K107C13- 45r7z1fr _rwv?'9' -7,90w 721- 077z!'griv21.'"777a7r ati-rr ry,r) 7l7' (,472SP °:7Y/S 70A" 42/1/1 Ir*111 4'"`' rusd-r2.,ertryi. '-‘440 '17.V•,-7/77) WadliA• ,e./0/ a Of "Yr-F1017 14-iv;19 r"'42, ?t, a-Ayr-VI/179V erdell Q-d-W2C oirv-V .%7) lig 9 "'","'"v76/ 1012,247", -?yis 4 rmy ?wry wterfl) -1-,y<cr»' p7ry rve4v)7 71-7, rfrr -vieu'rqg c77q(ci -„„ „ _A 71/nary,01/ oG- • -1f.17-7-Yvl'ivr 1-atilt-pry -)-"Pri2 -kb) -v7.:(Yrri /-14 tr2/-2-a °1l 7-9-x't 14.4.,11-977?-te.f Slit, 'V0.7 "n'?"28/ 'S" 1,veki L4' Ee 7'44e Olt CV1 --1'714.J9 714.00/ --r0 "4412 -n : -vpsierwyz -virera, DNINNYld v-moini AO A113 - 186l gz Nnr] Malin RS/i6 x'(17 • .4/7r19/470(-0P 0 Of 9 -17rer'r1 J'" h7YO arvy''7d Av -rwrittrvwba --yrprp.evn u.r■vvezi -111,6 Af (Itst #e sib Car Dr. 5. gto Axle b� . to .4141 4 LSeadkei: 7244, y , 1A)10 Co j�- r e aAea.. w -a_3s PI ou..eac4.s v ��Ca�d a 1 Gva fe c, co %r. 1 c s6N.,.. v i-3 � et aGh � ( a., 'ivt- b �xrr- P of ,AdA e p b 64- r- . VitAiita • !; L- - S a cis , b a. >-lt. �t . baehoy-�-a' � .s r � e4h ad 6 S. /68/4_4 trz,ta 404 7 -bu; P U 711-4V �o aK cencev '! olofrosed c6-2af1ru ivn. of GL yoaduil i»kLLh 1i4CV2 tche Gc,pon ldcxdo dd et dec. �C1nd. _ /' • 111 - N.E. 42nd #3 Seattle, WA 98105 SHIDLA McBROOM GATES & LUG.. �S Seattle ATTORNEYS AT LAW • A PROFESSIONAL SERVICE CORPORATION Bellevue 3500 First interstate Center Seattle. Washington 98104 Telephone t206) 223-4600 Telecopier t 206) 622 -5110 Telex: 29 -2988 Please Reply to Bellevue Office Mr. L. Rick Beeler Director of Planning City of Tukwila 6200 Southcenter Blvd. Tukwila, Washington 98188 RE: South 168th Street DEIS Dear Mr. Beeler: July 9, 1987 505 Honevacll Center 600 108th Ave. N. E. Bellevue. Washington 48004 Telephone 12_06r4i3 -0310) Telecopter1206)455 -4166 f`U 1 0 19871 CITY Y Ur `! vi•,'.'. tLA PLANNING DEPT. This office represents The Bon, Inc. with regard to The Bon Distribution Center ('[Center[[) located at 17000 Southcenter Parkway in Tukwila. Please accept the following points as the comments of The Bon to the June, 1987 Draft Environmental Impact Statement (DEIS) with regard to the above referenced project. I. Land Use Of utmost concern to The Bon is the severe disruption of the truck unloading activities that will occur on the north side of the Center. The DEIS does not adequately explore the impacts of the proposed project on these activities and does not provide sufficient specific information to address the anticipated significant impacts. As a result, it remains the position of The Bon that the proposed project will disrupt and perhaps even preclude the continued use of the Center. The Final Environmental Impact Statement (FEIS) should include sufficient analysis, including diagrams and plans, to illustrate the specific impact of each of the contemplated alternatives on the use of the Center. The DEIS is incomplete with respect to analysis of this nature. Additional . information is required with regard to the impacts on the Center as a result of the changes that will result to the existing railspurs in this area. The existing rail line provides an efficient and convenient access to the subject property. This will be altered by the proposed project in a manner that is not clearly identified. Additional information should be provided in the FEIS to analyze this impact on the use of the Center. II. Transportation As a general observation, it is evident that the proposed project will have only minimal beneficial impacts for transportation circulation in the vicinity. It will even have a negative impact by exacerbating the level of service at the Mr. Beeler Page Two intersection of Strander and Andover Park West. Given the substantial costs of this project, and the clear significant impacts on the Center and other abutting parcels, as well as the nearby wetlands, the viability of this project is questionable. While the DEIS does provide a base of information that is helpful to analyze the impacts of this project, it raises more questions than it answers thus far. Among the transportation related questions that arise from the DEIS are the following: 1. Does the development of the Minkler Blvd. extension lessen the need for 168th? Does not the Minkler Blvd. extension provide the most efficient and appropriate east -west connection in this area? Does the 168th connection provide only a minimal and secondary improvement? 2. Is the proposed project economically justifiable given the marginal improvements and the significant cost as well as negative impacts on abutting private property owners, which will necessarily require compensation? 3. Would a two -lane configuration be sufficient for the projected traffic volumes on 168th? Are the three and four -lane configurations of the alternatives included in the DEIS excessive and result in unwarranted impacts and costs? Would a two -lane configuration significantly lessen the impacts on the Center and other abutting parcels? 4. Is there sufficient detail regarding the truck unloading operations on the north side of the Center to adequately analyze the impacts on the use of the Center? Will the Center be capable of being used in its intended manner under the project alternatives? Are the authors of the DEIS familiar with the internal structure of the Center and familiar with the impacts of the project on the internal workings of the Center? Will a hazardous traffic situation result? 5. While alternative B appears to have the fewest impacts on the Center, is there sufficient analysis of the impacts of alternative B to conclude that it is an acceptable alternative that will not have significant impacts on the Center? 6. Will any of the alternatives not require an expensive redesign of the internal structure of the Center and is there sufficient information provided in the DEIS to reach a credible conclusion on this issue? A more detailed discussion of the foregoing and other points is raised in the June 30, 1987 letter from the Transpo Group, Inc. which is attached hereto as Exhibit A and incorporated herein by this reference. The Transpo letter reaches the conclusion that all alternatives will potentially require a substantial if not complete redesign of the Center. Only alternative B appears to have any potential for acceptability. However, there is insufficient information on the impacts of this alternative and it must therefore be considered unacceptable at this time. The FEIS should contain much more detail, including graphic depictions, on the existing truck patterns and internal workings of the Center and the changes that will be required as a result of the project. Clearly, a "before and after" analysis of these issues is called for. Mr. Beeler Page Three III. Utilities The DEIS, at page 99, states that no adverse environmental impacts are anticipated with regard to the "partial relocation and adjustment" of the utility and communication lines which currently serve the Center. However, there is no detail provided regarding the impacts on the Center that will occur as a result of the relocation and adjustment of these lines. It is not disclosed whether the utility and communication service provided by these lines will be interrupted during the construction process, and if so, for how long and what the resulting impacts are on the Center. The Center has substantial communication lines within the proposed right -of -way and the extent of these lines is not disclosed -or analyzed in the DEIS. It is suggested that further contact be made with The Bon staff in order to identify the extent of the communication lines and determine how 168th can be constructed without any interruption of the communication facilities in the Center. IV. Earth The DEIS states, at page 30, that, as a result of the roadway construction, settlement of the Center is anticipated, possibly to the extent of 1.5 inches. There is no further analysis of the impacts of that settlement on the Center or whether it will cause significant structural or other damage to the Center. We were advised by The Bon's consulting engineer that settlement of 1.5 inches may prove to be very significant and could cause potential damage to the structural integrity of the Center as well as damage to the unloading areas. In that event, it can be expected that the required compensation for the damage to the Center will escalate significantly. Please see the more detailed comments of William L. Schaible regarding this issue in his letter dated July 8, 1987, a copy of which is attached hereto as Exhibit B and is incorporated herein by this reference. V. Water, Plants, and Animals The DEIS identifies that the proposed project will require the filling of and construction within a portion of a 100 year floodplain, the Tukwila Pond and the surrounding wetlands. There is no discussion however, regarding whether the proposed project can encroach within this environmentally sensitive area and still comply with all applicable governmental regulations, including that of the City of Tukwila and the Army Corp of Engineers. It should also be analyzed whether the project is consistent with applicable comprehensive plan policies of the City of Tukwila regarding development in environmentally sensitive areas. The FEIS should additionally explore the precedent that will be established by the proposed project in terms of future development of the Tukwila Pond site and the encroachment of other development projects into the floodplain and wetland areas. VI. Economic At no point does the DEIS disclose or analyze the economic impacts of the proposed project. It is anticipated that any of the alternatives discussed in the DEIS will require a substantial restructuring of the internal use of the Center, or alternatively may force The Bon to relocate the Center elsewhere. Therefore, the economic impact of the proposed project on the Center property alone can be expected to be substantial. Additionally, together with the economic impacts on other abutting Mr. Beeler Page Four property owners, and the substantial costs of condemnation, the economic viability of the project should be fully analyzed and this information disclosed for the decision makers. The DEIS discussion of economics is limited to the projected costs of developing the roadway. There is no indication of property acquisition costs, nor the potential costs of compensating abutting landowners for damage to the residual of their land and improvements. For example, if The Bon must substantially modify the internal system of the Center as a result of the proposed project, it may cost in the millions of dollars. The Bon will expect to be compensated for these costs. VII. Legal In order for the City to successfully proceed with condemnation of the subject property for this project, it will be encumbent upon the City to demonstrate that 1) the use proposed is a truly public use;' 2) the public interest requires the taking of a portion of The Bon's parcel; and 3) the portion of the property taken is necessary for the public use. Steilacoom v. Thompson 69 Wn 2d 705 (1966). It is evident from the DEIS that the beneficial results from the proposed project are, at best, minimal while the cost and expense is extensive. Additionally, the resulting impacts on adjacent parcels and their use is also very substantial and the DEIS does not present an adequate mitigation approach for the impacts. At the same time, it is apparent that the Minkler Blvd. extension will be far more useful in terms of benefitting the traffic circulation iri' this area and will have a greater beneficial impact than will the proposed project. Under the circumstances, the City may have some difficulty in establishing that the proposed project is truly in the public interest and therefore it may be unable to meet its burden in taking this property through the eminent domain procedures. There is precedent for the Court's determining that a proposed taking is arbitrary and capricious and not in the public interest where reasonable alternatives are available which will have less impact on adjoining owners and will be less costly. State v. Superior Court for Yakima County 128 Wn 79 (1924). Therefore, it would be appropriate for the FEIS to include further analysis and disclosure of information which will more clearly establish the real public interest in proceeding with this project. At this time, the DEIS does not provide sufficient information to reasonably conclude that this project is either in the public's interest nor certainly in that of The Bon. Thank you for this opportunity to comment on the DEIS. The Bon will look forward to a thorough analysis of the issues raised herein. Enclosure JLH:st cc: Mr. T. P Harville, The Bon, Inc. Mr. Douglas Chantry, The Bon, Inc. Mr. Jim Maclsaac, Transpo Group, Inc. Mr. William L. Schaible, PE 026 -8 /JLH ours, ohn L. Hendrickson Transportation Planning & Traffic Engineering Consultants June 30, 1987 Mr. John Hendrickson Shidler, McBroom, Gates & Lucas 505 Honeywell Center 600 - 108th Avenue NE Bellevue, WA 98004 SUBJECT: S 168TH STREET DEIS Mvo TTnANSP0 Grove i) 1987 1; k L.• ` J 0 T Dear Mr. Hendrickson: Per your request, we have reviewed the subject report with a focus upon the interests of the Bon Distribution Center which will be impacted by the pro- posed road project. The following comments should be brought to the attention of the City of Tukwila for purposes of improving the EIS document. Minkler Boulevard Extension A major premise in the need for the S 168th Street project is a need to pro- vide a new east -west traffic connection through the superblock bounded by Southcenter Parkway, Strander Boulevard, Andover Park W, and S 180th Street (DEIS Summary, Page 1). However, its traffic impact analysis, as set forth on pages 86 -92, includes an assumption that Minkler Boulevard will be extended between Andover Park W and Southcenter Boulevard, with or without the S 168th Street project. Does The Minkler Boulevard extension lessen the need for the 168th Street project? Marginal Improvement to Vicinity Street System DEIS Figures 23 and 24 show traffic conditions with and without construction of S 168th Street. Though S 168th will result in some traffic reduction along Strander between Southcenter Parkway and Andover Park W, it will have marginal effect on improving traffic operations at the "four corners of the superblock ". S 180th Street traffic will be unaffected by the S 168th project. The project would result in a small improvement in traffic operations at the Strander/ Southcenter Parkway intersection; and it would result in worse operating conditions at the Strander /Andover Park W intersection. It would reduce the effectiveness of Minkler Boulevard as perhaps the more necessary east -west break of superblock circulation. Considering the marginal improvement to vicinity traffic operations versus the high dollar and environmental cost of the S 168th Street project, is the project justifiable? This question needs to be addressed. EXHIBIT The TRANSPO Group, Inc. • 14715 Bel-Red Road, Suite 100, Bellevue, Washington 98007-3940 • (206)641 -3881 Mr. John Hendrickson June 30, 1987 Page 2 nits TRANSPO Grove Lane Requirements The traffic estimates shown on Figure 24 of the DEIS are 6,500 vehicles per day, of which 2,500 are merely diverted from the underutilized Minkler Road corridor. Such volumes could be easily carried by a two -lane street. Except for potential development around the "Tukwila Pond ", the S 168th Street cor- ridor is fully developed. There does not appear to be a need for anything more than a three -lane street at most. Alternatives A, C and D do not appear to be warranted. The need for and number of lanes of the proposed project needs to be justified by the EIS. Alternatives Alternative C would negatively impact 15 of the 23 truck loading bays along the north side of the Bon warehouse; nine would not be usable by large tractor /trailer rigs. This is an unacceptable impact on the Bon warehousing operations. Alternative D would render all 23 truck loading bays unaccessible by large tractor /trailer rigs. This alternative is totally unacceptable. It is un- likely that the Bon warehousing operation could be revised to survive under this alternative. It is possible that the Bon warehousing operations could survive under alter- native A or B. Alternative A would have the less desirable impacts; again, there does not appear to be any justification for a four -lane street section. Alternative B has the least impact on the Bon warehousing operation. Further analysis is necessary to determine if it can properly accommodate truck load- ing operations. Truck Access /Operations The DEIS does not provide adequate discussion and illustration as to how the Bon warehouse north side truck operations will be accommodated under the various alternatives. The "curb cuts" shown for each alternative do not appear adequate to accommodate the very obtuse angle truck movements that will be necessary. Westbound truck egress from the loading bays is essential. The flat angle crossings of S 168th Street would appear to be very hazardous. The FEIS needs to illustrate large -rig truck docking and undocking wheel patterns under each alternative. If ingress from the east on S 168th is not possible, it should be so stated. Egress to the west on S 168th is essential; such egress patterns should be illustrated and their safety aspects discussed. Truck egress through the west parking areas other than via S 168th is totally unacceptable. If that is a design assumption, the FEIS should include a mitigated design of the west parking area to show acceptable truck egress. Mr. John Hendrickson June 30, 1987 Page 3 TRANSPO Conclusion The north side truck docking operations of the Bon Distribution Center are its most critical relative to large -rig truck access. This is where all incoming merchandise arrives (most merchandise arrives via large rigs). To change this incoming orientation would involve a complete redesign of the warehouse machine operation. For those of us who have toured the operation, such re- design could cost millions of dollars. It is essential to the S 168th Street project that such redesign not be necessitated. Alternative B is the only alternative that appears to minimize impacts on the north side truck operations of the Bon Distribution Center. To assure its acceptance, truck access, egress and docking operations must be further de- tailed in the FEIS. Unless an acceptable detailing is presented, we believe the Bon must oppose the development of an arterial street along the S 168th Street corridor. Very truly yours, The TRANSPO Group, Inc. 149.1 es W. Maclsaac, P.E. incipal Engineer JWM /dkg July 8, 1987 Mr. Douglas Chantry BON DISTRIBUTION CENTER 17000 Southcenter Parkway Tukwila, WA 98188 Reference: South 168th Street Corridor Gentlemen: You have recently requested that covering the "South 168th Street Engineers, Inc. Specifically your concern is how Inches (on page 30 of the E.I.S. structure. glOc rQ ray I.ompa>11yr ConauMh g ihtneera & Manion MOO 6th Avenue &gi t s Beattie, Washington aetti 44! 4950 we review the draft E.I.S. statement Corridor" prepared by Entranco the anticipated settlement of 1.5 statement) will affect the warehouse The statement that a settlement of 1.5 inches will occur is very bgeneral. More specifically we would expect that the north side uilding foundations would settle differentially from the interior columns and south wall footings. This could possibly place undue strain on the precast concrete walls as well as the floors. This possibility of damage to the structure should be recognized at the outset and steps taken to monitor the expected settlements as they relate to the warehouse. The monitoring procedure should be in place prior to the beginning of construction and continue, with records kept, until the roadway is complete. Also of concern is the impact that the selected location and the construction will have on warehouse operations. Damage or disruption of loading at the rail and truck docks is possible, if not probable. The deflection (settlement) of the subgrade in these areas would impair the day to day use of the loading facilities. Provision should be made for allowing normal operations to continue unhindered as much as possible. Apparently each of the "alternatives" impacts or completely deletes the diesel fueling station and underground serving tank and fire protection facilities. Also, settlement of the amount anticipated would or could damage the various utility service piping where it enters the building. This Includes water, fire service, and sanitary and storm drainage. EXHIBIT � MO11101.1. L`aw.ulNw� lwrh.... ■',Am .A Letter to Mr. Douglas Chantry of July 8, 1987 - Page 2 In our opinion the several concerns should be addressed and satisfactorily resolved well ahead of construction, during the project design phase. We should look for detailed solutions to each concern being presented for the review of the Bon Warehouse management as design proceeds. Such coordination is essential and will avoid many conflicts of interest in the future. I trust the foregoing will be helpful in evaluating the affect the roadway construction and especially the anticipated settlement will have on warehouse operations. Sincerely, VICTOR 0. GRAY & COMPANY ele-7 Z—(104-4A-e William L. Schaible, P.E. k ' v )p rr -Nrnoipti -01-5QJ cy pQckxg +z\A, ukv vv J cry --P7/1 Q4- IN9 Cir/L/-- C).-CkIX -\Ag P-10X u1 icouPsNL-P- Trn ci -F-C'n7r tri-N \kQ Cxl FNL410 c7nlep rkOcE -711:ff1rrrp C7Z„7\p'Y Tevt-z, -r-r-,vm\iw) uw10 L2b/ (L :.)i.-4.1•4401141 -\r\tk, rOrK7 I /861, 6- -1;11' •IS kr4,891 's `ga °JAI Azoa tkA± nzs&LA-t-,LL 'l$ lj 4 ..ILL • a c - � rnisf t v. r(U±9 -- P . ! 'D (1 A-) ' C> ur. -tz - ref a.SLQ NJA AO e a: zi Atics , .Q , LOA x'8(98 July 8, 1987 City of Tukwila 6200 Southcenter Parkway Tukwila, WA 98188 Attention: Mr. L. Rick Beeler Re: South 168th Street Draft Environmental Impact Statement Dear Mr. Beeler: MDETH JUL -71987 CITY OF 't ut:v 11 A PLANNING DEPT. I would like to make the following general comments relative to the DEIS for the proposed South 168th St. project. Due to the length of my comments, I have elected to present them in 2 parts. The first part will provide a summary of my comments. Detailed comments pertaining to sections of the DEIS will be addressed in the second part. As I read through the DEIS there was one key statement which appeared at least three times: "The variety and productivity of the proposed 168th St. project site is highest per unit area of the pond property since it encompasses the wetlands, pond edge, tree canopy, and the shallow islands in the southwest corner of the pond." As the DEIS points out, the construction of the proposed extension will drastically affect this area. We are dealing with a very fragile environment that seems out of place when you consider its location so close to major shopping /office" complexes and freeways. It is important to put this project in its proper perspective. The "superblock" was formed by poor planning and lack of foresight by the City of Tukwila. The Green River and Interstate Freeway "barriers" existed before extensive development took over the area. Now because of inadequate planning, the City of Tukwila is proposing to destroy part of a very unique and fragile environment. I do agree that a traffic problem exists on the "superblock ", but I fail to see how the proposed extension will provide any relief for the area. Traffic is extremely heavy at the intersections of Southcenter Parkway /Strander and Andover Park West /Strander but I cannot understand how the addition of two more intersections (with stop lights ? ?) will improve traffic flow. It is important to note that the major traffic problems (with the exception of Christmas) occur with the office workers and /or store employees commuting to and from work. Shoppers, for the most part, have learned to avoid the area during this peak flow. Regardless of the cause, this traffic is destined to the freeways that service the area, I -5, I -405 and Hgy. 518. Access to these points is very limited and the proposed extension will not provide improved flows to these maior points. It would also appear that traffic lights would be required for access to Andover Park west and Southcenter Parkway from S. 168th St.. Now instead of two intersections for congestion, there will be four. Traffic in this particular area tends to move north and south not east and west. I cannot envision cars moving north on Southcenter Parkway then turning right on S.168th St. to gain access to the freeways and Southcenter, likewise, I cannot see traffic moving south on Southcenter Parkway then turning left on S. 168th st. to gain access to the Pavillion complex. The S. 168th St. location is an extremely poor choice for east /west trafic movement or improved access to the freeways. While the biological data per appendix B was only gathered over a nine month period, it should include the periods of highest use by migrating species. CI have visited the Tukwila Pond site from 1 -4 times per month since 1973.) It is important to note that the use by migrating species also varies as to the time of the day the observations were taken. Although it is not indicated, I would hope that these observations were made at different time periods. The introduction states "Biological data suggest that the Tukwila Pond site is a highly used waterfowl area which is integrated with the Green River to the east." While this may be true, there are also other areas such as Longacres Race Track, which along with the pond, provide areas necessary for the needs of migrating species. Ducks and geese find the necessary forage at such areas and then move to open water areas to roost, rest and feed. Although the site has not been designated as significant wetland, I understand that it has not fallen under the scope of the classifications listed. For the area in which it is located, it certainly is a significant wetland, and as such, should be allowed to remain undisturbed. I would also like to stress some of the comments contained in Appendix A.- Scoping Comments. King County - Dept. of Planing and Community Development: "Tukwila Pond is noted as a valuable stopover for migrating waterfowl. The pond is used throughout the year by a large number of diverse waterfowl species. It provides critical habitat for resident and migratory waterfowl." Further, "We believe the potential for "enhancement" on the rest of the site is not Justification for eliminating an area that is already stable and providing excellent and rare habitat. If possible, Tukwila Pond should remain undisturbed." Municipality of Metropolitan Seattle: "After an in -depth analysis of the site which included a wetlands inventory report by a consulting wildlife biologist, Metro eliminated the site from further consideration. In addition,. "Any development within the Tukwila Pond area would adversely, affect wildlife and result in a reduction in both the numbers of individual and diversity of wildlife species." Seattle Audobon Society: "The southern margin of the pond contains the highest diversity of wetland vegetation and it is the area least impacted by human intrusions; for this reason it receives the highest use by wildlife, especially more reclusive waterfowl species. The placement of the road alignment in this area would destroy the most intricate aspect. of this wetland system." As I read the DEIS for the S. 168th St., I was amazed that this project was still under consideration. The comments relating to the biological impacts alone should make it apparent that this project is not in the best interest to the City. If the comments contained in the DEIS have truly been considered, it is obvious that this project cannot be done without tremendous damage to an already rare environment. This site is quickly becoming the most studied site in King County and all of the studies have reached the same conclusion: rare, unique, highly diverse, fragile, etc.. It is time for the City planners to take responsiblity for the "super- block ". It was created by poor planning and additional poor decisions like the proposed S. 168th St. will not and cannot alleviate the situation that has been created. Tukwila Pond is a fragile unique environment that needs to be left alone and protected not "mitigated" and altered. I am strongly opposed to all alternatives proposed, except alternative E. I would also suggest that the City establish a long term plan for Tukwila Pond. The City of Tuwila has already lost much of its open and green belt areas. It is time for the City to look at the Tukwila Pond site for what it truly is, a unique area not to be found in other major cites in Washington and which cannot be improved upon by improved access or mitigation. - Thank you for the opportunity to comment. Sincerely, Scott Salzer 233 S.W. 184th Seattle, WA 98166 July 8, 1987 City Of Tukwila 6200 Southcenter Blvd. Tukwila, WA 98188 Attention: Mr. L. Rick Beeler Re: South 168th Street Draft Environmental Impact Statement Supplemental Comments Dear Mr. Beeler: The following are additional comments relating to the DEIS for the S. 168th St. project. I do feel that it is necessary to respond to statements contained or overlooked in the DEIS. My comments will follow in the order that they appear in the DEIS. Re: Summary, Page 1. I do concur that a problem exists in the area designated as the "superblock ", but I do not feel that the 168th street extension will provide any relief for the traffic flow. It is stated that "The interstate freeway system and the Green River provide physical barriers which also concentrate traffic." I would like to point out . that these "barriers" existed long before this area was subj -ected to extensive development. A little foresight on the part of the city planners could have prevented the situation that now exists. Page 3. I do not see how the proposed extention will provide any relief to the congestion. True it may relieve congestion on Strander Boulevard, but that congestion will just be moved to other intersections. All that this extension will accomplish is to make two additional points for congestion. The additon of traffic lights to these proposed new intersections will further impede the flow of traffic. Page 3 & 4, Alternatives. All of the alternatives, except Alternative E, are unacceptable due to the direct impact on the pond and wetlands. Page 9, Purpose and Need for Action. The purpose and need as stated would not exist if proper planning had occurred for this area. This "superblock" exists due to the lack of thought and foresight by the City. I would also question if the South 168th St. will fullfill the needs as presented: a) From my observations and use of Strander Blvd, Southcenter Parkway and Andover Park West the majority of the traffic movement is associated with the freeway access points. The South 168th St. does nothing to improve traffic flow to these point. b) While the S. 168th St. will likely reduce volumes on Strander Blvd., traffic must still move thru the intersections at Strander /Southcenter Pky. and Strander /Andover Park W. to reach the freeway. Now instead of two congested intersections, you will have four!! c) I see no improvement in excess travel times. d) There would be alternative access to commercial properties, but these properties are very limited and additional access is not required. e) I do not feel that emergency response time will be greatly affected by the addition of this roadway. f) The addition of S. 168th St. will add two new areas to contribute to the congestion that already exists. Page 12. Alternatives. As previously mentioned, all the alternatives except E, should be considered unacceptable due to the adverse impact on the pond and wetlands. Page 30. Mitgating Measures. I do not feel that there is any mitgation that can make up to the loss of habitat and intrusion into this area of the pond. Page 33. Unavoidable Adverse Impacts. Under Alternatives A, B, C, & D filling of a portion of the pond is required. This "unavoidable" impact is crucial to the habitat that is now being utilized by the pond wildlife. This lost habitat cannot be "mitigated" at the existing site. Page 40 & 41. Plant And Animals. I would like to know the frequency of the observations, i.e., once /day, once /week, etc., time of day that the observation were made. Waterfowl will tend to move throughout the day from feeding to resting areas. I would question whether the waterfowl are integrated with the Green River. The Green River itself does not provide a feeding or roosting area. The are more closely associated with Longacres and the Kent lagoons. Although the pond has not been designated a significant wetland by the U.S. Army Corps of Engineers and King County, there should be no question as to its value. As I recall, the designation for wetlands in King County was for the unincorporated areas and not in incorporated cites, so reference to their classification is meaningless. How, exactly, will the City mitgate for the wetland habitat. I do not see that border plants and sloped banks will mitigate for lost nesting and feeding areas. Page 41 & 42. Existing Conditions. This site is truly unusual considering the surrounding area. Extensive development almost to the shores of the pond have not prevented the high use by wildlife. It is also in this section that a very strong statement is made for preservation of Tukwila Pond in its present state: "The variety and productivity of the proposed 168th Street protect site is the highest per unit area of the pond property since it encompasses the wetlands, pond edge, tree canopy and the shallow islands in the southwest corner." If the City of Tukwila is willing to alter this portion of the pond site, how -gib.' , ,i` -fit be before another slice is taken? A precedentIVIII:be.:s: and a message sent out . that sensitive environmentak.areas =_dre of no concern to the City. I will argue, ar th-ith- statement .the .."limited summer value to waterfowl and marsh- :birds." Waterfowl use this heavy cover for nesting as do marsh bird such as wrens and yellowthroats. Page 42. First paragraph. Mammal activity is not limited along the south shore. The are muskrat, racoon and other small rodents that depend on this habitat. I have seen muskrat numerous times in this area and racoon tracks and scat are a common site. I would question how much observation time it took to determine this "limited" mammal activity. Page 47. "Open water fish habitat... ", it would seem that time would be taken to identify the fish species that are present in the pond. These "unidentified" fish are important to the birds mentioned in the same paragragh. Certainly this pond is not too large to take the time to collect and identify the species present. - Page 49 & 50. Direct Impacts. Any filling of the Pond property as proposed in alternatives A, B, C, & D should be unacceptable. The DEIS even states "The proposed fill slope planned at the edge of Tukwila Pond would also eliminate the natural buffer between the existing rail and truck traffic patterns at the pond edge." In view of this, how does the City propose to mitigate by the planting of trees and shrubs along the roadway? Page 50 & 51. Wildlife Impacts From Wetland Loss. As stated, loss of wetlands, pond and large riparian trees under Aternatives A, B, C, & D would have significant impact on the wildlife. Page 51. Secondary Impacts. Construction - It is important to point out that construction impacts, as noted, would be very significant during the fall and winter months. This activity would greatly influence the migrating waterfowl. Road Operation - As the DEIS points out, there is a great potential to further development to the Tukwila Pond property due to what would appear to be improved property access. This stresses the point that the City of Tukwila should make a long term evaluation of what is to be done on this site. This should include a rezone from the current C -P designation. Page 51. It is mentioned that species, such as canvasback, that are less tolerant of human activity would likey cease to utilize the pond. This is gust one specie, there are others that less likely to be found if this proposed street is approved. These would include rails, soras and herons. While it is true that most migratory birds would likely return after construction, there would be a loss of very important habitat that may lessen their numbers and decrease the nesting activity and success. There are many unusal species that utilize the pond and the potential loss of these species should be strongly considered. Page 53. Refer to first section dealing with semi -tame ducks and crosses. There are all to many areas that have "tame" ducks. The presence of these tame ducks is unfortunate as they become aggressive to other ducks and cross breed to produce permanent residents. There are many areas for the feeding of such "crosses. One excellent example isBellfield Industrial Park in Bellevue. While it may be fun to "feed the ducks ", the presence of these crosses (including geese) is the result of too much intrusion into a natural environment. In addition to the aggressiveness of the semi -tame ducks, they also present problems with pollution. By making Tukwila Pond a permanent year round home, they will greatly increase the potential for high coliform levels in the pond. This situation has been documented and it is realized as a threat to small bodies of relatively stagnant waters. Page 53. Impacts Conclusion. While Aternative D would be the least impacting to the environment, its impact are still unacceptable. Again, it is mentioned that the potential for increased development is a possibility. I still feel that no degree of mitigation can compensate for the loss of habitat resulting from Alternatives A, B, C, & D. Mitigating Measures - While it is easy to replace the riparian and deciduous trees, what about the mudflat and pond areas. How will these be mitigated ? ?. Page 54. The wetland lost is not replaceable at the present site without extensive modifications to the remaining pond. It is suggested that it could be but there is no description of how this would be accomplished. As far as off -site replacement, where would this be ?? This should be addressed! I am not aware of another site in Tukwila that could be modified for such a habitat. How will the effects if increased traffic be mitigated? The buffer of trees and shrubs will help but that will not be enough to protect the nesting and feeding areas currently used on the south edge of the pond and wetland. Page 54. Unavoidable Adverse Impacts. I don't believe that any mitigation can make up for the lost habitat that would destroyed by the S. 168th St. project. Most likely, the displaced species would re- locate but that would be a loss to the unique environment that exists at the Pond. This type of wetland in the Green River Valley is at a premium and is slowly being eliminated. Take for example the developments in Renton just south of I -405 and east of Longacres. While habitat such as the Tukwila pond do not provide revenue, they are important as green belts and do provide enjoyment for many people. While they not be used by a great majority of individuals, it is pleasing to know that such areas still exists in extensively developed areas. Page 67. Natural Environment. The natural environment that currently exists serves its function very well. It does not currntly need "mitigation" to continue to provide critical habitat for wildlife. If the City of Tukwila is serious concerning its long range goals for a natural environment, projects such as this should not be considered. Page 89. Transportation Circulation in the CBD. While S. 168th St. may reduce traffic volumes on Strander Blvd., how will they help in the area of the "superblock" and with access to the freeways ?? To suggest that the S. 168th St. would make a shorter route to "one" resturant is an absurd reason to destroy critical and unique habitat. How important can five minutes of a lunch hour be ? ? ?? Does this take into consideration the possibility.of traffic lights at Andover Park West /168th St. and Southcenter Parkway /168th ? ?? My guess is that it would not save much time! Page 95. Mitigating Measures. While the plan to "buffer" the remaining pond from S. 168th St may sound good, what is being done for the destroyed habitat? No amount of trees could "augment" what currently exists on the southern pond /wetland boundary. Unavoidable Adverse Impacts. With Alternative E there are no unavoidable advers impacts. Appendix A - Scoping Comments. It is important to note specific comments from past groups interested in Tukwila Pond and their concern for the environmetal impacts. It might also be appropriate to include the Chartwell Development DEIS. Appendix B - Biological Evaluation of Tukwila Pond. Much of this information is redundant to the contents contained in the body of the DEIS, but certain points need to be raised. B -2. Again we see the following statment, "The variety and productivity..,..etc. . Obviously the authors felt this was a unique site and the proposed project would have a significant impact on the pond site. B -5. Large raptors, in addition to smaller raptors, do utilize this site as a regular hunting area. The absence of casts is a poor evaluation criteria. Birds. If adequate studies have been done, it would be hard to miss broods of mallard, gadwall and coot on the pond. Canada geese have been observed on a nest without success. Pheasants, in additon to quail, have successfully raised young on the site. Page B -6 & 7. While the list is relatively complete, the number of waterfowl are extremely low. There are many days during the winter that 1,000 - 2,000 duck can be observed at one time. Many species of warblers are found at the site, in addition to Canada goose, savannah sparrow, horned larks, water pipits and meadowlarks. Page B -8. Mammals. Muskrat are common and should added to the list. Page B -9. Fish, Reptiles & Amphibians. I do feel that it is important to identify "..two small unidentified species of fish.." mentioned. I am not sure about the trout, but I do know that the pond does support brown bullhead. Fish sampling on a pond this size would be very easy and should be done due to the potential for pond loss under Alternatives A -D. I am amazed at the ommision of bull frogs. The pond supports a large population of them and they are easily observed along the pond edge. B -10 & 11. Biological. While the southern border does not support large numbers of waterfowl or marsh birds during the summer, it does provide important habitat for nesting. In addition, it is noted that the southwest corner is important and heavily used by migrating shorebirds. This mudflat habitat is limitied on the pond and without it the shorebirds would not return. Please take special note of the last two paragraphs on this page. It is the third time that the statment(s) appear. I would apologize for the length of my comments, but I do feel that it is necessary. This DEIS supports many of the comments contained in previous studies, which also concluded that this is a unique fragile habitat. I am surprised that this protect is still under consideration based upon the data presented in this document. I don't see that a trade off of potential benefits for the S. 168th St. protect and destruction of habitat exists. I strongly urge that this project be stopped before it proceeds any further. I would like to apologize for the length of these comments, but I do feel that they are important. Regards, Scott Selzer 233 S.W. 184th Seattle, WA .98166 King County Division of Roads and Engineering Department of Public Works 956 King County Administration Bldg. 500 Fourth Avenue Seattle, Washington 98104 (206) 344 -7490 June 29, 1987 Mr. L. Rick Beeler SEPA Responsible Official City of Tukwila 6200 Southcenter Boulevard Tukwila, WA 98188 RE: South 168th Street Draft Environmental Impact Statement (DEIS) Dear Mr. Beeler: Thank you for your June 3, 1987 letter concerning the South 168th Street Draft Environmental Impact Statement (DEIS). I have reviewed the above DEIS and have no comment on the project. The DEIS covers the items identified in the Scoping Notice for transportation impacts. The new road will be located entirely within the City of Tukwila and will not have a significant impact on King County roads. Thank you again for the opportunity to review the South 168th Draft DEIS. If you have any questions, please contact me at 344 -7490 or Bill Hoffman, Transportation Planning Section Manager, at 344 -7402. Sincerely, Louis J. Haff, P County Road Engineer LJH:LG:lh /CCF R -4704 cc: Bill Hoffman, Manager, Transportation Planning Section PUGET SOUND AIR POLLUTION CONTROL AGENCY Mr. Vernon M. Umetsu Associate Planner City of Tukwila 6250 Southcenter Blvd. Tukwila, WA 98188 Dear Mr. Umetsu: 619871 ?L.ANN:'' "PT. 200 West Mercer Street, Room 205 Seattle, Washington 98119 -3958 Telephone: (206) 344 -7330 Facsimile: (206) 340 -4788 July 2, 1987 South 168th Street DEIS The following comment is based upon our review of the draft EIS for the South 168th Street extension. Regarding your comment on page 34 regarding the ozone nonattainment area, EPA published its redesignation action in the January 2, 1987, Federal Register, and the non - attainment area redesignation action finally became effective on March 2, 1987. Thank you for circulating the draft EIS for comment. Sincerely, hur R. Dammkoehler it Pollution Control Officer sm SERVING: KING COUNTY 200 West Mercer SI. Room 205 Seattle. 98119 -3958 12061 344 -7330 KITSAP COUNTY Dial Operator for Toll Free Number Zenith 8385 Bainbridge Island Residents Dial 344-7330 PIERCE COUNTY 901 Tacoma Avenue South 213 Hess Building Tacoma. 98402 -2101 (2081 593-2225 SNOHOMISH COUNTY 1- 800 -552 -3585 BOARD OF DIRECTORS CHAIRMAN: Doug Sutherland. Mayor Tacoma VICe CHAIRMAN: Ray Aardal. Commissioner Kitsap County 14893 Interurban Avenue ;;o,_,t Apartment 15 Tukwila, Wa siainGt on 9L-168 3 July 1987 .:r. Vernon, M. tJrn t su Aasociate :planner amity of Tukwila CO 2 3outhcenter Boulevard Tukwila, ,v:•a sninL;t on 94188 Lear Mr. Jmet3u: Thank you for makire the effort to make the Draft En vironmental i a h:t i m p a c t Statement (DEIS) for South 168th Street available t the Tukwila Public Library. Tukwila ro::d is an important ecosystem and any project that affects it should be evaluated carefully. It is especially important because of t`i= lost; of wetlands in other parts of the Green River .Valley. Since the reasons given for the need for South 168th Street (paEe 9 of the DEIS) should have been considered when the "Superblock', was originally desined I am concerned that this DEIS does not consider possible development of the rest of Tukwila Pond. I t iirik t::at the fate of the pond should be determined before road construction on a portion of the pond is considered. A project tnat would f ill in the pond could e t more traffic - tranaer oulevard and ndoverPark lestthaniscurrntlyproj ect ed. Another reason that the 'entire pond should be considered is the vaEue discussion of mitigation for the less of wetlands (paEe 54 of the LEIS). If construction is allowed on the pond after construction of the road it would be t[iat were created as mitigation taose that new wetlands t ec 4 g_ ticn for nose �ost by tie road t on would also be lost The LEIS �doesnot consider the possibility that traffic congestion the ", Perbloca could be cauaed in part by traffic t on 1 -5, I -405, and the Wiest Valley Road. y yc °neJ� ion Nays other than road construction could be considered to reduce traffic congestion. These could include car pools, different shift ties, and better bus service. Sincerely yours, m. GL 6- John M. Wolf Mr. Vernon M. Umetsu Associate Planner City of Tukwila 6200 Southcenter Boulevard Tukwila, Wash. 98188 16813 Southcenter Parkway Seattle, Washington July 6, 1987 �r C ! 987 ? L ;41\: :` DEPT. Subject: Draft Environmental Impact Statement - South 168th St., June 1987 Dear Mr. Umetsu: Following are my comments on the above subject. My major concern is the traffic impact at the T- intersection of South 168th and Southcenter Parkway. Please assure that the finalized traffic signals provide safe egress to and ingress from each direction at my residence. In addition, since the METRO bus zone is on the east side of Southcenter Parkway directly opposite my residence, recommend a crosswalk at that point. Thank you for sending me the draft and for your consideration to the above comments. Yours truly, a: 11/-6-0-;let Matt M. Mikami REAL PROPERTY WES1, INC. 101 California Street, Suite 2525, San Francisco, California, USA 94111 ❑ Telephone (415) 421-5100 ❑ Telex 5108011419 ❑ Telecopier (415) 421-6021 July 2, 1987 VIA U.P.S. Mr. Vernon M. Umetsu Associate Planner Department of Planning City of Tukwila 6200 Southcenter Boulevard Tukwila, WA 98188 ( r7, Re: Proposed Construction of South 168th Street Tukwila, Washington Dear Mr. Umetsu: 19871 Real Property West is the owner of Parkway Square Shopping Center, immediately adjacent to the route of the above - captioned proposed new street. By reference thereto, the concerns and objections stated in the letter dated December 2, 1985 to Mr. Phillip Frazer of the City of Tukwila and from Larry W. Summerton, Contract Property Manager for Hayden Corporation on behalf of Real Property West, are repeated and incorporated herein. This letter is written in response to the Draft Environmental Impact Statement for the above - captioned proposed street construction and will further express this company's concerns and objections as they relate to the proposal to construct South 168th Street. We note from the scoping comments attached to the DEIS as Appendix A that virtually every correspondent is opposed to the proposed new street for a number of different reasons and, in particular, that each of the adjacent property owners who will be most effected if the street is constructed, are also opposed for valid and legitimate reasons. We especially support the remarks of Mr. Dennis J. McLerran on behalf of The Bon Distribution Center where, in Article VI of this letter to Mr. Brad Collins of the City of Tukwila dated December 16, 1985, Mr. McLerran suggested that a cost /benefit analysis would be highly desirable for decision makers and the public to have reliable financial information available when decisions must be made on the project. We are disappointed to note that the DEIS does not contain such an analysis. We are also disappointed and surprised that the City of Tukwila continues to support this proposed new street when Table 11 on Page 81 of the DEIS reveals that the level of service and average vehicle delay time are only very marginally improved in Mr. Vernon M. Umetsu July 2, 1987 Page 2 certain instances with the project proceeding. Indeed, there are many instances revealed by Table 11, whereby the construction.of the project will lead to a very significant deterioration in the level of service and average vehicle delay time. With the reiteration of our previous concerns and objections and these new findings revealed by the DEIS, this company remains very much opposed to the construction of South 168th Street. Yours sincerely, REAL PROPERTY WEST, INC. Derek Aynsley President DA /453 cc: Larry Summerton Jr METRO Municipality of Metropolitan Seattle Exchange Building • 821 Second Ave. • Seattle, WA 98104 -1598 July 1, 1987 Mr. Vernon M. Umetsu, Associate Planner City of Tukwila 6200 Southcenter Blvd. Tukwila, Washington 98188 Draft Environmental Impact Statement File Name: City of Tukwila - South 168th Street Dear Mr. Umetsu: 11C3n1.1] [5,,,r161 I:l87 f3 i.i ;.Y PLA!V ":t "!r DrPT. Metro staff has reviewed the draft EIS and offers the following comments. Metro anticipates no significant impacts to its wastewater or public transportation facilities from the project. We anticipate no significant degradation of surface water quality provided all mitigation measures both during and after construction are implemented in a timely manner. The proposal includes fill in the least disturbed and most diverse (in vegetation) southern portion of Tukwila Pond. Although mitigation measures proposed in this project to reduce water quality impacts should be adequate to maintain surface water quality on the site, the proposed road within Tukwila Pond would adversely affect the wetland's water storage capacity, thereby reducing its water purification potential. The project would also affect habitat and reduce the wetland's value as a wildlife refuge. Metro recognizes wetlands such as Tukwila Pond as environmentally sensitive areas with unique characteristics for water quality protection and wildlife. habitat. Wetlands are important ecological systems which can improve water quality in varying degrees by temporarily or permanently retaining suspended materials, excess nutrients, toxic chemicals and disease causing micro - organisms. In addition, Tukwila Pond functions as a major stopover for migrating birds. In 1983, Metro evaluated the Tukwila Pond area as a possible site for the Tukwila Transit Center. After an in -depth analysis of the site which included a wetlands inventory report by a consulting wildlife biologist, Metro rejected the site for that purpose. Mr. Vernon Umetsu July 1, 1987 Page Two Metro acknowledges that King County has included wetlands in its Sensitive Areas program. While recognizing that the proposed project is within the corporate limits of the city of Tukwila, we encourage the proponent to utilize these Sensitive Areas guidelines and mitigation measures to avoid adverse impacts which may arise from the construction and implementation of the road in Tukwila Pond and adjacent wetlands. Metro does not endorse any construction activity related to the project in Tukwila Pond and adjacent wetlands. Additionally, a buffer zone to the wetland should be established if no other feasible, less environmentally - damaging alternative exists. Metro recommends that this zone extend at least 50 feet away from the wetland's boundary. We also have concerns about the proposal's statement that it would "enhance" the remaining wetland or would replace the wetland loss with on- or off -site replacement. The EIS states that replacement would be contingent, in part on, the availability of suitable sites. Should the proponent find that no other feasible, less environmentally - damaging alternative exist, measures to prevent degradation of water quality should be taken. These measures should include, but not be limited to: o use of sediment curtains or containment fabrics to prevent sedimentation into the pond; o identification of runoff discharge points into surface waters through King County's drainage planning process; o methods to prevent toxic materials, petro- chemicals and other pollutants from entering surface water during and after construction; o provisions for maintaining adequate setbacks and wetland vegetation; and o revegetation of affected areas with native species. 44-% Gregory M. Bush, Manager Environmental Planning Division Mr. Vernon Umetsu July 1, 1987 Page Three Thank you for the opportunity to review and comment on the proposed project. Sincerely, GMB:dwg ANDREA BEATTY RINIKER Director STATE OF WASHINGTON DEPARTMENT OF ECOLOGY Mail Stop PV -11 • Olympia, Washington 98504-8711 • (206 ffifilq,11 June 30, 1987 1987 pi DEPT. Mr. Vernon Umetsu City of Tukwila 6200 Southcenter Blvd. Tukwila, WA 98188 Dear. Mr. Umetsu: Thank you for the opportunity to comment on the draft envi- ronmental impact statement for the South 168th Street Project. We reviewed the EIS and have the following com- ments. Tukwila Pond and its associated wetlands represent an impor- tant natural resource. Due to its location in a highly de- veloped area, this pond plays a particularly important role in providing critical habitat for waterfowl and other migra- tory birds. It also provides important stormwater storage and water purification functions. We support any efforts to retain the pond and wetlands as a natural'area. Therefore, we favor the no action alternative in the draft EIS. However, if a road must be built to al- leviate a critical traffic congestion problem, we support the selection of Alternative D. This alternative will minimize impacts to the pond and wetlands. If Alternative D is chosen, off -site mitigation in the form of wetland creation or restoration should be required. If you have any questions, please call Mr. Andy McMillan of the Shorelands Program at (206) 459 -6774. BJR: cc: Andy McMillan Sincerely, Barbara J. Ritchie Environmental Review Section Washington State Department of Transportation District 1 Office of District Administrator 6431 Corson Avenue South #C -81410 Seattle, Washington 98108 206 764.4141 June 17, 1987 Mr. Vernon M. Umetsu, Associate Planner City of Tukwila 6200 Southcenter Boulevard Tukwila, Washington 98188 Dear Mr. Umetsu: Duane eerentson Secretary of Transportation 1 i1j�r1�? 'UPI • 1 J !UN 2 2 19871 ` CIlY uF...`Ui.e.,LA i PLANNING DEPT. SR 5 MP 153.75 Vicinity CS 176700 DEIS for South 168th Street This letter is in response to the DEIS review we received from the City of Tukwila on June 8, 1987. This proposed roadway is bordered by the Tukwila Pond to the north, Andover Park West to the east, Southcenter Parkway to the west and a Union Pacific Railway spur to the south. The Department of Transportation feels this new arterial will have no adverse impact on I -5 or I -405. Thank you for the opportunity to comment on this proposal. If you have any questions, please feel free to contact this office at 236 -4403. CHUCK GLEICH Developer Coordinator -South CG /ds RICHARD I. THOMPSON Director STATE OF WASHINGTON 11'JLr n[5,.IN T-1. 1 [JUN ? ' 19871 CITY OF�it;tcvv. LA PLANNING DEPT. DEPARTMENT OF COMMUNITY DEVELOPMENT OFFICE OF ARCHAEOLOGY AND HISTORIC PRESERVATION 111 West Twenty -First Avenue, KL -11 • Olympia, Washington 98504 -5411 • (206) 753 -4011 • SCAN 234 -4011 June 11, 1987 Mr. Vernon M. Umetsu Associate Planner Department of Planning 6200 Southcenter Boulevard Tukwila, WA 98188 Log Reference: 931- C -KI -07 Re: South 168th Street DEIS Dear Mr. Umetsu: A staff review has been completed of your draft environmental impact statement. Based on the information provided for our review, in our opinion the proposed project will have no effect on presently known archaeological or historic resources included in or eligible for inclusion in the National Register of Historic Places. Thank you for this opportunity to comment. Sincerely, Robert G. Whitlam, Ph.D. State Archaeologist (206) 753 -1405 dw Archaeology and Historic Preservation • Community Services • Emergency Management • Fire Protection Services • Local Development and Housing • Local Government Services • Public Works 3 Tom Elwei1,, DOE Environmental Section, was consulted regarding the need to evaluate retaining walls as a "feasible alternative" and the detail of analysis required. His informal opinion is as follows: 1. The retaining wall option should be investigated since it is an option which could be feasible and should be included as one of the project alternatives presented to Council. He agrees that the City Council would have the option cf choosing a non -wall alternative since the net environmental impacts of all alternatives would be the same -with mitigation. . No extremely detailed studies are necessary in evaluating the •wall option. It is sufficient to generally describe the alternative. I have totally fabricated a general description to my understanding of his acceptable level of detail to give you an idea of what I'm talking about. The numbers are fabricated, but would you accept the narrative below as having sufficient detail? A Totally Fabricated Retaining Wall Narrative Evaluation Very preliminary engineering estimates indicate that a retaining wall • could be used with all alternatives. However, design and construction would be extremely difficult and absolute feasibility cannot be guaranteed without further extensive study. Soils studies and a general evaluation of retention requirements have shown that there are no suitable load bearing strata above sixty feet .in depth. Therefor=, pilings and a floating retaining wall design would be required-. At a minimum, a retaining wall would be typifiad . b.y the: following: Minimum Site Preparation 1. Native soil would have to be excavated to a depth of ten feet and replaced with structural fill and preload for one year to allow for settling. Additional structural fill will be required over this period. • The fill elevation would have to be Monitored tc, determine when settling has been completed. Prototypicah Minimum Retaining Wall Design 3. ;`.A ; • prototypi cal floating wall would be located roximately six to eight feet north of the road curb. 4. •The wall would be saw toothed in shape, have two foot diameter pilings spaced 10 feet apart and 30 feet deep . 5. A Continuous footing, four feet,d=ep and eight feet wide, would run along the base of the wall. S. No wetland buffering slope will, be provided beyond the retaining wall in order to minimize wetland encroachment (which is the stated purpose of the retaining wall). Thus, the most environmentally positive retaining wall alternative would reduce wetland encroachment over the slope buffer jby approximately four feet over all alternatives, would not significantly change the impacts to the southwest snag swamp, and southeast wet meadow from the buffer -slope alternative, and would retain several grass- and mud - shallow areas (in the retention wall alternative) in place of a 15 foot wide, landscape buffer (in the buffer -slope a lternative) . ,„(1_,..,.,� c.. ©e • 5;1 -;t1 4( 5-7 .u-sa. -ae l,"e. --tom- , { ���l.lJQ Sl :-1/ ' O )V )) ')1* -3— 3 -604 _I. 51 'l(, ( J�1,i),9 ,t-9 be ,,4-iyhr? tv'Dl 4 —7-) V ri 1_7)v/iv) y�% 3"a) 8 07' ( ON. „9/% via l —? JN/ d ? 2 , ,, � ):2) 9133 ,, �. -�� V(1) iv in S (6 8 _Cr o/C6 /4/4-/L/A/e,' • P, _ -k )o00( P , . V 7 Y. 1_ AQZ [0 [SEP 8 1987 CtTY OF Vi LA PLANNING LEPT. DALE E. AIV LEL:SON CITY OF TUKWILA NA ENVIRONMENTAL IMPACT STATEM-ENT SOUTH 168TH STREET 0c7nDSEA. 1UP4 1987 e ENTRANCO ENGINEERS, INC. Final Environmental Impact Statement * South 168th Street * October 1987 1- Cover 2- City's Cqyer Letter 3- Title Page (Revised) 4- Fact Sheet (Revised) 5- Table of Contents 6- Distribution List for the Final EIS A total twenty-nine comment letters to the draft environmental impact statement were received. Seventeen of these required responses; these are included below. The twelve letters which didn't require response are included. A summary of all comment letters is presented in Table 1. Table 1 ILEI I01eflt / Author II, PUGET POWER Mr. Vernon M. Umetsu Associate Planner City of Tukwila 6200 Southcenter Boulevard Tukwila, WA 98188 Dear Mr. Umetsu: July 10, 1987 We have reviewed the.South.168th Street Draft Environmental Impact Statement and submit the following comments for your consideration. Puget Power previously provided.comments on the impacts of the proposed 168th Street arterial on our electrical system to Entranco Engineers, Inc., in a letter dated February 13, 1986. At this time, we would like to reiterate those concerns. The underground 115 kV transmission line and the underground 15 kV distribution.cable located between Southcenter Parkway and Andover Park West would be difficult to maintain and repair within the existing alignment if paving is placed over the power trench containing these electrical lines. Repairing portions of these lines would require removal of a considerable amount of street surfacing. If it ever became necessary to replace the cable rather than repair it, the full length of the .power trench would have to be.excavated. Because the 115 kV line installa- tion uses a cable which is experimental in nature, its life expectancy is not known. This may mean that repair will be required before its planned life expectancy. Therefore, we do not consider paving over the existing power trench as a viable alternative. Possible alternatives to paving over the existing power trench include: 1. A conduit system which utilizes PVC pipe could be installed under the new street system. This would require large underground vaults every 1000 feet of conduit run and the installation of new cables. Existing easements would also have to be renegotiated. 2. The sidewalk power trench could be relocated. This could prove to be difficult due to existing improvements on adjacent property and because new easements would need to be acquired. 3. Overhead lines could be installed adjacent to the proposed street. This may require a new cable station or a pole mounted cable termination. In lieu of this, overhead lines would have to be extended to the nearest cable station which is located just east of the West Valley Highway. Overhead lines, it should be noted, are in conflict with a City of Tukwila ordinance. This option would also require the acquisition of new easements. 54 -DC -3956 Puget Sound Power & Light Company P.O. Box 0868 Bellevue, Washington 98009 -0868 (206) 454 -6363 Mr. Vernon M. Umetsu -2- July 10, 1987 As mentioned above, all three alternatives would require either renegotiation of existing easements or securing new easements. Easements secured to provide operating rights for the existing 115 kV and 15 kV lines between Southcenter Parkway and Andover Park contain language specific to the original installation of these facilities. Any work proposed within the existing easement area will require renegotiation of these rights. If the existing improvements to the adjacent property (i.e., railroads and buildings) allow for the relocation of our power lines, the acquisition of new easements will also involve considerable expense. The process of design, survey, appraisal and negotiations could take at least one year. Another concern that Puget Power has is that undergrounding a 115 kV cable is not the usual practice. The cable used in our current line is experimental in nature. Installing a conduit system or relocating the line will require new 115 kV underground cable. At this time, we have not investigated the availability of such cable. The cable Puget is currently using is no longer available from the manufacturer. Based on a preliminary review, the estimated cost for relocating the lines or installing a conduit system could exceed $600,000 if alternative D in the Draft EIS is implemented. This does not include the cost of securing additional easements. One final comment is that installing the new line may take a month or longer during which time there will be reduced electrical reliability to surrounding areas. To minimize impacts to our electrical system, we suggest that the Project Engineer meet with Puget Power's Division Engineer early in the planning process. We also recommend that, whenever possible, our power line relocations be included in any state or local permit applications you may file. Thank you for the opportunity to review and comment on this Draft Environmental Impact Statement. If you have any questions regarding our response, please let me know. Very truly yours, M. V. Stimac, Manager Licensing & Regulation MVS:BML /bl —." 1E r^,--:' .j- Lrl 1 . sj 1j L i.O 1987 T i ---- • •• __..... ..., i Bi 19 87 7 1)J Lk.k uJe (.1,410. TL biJL I .1)— A JCLI I iLu .0 J 0„.YY1- cuz nEL-E_-5 0 i-P../LIA__LA Zza) bud 1 ) _14-) _ C13- i I jaL i Cr , Q124i1 41)g---E)- 322-- a-afs.A r, tue,_ tit"-OL 4-1 __Lcirl___06 L:_d t/v t 1 • - 1.(3-et 1,60-kcii . Rainier Audubon Societ P.O. Box 778 Mr. Vernon Umetsu Associate Planner Department of Planning City of Tukwila 6200 Southcenter Boulevard Tukwila, WA 98188 Subject: South 168th Street Draft EIS Dear Mr. Umetsu: Auburn, Washington 980 (12 lc. • July 8, 1987 .:.0 19871 �;: • •- r.: !=T Rainier. Audubon Society has reviewed the South 168th Street Draft EIS and is concerned about . the loss of valuable wetlands. Tukwila Pond is a valuable wildlife area. The southern end of the pond contains the highest diversity of wetland habitats, which support the greatest number of wildlife. It is listed as a site to visit in the book Birding in King County by Hunn. On page 40, it states "Tukwila Pond has not been designated as a significant wetland habitat by the U.S. Army Corps of Engineers and King County. ". The only reason Tukwila Pond has not been designated as a significant wetland by King County is because it's within Tukwila's city limits. Using King County's rating system, Tukwila Pond would be assigned a Unique /Outstanding wetland rating because the wetland is greater than 10 acres in size and has 3 of more wetland classes, of which one is open water. In King County, Unique /Outstanding rated wetlands and their 100 foot buffers can not be altered. This valuable wetland system would be protected if it was placed under their jurisdiction. The U.S. Army Corps of Engineers does not rate wetlands. However, for this project the U.S. Army Corps of Engineers will require a 404 permit to fill wetlands at Tukwila Pond based on their letter written March 2, 1987. This Draft EIS has not addressed the basic requirements of that permit process. The Corps requires an evaluation of every application concerning the practicability of using reasonable alternative locations and methods to accomplish the proposed action. This Draft EIS only considers roadway alternatives within the corridor adjacent to Tukwila Pond. r� Rainier Audubon Society P.O. Box 778 Auburn, Washington 98002 The justification of this roadway appears to be to improve access to the property. This would only increase the potential for development of the remaining portion of the Tukwila Pond property. According to the traffic studies, the level of service benefited from this roadway being constructed in mimimal. Why is there not a traffic analysis or comparison of the traffic situation with and without the proposed Minkler Boulevard to the south? Construction of the Minkler roadway would have miminal impacts on natural resources, and should benefit the traffic flow pattern and emergency vehicle response. Rainier Audubon believes .a wetland mitigation plan needs to be discussed in detail, to determine if it is possible to compansate for the proposed wetland loss. It is not justified to destruct the most productive area of this wetland, without completing a comprehensive mitigation plan before the roadway is built. Waiting up to 5 years before mitigation occurs at some as yet undetermined location is not valid mitigation. Sincerely, Tina Miller Conservation Chairman Rainier Audubon Society King County Parks, Planning and Resources Department 1108 Smith Tbwer 506 Second Avenue Seattle, Washington 98104 (206) 344 -7503 Mr. Vernon M. Umetsu, Associate Planner Department of Planning City of Tukwila • 6200 Southcenter Boulevard Tukwila, WA 98188 RE: South 168th Street Draft EIS Dear Mr. Umetsu: July 8, 1987 Thank you for the opportunity to comment on the Draft Environmental Impact Statement (dEIS) for the construction of South 168th Street. After reviewing the document, we offer the folowing comments which should be addressed in the Final EIS to fully evaluate the environmental impacts of the proposed project. 1. The Final EIS should discuss an alternative which minimizes the impacts on Tukwila Pond and the loss of wildlife habitat. Alternatives A,B, and C will result in the loss of at least 2.8 acres of wetland habitat, and Alternative D will eliminate 1.8 acres of habitat. All of these alternatives are designed to "achieve the necessary improvements in traffic circulation, safety and property access." (p.4). Development of a new Alternative (Alternative F), which could minimize filling of the wetland, could have a 3 -lane roadway similar to Alternative B, but with the alignment of Alternative D. The width of these lanes could be reduced to 12 feet, which is the general county and national standard. The north - facing roadway edge, which would extend into the wetland, could be supported by a rock or concrete retaining wall. This would eliminate the 2:1 side slope of fill as proposed. Minimizing the width of the road and accompanying fill will reduce encroachment into the wetland and subsequent costs of mitigation. (-2. The Final EIS should include a detailed mitigation plan for the loss of wetland habitat. Mitigation is a mandated requirement under Section 404 of the Federal Clean Water Act, and is not an option as suggested on page 54 of the dEIS. A complete mitigation plan should be developed and include discussion of the location, goal, timing, methodology, monitoring procedure, and contingency plan for the Mr. Vernon Umetsu page two mitigation. The plan should be developed by a consultant with proven experience and success in wetlands mitigation, and should be reviewed by the federal resource agencies with jurisdiction (particularly EPA, COE, and USFWS) prior to inclusion in the final document. The cost of the mitigation must be included in the cost of construction of the roadway, and not tied to future development proposals on the property. 3. Discussion of the wetland habitat types should be consistent throughout the document. The determination of the wetland edge as shown in figure 18 should be based on an established delineation procedure. The U.S. Army Corps of Engineers recently published a Delineation Manual (Technical Report Y -87 -1) which outlines a process to delineate a wetland edge based on soils, vegetation, and hydrological indicators. ti The term "palustrine scrub- shrub" is a wetland habitat definition according to the U.S. Fish and Wildlife's Classification of Wetlands and Deepwater Habitats of the United States (1979). Therefore, the "palustrine scrub - shrub" area, shown in figure 18 as a "Riparian Border ", should be included inside the wetland area. The four vegetative habitat zones, shown on page B-2, have no regulatory significance and should be replaced with definitions utilized in the U.S. Fish and Wildlife classification system. This classification system has been adopted nation -wide, and should be adhered to for consistency. Page 33 should be corrected to note that 2.8 acres of wetland will be filled (not 0.5 acres) under Alternatives A,B, & C, and 1.8 acres (not 0.25 acres) will be filled under Alternative D. Once again, we appreciate the opportunity to comment on the dEIS. We hope that these comments will assist you in producing a final EIS which addresses the probable adverse impacts of the proposed development, and discusses all feasible alternatives. Sincerely, cc. Derek Poon, Chief, Resource Planning Section ATTN: Erik Stockdale, Resource Planner 0 1987 f•r.; jr JK• • Rto■sr—fl F.17.:13T cal cLi 100 yg/ Pe. So, /(T4 DffCs / I 4jLu_.„L{ "Alo E 2YL4,, et-17_ c.ta 3caitle Audubon 33ocetp Washington Nonprofit Corporation 619 Joshua Green Building • Seattle. WA 98101 • 2061622 -6695 6 July 1987 Mr. Vernon M. Umetsu, Associate Planner Department of Planning City of Tukwila 6200 Southcenter Boulevard Tukwila WA 98188 Dear Mr. Umetsu: 1 Re: Tukwila Pond and S. 168th St. DEIS We have reviewed the Draft Environmental Impact State - statement (DEIS) for the proposed construction of South 168th•Street. Although many and diverse impacts may result from the proposed project, our concerns are primarily related to the potential impacts of the project on Tukwila Pond, its wetlands, and its wildlife. During our review we identified a number of what we see as shortcomings in the project and the DEIS. To permit full evaluation of the environmental impacts of the proposed project, the Final Environmental Impact Statement must address these concerns: 1. Failure to Provide for a Project Alternative Which Protects Tukwila Pond. a. All of the alternatives (A, B, C, and D) pre - presented in the DEIS appear adversely to impact the pond and its associated wetlands. Alternatives A, B, and C result in the loss of 2.8 acres of habitat (Table 1, pg. 7, pg. 50) and alternative D would eliminate 1.8 acres of habitat (pg. 50). Although not presented in the DEIS, a feasible alter- native appears to exist which would allow construction of the roadway, while minimizing the impacts on Tukwila Pond. This alternative must be presented in the Final EIS and should include the following design elements: (1) A 3 -lane roadway section similar to that used in "Alternative B ". A 3 -lane roadway would easily II carry twice the daily traffic volume projected for the "f1 -2- year 1990 (LOS =C). With a high volume of turning vehicles, especially trucks, a 4 -lane roadway is essentially reduced to two lanes of through - traffic. The use of a center, two - way left -turn lane provides the same capacity, and with increased safety. (2) Two 11 -foot through -lanes with a 12 -foot center turning -lane. Even under traffic conditions containing a high percentage of trucks this configuration will provide ample lane width for lateral vehicular clearance (WSDOT Design Manual, WSDOT Local Agency Guidelines). Interstate freeways require only a 12 -foot lane width (WSDOT Design Manual). The proposal by the DEIS to use 13 and 14 -foot lane widths in "Alternative B" appears excessive. Beyond minimizing the impacts to Tukwila Pond and its associated wetlands the 3 -lane alternative described above may reduce the overall cost of the project by reducing the road width and the amount of fill needed to support the roadway. b. The proposed 6 -foot sidewalks should be eliminated or reduced to five feet. In any case the Final EIS must investigate the need for a pedestrian corridor along South 168th Street. The investigation should include a review of the projected pedestrian use of South 168th Street and the consideration of alternative pedestrian corridors. Sidewalks along the existing roadways in the vicinity of the project are, at most, five feet in width. Given the sensitivity of the site and the lack of data showing extensive pedestrian use, the proposal to use 6 -foot side- walks appears unwarranted. c. Whatever the design selected, the north side of the roadway, along Tukwila Pond, should be supported by a rock or concrete retaining wall, as suggested on pg. 33 of the DEIS. The 2:1 side slope proposed by the DEIS requires additional fill material and unnecessary encroachment upon the wetlands of Tukwila Pond. Whatever the lane design, the roadway alignment along Tukwila Pond should be shifted to the south with a southern shoulder alignment similar to "Alternative D ". 2. Failure of the Project to Provide for Definitive Wetland Mitigation. The discussion of wetland mitigation in the DEIS (pg. 43, 43, 54, 55, and 95) is vague, deceptive, and otherwise inadequate. Mitigation is a requirement, not an option, as L -3- suggested in the DEIS (pg. 54). With such adverse impacts as the elimination of habitat, the Project and the Final EIS must include a detailed mitigation proposal. How can the City and the public assess the impact of the project unless a detailed plan is presented which shows how and where the habitat will be replaced? The following issues regarding mitigation must be addressed in the .Final EIS: a. On page 42 of the DEIS the following statement is made describing the southern wetlands.of.Tukwila Pond: "The variety and productivity of the proposed 168th Street project site is the highest per unit area of the pond . property since it encompasses'the wetlands, pond edge, tree canopy and the shallow islands in the southwest corner of the pond." • We do not . believe that mitigation can duplicate or replace the complex natural system currently existing along the southern portion of Tukwila Pond. The Final EIS must address how each component of this complex southern shoreline is to be replicated. b. Photo 10 in the DEIS shows the "Snag Swamp" located in the southwest corner of Tukwila Pond. The caption reads, "Area heavily used by ,canvasback, pintail, green winged teal, shoveler and ruddy ducks,. great blue heron and crows." Page 43,, Figure 18 shows the elimination of a portion of the snag swamp by Alternatives A, B, and C. We do not believe that this valuable snag habitat can be easily duplicated. The Project and the Final EIS must detail how the "Snag Swamp" would be duplicated in the mitigation process. c. Page 55, Figure 19 shows the "Proposal for Wetland Mitigation ". The figure depicts wetland shrubs and ;trees growing on a steep 2:1 side slope. Wetland '..vegetation, by definition, grows in damp soil where water has accumulated. It is unrealistic to assume that enough water will,accumulate on the 2:1 side slopes to sustain the tall dense wetland vegetation illustrated in Figure 19. The Final EIS must present amore realistic proposal for. wetland mitigation. d. Recognizing the integral importance of the southern wetlands to the natural . function of Tukwila Pond as a whole, how can mitigation occur if wetland replacement is located offsite, as suggested by the DEIS (pg. 54)? We do not consider partial offsite mitigation to be acceptable. Existing wetlands eliminated by the project must be replaced on site. Therefore, condemnation of land for the project must include condemnation for wetland mitigation. The precise location of wetland mitigation must be presented. -4- e. Under Mitigating Measures on page 53, it states that the vegetation plantings to be placed between the north side of the roadway and Tukwila Pond are to "discourage casual pedestrian intrusion into the pond area" and to "minimize spillover from street lights ". Yet under Mitigating Measures on page 95 the following statement is made, "The North side of the road is intended to be visually accessible to the roadway traveler, so that with time and additional growth, the trees will direct views across the pond." This apparent inconsistency should be corrected in the Final EIS. f. On page 54 the DEIS indicates that mitigation would be scheduled within one.year of road construction, depending upon area and in any case within five years after completion of the project. Scheduling of the mitigation with respect to the filling of the wetland must be reevaluated. To guarantee equivalent wetland replacement, mitigation must occur prior to filling of the existing wetland. All mitigation must be included in the construction plans for the roadway and funded as part of the project. 3. Failure to Provide an Adequate Biological Evaluation of Tukwila Pond. Review of DEIS Appendix B (pgs. B1 -B14), and "Plants and Animals" (pgs. 40 -56), revealed several inaccurate statements and procedural errors in the biological evaluation of Tukwila Pond. The following issues must be addressed in the Final EIS: a. In general the biological evaluation in the DEIS attempts to dissect Tukwila Pond into many artificial components. By so dividing Tukwila Pond an attempt is made to minimize the biological importance of each component. The ability of the Tukwila Pond properly to function as high quality wildlife habitat is dependent upon the interaction of its various component parts. The elimination or reduction of individual components such as the small ;breeding pond in the southwest corner, the "wet meadow ", or the "snag swamp" may significantly impact the entire Tukwila 'Pond system. The environmental value of Tukwila Pond lies in the interrelationship of its component parts, not in one or another of the parts standing alone. b. In the DEIS the following statements are made (pg. 40 -41): "Tukwila Pond has not been designated as a significant wetland by the U. S. Army Corps of Engineers and King County. However, no determination of significance has been made by any agency with jurisdiction." (Appendix B, Page 1): "This site has not been designated as significant wetland habitat by any Federal, State or local agency with jurisdiction." 1 -5- consistently included. d. On photo 10 in the DEIS Appendix Section on "Biological Evaluation of Tukwila Pond" it is noted that the "Snag Swamp" is heavily used by wildlife yet, on pages 40 -48, no discussion about nor description of is given for the "Snag Swamp" (photo 10). To fairly assess the impacts of the project, the Final EIS must discuss this important area. Special mention should be made of the use of the snags by raptors and cormorants. i -6- e. On page 2, Appendix B, Tukwila Pond is subdivided into Four habitat zones. One of these zones is titled "Transitional vegetation." Nowhere in the DEIS is there a description of the "Transitional vegetation" zone. Likewise, nowhere on Figure 18 is the "Transitional vegetation" zone shown. To assess the impacts of the project the Final EIS must show the location of and discuss this zone. f. On page 47, "two small unidentified species of fish" are briefly mentioned. Considering the importance of fish as a food source for waterfowl and marsh birds, further evaluation of the fish within Tukwila Pond must be presented in the Final EIS. The evaluation must identify the species of fish and assess the potential impact of increased turbidity caused by the project on their life cycles. g. On page 14, Appendix B, Table 5 presents the Habitat Suitability Index for the Habitat Evaluation Procedure (HEP). The Wetland habitat (4) appears to have been left out of the analysis for the project site. After recognizing the existence of wetland habitat on the project site it is unclear why it was not included in the analysis. The Final EIS must correct or explain this apparent inconsistency. h. On page 11, Appendix B, the DEIS portrays the southwestern flooded bush area and the open ponds as temporary and changing. Minimal information is presented to support portrayal of a temporary or changing condition. The Chartwell Corporation DEIS description of the site in 1979, nearly eight years ago, reflects Tukwila Pond as it is seen today. Any undocumented insinuation that the habitat at Tukwila Pond is temporary is misleading and must not be included in the Final EIS. i. On page 7, Table 2, Appendix B, the name yellow -green swallow appears. This should be Violet -green swallow. 4. Failure to Provide an Adequate Hydraulic Analysis of Tukwila Pond. Review of the section of the DEIS entitled "Water ", pages 37 -40, disclosed the following inadequacies in the hydraulic analyses. (These issues must be addressed in the Final EIS): a. Under Existing Conditions, page 37, the DEIS indicates that the source of water for Tukwila Pond is surface runoff from adjacent paved properties. Field investigations of the site indicate that the surface waters from the adjacent properties are collected by several storm -7- sewers, none of which outfall to Tukwila Pond. Also, no documentation is presented which supports the statement on page 37 that more water leaves the pond by evaporation and transpiration than by the existing storm drain outfall from the pond. Considering the proposal described in the DEIS to divert water away from Tukwila Pond to the P -17 Channel, the Final EIS must present a detailed evaluation of the water budget of Tukwila Pond. The evaluation must include a study of potential groundwater sources and recharge points. b. The DEIS, on page 37, mentions a 48 -inch storm drain outfall along the eastern boundary of Tukwila Pond. Drainage plans from the Tukwila Department of Public Works show the outfall to be only 15 inches. This discrepancy must be corrected in the Final EIS. c. The DEIS, on page 37, states that "Recent revisions to the regional system include the construction of an overflow line to the P -17 drainage channel from Tukwila Pond, constructed in 1985 ". The drainage plans from the Tukwila Department of Public Works indicate that the overflow would be from the Andover Park West Storm Sewer System, not Tukwila Pond. This possible discrepancy must be resolved in the Final EIS. d. Pages 40 and 54 of the DEIS briefly mention that a temporary erosion control plan "could" be developed for the construction site. To assess the potentially serious impacts of sediment -laden water entering Tukwila Pond, the Final EIS must include a detailed erosion control proposal for the project, considering the several alternatives. We at Seattle Audubon continue to be sincerely concerned about the serious impact this project would have on Tukwila Pond with its associated wetlands and wildlife. To permit appropriate evaluation of these impacts, the issues raised in this letter must be adequately addressed in the Final EIS. ncerely ours, RICHARD L BUTLER President l' i Even if documentary reference were provided, however, it is inappropriate for the City to assert, in its own EIS, that the special development considerations applicable to the Tukwila Pond Property would in no case preclude development of that Property. The effect of the special development considerations in practice must be determined by an environmental and zoning review process before the City, a process that is highly discretionary. As such, it is not possible for the City to predict with authority - Mr. Rick Beeler July 9, 1987 Page Two 5 the outcome of such a discretionary process. In fact, the special development considerations may work in a given case effectively to preclude development, whether that proposed Gt4k. development is a road extension or a commercial project on . the property. This assertion in the DEIS is self- serving and unsupportable, and should be stricken. I"' In addition, this discussion in the DEIS further asserts that "previous site development conditions, as defined in City Council Resolutions 656 and 736, are not applicable to this project." For this claim, the DEIS refers to a personal communication with Brad Collins, former Planning Director for the City of Tukwila. No rationale is given, however, for this assertion, and it is unclear how the former Planning Director may dictate the application of environmental and development policies adopted by the City Council. Resolution 656 and 736 deserve fuller discussion in this EIS,'and their applicability to the 168th Street Extension project should be seriously reviewed. 2. Right of Way Acquisition. The DEIS identifies that up to approximately 75,000 square feet of the Tukwila Pond Property will be required for acquisition by the City in connection with the 168th Street Extension project. The zoning for the Tukwila Pond Property, as discussed in the DEIS, envisions a "high intensity commercial use" for the site. DEIS at 61. As such, this Property represents some of the most expensive real estate in the entire City. L Because of these considerations, the cost of acquiring the necessary portion of .the Tukwila Pond Property may be considerable. The DEIS, however, includes no discussion of the fiscal impact on the City of Tukwila of such right -of -way acquisition costs and associated relocation expenditures. This is an omission that should be corrected in the final EIS. For the purposes of the discussion the EIS should, .of course, examine a "worst case impact analysis. For the purposes of right -of -way acquisition, we suggest that a figure of $16.00 per square.foot would be appropriate,.bringing the cost of right -of -way acquisition for the Tukwila Pond Property itself to as much as $1.2 million. The DEIS also notes in passing and without discussion that additional property may be required from the Tukwila Pond parcel. Such additional property may be necessary to provide for wetland habitat replacement or to mitigate parking loss on adjacent properties. DEIS at 74. It is impossible to evaluate such comments, however, in the absence of more specific information relating to which portions of the Tukwila Pond Property the City may additionally seek to acquire. Obviously, the taking of portions of this Property may have a serious impact upon its developability, depending upon the size and location of 191 Mr. Rick Beeler July 9, 1987 Page Three 1 the portions of the Property taken. The final EIS should contain a full discussion of these alternatives. fl3. Transportation. The DEIS should discuss potential access from the Tukwila Pond Property onto the 168th Street Extension. 4. Fill Activities. The DEIS notes that several acres of pond and wetland area on the Property may be filled in connection with the project. Such fill may further require the creation of replacement habitat, possibly also on the Property. But the DEIS contains no discussion of what impact such fill and possible replacement may have, from a regulatory viewpoint, on development of the remainder of the Property. If, for example, the fill associated with the 168th Street project could effectively preclude filling of other areas . on the Property, this possibility must be discussed and evaluated in the DEIS. 5. Restoration. The DEIS indicates that restoration of wetland and buffer areas may be a part of the 168th Street project. Yet such restoration may be inconsistent with the position taken by the City with respect to the Property which calls for fill and, development of the entire site. Such an approach has been encouraged by the City in dealings with at least one prospective developer of the Property, and the inconsistency between this position and the restoration plans described in the DEIS must be discussed. These represent the Bank's comments on the DEIS. We will be happy to discuss these issues with you at greater length if you desire. Thank you for the opportunity to comment, and we look forward to publication of the final EIS for this project. Additionally, since the Bank has received no prior notice of r- the environmental review process for this project, we ask that Lyou send copies of the Final EIS and all other notices to Mr. Michael LeFevre, Toronto Dominion Bank, Pacific Division, Toronto Dominion Tower, P.O. Box 10001, Pacific Centre, Vancouver, British Columbia, Canada V7Y 1A2. JCM /mw cc: Mr. M. LeFevre Mr. Dave Tysoe Sincerely, fib(" John C. McCullough 0 Vernon Umetsu Director of Planning City of Tukwilla Dear Sir, 1987 , tel: n 1997 014. cif vt.v4kA p'i ;NN.4NG I am writing to you to express my concern for the preservation of the Tukwilla Pond and my strong opposition to the proposed road construction through that area. As a nearby resident, shopper and spouse of a worker of the Southcenter area I am aware of the traffic conges- tion. However I do not believe that construction of yet another road through this environmentally sensitive area is the answer. The Tukwilla Pond is an oasis of wildlife in what is fast becomming an urban jungle. We do not need more asphalt. We need relief, relief provide by the viewing of the wildlife at the Tukwilla Pond. I urge you to put aside your plans for road building and preserve this valuable asset for the community. Sincerly 4441 Carol L. Potter cc: Gary L. Van Dusen, Mayor Wendy A. Morgan, City Council Edgar D. Bauch, City Council Joe H. Duffle, City Council Mable J. Harris, City Council Charles Simpson, City Council Marilyn Stoknes, City Council James Mc Kenna, City Council v V.04A■--- . _____,z;i-,,,16, z / 1,,, ae,,„ Rkt'e 6 7.,2„,d6,, - / )-2 .A /i:e2 /t^6 aee-4/ 127,a_it5 -G*7Z-1, ./ . J/i1/1,4' -•■Z"- a- )...v , .- ,,/ 04-ee l'`/Q-e, /-7i d" /1 21, G_ a. .-ee . ...j.;;, ,d/-z-e-e- ?2c-a-- / 7 G-14) ./ JUL. - 2.1987. are of TuKvvia. PLAIN/WW1 I:1E9T. A2 -11-a'ia) . , I JUN 3 0 19871 /4- d v- • • C!TY OF 'flitMLA Cx„, 1)1_ ANsrjr; pEp-r. /b/YrAJ Cfr te-z a4ao 1' 77IC 1/;lai*/37" MIY;•IN)Cf.'ilVil. JUN 3 0 1987 CITY OF TUY.4VILA PLANNING DEPT. Vernon Umetsu _Department of Planning City of Tukwila 6200 Southcenter Boulevard Tukwila, Wa. 98188 15130 65th Ave S. Tukwila, Wa. 98188 June 26, 1987 Dear Mr. Umetsu, As avid birdwatchers and nature lovers, we would like to protest the destruction of any part of Tukwila Pond for construction of a road. This pond is an important part of the migration of birds each year. To destroy any part of it would be a real loss to the community. It is one of our real pleasures of living in Tukwila to be close enough to drop in often to see the birds, especially during the season when the young hatch. Please consider other answers to any traffic problems in this area.' Yours truly, - JaaaAJ /727. Robert D Buckingham Billie M Buckingham June 25, 1987 Vernon Umetsu Dept. of Planning City of Tukwila 6200 Southcenter Blvd. Tukwila, WA 98188 Dear Mr. Umetsu: RECEIVED JUN 2 9 1987 Adrienne ?fleopfcilus 15110 Sunwood Blvd. Tukulira# Wisittingavn 98188 I understand that the City of Tukwila Department of Public Works is proposing to construct a multilane roadway, South 168th Street, across the southern margin of Tukwila Pond. I would like to register my strong opposition to this infringement on a rare area where we can still see waterfowl, shorebirds, and songbirds at almost any time of the year. As you must know, the small area of .Tukwila Pond is one of the few "watering holes' for hundreds of migratory water birds in this area. It is used for resting, breeding and feeding. If we continue to take over the areas of wildlife, it will be a much sorrier place in the years to come - for us and for our descendents. One of the many beauties of the Seattle area is the 'wild places' where we can still go, so close to home, to enjoy wildlife. Let's not ruin any more. I hope that you and the others involved will re -think this and leave Tukwila Pond wild. Thank you. i Sincerely, ey-wae Adrienne Theophilus cc: Gary L. Van Dusen, Mayor Wendy A. Morgan, City Council Edgar D. Bauch, ' Joe H., Duffie F{Rritli • a 1! juN 24 19871 • raj{ OF F' K:.'iLA 'PT PL.A.r1N!'. r. o7 PT. (/‘2,,,2 Lea:,e0t, .-tVacaervcei 11&)- , 72tz y� eq—ez-eXe REC r /El] JUN 2 3 1 7 /t'4-' 7-4/11 w,, 17,1(!aQ ►-r 101 (2) C&v cLZ 12.a61 Ga c.;bile„0.4-4 'l d rte t .(r71 Z14.--4-, °24-‘17 e /4 `-rt`"(' MS AGNES M. WILDER 515 S WITH ST WESLEY GA DES MOINES, WA. 98196 metze& rz 0a cfaleaca,t, .(J L_/- _der),( )97- 26U'icd J-0-1 JUN 25 19871 - CITY OF ru-K•vi“...A. PLANN!Nri OEPT. "MA 1/ .n lei ,�.Q,u- • City oP Tu,hwc�C, (� 610 D •Sa-x, t'G2 o /3 /vd ..rule w :14 / GI)o. 9g/S' 4& /)ti . Zl sue- : e. . eA- pra y- wIto ��oaro [JUN 25 19871 CITY OF TUKW, A PLANNING DEPT. a 3 , 198'7 `•23 3 S. " /82,Edc%. Sea: Ike, W t . W/67 c ee- 2 oti.C€d -I.» z., 1^2 M, Tom;- C J. d,e_,a - :3 o h.2 AL1 arauw 4 T u Z%ut y '- &-k.A oir. %2,Ae1 t - Blvd. a xi evtr xd d foz. aix.o CA,e4101- .4-teetU ta-Ch 117 CLxa%evPr� Gv . L oy-& Aiwa l s. /63k, S& Ae.a49 a e6 -t s _ o t ) N i r 4 c G S k 6 t - a - t e -9!07' )e4L Cip , Q"`#,{ c%i.Z y JuitA b1A,AbvtCo k 'A- 't1 lo 020,5,4 41.6aa144,.2 ,2_,,,„41 WA4-# 0)11-eit-N;ei6fe.. JAtioyed ba toh, LJ &O view A. fit-drn D /z ' ' J 1z»* . .L %1//,� _ LNa-114.-4.0 aL - � Z cu Gl f�j / �4v/ 664- vn. �-al" .ArN 1 E 'ix Os/ J`.& d)'L s ear -144 be. kpc.L414-e -44(6 (s5,0#1:ex..e4-44-1 z .4" w An 4,444.- Gn.id itZ nine cnuit i �G . ,40 4-0 ru 6 r 1 /3 -C 1€ ae ,A(L Cr �le- AAA-. T c�w . C P w /ea -he_ a 1/ f'.h- , 1")14-k- Cn~eU v' ew .A. , a ,alC CZA a /634_ vve- ,..ed_ 4.9-& L.5 Ce:0 Icf- Lo - &d4c az4- Dr . AT (40,4 i Cor. Dr- . etz -I .b.e_ cS 7344,7 , LA.) et/de.k;d aA-eat_ .71 ttiv tttr_44 ck) 44..- rz, 3 ¼5k p e-z-Izz -Ad ? 7 a:p.A.12. eo.e o-ice At, A*A.„.,,e,/, 0/2, bre. 1 C d'h4t-vet.14.0v•-- • 51/_ JA145 e-2AA. " ele-ktrd _,Acrio.ciAj a f It41.4, o P a p a-A.ve 6, Ad aderkzi A4 4) _r kiatzet dUl': Ae_ fre2/2.1-el., a.pki eadazis 6 mAI-- a_ "z44-4,x4,1 befe,h0q-,..<-41 p nk,Ls w V'ttaZ 14-Ja eizidad „5: /6ek_ uvlo 2-4440 "ro ,coccernceoe2d: d)Yfl plor,sed1/2) c-enV-ntofmn of 0/1 roaduia, tuktith ificreoacife-0 tGr,fig4, 63, -ruktak /Sid . AtAlizti/errar-e--. : _____-• . :- , i. ; .: jr 1 ' ••-i 1L-A 2L AN'! : ,-pi. ___-_ 111 - N.E. 42nd #3 Seattle, WA 98105 • .1 15�p SHIDLI McBROOM GATES & LIk. %S ,ATTORNEYS AT LAW • A PROFESSIONAL SERVICE CORPORATION Mr. L. Rick Beeler Director of Planning City of Tukwila 6200 Southcenter Blvd. Tukwila, Washington 98188 RE: South 168th Street DEIS Dear Mr. Beeler: July 9, 1987 IA/ Bellevue • 51)5 Honevu eli Center • 1100108th Ave. N. E. Bellevue. W4..hmeron 48111/1 Telephone 120n 115 34o3 1 h Telecopier 12l)h 1 455.'J1h6 0-1L; ESlin JUL 10 1987; CITY ()r PLANNING DEPT. This office represents The Bon, Inc. with regard to The Bon Distribution Center ( "Center ") located at 17000 Southcenter Parkway in Tukwila. Please accept the following points as the comments of The Bon to the June, 1987 Draft Environmental Impact Statement (DEIS) with regard to the above referenced project. I. Land Use Of utmost concern to The Bon is the severe disruption of the truck unloading activities that will occur on the north side of the Center. The . DEIS does not adequately explore the impacts of the proposed project on these activities and does not provide sufficient specific information to address the anticipated significant impacts. As a result, it remains the position of The Bon that the proposed project will disrupt and perhaps even preclude the continued use of the Center. The Final Environmental Impact Statement (FEIS) should include sufficient analysis, including diagrams and plans, to illustrate the specific impact of each of the contemplated alternatives on the use of the Center. The DEIS is incomplete. _ -with respect to analysis of this nature. Additional information is required with regard to the impacts on the Center as a result of the changes that will result to the existing railspurs in this area. The existing rail line provides an efficient and convenient access to the subject property. This will be altered by the proposed project in a manner that is not clearly identified. Additional information should be provided in the FEIS to analyze this impact on ,_01e use of the Center. II. Transportation As a general observation, it is evident that the proposed project will have only minimal beneficial impacts for transportation circulation in the vicinity. It will even have a negative impact by exacerbating the level of service at the d Mr. Beeler Page Two intersection of Strander and Andover Park West. Given the substantial costs of this project, and the clear significant impacts on the Center and other abutting parcels, as well as the nearby wetlands, the viability of this project is questionable. While the DEIS does provide a base of information that is helpful to analyze the impacts of this project, it raises more questions than it answers thus far. Among the transportation related questions that arise from the DEIS are the following: r5- 4 I IS- 5 1. Does the development of the Minkler Blvd. extension lessen the need for 168th? Does not the Minkler Blvd. extension provide the most efficient and appropriate east -west connection in this area? Does the 168th connection provide only a minimal and secondary improvement? 2. Is the proposed project economically justifiable given the marginal improvements and the significant cost as well as negative impacts on abutting private property owners, which will necessarily require compensation? 3. Would a two -lane configuration be sufficient for the projected traffic volumes on 168th? Are the three and four -lane configurations of the alternatives included in the DEIS excessive and result in unwarranted impacts and costs? Would a two -lane configuration significantly lessen the impacts on the Center and other abutting parcels? 4. Is there sufficient detail regarding the truck unloading operations on the north side of the Center to adequately analyze the impacts on the use of the Center? Will the Center be capable of being used in its intended manner under the project alternatives? Are the authors of the DEIS familiar with the internal structure of the Center and familiar with the impacts of the project on the internal workings of the Center? Will a hazardous traffic situation result? 5. While alternative B appears to have the fewest impacts on the Center, is there sufficient analysis of the impacts of alternative B to conclude that it is an acceptable alternative that will not have significant impacts on the Center? . Will any of the alternatives not require an expensive redesign of the internal structure of the Center and is there sufficient information provided in the DEIS to reach a credible conclusion on this issue? A more detailed discussion of the foregoing and other points is raised in the June 30, 1987 letter from the Transpo Group, Inc. which is attached hereto as Exhibit A and incorporated herein by this reference. The Transpo letter reaches the conclusion that all alternatives will potentially require a substantial if not complete redesign of the Center. Only alternative B appears to have any potential for acceptability. However, there is insufficient information on the impacts of this alternative and it must therefore be considered unacceptable at this time. The FEIS should contain much more detail, including graphic depictions, on the existing truck patterns and internal workings of the Center and the changes that will be required as a result of the project. Clearly, a "before and after" analysis of these issues is called for. Mr. Beeler Page Three III. Utilities The DEIS, at page 99, states that no adverse environmental impacts are anticipated with regard to the "partial relocation and adjustment" of the utility and communication lines which currently serve the Center. However, there is no detail provided regarding the impacts on the Center that will occur as a result of the relocation and adjustment of these lines. It is not disclosed whether the utility and communication service provided by these lines will be interrupted during the construction process, and if so, for how long and what the resulting impacts are on the Center. The Center has substantial communication lines within the proposed right -of -way and the extent of these lines is not disclosed or analyzed in the DEIS. It is suggested that further contact be made with The Bon staff in order to identify the extent of the communication lines and determine how 168th can be constructed without any interruption of the communication facilities in the Center. IV. Earth The DEIS states, at page 30, that, as a result of the roadway construction, settlement of the Center is anticipated, possibly to the extent of 1.5 inches. There is no further analysis of the impacts of that settlement on the Center or whether it will cause significant structural or other damage to the Center. We were advised by The Bon's consulting engineer that settlement of 1.5 inches may prove to be very significant and could cause potential damage to the .structural integrity of the Center as well as damage to the unloading areas. In that event, it can be expected that the required compensation for the damage to the Center will escalate significantly. Please see the more detailed comments of William L. Schaible regarding this issue in his letter dated July 8, 1987, a copy of which is attached hereto as Exhibit B and is incorporated herein by this reference. V. Water, Plants, and Animals The DEIS identifies that the proposed project will require the filling of and construction within a portion of a 100 year floodplain, the Tukwila Pond and the surrounding wetlands. There is no discussion however, regarding whether the proposed project can encroach within this environmentally sensitive area and still comply with all applicable governmental regulations, including that of the City of Tukwila and the Army Corp of Engineers. It should also be analyzed whether the project is consistent with applicable comprehensive plan policies of the City of Tukwila regarding development in environmentally sensitive areas. The FEIS should additionally explore the precedent that will be established by the proposed project in terms of future development of the Tukwila Pond site and the encroachment of other development projects into the floodplain and wetland areas. VI. Economic At no point does the DEIS disclose or analyze the economic impacts of the proposed project. It is anticipated that any of the alternatives discussed in the. DEIS will require a substantial restructuring of the internal use of the Center, or alternatively may force The Bon to relocate the Center elsewhere. Therefore, the economic impact of the proposed project on the Center property alone can be expected to be substantial. Additionally, together with the economic impacts on other abutting Mr. Beeler Page Four property owners, and the substantial costs of condemnation, the economic viability of the project should be fully analyzed and this information disclosed for the decision makers. The DEIS discussion of economics is limited to the projected costs of developing the roadway. There is no indication of property acquisition costs, nor the potential costs of compensating abutting landowners for damage to the residual of their land and improvements. For example, if The Bon must substantially modify the internal system of the Center as a result of the proposed project, it may cost in the millions of dollars. The Bon will expect to be compensated for these costs. VII. Legal In order for the City to successfully proceed with condemnation of the subject property for this project, it will be encumbent upon the City to demonstrate that 1) the use proposed is a truly public use; 2) the public . interest requires the taking of a portion of The Bon's parcel; and 3) the portion of the property taken is necessary for the public use. Steilacoom v. Thompson 69 Wn 2d 705 (1966). It is evident from the DEIS that the beneficial results from the proposed project are, at best, minimal while the cost and expense is extensive. Additionally, the resulting impacts on adjacent parcels and their use is also very substantial and the DEIS does not present an adequate mitigation approach for the impacts. At the same time, it is apparent that the Minkler Blvd. extension will be far more useful in terms of benefitting the traffic circulation in this-area and will have a greater beneficial impact than will the proposed project. Under the circumstances, the City may have some difficulty in establishing that the proposed project is truly in the public interest and therefore it may be unable to meet its burden in taking this property through the eminent domain procedures. There is precedent for the Court's determining that a proposed taking is arbitrary and capricious and not in the public interest where reasonable alternatives are available which will have less impact on adjoining owners and will be less costly. State v. Superior Court for Yakima County 128 Wn 79 (1924). Therefore, it would be appropriate for the FEIS to include further analysis and disclosure of information which will more clearly establish the real public interest in proceeding with this project. At this time, the DEIS does not provide sufficient information to reasonably conclude that this project is either in the public's interest nor certainly in that of The Bon. Thank you for this opportunity to comment on the DEIS. The Bon will look forward to a thorough analysis of the issues raised herein. Enclosure JLH:st cc: Mr. T. P Harville, The Bon, Inc. Mr. Douglas Chantry, The Bon, Inc. Mr. Jim Maclsaac, Transpo Group, Inc. Mr. William L. Schaible, PE 026 -8 /JLH V ours ohn L. Hendrickson Transportation Planning & Traffic Engineering Consultants June 30, 1987 Mr. John Hendrickson Shidler, McBroom, Gates & Lucas 505 Honeywell Center 600 - 108th Avenue NE Bellevue, WA 98004 SUBJECT: S 168TH STREET DEIS Th® TRANSPO Grove Dear Mr. Hendrickson: Per your request, we have reviewed the subject report with a focus upon the interests of the Bon Distribution Center which will be impacted by the pro- posed road project. The following comments should be brought to the attention of the City of Tukwila for purposes of improving the EIS document. Minkler Boulevard Extension A major premise in the need for the S 168th Street project is a need to pro- vide a new east -west traffic connection through the superblock bounded by Southcenter Parkway, Strander Boulevard, Andover Park W, and S 180th Street (DEIS Summary, Page 1). However, its traffic impact analysis, as set forth on pages 86 -92, includes an assumption that Minkler Boulevard will be extended between Andover Park W and Southcenter Boulevard, with or without the 5 168th Street project. Does The Minkler Boulevard extension lessen the need for the 168th Street project? Marginal Improvement to Vicinity Street System DEIS Figures 23 and 24 show traffic conditions with and without construction of S 168th Street. Though S 168th will result in some traffic reduction along Strander between Southcenter Parkway and Andover Park W, it will have marginal effect on improving traffic operations at the "four corners of the superblock ". S 180th Street traffic will be unaffected by the S 168th project. The project would result in a small improvement in traffic operations at the Strander/ Southcenter Parkway intersection; and it would result in worse operating conditions at the Strander /Andover Park W intersection. It would reduce the effectiveness of Minkler Boulevard as perhaps the more necessary east -west break of superblock circulation. Considering the marginal improvement to vicinity traffic operations versus the high dollar and environmental cost of the S 168th Street project, is the project justifiable? This question needs to be addressed. EXHIBITjg The TRANSPO Group, Inc. • 14715 Bel-Red Road, Suite 100, Bellevue, Washington 98007 -3940 • (206)641 -3881 Mr. John Hendrickson June 30, 1987 Page 2 TNANSPO Grove Lane Requirements The traffic estimates shown on Figure 24 of the DEIS are 6,500 vehicles per day, of which 2,500 are merely diverted from the underutilized Minkler Road corridor. Such volumes could be easily carried by a two -lane street. Except for potential development around the "Tukwila Pond ", the S 168th Street cor- k / ridor is fully developed. There does not appear to be a need for anything more than a three -lane street at most. Alternatives A, C and 0 do not appear to be warranted. The need for and number of lanes of the proposed project needs to be justified by the EIS. Alternatives Alternative C would negatively impact 15 of the 23 truck loading bays along the north side of the Bon warehouse; nine would not be usable by large tractor /trailer rigs. This is an unacceptable impact on the Bon warehousing operations. Alternative 0 would render all 23 truck loading bays unaccessible by large tractor /trailer rigs. This alternative is totally unacceptable. It is un- likely that the Bon warehousing operation could be revised to survive under this alternative. It is possible that the Bon warehousing operations could survive under alter- native A or B. Alternative A would have the less desirable impacts; again, there does not appear to be any justification for a four -lane street section. Alternative B has the least impact on the Bon warehousing operation. Further analysis is necessary to determine if it can properly accommodate truck load- ing operations. Truck Access /Operations The DEIS does not provide adequate discussion and illustration as to how the Bon warehouse north side truck operations will be accommodated under the various alternatives. The "curb cuts" shown for each alternative do not appear adequate to accommodate the very obtuse angle truck movements that will be necessary. Westbound truck egress from the loading bays is essential. The flat angle crossings of S 168th Street would appear to be very hazardous. The FEIS needs to illustrate large -rig truck docking and undocking wheel patterns under each alternative. If ingress from the east on S 168th is not possible, it should be so stated. .Egress to the west on S 168th is essential; such egress patterns should be illustrated and their safety aspects discussed. Truck egress through the west parking areas other than via S 168th is totally unacceptable. If that is a design assumption, the FEIS should include a mitigated design of the west parking area to show acceptable truck egress. Mr. John Hendrickson June 30, 1987 Page 3 TRANSPO Grove Conclusion The north side truck docking operations of the Bon Distribution Center are its most critical relative to large -rig truck access. This is where all incoming merchandise arrives (most merchandise arrives via large rigs). To change this incoming orientation would involve a complete redesign of the warehouse machine operation. For those of us who have toured the operation, such re- design could cost millions of dollars. It is essential to the S 168th Street project that such redesign not be necessitated. Alternative B is the only alternative that appears to minimize impacts on the north side truck operations of the Bon Distribution Center. To assure its acceptance, truck access, egress and docking operations must be further de- tailed in the FEIS. Unless an acceptable detailing is presented, we believe the Bon must oppose the development of an arterial street along the S 168th Street corridor. Very truly yours, The TRANSPO Group, Inc. 119,14aeethAW.c. es W. Maclsaac, P.E. incipal Engineer JWM /dkg July 8, 1987 Mr. Douglas Chantry BON DISTRIBUTION CENTER 17000 Southcenter Parkway Tukwila, WA 98188 Reference: South 168th Street Corridor Gentlemen: You have recently requested that covering the "South 168th Street Engineers, Inc. Specifically your concern is how inches (on page 30 of the E.I.S. structure. 'Wc rO ray C twig Consulting nee. s Planners 1100 Set Mena 844u Seattle, Washington 08111 441.7960 we review the draft E.I.S. statement Corridor" prepared by Entranco the anticipated settlement of 1.5 statement) will affect the. warehouse The statement that a settlement of 1.5 inches will occur is very general. More specifically we would expect that the north side building foundations would settle differentially from the interior columns and south wall footings. This could possibly place undue strain on the precast concrete walls as well as the floors. This possibility of damage to the structure should be recognized at the outset and steps taken to monitor the expected settlements as they relate to the warehouse. The monitoring procedure should be in place prior to the beginning of construction and continue, with records kept, until the roadway is complete. Also of concern is the impact that the selected location and the construction will have on warehouse operations. Damage or disruption of loading at the rail and truck docks is possible, if not probable. The deflection (settlement) of the subgrade In these areas would impair the day to day use of the loading facilities. Provision should be made for allowing normal operations to continue unhindered as much as possible. Apparently each of the "alternatives" impacts or completely deletes the diesel fueling station and underground serving tank and fire protection facilities. Also, settlement of the amount anticipated would or could damage the various utility service piping where it enters the building. This includes water, fire service, and sanitary and storm drainage. EXHIBIT � 17 -Z etter to Mr. Douglas Chentry of July 8, 1987 - Page 2 Ilin our opinion the several concerns should be addressed and satisfactorily resolved well ahead of construction, during the project esign phase. We should look for detailed solutions to each concern 'eing presented for the review of the Bon Warehouse management as esign proceeds. Such coordination is essential and will avoid many conflicts of interest in the future. , 17�Z -g • ." • / kify-rnkA 2,r\rci -YfliglkON-1 kiwo #4.r-r) ivocr-r-AD-rt I;NAt) d -Nrpoifati yow pQdctQ pr\k/ kl,(19 (T5 4/0X pcx-PsN-C)-10?t70-7 cYT)-vici FNL9d vrni(P r i7\/ —3°7 I Frrn-lq- rrv/r/J\k_Crt). d (..37.71.1.441Plitit\krn ..• • !I • 11.86i, 6 - 's {p u King County Division of Roads and Engineering Department of Public Works 956 King County Administration Bldg. 500 Fourth Avenue Seattle, Washington 98104 (206) 344-7490 June 29, 1987 Mr. L. Rick Beeler SEPA Responsible Official City of Tukwila 6200 Southcenter Boulevard Tukwila, WA 98188 RE: South 168th Street Draft Environmental Impact Statement (DEIS) Dear Mr. Beeler: Thank you for your June 3, 1987 letter concerning the South 168th Street Draft Environmental Impact Statement (DEIS). I have reviewed the above DEIS and have no comment on the project. The DEIS covers the items identified in the Scoping Notice for transportation impacts. The new road will be located entirely within the City of Tukwila and will not have a significant impact on King County roads. Thank you again for the opportunity to review the South 168th Draft DEIS. If you have any questions, please contact me at 344 -7490 or Bill Hoffman, Transportation Planning Section Manager, at 344 -7402. Sincerely, Louis J. Haff, P. County Road Engineer LJH:LG:lh /CCF R -4704 cc: Bill Hoffman, Manager, Transportation Planning Section , SERVING: KING COUNTY 200 West Mercer St. Room 205 Seattle. 98119 -3958 (2061:M4-7330 KITSAP COUNTY Oial Operator for Toll Free Number Zenith 8385 Bainbridge Island Residents Dial 344 -7330 PIERCE COUNTY 901 Tacoma Avenue South 213 Hess Building Tacoma. 98402 -2101 (206) 593 -2225 SNOHOMISH COUNTY 1.800 -552 -3565 BOARD OF DIRECTORS PUGET SOUND AIR POLLUTION CONTROL AGENCY Mr. Vernon M. Umetsu Associate Planner City of Tukwila 6250 Southcenter Blvd. Tukwila, WA 98188 Dear Mr. Umetsu: 6 ;9871 C; •,._r1 PLAN' :; 200 West Mercer Street, Room 205 Seattle, Washington 98119 -3958 Telephone: (206) 344 -7330 Facsimile: (206) 340 -4788 July 2, 1987 South 168th Street DEIS The following comment is based upon our review of the draft EIS for the South 168th Street extension. Regarding your comment on page 34 regarding the ozone nonattainment area, EPA published its redesignation action in the January 2, 1987, Federal Register, and the non - attainment area redesignation action finally became effective on March 2, 1987. Thank you for circulating the draft EIS for comment. Sincerely, sm hur R. Dammkoehler it Pollution Control Officer VIC.F (.NAIRMAN' Rae Aardal. Commissioner Kasai County Vernon M. L'netsu Dissociate planner J i t y of Tukwila 2C0 Jou4hc'enter Boulevard Tukwila, pis ahin`t on 96188 Dear 1Ir. Umet au: Ts. nk you for .:.eking the effort to "aie the ira Env fio.'it 1 Inp: ct statement (JETS ) for South iE6t:a1 Street aysi1 , a t .tae Tukwila ijuulic Library. Tukwila pond is an important ecosystem and any project that It should be evaluated carefully. It is Especially important cffec because of ti.he loan of wetlaahe in otter parts of the sreer. River Valley. Since the reasons given for the need for South 168 t Street y of tae DDS ), should have been considered hen the Superb'1oc�kfre was oritir_ally dGsidned I am. concerned that this DEIS does not consider possible development of . the rest of Tukwila Pond. I think t:. t the fet* of the and conytrLCtlon on a � should be detert�:ned before rod a portion of the pond it' considered. A project tat woul.. fill in tae pond could generate alot more traffic on jhit:ander Boulevard and Andover Park Jest than is currently pro - ected. 148; 3. Inta *"n Avenue 7.; `ta 1 Apartment Tu rila, Wa srxin;t on 9.6168 3 J ulY 1987 t... Anot.;er reason that the ant vague discussion Of miti at of t:`e LEIS). If construct ccnatruct'_on of the road it that were created as m itiga construction would also: be ire pond should be considered is the ion for the loss of wetlands (page 54 ion is allowed on the pond after would be possible that new wetlands tian for those lost by the road lost. The LEIS, does not consider the possibility that traffic congestion in tii Superblock could be caused in part by traffic conj eation on 1 -5, I -405, and the Hest Valley Road. way's other than road construction could be considered to reduce trwffic congestion. These could include car poplar different .,Aift :1-::es, and better bus service. Sincerely yours, John M. iolf 1 16813 Southcenter Parkway Seattle, 'Washington July 6, 1987 Mr. Vernon M. Umetsu Associate Planner City of Tukwila 6200 Southcenter Boulevard Tukwila, Wash. 98188 Subject: Draft Environmental Impact Statement - South 168th St., June 1987 Dear Mr. Umetsu: Following are my comments on the above subject. \--- My major concern is the traffic impact at the T- intersection of South 168th and Southcenter Parkway. Please assure that the finalized traffic signals provide safe egress to and ingress from each direction at my residence. In addition, since the METRO bus Lzone is on the east side of Southcenter Parkway directly opposite my residence, recommend a crosswalk at that point. Thank you for sending me the draft and for your consideration to the above comments. Yours truly, Matt M. Mikami REAL PROPERTY WESZ , INC 101 California Street, Suite 2525, San Francisco, California, USA 94111 ❑ Telephone (415) 421-5100 ❑ Telex 5108011419 ❑ Telecopier (415) 4216021 July 2, 1987 VIA U.P.S. Mr. Vernon M. Umetsu Associate Planner Department of Planning City of Tukwila 6200 Southcenter Boulevard Tukwila, WA 98188 Re: Proposed Construction of South 168th Street Tukwila, Washington Dear Mr. Umetsu: Real Property West is the owner of Parkway Square Shopping Center, immediately adjacent to the route of the above - captioned proposed new street. By reference thereto, the concerns and objections stated in the letter dated December 2, 1985 to Mr. Phillip Frazer of the City of Tukwila and from Larry W. Summerton, Contract Property Manager for Hayden Corporation on behalf of Real Property West, are repeated and incorporated herein. This letter is written in response to the Draft Environmental Impact Statement for the above - captioned proposed street construction and will further express this company's concerns and objections as they relate to the proposal to construct South 168th Street. We note from the scoping comments attached to the DEIS as Appendix A that virtually every . correspondent is opposed to the proposed new street for a number of different reasons and, in particular, that each of the adjacent, property owners who will be most effected if the street is constructed, are also opposed for valid and legitimate reasons. We especially support the remarks of Mr. Dennis J. McLerran on behalf of The Bon Distribution Center where, in Article VI of this letter to Mr. Brad Collins of the City of Tukwila dated December 16, 1985, Mr. McLerran suggested that a cost /benefit analysis would be highly desirable for decision makers and the public to have reliable financial information available when decisions must be made on the project. We are disappointed to note that the DEIS does not contain such an analysis. We are also disappointed and surprised that the City of Tukwila continues to support this proposed new street when Table 11 on Page 81 of the DEIS reveals that the level of service and average vehicle -delay time are only very marginally improved in a u.na.wr of Th. Canitd 6 Cnurrthe Groan. Landon . Ernl.nd 321 -Mr. Vernon M. Umetsu July 2, 1987 Page 2 certain instances with the project proceeding. Indeed, there are many instances revealed by Table 11, whereby the ' construction of the project will lead to a very significant deterioration in the level of service and average vehicle delay time. With the reiteration of our previous concerns and objections and ),3 these new findings revealed by the DEIS, this company_ remains very much opposed to the construction of South 168th Street. Yours sincerely, REAL PROPERTY WEST, INC. I Derek Aynsley President DA /453 cc: Larry Summerton -METRO Municipality of Metropolitan Seattle Exchange Building • 821 Second Ave. • Seattle, WA 98104 -1598 July 1, 1987 Mr. Vernon M. Umetsu, Associate Planner City of Tukwila 6200 Southcenter Blvd. Tukwila, Washington 98188 Draft Environmental Impact Statement File Name: City of Tukwila - South 168th Street Dear Mr. Umetsu: Ir?Iri�J7f�' �►j ,_�J 1 'AL - n 19871 Lit Y or i ti'sL°.i_A PLANNING DEPT. Metro staff has reviewed the draft EIS and offers the following comments. Metro anticipates no significant impacts to its wastewater or public transportation facilities from the project. We anticipate no significant degradation of surface water quality provided all mitigation measures both during and after construction are implemented in a timely manner. The proposal includes fill in the least disturbed and most diverse (in vegetation) southern portion of Tukwila Pond. Although mitigation measures proposed in this project to reduce water quality impacts should be adequate to maintain surface water quality on the site, the proposed road within Tukwila Pond would adversely affect the wetland's water storage capacity, thereby reducing its water purification potential. The project would also affect habitat and reduce the wetland's value as a wildlife refuge. Metro recognizes wetlands such as Tukwila Pond as environmentally sensitive areas with unique characteristics for water quality protection and wildlife habitat. Wetlands are important ecological.. systems which can improve water quality in varying degrees by temporarily or permanently retaining suspended materials, excess nutrients, toxic chemicals and disease causing micro - organisms. In addition, Tukwila Pond functions as a major stopover for migrating birds. In 1983, Metro evaluated the Tukwila Pond area as a possible site for the Tukwila Transit Center. After an in -depth analysis of the site which included a wetlands inventory report by a consulting wildlife biologist, Metro rejected the site for that purpose. We also have concerns about the proposal's statement that it would "enhance" the remaining wetland or would replace the 1A'? that replacement would be contingent, in part on, the wetland loss with on- or off -site replacement. The EIS states availability of suitable sites. Should the proponent find that no other feasible, less environmentally - damaging alternative exist, measures to prevent degradation of water quality should be taken. These measures should include, but not be limited to: I o use of sediment curtains or containment fabrics to prevent sedimentation into the pond; o identification of runoff discharge points into surface -- wate rs through King County's drainage p lannin g process; _ Mr. Vernon Umetsu July 1, 1987 Page Two Metro acknowledges that King County has included wetlands in its Sensitive Areas program. While recognizing that the proposed project is within the corporate limits of the city of Tukwila, we encourage the proponent to utilize these Sensitive Areas guidelines and mitigation measures to avoid adverse impacts which may arise from the construction and implementation of the road in Tukwila Pond and adjacent wetlands. Metro does not endorse any construction activity related to the project in Tukwila Pond and adjacent wetlands. Additionally, a buffer zone to the wetland should be established if no other feasible, less environmentally - damaging alternative exists. Metro recommends that this zone extend at least 50 feet away from the wetland's boundary. o methods to prevent toxic materials, petro- chemicals and , t5 other pollutants from entering surface water during and after construction; tti o provisions for maintaining adequate setbacks and wetland vegetation; and o revegetation of affected areas with native species. Mr. Vernon Umetsu July 1, 1987 Page Three Thank you for the opportunity to review and comment on the proposed project. Sincerely, Gregory M. Bush, Manager Environmental Planning Division GMB:dwg �? S STATE OF WASHINGTON DEPARTMENT OF ECOLOGY Mail Stop PV -11 • Olympia, Washington 98504-8711 • (206)1 45 4 ` i; 11„+`/ 15 U11 1 H.'L-;9811 pi .ANNiNG DEPT. June 30, 1987 Mr. Vernon Umetsu City of Tukwila 6200 Southcenter Blvd. Tukwila, WA 98188 Dear Mr. Umetsu: Thank you for the opportunity to comment on the draft envi- ronmental impact statement for the South 168th Street Project. We reviewed the EIS and have the following com- ments. Tukwila Pond and its associated wetlands represent an impor- tant natural resource. Due to its location in a highly de- veloped area, this pond plays a particularly important role in providing critical habitat for waterfowl and other migra- tory birds. It also provides important stormwater storage and water purification functions. We support any efforts to retain the pond and wetlands as a natural area. Therefore, we favor the no action alternative in the draft EIS. However, if a road must be built to al- leviate a critical traffic congestion problem, we support the selection of Alternative D. This alternative will minimize impacts to the pond and wetlands. 1 If Alternative D is chosen, off -site mitigation in the form of wetland creation or restoration should be required. If you have any questions, please call Mr. Andy McMillan of the Shorelands Program at (206) 459 -6774. BJR: cc: Andy McMillan Sincerely, Barbara J. Ritchie Environmental Review Section Washington State -„ Department of Transportation District 1 Office of District Administrator 6431 Corson Avenue South #C -81410 Seattle, Washington 98108 206 764.4141 June 17, 1987 Mr. Vernon M. Umetsu, Associate Planner City of Tukwila 6200 Southcenter Boulevard Tukwila, Washington 98188 Dear Mr. Umetsu: Duane Berentson Secretary of Transportation 1 I 'UN 22 1987 1 C;i i-.y ui -iik. . /,: PLANNING DEPT. SR 5 MP 153.75 Vicinity CS 176700 DEIS for South 168th Street This letter is in response to the DEIS review we received from the City of Tukwila on June 8, 1987. This proposed roadway is bordered by the Tukwila Pond to the north, Andover Park West to the east, Southcenter Parkway to the west and a Union Pacific Railway spur to the south. The Department of Transportation feels this new arterial will have no adverse impact on I -5 or I -405. Thank you for the opportunity to comment on this proposal. If you have any questions, please feel free to contact this office at 236 -4403. CHUCK GLEICH Developer Coordinator -South CG /ds :1- STATE OF WASHINGTON DEPARTMENT OF COMMUNITY DEVELOPMENT OFFICE OF ARCHAEOLOGY AND HISTORIC PRESERVATION 111 West Twenty -First Avenue, KL -11 • Olympia, Washington 98504 -5411 • (206) 753 -4011 • June 11, 1987 Mr. Vernon M. Umetsu Associate Planner Department of Planning 6200 Southcenter Boulevard Tukwila, WA 98188 Log Reference: 931- C -KI -07 Re: South 168th Street DEIS Dear Mr. Umetsu: LIUN ' 2 19871 CITY OF I �nr,VILA PLANNING DEPT. SCAN 234 -4011 A staff review has been completed of your draft environmental impact statement. Based on the information provided for our review, in our opinion the proposed project will have no effect on presently known archaeological or historic resources included in or eligible for inclusion in the National Register of Historic Places. Thank you for this opportunity to comment. Sincerely, Robert G. Whitlam, Ph.D. State Archaeologist (206) 753 -4405 dw Archaeology and Historic Preservation • Community Services • Emergency Management • Fire Protection Services • Local Development and Housing • Local Government Services • Public Works '41311° 3 July 8, 1987 City of Tukwila 6200 Southcenter Parkway Tukwila, WA. 98188 Attention: Mr. L. Rick Beeler Re: South 168th Street Draft Environmental Impact Statement Dear Mr. Beeler: JUL -7 1987 CITY OF 1.jRV4ILA PLANN'N(; DEPT. I would like to make the following general comments relative to the DEIS for the proposed South 168th St. project. Due to the length of my comments, I have elected to present them in 2 parts. The first part will provide a summary of my comments. Detailed comments pertaining to sections of the DEIS will be addressed in the second part. As I read through the DEIS there was one key statement which appeared at least three times: "The variety and productivity of the proposed 168th St. project site is highest per unit area of the pond property since it encompasses the wetlands, pond edge, tree canopy, and the shallow islands in the southwest corner of the pond." As the DEIS points out, the construction of the proposed extension will drastically affect this area. We are dealing with a very fragile environment that seems out of place when you consider its location so close to major shopping /office complexes and freeways. It is important to put this project in its proper perspective. The "superblock" was formed by poor planning and lack of foresight by the City of Tukwila. The Green River and Interstate Freeway "barriers" existed before extensive development took over the area. Now because of inadequate planning, the City of (Tukwila is proposing to destroy part of a very unique and fragile environment. I do agree that a traffic problem exists on the "superblock ", but I fail to see how the proposed extension will provide any relief for the area. Traffic is extremely heavy at the intersections of Southcenter Parkway /Strander and Andover Park West / Strander but I cannot understand how the addition of two more intersections (with stop lights ? ?) will improve traffic flow. It is important to note that the major traffic problems (with the exception of Christmas) occur with the office workers and /or store employees commuting to and from work. Shoppers, for the most part, have learned to avoid the area during this peak flow. Regardless of the cause, this traffic is destined to the freeways that service the area, I -5, I -405 and Hgy. 518. Access to these points is very limited and the proposed extension will not provide improved flows to these major points. It would also appear that traffic lights would be required for access to Andover Park west and Southcenter Parkway from S. 168th St.. Now instead of two intersections for congestion, there will be four. Traffic in this particular area tends to move north and south not east and west. I cannot envision cars moving north on Southcenter Parkway then turning right on S.168th St. to gain access to the freeways and Southcenter, likewise, I cannot see traffic moving south on Southcenter Parkway then turning left on S. 168th st. to gain access to the Pavillion complex. The S. 168th St. location is an extremely poor choice for east /west trafic movement or improved access to the freeways. While the biological data per appendix B was only gathered over a nine month period, it should include the periods of highest use by migrating species. (I have visited the Tukwila Pond site from 1 -4 times per month since 1973.) It is important to note that the use by migrating species also varies as to the time of the day the observations were taken. Although it is not indicated, I would hope that these observations were made at different time periods. The introduction states "Biological data suggest that the Tukwila Pond site is a highly used waterfowl area which is integrated with the Green River to the east." While this may be true, there are also other areas such as Longacres Race Track, which along with the pond, provide areas necessary for the needs of migrating species. Ducks and geese find the necessary forage at such areas and then move to open water areas to roost, rest and feed. Although the site has not been designated as significant wetland, I understand that it has not fallen under the scope of the lassifications listed. For the area in which it is located, it certainly is a significant wetland, and as such, should be allowed to remain undisturbed. I would also like to stress some of the comments contained in Appendix A.- Scoping Comments. King County - Dept. of Planing and Community Development: "Tukwila Pond is noted as a valuable stopover for migrating aterfowl. The pond is used throughout the year by a large umber of diverse waterfowl species. It provides critical habitat or resident and migratory waterfowl." Further, "We believe the otential for "enhancement" on the rest of the site is not ustification for eliminating an area that is already stable and roviding excellent and rare habitat. If possible, Tukwila Pond hould remain undisturbed." • I• Municipality of Metropolitan Seattle:. "After an in -depth analysis of the site which included a wetlands inventory report by a consulting wildlife biologist, Metro eliminated the site from further consideration. In addition, "Any development within the Tukwila Pond area would adversely affect wildlife and result in a reduction in both the numbers of individual and diversity of wildlife species." Seattle Audobon Society: "The southern margin of the pond contains the highest diversity of wetland vegetation and it is the area least impacted by human intrusions; for this reason it receives the highest use by wildlife, especially more reclusive waterfowl species. The placement of the road alignment in this area would destroy the most intricate aspect.- of this wetland -ytem. As I read the DEIS for the S. 168th St., I was amazed that this project was still under consideration. The comments relating to the biological impacts alone should make it apparent that this project is not in the best interest to the City. If the comments contained in the DEIS have truly been considered, it is obvious that this project cannot be done without tremendous damage to an already rare environment. This site is quickly becoming the most studied site in King County and all of the studies have reached the same conclusion: rare, unique, highly diverse, fragile, etc.. It is time for the City planners to take responsibl'ity for the "super- block ". It was created by poor planning and additional poor decisions like the proposed S. 168th St. will not and cannot alleviate the situation that has been created. Tukwila Pond is a fragile unique environment that needs to be left alone and protected not "mitigated" and altered. I am strongly opposed to all, alternatives proposed, except alternative E. I would also suggest that .the City establish a long term plan for Tukwila Pond. The City of Tuwila has already lost much of its open and green belt areas. It is time for the City to look at the Tukwila Pond site for what it truly is, a unique area not to be found in other major cites in Washington and which cannot be improved upon by improved access or mitigation. Thank you for the opportunity to comment. Sincerely, Scott Salzer 233 S.W. 184th Seattle, WA 98166 July 8, 1987 City Of Tukwila 6200 Southcenter Blvd. Tukwila, WA 98188 Attention: Mr. L. Rick Beeler Re: South 168th Street Draft Environmental Impact Statement Supplemental Comments Dear Mr. Beeler: The following are additional comments relating to the DEIS for the S. 168th St. project. I do feel that it is necessary to respond to statements contained or overlooked in the DEIS. My comments will follow in the order that they appear in the DEIS. Re: Summary, Page 1. I do concur that a problem exists in the area designated as the "superblock ", but I do not' feel that the 168th street extension will provide any relief for the traffic flow. It is stated that "The interstate freeway system and the Green River provide physical barriers which also concentrate. traffic." I would like to point out that these "barriers" existed long before this area was subjected to extensive development. A little foresight on 'the part of the city planners could have prevented the situation that now exists. Page 3. I do not see how the proposed extention will provide any relief to the congestion. True it • may relieve congestion on Strander Boulevard, but that congestion will Just be moved to other intersections. All that this extension will.accomplish is to make two additional points for congestion. The additon of traffic lights to these proposed new intersections will further impede the flow of traffic. Page 3 & 4, Alternatives. All of the alternatives, except Alternative E, are unacceptable due to the direct impact on the -I- --pond and wetlands. Page 9, Purpose.and Need for Action. The purpose and need as stated would not exist if proper planning had.occurred for this area. This "superblock" exists due to the lack of thought and foresight by the City. I would also question if the South 168th St. will fullfill the needs as presented: a) From my observations and use of Strander Blvd, Southcenter Parkway . and Andover Park West the majority of the traffic movement is associated with the freeway access points. The South 168th St. does nothing to improve traffic flow to these point. b) While times. d) There would be alternative access to commercial properties, but these properties are very limited and additional access is not required. e) I do not feel that emergency response time will be greatly affected by the addition of this p b' Y roadway. f) The addition of S. 168th St. will add two new areas to contribute to the congestion that already exists. Page 12. Alternatives. As previously mentioned, all the alternatives except E, should be considered unacceptable due to , the adverse impact on the pond and wetlands. Page 30. Mitgating Measures. I do not feel that there is any L mitgation that can make up to the loss of habitat and intrusion `% into this area of the pond. IIPage 33. Unavoidable Adverse Impacts. Under Alternatives A, B, C, & D filling of a portion of the pond is required. This "unavoidable" impact is crucial to the habitat that, is now being utilized by the pond wildlife. This lost habitat cannot be "mitigated ".at the existing site. site, how 4 ;,.=mot be before another slice is taken? A precedent== 40bet. and a message sent out that sensitive environmeriti areas are of no concern to the City. I will argue` th - -t a statement the .."limited summer value to waterfowl and - marsh - birds. " Waterfowl use this heavy cover for nesting as do marsh bird such as ren and el lowthroats. �� 0,' j L �`a Page 47. "Open water f i-sh habitat...", it would seem that time would be taken to identify the fish species that are present in the pond. These "unidentified" fish are important to the birds mentioned in the same paragragh. Certainly this pond is not too large to take the time to collect and identify the species present. Page 49 & 50. Direct Impacts. Any filling of the Pond property as proposed in alternatives A, B, C, & D should be unacceptable. The DEIS even states "The proposed fill slope planned at the edge of Tukwila Pond would also eliminate the natural buffer between the existing rail and truck traffic patterns at the pond edge." In view of this, how does the City propose to mitigate by the planting of trees and shrubs along the roadway? Page 50 & 51. Wildlife Impacts From Wetland Loss. As stated, loss of wetlands, pond and large riparian trees under Aternatives A, B, C, & D would have significant impact on the wildlife. Page 51. Secondary Impacts. Construction - It is important to point out that construction impacts, as noted, would be very significant during the fall and winter months. This activity would greatly influence the migrating waterfowl. Road Operation - As the DEIS points out, there is a great potential to further development to the Tukwila Pond property due to what would appear to be improved property access. This stresses the point that the City of Tukwila should make a long term evaluation of what is to be done on this site. This should include a rezone from the current C -P designation. Page 51. It is mentioned that species, such as canvasback, that are less tolerant of human activity would likey cease to utilize the pond. This is just one specie, there are others that less likely to be found if this proposed street is approved. These would include rails, soras and herons. While it is true that most migratory birds would likely return after construction, there would be a loss of very important habitat that may lessen their numbers and decrease the nesting activity and .success. There are many unusal species that utilize the pond and the potential loss of these species should be strongly considered. Page 53. Refer to first section dealing with semi -tame ducks and crosses. There are all to many areas that have "tame" ducks. The presence of these tame ducks is unfortunate as they become aggressive to other ducks and cross breed to produce permanent residents. There are many areas for the feeding of such "crosses. One excellent example is Bellfield Industrial Park in Bellevue. While it may be fun to "feed the ducks ", the presence of these crosses (including geese) is the result of too much intrusion into a natural environment. In addition to the aggressiveness of the semi -tame ducks, they also present problems with pollution. By making Tukwila Pond a permanent year round home, they will greatly increase the potential for high coliform levels in the pond. This situation has been documented and it is realized as a threat to small bodies of relatively stagnant waters. Page 53. Impacts Conclusion. While Aternative D would be the least impacting to the environment, its impact are still unacceptable. Again, it is mentioned that the potential for increased development is a possibility. I 'still feel that no degree of mitigation can compensate for the loss of habitat resulting from Alternatives A, B, C, & D. Mitigating Measures - While it is easy to replace the riparian and deciduous trees, what about the mudflat and pond areas. How will these be mitigated ? ?. Page 54. The wetland lost is not replaceable at the present site without extensive modifications to the remaining pond. It is suggested that it could be but there is no description of how this would be accomplished. As far as off -site replacement, where would this be ?? This should be addressed! I am not aware of another site in Tukwila that could be modified for such a habitat. How will the effects if increased traffic be mitigated? The buffer of trees and shrubs will help but that will not be enough to protect the nesting and feeding areas currently used on the south edge of the pond and wetland. Page 54. Unavoidable Adverse Impacts. I don't believe that any mitigation can make up for the lost habitat that would destroyed by the S. 168th St. project. Most likely, the displaced species would re- locate but that would be a loss to the unique environment that exists at the Pond. This type of wetland in the Green River Valley is at a premium and is slowly being eliminated. Take for example the developments in Renton Just south of I -405 and east of Longacres. While habitat such as the Tukwila pond do not provide revenue, they are important as green belts and do provide enjoyment for many people. While they not be used by a great majority of individuals, it is pleasing to know that such areas still exists in extensively developed areas. Page 67. Natural Environment. The natural environment that currently exists serves its function very well. It does not currntly need "mitigation" to continue, to provide critical habitat for wildlife. If the City of Tukwila is serious. concerning its long range goals for a natural environment, protects such as this should not be considered. Page 89. Transportation Circulation in the CBD. While S. 168th St. may reduce traffic volumes.on Strander Blvd., how will they help in the area.of the "superblock" and with access to the freeways ?? To suggest that the S. 168th St. would make'a shorter route to "one" resturant is an absurd reason to destroy critical and unique habitat. How important can five minutes of a lunch hour be ? ? ?? Does this take into consideration the possibility.of traffic lights at Andover Park West /168th St. and Southcenter Parkway /168th ? ?? My guess is that it would not save much time! Page 95. Mitigating Measures. While the plan to "buffer" the remaining pond from S. 168th St may sound good, what is being done for the destroyed.. habitat? No amount of trees could "augment" what currently exists on the southern pond /wetland boundary. Unavoidable Adverse Impacts. With Alternative E there are no unavoidable advers impacts. • Appendix A - Scoping Comments. It is important to note specific comments from past groups interested'in Tukwila. Pond and their concern for, the environmetal impacts. It might also be appropriate to include the Chartwell Development DEIS. Appendix B - Biological Evaluation of Tukwila Pond. Much of this information is redundant to the contents contained in the body of the DEIS, but certain points need to be raised. B -2. .Again we see the following statment, "The variety and productivity ....etc. ". Obviously the authors felt this was a unique site and the proposed protect would have a significant impact on the pond site. B -5. Large raptors, in addition to smaller raptors, do utilize this site as a regular hunting area. The absence of casts is a poor evaluation criteria. Birds. If adequate studies have been done, it would be hard to miss broods of mallard, gadwall and coot on the pond. Canada geese have been observed on a nest without success. Pheasants, in additon to quail, have successfully raised young on the site. Page B -6 & 7. While the list is relatively complete, the number of waterfowl are extremely low. There are many days during the winter that 1,000 - 2,000 duck can be observed at one time. Many species of warblers are found at the site, in addition to Canada goose, savannah sparrow, horned larks, water pipits and meadowlarks. Page B -8. Mammals. Muskrat are common and should added to the list Page B -9. Fish, Reptiles & Amphibians. I do feel that it is important to identify "..two small unidentified species of fish.." mentioned. I am not sure about the trout, but I do know that the pond does support brown bullhead. Fish sampling on a pond this size would be very easy and should be done due to the potential for pond loss under Alternatives A -D. I am amazed at the ommision of bull frogs. The pond supports a large population of them and they are easily observed along the pond edge. B -10 & 11. Biological. While the southern border does not support large numbers of waterfowl or marsh birds during the summer, it does provide important habitat for nesting. In addition, it is noted that the southwest corner is important and heavily used by migrating shorebirds. This mudflat habitat is limitied on the pond and without it the shorebirds would not return. Please take special note of the last two paragraphs on this page. It is the third time that the statment(s) appear. I would apologize for the length of my comments, but I do feel that it is necessary. This DEIS supports many of the comments contained in previous studies, which also concluded that this is a unique fragile habitat. I am surprised that this project is still under consideration based upon the data presented in this document. I don't see that a trade off of potential benefits for the S. 168th St. project and destruction of habitat exists. I strongly urge that this project be stopped before it proceeds any further. I would like to apologize for the length of these comments, but I do feel that they are important. Regards, � ?C Scott Salzer 233 S.W. 184th Seattle, WA 98166 Response to comments in letter from Puget Power (1): 1-1 Comments Acknowledged. Response to comments in letter from Barb Holt (2): 2-1 Comments acknowledged. 2-2 The State Environmental Policy Act (SEPA) (WAC- states that reasonable alternatives must be considered. Due to the limited space between adjacent property facilities (buildings, utilities, parking) no alignment would have totally eliminated pond property habitat encroachment. Alternative D is intended to represent -areasonable alternative which minimized encroachment on the pond property wildlife habitat. It, however; has other impacts which are of concern to adjacent property owners (See comment 15). We have considered additional mitigation to alternative D (see comment 4-1) which further reduces encroachment. 2-3 Comments acknowledged. Response to comments in letter from Rainier Audubon Society (3): 3-1 Comments acknowledged. 3-2 Page ii of the draft environmental impact statement (DEIS) notes that the 404 permit will be required. The SEPA process is separate from the federal 404 permit process and does not have to provide detailed information for 404 compliance. This process will occur prior to project construction. 3-3 Page 1 of the DEIS provides the purpose of the action. Page 51 describes the potential secondary impacts from road operation to plants and animals. Pages 86-91 discuss the transportation impacts. Minkler Boulevard was considered in place for the transportation analysis (page 86). The Minkier project has recently gone through SEPA review (August 1986), and was therefore not considered an alternative for this DEIS. 3-4 The City feels that a detailed mitigation plan was not necessary at this point in the environmental process. Mitigation detail is not a requirement of the SEPA process; we believe enough information has been presented to allow a decision to be made. The City has made a firm committment to provide replacement habitat as mitigation. A mitigation plan would have to be developed prior to road construction. The costs of mitigation would be included as part of the road construction costs. Response to comments in letter from King County Parks, Planning, and Resources Department (4): 4-1 Please see response to comment 2-2. As noted under earth mitigation on pages 30-33 of the DEIS, we have considered additional mitigation to alternative D which further reduces encroachment on the wildlife habitat. This mitigation includes replacing a fill slope with a retaining wall, and eliminating the north sidewalk. We have also taken you suggestion and reduced the number of lanes from four to three. The net effect this has on the degree of wildlife habitat encroachment is shown in Figure 1. This results in a reduction of habitat 'loss from 1.8 acres to acres. These changes have not altered the impacts of alternative D to other property owners (see comment 15). 4-2 Clarification of the intent of the statement of 54 is needed. The phrase of "not a mandated requirement" was meant to apply to the timing of the mitigation. A committment to mitigation has been made. Please see response to comment 3-4 in reference to the 404 permit. 4-3 The wetland edge determination has been cross-checked with methodology detailed in the report you have cited and the designated wetland habitat shown in Figure 18 is accurate as shown (Van Wormer, Personal Communication, 1987). All lands in Figure 18 not designated wetlands were confirmed using the new criteria. 4-4 The riparian border, as noted in Figure 18, is not all wetland. Please see response to comment 4-3. 4-5 Page 30 of the DEIS accurately states the loss of pond area (in square feet) which correspond to your statement of 0.5 and 0.25 lost acres, for alternatives A,B,C and 0, respectively. This is not to be confused with wetland habitat loss (stated on page 49 and 50). Response to comments in letter from Frank Jovanovich (5): 5-1 Comment acknowledged. 5-2 Please see response to comment 2-2. 5-3 Comment acknowledged. Response to comments in letter from Seattle Audubon Society (6): 6-1 Please see response to comments 2-2 and 4-1. 6-2 Please see response to comments 3-4. 6-3 All of the habitat components are capable of being duplicated. For example, the. "snag swamp" can be created by regulating wetland water levels, allowing the willows to grow and subsequently inundating them to create "snags". 6-4 We are confident that appropriate wetland shrubs and trees can be established on the 2:1 slope. Experience has s h own that this vegetation can be established on a 1:1 slope. 6-5 Please see response to comment 3-4. We believe that direct habitat loss can be mitigated through off-site replacement. However, secondary impacts, as identified on page 51-53, also need mitigation to minimize impacts. As noted on page 54, some impacts to wildlife and its habitat would be unaviodable. 6-6 The roadway landscape and habitat mitigation analyses were prepared separately and admittedly are not clear in the DEIS. The intent o+ the analysis is to have pond wildlife mitigation take priority over the aesthetic views. Therefore, project mitigation would be as shown in DEIS Figures 19 and 29 (pages 55� and 97,respectively), not as stated on page 95. 6-7 Please see reponse to comments 3-4, 4-2, and 4-2. 6-8 Existing conditions have identified biological components and their values (pages 40-49). The impact discussion (pages 49- 55) identifies the relationship of these components and how they relate to both the south shoreline of the pond and. the pond as a whole. 6-9 The statements you cite are correct as stated. The Army Corps of Engineers states that the pond is now under 404 permit jursidiction. This determination has historically been in a state of uncertainty as noted in the other Corps correspondence in Appendix A. The City. acknowledges King County's efforts to provide further clarification to the Corps position (See letter in Appendix A from King County to the Corps dated February 2, 1987). We disagree with your statement that no jurisdiction other than Tukwila can designate the pond as significant habitat. We understand that this can still happen under the 404 processby federal agencies, the State (if it chooses to designate it under Shorelines jursidiction, or the City (by Council Resolution). 6-10 Page 68 of the DEIS cites Resolutions 736 and 656 as not applicable to this project. This has been re-confirmed by City counsel in August, 1987. 6-11 Please see response to comments 4-3 and 4-4. 6-12 The "snag swamp" is referred to as a "flooded brush area an page 47 of the DEIS. Use of this habitat is not likely because it is too low and exposed; review of birders lists has not revealed any sitings. The cormorants are listed in Appendix B, Table 2. 6-13 The transistional zone refers to the area of habitat change from wetlands to uplands and is represented on Figure 18 as the wetland boundary line. 6-14 The fish have been identified as prey for other species; we believe documentation of their presence is the important point. Identification of individual species is not as critical since the Washington Department of Wildlife has not designated any sensitive or endangered species in the project area. 6-15 Comment acknowledged; a corrected Table 5 for appendix B is provided below. 6-16 It is our understanding that the Chartwell work documented the snag area as a willow stand in 1979. Since that time, the pond level has risen and the willows were killed; a snag area resulted. 6-17 Comment acknowledged; the yellow-green swallow should be termed a VioleL-green swallow. 6-18 Our field investigations during three site visits in 1985 through 1987 reveals the presence of two prominant drainage ditches entering Tukwila Pond. They are on the northeast and southwest sides of the pond and have both have been observed containing runoff into the pond. The diversion to the P-17 channel was plugged during these observations. 6-19 - Drainage plans indicate the storm drain in _ inches in diameter; this has been confirmed during a September field check. 6-20 - Drainage plans indicate the storm drain is connected to and drains --------; this has been confirmed during a September field check. 6-21 - A detailed erosion control plan will be prepared prior to construction, during the permitting stage of the project, 7-1 - Your comment is acknowledged; alternative D is provided to minimize impacts to the Tukwila Pond property; see comment 2-2. 7-2 - The reference on page 68 "City of Tukwila, 1977" should read City of Tukwila, 1982. This is the City of Tukwila Comprehensive Land Use Policy Plan. The statement is accurate as stated. 7-3 - The City's attorney was consulted for the determination on the applicability of past resolutions; this has been checked again, and the interpretation stands. 7-4 - The estimated project cost stated on page 3 assumed a cost of per acre of Tukwila Pond property; this was based on The actual costs of property for project development would be determined during right of way aquisition. The State Environmental Policy Act does not require an economic analysis. 7-5 - Wetland replacement could require from 1.8 to 2.8 acres of Tukwila Pond property (DEIS pages 49-50) , if the pond property is chosen. Wetland replacement mitigation would affect existing upland areas immediately west of the pond which would be converted to wetlands. Please also see response to comment 3-4. Parking mitigation would require from 3 to 14 car spaces (DEIS page 73) if the pond property is chosen. This would equal acres. Parking replacement mitigation would likely affect existing upland areas immediately east of Parkway Square. 7-6 - Existing conditions for the Tukwila Pond property show no development which would require access. 7-7 - Please see response to comment 3-2. 7-8 - No application has been submitted or approved by the City which calls for fill and development of the entire site (see page 61 of DEIS). 7-9 - Comment acknowledged. 8-1 - Comment acknowledged. 9-1 - Comment acknowledged. 10-1 - Comment acknowledged. 11-1 - Comment acknowledged. 12-1 - Comment acknowledged. 13-1 - Comment acknowledged. 13-2 - These options were not considered reasonable alternatives due to the probable relocation of existing buildings. Please see response to comment 2-2. 13-3 - Comment acknowledged' 14-1 - Comment acknowledged. 15-1 - Pages 72-74 of the DEIS quantify the impact to truck parking spaces for the Bon. Table 7 (page 73) should be revised from 5 to 15 for the number of spaces changed for alternative C for the Bon%; The text at the bottom of page 73 is accurate as 'stated. Figure 8 has been modified to specifically indicate which truck parking spaces are affected and directions of truck movement. 15-2 - Page 72 of the DEIS describes the impacts of project alternati,-ves to existing railroad facilities. Alternative D would require limitation ^ of rail service to the Bon by eliminating one of two spurs. Based on input from you, this would significantly limit the amount of rail freight into the Bon warehouse by precluding the parallel alignment of rail cars. 15-3 - Comment acknowledged' 15-4 - The traffic impact analysis for 1990 conditions assumed that Minkler Bvld. was in operation (page 86 of DEIS). No other analysis of Minkler Bvld. was performed to answer your questions pertaining to Minkler. Improvements are predicted in overall 1990 noon peak hour LOS and delay time for the Strander Boulevard/Southcenter Parkway intersection. Traffic conditions at the Andover Park West/Strander Boulevard intersection become worse (pages 88-89 of the DEIS). The impact analysis quantified the potential changes to intersection delay time (Table 11, page 81 of the DEIS). 15-5 - This is a City of Tukwila Council decision which will be based, in part, on the analysis presented in the environmental . impact statement. 15-6 - The two lane configuration would not be adequate considering the mix of traffic in this area zoned as Industrial Park and Planned Business Center. Please see response to comment 15-5. 15-7 - Please see response to comment 15-1. |he project engineer and traffic engineer toured the Bon facility and provided input to the preparaLioo of the DEIS, in particular on the truck parking impacts. As noted on page 74 of the DEIS, the alternatives A and B would likely cause modifications in the current operation of truck parking. For example, tractors may have to disconnect from the trailers once docked. These modifications would be based •on the need to minimize potential traffic safety concerns. 15-8 - Please see response to comment 15-5. 15-9 - Based on our understanding of the Bon's operation (see response to comment 15-7), alternatives A and 8 would not result in an extensive redesign. Alternatives C and D would necessitate changes in the warehouse operations (see DEIS pages 72-74). 15-10 - Comment acknowledged. 15-11 - Comment acknowledged. Specific plans for mitigation of potential utility interruptions will be prepared during right of way aquisition and project design. 15-12 - Comment acknowledged. Specific plans for monitoring of settlement will be prepared and implemented prior to construction. 15-13 - Please see response to comment 3-2. The comprehensive plan and its applicability is discussed in pages 65-68. Secondary impacts to existing Tukwila Pond plants and animals, resulting from the increased potential for property development, is discussed at the bottom of page 51. 15-14 - Please see response to comment 7-4. 15-15 - The need for the project is stated on pages 1-3 of the DEIS. 16-1 Please see response to comment 15-4. 16-2 Please see response to comment 15-5.. 16-3 Please see response to comment 15-6. 16-4 Please see response to comment 15-9. 16-5 Please see response to comment 15-7. 16-8 Please see response to comment 15-1. Discuss with Jim. 16-7 Please see response to comment 15-7 and 16-6. 17-1 Please see response to comment 15-12. 17-2 - Comment acknowledged. 18-1 - Comment acknowledged. 19-1 - Comment acknowledged. 20-1 - Comment acknowledged. 21-1 - Comment acknowledged. 21-2 - Please see page 67 for a discussion of the City's Comprehensive Land Use Policy as it pertains to Tukwila Pond. Page 68 states that the pond is not designated a shoreline under any Shoreline Master Program. Page 62 describes the zoning designation as CP - Planned Business Center. The traffic analysis (page 91) assumed that the Tukwila Pond property was developed in accordance with the zoning code and the Tukwila Transportation Improvement Plan (1979). 21-3 - Comment acknowledged. Please see response to comment 3-4. 21-4 - Traffic projections (page 68 of the DEIS) consider traffic volumes for major arterials. 21-5 - Comment acknowledged. However other project needs stated on page 9 of the DEIS would not be met by these options. 22-1 - Comment acknowledged. This issue will be addressed in project design. 22-2 - Cross walks are proposed at the T intersection you mention. 23-1 - Comment acknowledged' 23-2 - Comment acknowledged. 23-3 - Comment acknowledged. 24-1 - Comment acknowledged. 24-2 - Comment acknowledged. Please see response to comment 3-4. 24-3 - This will be considered in development of the temporary erosion and sedimentation control plan mentioned on page 40 pf the DEIS. 24-4 - Discharge points are identified in text and in Figure 17 (pages 38-39) of the DEIS. Please also see response to comments 6-18, 6-19, and 6-20. 24-5 - This will be considered in development of the temporary erosion and sedimentation control plan mentioned on page 40 of the DEIS as well as the drainage design for the project. 24-6 - Comment acknowledged. Please see response to comment 3-4. 25-1 - Comment acknowledged. 26-1 - Comment acknowiedged. 27-1 - Comment acknowledged. 28-1 - Comment acknowledged. 28-2 - Existing traffic conditions are shown in Figure 21 of the DEIS. The analysis of the need for traffic signals (pages 90 and 91 of the DEIS) confirm the need for traffic signals at each end of the proposed roadway as you mention. This analysis assumed that the Tukwila Pond property was developed in accordance with the zoning code and the Tukwila Transportation Improvement Plan (1979). 28-3 - Comments acknowledged' As noted on page B-1 of the DEIS, biological observations were made during field visits from November 1985 to June 1986. These were extended from winter through early summer to identify seasonal use and use by migratory species. 28-4 - Comments acknowledged' 29-1 - Comments acknowledged. 29-2 - Comments acknowledged. Please see response to comment 28- 2. 29-3 - Comment acknowledged. 29-4 - Comments acknowledged. Please see response to comment 28- 2. 29-5 - Comment acknowledged. 29-6 - Comments acknowledged. Please see responses to comments 6-2, 6-3, 6-4` 6-5, and 6-6. 29-7 - Comment acknowledged. Please see response to comment 28- 29-8 - Comments acknowledged. Please see response to comment 29- 6. 29-9 THROUGH END - ASKING FOR MORE DIRECTION FROM REX 5 com me/( 1131FLIMM [JU! ')O 1987 CITY OF TUKWiLA 1 PLANNING DEpT. lax Reform '86 /v. 35P) Pad, tAhl 9Ro3 CEIVED JUL 1 7 1987 DAN hi) Ulm /0,(40eAt p,.tiszti Ao a e.4yr. VA/ tyvi (A/vrtzr44- Paz, h& AIN 4,4,w-de() f"wv- AIL A, A-via or- 7:Lxr/et&A, toa.7 (r) 1201(-4 lore /t c-IA-d/or ati e",,,,m4e4" "paitita grAAL €-. -t 044 A4;111COALtd, /11 (dfi/ AU:(LQ Mdt.a1^-) /4 L4t4 . AkAArtitlul 4eo u eL110-4-ds- a, Ai-441410-c 911,64414- rA. 6onAin. . 4-14c-eAder AttlAuudv-,6, - - ' 4007-N.E. 105th , M r &lc Seattle WA 98125 C11 I/. 4-1 - - 1 176 11-1 , IR I I? 11 \\,11{- 1 ill --7, 1 ii 1 Lb ',9 iS,LI VI ,S1 ,D ti 1 i AU G 14 1987 I 1 CITY OF 'TUKWILA 1, PLANNING rip-r. 1 rze &, s...4 -It 4..... • u.....4 -... „c2 _._.,i- Tu_k . ,, I I.- pe,4 , 7-4/, ,...... Iliteaor 0 '--,.- a C J ih.. ,.,.j - S .4V. 4p, .-i` r-.4.40 rei /.i.-4-e-0-484- ( . ,,..._. V.-II/el . a" •11- I 1* 4 A IN rerc.-4- g.n o ;P. n ...‘ ....41... i -rn-en. eye -. n--...1< 4. e ......, r.r.r . < .1 —1-4.. ot,67 soi,,,,„• 0, ,....;ii c.-er..„ i—j+et— f-,,O4.4.4, i-. -7-c.dc......, 4._ e 0 e a .1- c-r e.ek, I-. p 4.,- ii'S 4.., 1. c /Dv, • 'Mr., V, t11 U i'Vl •er...0 Ul. ,I_ 1 '-------) UT. el) ) ) • - ' ) t,) 6 / .1, i LAA-4./Li,b a- • el 1 (1 ki\J vu.S(fi —re c_r.) 1 t ix° J C& c.v.— C_QS Fk c-i‘C j LIl : ick —r-> ,..■---\, -C Q-4-- i e-) /d II \vszkv-v May) • I a —1?-6 • i • J 0_ ,c2),,,a_ v„„ 11,-6 A,Ad c_L L3 r PaSecl. , c v, e e I:C. 80cI r rsh 8 Blaine Seattle, WA 98112 16 i , Vex- hot, H. ci_ ton. . 0-• C c_ i- ■ . Liu i Sincla i eLeyvis IJSA 441 iT• o AAA RECEIVED JUL 1 51981 FUNFLAG WINDSOCKS: RAINY DAY INC. P.O. Box 31662, Seattle, Washington 98103 (206) 525 -0785 July 13, 1987 Mr. Vernon M. Umetsu, Associate Planner Dept. of Planning City of Tukwila 6200 SouthCenter Blvd. 6200 Southcenter Blvd. Tukwila, Wash. 98188 Dear Mr. Umetsu; RECEIVED CITY OF IUKWILA JUL 2'' 1987 save DE We are writing in regard to the Tukwila Pond. We believe that it would be short sighted to plan to allow commercial development of this most unique and scarce type of area. This area with the pond and wild life refuge should be zoned PARKS AND OPEN SPACE. As a customer of a silk screen printing firm located on Andover Park East we are frequent business visitors to the area. It is refreshing to be able to enjoy if only briefly the sight of birds and a bit of water in an area so highly developed as the Southcenter area is. As shopping "visitors to the area we find the Southcenter Parkway area of shops overwhelming and not inviting. The traffic along Southcenter Parkway is very heavy and the speed limit too fast. We don*t think the pond area needs to be developed and filled for more shops and parking lots. Seattle and the surrounding areas including Tukwila still have some natural beauty left that can be retained for the future such as the Pond Area. In the long run it will attract more people and business to the area by leaving it intact and developing a small park for all to enjoy. As concerned members of the Audubon Society and as a company that deals in wildlife images on our product we urge your planning dept. to REZONE TUKWILA POND as PARKS AND OPEN SPACE. The long term benefit will be in Tukwila *s favor. Very truly yours, y Day Inc. /FUN FLAG WIN Susan G. Welch and Mary M Ho ath JUL 23 1987 v� CITY O- TUKdJlLA PLANNING DEPT. s Kathryn Cook 7751 17th Ave NE Seattle, WA 98115 July 21st, 1987 Dear Mr. Umetsu, I would just like to express my opinions concerning the development of Tukwila Pond. There are some plans to fill in the pond to create a new shopping mall and to construct a multi -lane roadway. I am not against new developments, however when those developments might destroy one last refuge for wildlife in an area, I feel there should be extra consideration given. The Tukwila Pond is a valuable stopover area for migratory birds and as a wintering and breeding area for other birds. The south end is quite developed now, and that these birds are able to integrate so well with the existing buildings and traffic flow is quite amazing. There are not many spots available for these birds in the Green River Valley. Many of the people that work in the area, enjoy driving by and watching the birds. My husband says that a lot of the workers like to eat lunch by the pond. It is not just a place for "birdwatchers ", but for all sorts of people to enjoy. It is a respite from the complexes and office buildings and warehouses that dominate the area. I do not feel that the DEIS has adequately covered all of the options for the pond. ,There is no alternative roadway presented which would minimize impact to the southern wetland of the Tukwila Pond. I would really like to see a little more thought and care given to the fate of this tiny pond. Surely there are other areas that could be developed. Such a place deserves to be protected and possibly made into a community park for everyone to enjoy. I myself might travel down to the shopping centers in south Seattle, if I knew there was a nice park to have lunch at nearby. Personally, I think the zoning laws should be changed to offer long -term protection of this pond, from commercial to parks and open space. I thank -you for listening and hope you will consider Tukwila Pond as more than just another parcel of land. It has very special qualities that are hard to find in a city our size. Someday, you may be glad you made a special effort to control the development of it. Sincerely, Kathryn C k • Vir Pte. ,av■}R c mt.Q,tt.A., v Pa n-a �O ,t (11 44 IT Lite- o a atetra . /� wadte.v ,14e42444, xl,twee l0 N. 3e wit/ 762103 dkji I11,irg7 RECEIv:1 JUL 1 7198t ap 6,L. co - /6g-'1,43t h2.4 0 a44 ti a4g4T )E /S v s 2itok irti;e79410/640t44-deA. 44,e;ri ate,,, cc: Ti2:::11448. .11zrvifkafAi et. C4744,4.41 Plimi-Gtta/ ---TEEREF-1 JUL 28 1987 CITY O- TUKWILA PLANNING DEPT._ July 15, 1987 SHARON L. GIVAN, M.Eo. 4220 N.E. 65TH SEATTLE, WA 98115 TELEPHONE (206) 524 -5364 Mr. Vernon M. Umetsu, Associate Planner Department of Planning City of Tukwila 6200 Southcenter Boulevard Tukwila, WA 98188 Dear Mr. Umetsu: • RECEIVED JUL 1 7 1987 I am writing out of concern for the preservation of the Tukwila Pond and wetlands. It is my understanding that the pond is in jeopardy by the proposed "development" by the Cafora Company and by. the City of Tukwila Department of Public Works which wishes to construct a multi -lane roadway across the southern wetland of the pond. In my opinion, this would be a grave mistake. This fragile habitat is an important wintering and nesting site for migratory waterfowl in the Green River Valley. Habitats of this type are few and far between and are becoming increasingly rare. Once these environments are destroyed, they don't come back, and we are all diminished by the impact. I urge you, the mayor, and the city council to protect this vital wildlife area by changing the zoning from commercial to parks and open space. Sincerely, Sharon L. Givan, M.Ed. cc: Mr. Gary L. Van Dusen, Mayor Dear %%1 . Vic h to RECEIVED JUL 2 0 1987 As a resident of King County for the past 18 years and a member of the Seattle Audubon Society I am writing to express concern over the fate of the Tukwila Pond. I lived in Kent from 1973 to 1982 and witnessed the filling of the Green River floodplain with shopping malls, office buildings, and warehouses. I realize there are major traffic problems because of commercial and residential development and I understand that more roadways may be needed. But I feel that the Draft Environmental Impact Statement for the proposed construction of So. 168th St. does not adequately minimize the impact to the Tukwila Pond and the surrounding wetlands. Therefore, I support Alternative E. As a "birder" I have visited the Tukwila Pond and enjoyed watching the ducks feed there. Because it is one of the only aesthetically pleasing places in Tukwila I think it would be to the benefit of the city's reputation to protect and promote the Pond. Changing the zoning from commercial to parks and open spaces would offer protection to the area. I hope this issue can be resolved to the benefit of wildlife, people, and the City of Tukwila. Thank you for your attention. Sincerely, E Fo JUL 28 19871 CITY OFTUKVViLA PLANNING DEPT,_ 7 7701 Jones Ave. N.W. Seattle, WA. 98117 Dear Ay-, L vyt PAC C IEM - L © Jl1L 20 1987 CITY C3F TUK'MLA P pNNIN r PT. As a resident of King Count • / ye • nd a member of the Seattle Audubon Society I am writing to express concern over the fate of the Tukwila Pond. I lived in Kent from 1973 to 1982 and witnessed the filling of the Green River floodplain with shopping malls, office buildings, and warehouses. I realize there are major traffic problems because of commercial and residential development and I understand that more roadways may be needed. But I feel that the Draft Environmental Impact Statement for the proposed construction of So. 168th St. does not adequately minimize the impact to the Tukwila Pond and the surrounding wetlands. Therefore, I support Alternative E. As a "birder" I have visited the Tukwila Pond and enjoyed watching the ducks feed there. Because it is one of the only aesthetically pleasing places in Tukwila I think it would be to the benefit of the city's reputation to protect and promote the Pond. Changing the zoning from commercial to parks and open spaces would offer protection to the area. I hope this issue can be resolved to the benefit of wildlife, people, and the City of Tukwila. Thank you for your attention. Sincerely, • /'v- 7701 Jones Ave. N.W. Seattle, WA. 98117 SHARON L. GIVAN, M.ED. 4220 N.E. 65TH SEATTLE, WA 98115 TELEPHONE (206) 524 -5364 July 15, 1987 Mr. Vernon M. Umetsu, Associate Planner Department of Planning City of Tukwila 6200 Southcenter Boulevard Tukwila, WA 98188 Dear Mr. Umetsu: LIB rifi UL 17 1987 C(TY OF :ruJKw(LI\ PLANNING DEPT. I am writing out of concern for the preservation of the Tukwila Pond and wetlands. It is my understanding that the pond is in jeopardy by the proposed "development" by the Cafora Company and by the City of Tukwila Department of Public Works which wishes to construct a multi -lane roadway across the wouthern wetland of the pond. In my opinion, this would be a grave mistake. This fragile habitat is an important wintering and nesting site for migratory waterfowl in the Green River Valley. Habitats of this type are few and far between and are becoming increasingly rare. Once these environments are destroyed, they don't come back, and we are all diminished by the impact. I urge you, the mayor, and the city council to protect this vital wildlife area by changing the zoning from commercial to parks and open space. Sincerely, Sharon L. Givan, M.Ed. cc: Mr. Gary L. Van Dusen, Mayor LA.44A/ FUNFLAG WINDSOCKS: RAINY DAY INC. P.O. Box 31662, Seattle, Washington 98103 (206) 525 -0785 July 13, 1987 Mr. Vernon M. Umetsu, Associate Planner Dept. of Planning City of Tukwila 6200 SouthCenter Blvd. 6200 Southcenter Blvd. Tukwila, Wash. 98188 Dear Mr. Umetsu; Eti87 1 i CITY OF TrUKV ..j1 PLANTING DEPT. We are writing in regard to the Tukwila Pond. We believe that it would be short sighted to plan to allow commercial development of • this most unique and scarce type of area. This area with the pond and wild life refuge should be zoned PARKS AND OPEN SPACE. As a customer of a silk screen printing firm located on Andover Park East we are frequent business visitors to the area. It is refreshing to be able to enjoy if only briefly the sight of birds and a bit of water in an area so highly developed as the Southcenter area is. As shopping visitors to the area we find the Southcenter Parkway area of shops overwhelming and not inviting. The traffic along Southcenter Parkway is very heavy and the speed limit too fast. We don *t think the pond area needs to be developed and filled for more shops and parking lots. Seattle and the surrounding areas including Tukwila still have some natural beauty left that can be retained for the future such as the Pond Area. In the long run it will attract more people and business to the area by leaving it intact and developing a small park for all to enjoy. As concerned members of the Audubon Society and as a company that deals in wildlife images on our product we urge your planning dept. to REZONE TUKWILA POND as PARKS AND OPEN SPACE. The long term benefit.will be in Tukwila *s favor. Very truly yours, n Day Inc. /FUN FLAG WINDSAS Susan G. Welch and Mary M Ho ath T)v) . ThL1d atk, a~cipte, PI aotAttiv & 0 0 4tL iLr. JAA)-(Aritti, 9g1g1 I JUL 1 5 1987 CTFT1Y TU LA PLANNiNG DEPT. 38(m/El. t 9r/o3 iq g? PAA, , 14."4.1treLA4.,: opt 0 to* rt.a d4a Att 414 TAG ortir,un aegv%.61,41.es,t Dlr 402(4,4.6k, i°11s-et io A Afrpted /611;1C1 ta A/1-Cite/t ei/sk.42 ctweiLi, 2 any 4 te Lr t 7O Ott2e,) Li InttliZrt4e, I7 A;‘) nticedit Ir• et/y., '41-4244411A1L frAli4446 •(-2"vt^‹-t-- /niZA.ga a/test AnGrAt .2-vault& fola -14,44t/t) 0. itt474r3€4 com4r44,‘,,tie MI 0.a 44cP4147 I" ap.aitattlt4t Zta PE/S 4; •tivvt Mev A■tO Pit g41.,Ya 41t1;01 a4n./ 1,frirtti fl‘ CL 41,061) 7 At, n1 tt(Z;s9J Ci Olt4e A14111A4,c,0 /1 A141740 CAIU jit4741k 1014 niq V120/ edqt44.CO • CC: 1711)21f, .1114v #454414&) e#1444.ta PlwAktta. AuutA,,g. V-aw6,,/ Mir. Umetsu, LAYREVIE0 JU! 1.5.19871 PLANNING DEPT. I wish to express my concern about the proposed development of Tukwila Pond. This is a small but valuable habitat that may better serve the public as a park than as another shopping center./ I believe the DEIS does not adequately address the idea of minimum damage from the proposed road alignment. Please consider Alter- native E. As the population of our area expands, there will be a demand for more open spaces. A change in the zoning of this area would help preserve something of value that is not available in many urban areas. It would also be something that could be used for environmental education in the schools. Thank you for your consideration of this matter. Sincerely, w-/9. Walter A.Kuciej 4301 34th W. #3 Seattle Wa. 98199 The Mountain is out On crisp, clear winter days in South King County, It's hard not to be awed by Mount Rainier. For many residents the Mountain is only visible from long stretches of Interstate 5 or from the Valley floor. Others, like those On the Enun Rainier. The Mountain, here, 196th Avenue Southeast, nton contemplates halt to cruiser rnerry- tyc By TONY DAVIS Staff Reporter Plans to crack down on cruisers in Renton.nioved a step further Wed- nesday,; despite possible opposition from the American Civil Liberties Union aid warnings from some kids that it won't do any good. With about 30 youths in the audi- ence, the City Council's Public Safe- constitutional problems. The com- mittee held off requesting an ordi- nance until the staff could take time to research the issue further. The anti - cruising ordinance would limit the number of times cruisers could go around spots that police label heavy traffic areas. The night -club ordinance would, among other things, require club owners to require patrons to pay the full admission charge when they re- enter the club and force owners to clean up litter and have security officers on the property. City officials have said similar anti- cruising ordinances in Califor- nia, Oregon and Texas have with- stood court challenges. But the pro- posal seems likely to raise the eyebrows of the ACLU. "To the extent that they are trying to control noise, fighting or tral that's OK," said Howard Stamb( Seattle lawyer who works a cooperative attorney for the AC "But if they are trying to inter' with kids' constitutionally prote. right of association, I won't go s( as to say it is unconstitutional, bt implications ape troubling." In a telephone interview be Wednesday's committee meet members to draw up ordinances limiting cruising and regulating night clubs. Robert Hughes, com- mittee chairman, predicted the council will consider the ordinances in a month. A separate proposal to put a curfew on youths seems in trouble. City Attorney Larry Warren told the committee the idea had possible corps could, dampen wetlands projects t ?' By TONY DAVIS Staff Reporter `. The •; U.S. Army Corps of En- gineers; no friend of environmental- ists, may become their unwitting ally in • controversies involving a Renton blue heron rookery and the Tukwila Pond., New federal. regulations have gi- ven the corps power over the filling of all wetlands that attract migrat- ory birds. Immediately, the new regulations could delay for six months to a year developments that would destroy the pond and fill land near the heron rookery. For the longer term, they will • make it more difficult to build projects in virtually any wetlands, in King County or anywhere else. The county has close to 900 wet- lands. Environmentalists' concern about their rapid disappearance have made many of them battleg- rounds in prime development areas. "It will require a major reassess- ment of what can and can't be done in the Valley," said Larry Warren, Renton's city attorney. "It could be a big problem," said Barbara Moss, director of planning for Seattle -based First City Equities, which is building a 36- building office park near the heron rookery in northwest Renton. "It's just another layer of the permitting process, making development more difficult." "I suppose if I Were a developer, knowing how developers work, I'd be screaming to high heaven," said a spokesman for Sen. John Chafee, R- R.I., a strong advocate of wetlands protection who helped push the corps into taking action on the issue. The corps has told First City that it will need the agency's approval to fill wetlands at its office park. It has given similar warnings to five smal- ler projects in King County. And it expects to decide by the end of next week whether to intervene in the pond issue, said Sam Casne, chief of the corps' environmental section in Seattle. Exactly how the new rules will affect development is unclear. Corps officials say their goal will not be to stop projects, but to make sure they don't damage wetlands. Casne said, however, that the new rules are very restrictive, and could stop some projects. Other projects will have to take steps to ease their effect on wetlands, or buy wetlands elsewhere to compensate for their loss. David Ortman, Northwest repre- sentative of Friends of the Earth, said the new rules will be helpful. See WETLANDS, page A3 Inside Weather Mostly fair today with some cloudiness. Highs near 50. W variable 5 to 10 mph. lncrea cloudiness tonight and Friday, rain likely by late Friday. Lows the low and mid -30s. Highs nea Chance of rain 10 percent tor and 50 percent Friday. Det page B6. Business Boeing Commercial Airplane predicts worldwide sales tot: $222 billion for delivery from ., 4.;1i s1 ' 'th1 . eac i gam. ,; sent • a.certift.: -.life ' i n Play , • wetlands- • .. a T= {! r∎401. a Continued from page Al But he is not overly excited about the corps' action 'because of • the agency's past: record. He said the environmental group found in a study that in 10 years ending in 1984, the corps' Seattle office had denied only five of hundreds of permit applications. Back East, federal intervention in wetlands issues has killed two wide- t ly publicized projects: a shopping center in Attleborough, Mass.; and t the legendary Westway road .project .. `s along the west side' of Manhattan ow Island. Both projects died when f other branches of the federal gov- ernment — the U.S. Environmental. sa Protection Agency." and the court . re system' —. overturned corps deci- • we sions.to grant permits. . "We have found the co loo paper tiger in wetlands protection," co Ortman said. Casne replied. that even though b0-a the agency issues permits, develo boo ers often have to back away from egpe wetlands or kill their projects be- also cause the rules are strict enough. buil "The process works. The permits proj are issued, and the wetlands stay," he said. Under the new rules, the SCS than 10 acres._ ' Projects ect) the Tukwila Pond and Black River from projects are — usually have to apply corps for sweeping permits called 404 the w permits. Casne said he did not know Warr if the pond and office park projects - The will need 404 permits. But if they do, in the they have noealternative lv to filling in issue the wetlard#a °• m F -;r ,.,� Renton City Attorney _ who has dealt with ntnierou wetlands issues, pronounce Tukwila Pond'proJect "in deep ble." Casne indicated that i agency finds the pond has wet values, it wont be easy fo company to fill all of it. it pro would have to leave at least so he pond alone, he said. "You have to convince us here are no available�uplands f hopping center, whether or not wn them," he said.. "It's very ∎cult .:.. but it has-been done:" An imaginative developer, id, will realize he can get hig nts if he builds an office ar tlands than if he builds one ov king a parking. lot. Warren said the new rules a uld affect thecity's. plans to se acre wetlands -in the heart of t ming' Valley floor, and use t ney. to- buy more wetlands in I nsive parts of town. The rul could affect the city's plans d the P -1 channel- flood cont ect, he said. We may be in a situation' whe` CS (Soil Conservation Service h is helping. build the P -1 pro requires us to pump • Ovate wetlands into the P -1; and the requires us to keep water in etlands; .to keep it wet, ". said n. regulations are another` step gradual_ governmental tight= of wetlands protection, an virtually, unknown a decade ate. e. sc ned,. alt an.: alumnIt : rs . ctIve:. ,. Fiat*: Davis,,, 1970 grad Warren ago. • Until-now,. the corps'_power over wetlands stopped at those lying 9`other • next to major rivers or tributaries. trt a �, The corps. was prodded into issu- fthe .ing the rules -. by the•.U.S: Senate. lands Environment and Public Works Committee; and by a' new interprete- r the tion of federal` law by - the U.S. bably Environmental Protection Agency. me of' Under that interpretation, the corps' that jurisdiction covers all wetlands that are homes for migratory birds. or a In effect, that means all wetlands,. you said Casne. "The 404 permit is controversial,' -and,' the basic, reason . that it is he controversial is -that nobody thinks her' , 'wetlands are important," said Cleve ound Corlett, a press. secretary for Sen. er Chafee: "People say oh, well, it's. three acres, people are dumping a. Iso: refrigerator in it and:,what differ= II a - ence does it:make ?' he- "I say wetlands are critical breed - he... ing - grounds, . for Migratory water - ess fowl and other•wildlife, fish; and in • es some cases in the South' for hard - to wood and flora." rol Yet, humanity, not nature, created the Tukwila .Pond and the heron re • rookery The pond formed because , of a complicated series of mishaps designing a storm•drainage system r in the Southcenter area: • The heron rookery lies on land that once was a golf course, and that First City Equities gave to Renton when it got zoning approval for the • office park. It was born when the. - federal government . built a pond there for the P -1' flood control Cruising . Continued from page Al else. "If you just watch a car go ro round, they're not doing thing legitimate," he said: just go round and round. It's t right, and if it's only a dozen ca so, it's no problem. But when they bumper to bumper, no- one fro side street can get through. there's a police emergency or a.fi you can't get through." At Wednesday's meeting, a gro of teens and young. adults told committee they thought the pro al was unfair to them and probab wouldn't do any good. "I wonder what us. kids are gone do if we can't cruise around th Loop," said Denise Haldeman, a Bellevue resident who attends H zen High School. "We're not at the age where w like to roller skate, you know, another teen said. Afterward, Haldeman said, "If you want to cruise, you'll. drive somewhere else. I see there is a problem, but not much of a solution for if On the curfew issue, Warren the committee an ordinance w ound be premature, until staff does any studies of precisely what social They it is designed to cure. He sugges heir . the council target the ordinanc car or specific age groups, times of 're days of week and in places wh m .a kids cause problems. If The city's. efforts come a. re, months after controversy, includ opposition from the ACLU and ki up groups, • forced Seattle o shelve the, curfew ordinance. It had the suppo pos- of Mayor Charles Royer, and wou ly • - have banned kids under 15 from t streets from midnight to 5 a.m: a- "It may be okay to put a curfew o e say, kids 10 years old, the area blur when you get to 14,15 or 16," Warre Ha said. `Where, is the cutoff? Wh social 'issues are you trying to resol e ve? I don't know whether we could draft something legal or constitu tional." Police Chief Alan Wallis told the committee that a constitutional cur- few ordinance would help officers Nr Pro ect. • told ordinance," he said. mild Michael Farness,. administrative . more assistant to- Mayor' Barbara Shin - ills Poch, said that after newspaper ted stories appear about runaways, the • e at mayor often gets calls from people day, saying, "Here's where they are, do . ere - something. "But I certainly' understand Lar- few .ry's concerns. We've been on the ing ., forefront a lot of times with con.- - ds' stitutional issues." ' a The dance hall ordinance appears rt aimed' heavily at the Encore,, a Id • downtown night club that has been a he • sore spot for police Warren said the ordinance would interfere with kids n "looking for a fight or to use drugs." s Similar ordinances are in effect in n Redmond and Seattle, he said. He at said courts have indirectly held it constitutional, in several cases re- volving around nuisance charges. Dealing with the Encore is "an overtaxing burden," Wallis said. • "We attempted to do it with negotiations at the beginning of the hr.c;.�c.co f.••• .. • • flow: char ! Board lid 'and cou' > current;;f the to th could b with tint, Russe Butt1tgg0�n; thing't-n "Judges secutor t lease■ Leff -fo ,sat id SH ssi, Ward Our delecta breakfast, C From 6:30a. a.m. No Cou1 CONVENIE .1',I