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HomeMy WebLinkAboutSEPA EPIC-SA-3 - TRILLIUM COMMERCIAL COMPLEX - ENVIRONMENTAL IMPACT STATEMENT (EIS)TRILLIUM COVIVIERCIAL COMPLEX EIS EPIGSA -3 Frank Todd, Mayor 6230 SOUTHCENTER BLVD. TU KW! LA, WASHINGTON 98067 PLANNING DEPARTMENT Wilsey & Ham, Inc. ATTN: Ms. Llewellyn Matthews 15 South Grady Way Evergreen Building Renton, Washington 98055 Dear Ms. Matthews: 11 January 1974 The Final Environmental Impact Statement filed with this office regarding the TRILLIUM project has been reviewed. by the appropriate City officials and this letter shall constitute formal acceptance of that statement in accord- ance with the following stipulations. While the Final Statement includes considerable information regarding ambient air quality as well as a copy of the Transportation Control Plan recently promulgated by the Environmental Protection Agency, the City of Tukwila has no authority to process an application for the Parking Management permit required by the Transportation Control Plan. It is suggested that the developer or his designated representative contact the Region X office of the U.S. Environmental Protection Agency as soon as possible, as a substantial review time is also required. One insufficiency of the Final Statement is the omission of an alternative means of supplying water to the proposed development in the event the existing system fails. An alternative for consideration would be the establishment of a contractual Developer's Agreement with the City to construct, at the developer's expense, an adequate water supply line north along Southcenter Parkway connecting with the Bow Lake supply line'near the Southcenter Theatre. Other alternatives should be discussed with Mr. Steve Hall, Director of Public Works. Ms. Llewellyn Matthews Page 2 The proposed development has been determined to be a major contributing factor to future increased traffic burdens. In consideration of this determination, the possible future need for additional right -of -way and street improve - ments should be recognized in the early planning stage. Lastly, and as you are probably already aware, be advised the C -M zone in which this proposal is to be located requires review and approval of site and landscape plans by the City's Board of Architectural Review. To accomplish this, please submit the required plans to this office to have the matter placed on their agenda. Our appreciation is extended for your cooperation and excellent Impact Statement. Please direct any inquiries . to this office at 242 -2177. GC /lt_ • Sincerely, r? 0 e3/Richard B. Hansen ,'/ Acting Planning Coordinator . L' r cc: Mayor Todd Dir Pub Wks Pres, City Council Chmn, Ping Comm • Frank Todd, Mayor CITY or TUKWILA 6230 SOUTHCENTER BLVD. TUKWILA, WASHINGTON 98067 PLANNING DEPARTMENT Wilsey & Ham, Inc. ATTN: Ms. Llewellen Mathews 15 South Grady Way Evergreen Building Renton, Washington 98055 Dear Ms. Mathews: 21 December 1973 This office, on 29 October 1973, disbursed some twenty copies of the Draft Environmental Impact Statement for Trillium to concerned Federal, State and regional agencies. The forty -five day review period is complete as of this date and we have received several comments. Please find enclosed a copy of each comment. None of the comments appear to be very critical and we assume a final statement will be forthcoming very soon. Please keep in mind the recent. Transportation Control Plan promulgated . by the Environmental Protection Agency. Sincerely, y Richard B. Hansen Acting Planning Coordinator GC /lt Encl: 1. Ltr, Dept of Fisheries, dtd 13 Nov 73 2. Ltr, Corps of Engrs, dtd 28 Nov 73 3. Ltr, Dept of Game, dtd 28 Nov 73 4. Ltr, K. C. Dept of Health Dept, dtd 20 Nov 73 5. Ltr, State Pks Comm, dtd 2 Nov 73 6. Ltr, State Hwy Comm, dtd 23 Nov 73 7. Ltr, Fed Hwy Admin, dtd 28 Nov 73 8. Ltr, State Dept of Nat Res, dtd 20 Nov 73. 9. Ltr, P.S.A.P.C.A.,.dtd 17 Dec 73 10.Ltr, U.S. Env Protection Agny, dtd 14 Dec 73 cc: Mayor Todd. DANIEL J. EVANS GOVERNOR ROOM 115, GENERAL ADMINISTRATION BUILDING ® PHONE 753 -6600 OLYMPIA, WASHINGTON 98504 November 13, 1973 City of Tukwila Planning Department 6230 Southcenter Boulevard. Tukwila, Washington 98067 Attention Mr. Delbert F. Moss, Planning Coordinator Gentlemen: THOR C. TOLLEFSON DIRECTOR Your fetter of October 29, 1973 requests our review of an Environmental Impact Statement for a project entitled Trillium, a business and commercial complex to be located in Tukwila. Following are our comments: 1. On page 16, reference is made to the Tukwila Comprehensive Plan, adopted in 1962, "....which is still somewhat applicable today ". As pointed out in our reviews of other similar projects recently proposed for this area, the Environmental Impact Statements have not,indicated whether the proposed developments follow any up- dated plan or are consistent with all other plans and policies. 2. One of our major concerns in this project, as in the others, is the increased quantity of storm water runoff and degradation of water quality in the Green- Duwamish River. Incidentally, on page 1 the project site is located as 1/4 mile from the river and on page 23 as one mile away. 3. The third and fourth sentences on page 39 should read:. "Most of the chinook runs are produced from fry or fingerlings released from the Washington State Department of Fisheries' hatchery located on the Soos Creek tributary. Much natural spawning by chinook and other species of salmon also occurs." 4. In Table 10, the generic name for dace should be spelled Rhinichthys and the scientific name for starry flounders should be listed as Platichthys stellatus. I have pointed out the latter error in the other statements prepared for the City of _ Tukwila by Wilsey and Ham. We appreciate the opportunity to comment upon this project. Sincerely, Gilbert A. Holland Fisheries Research Coordinator cc: D. L. Lundblad - Dept. of Ecology E. S. Dziedzic - Dept. of Game Wilsey and Ham, Inc. - Renton , DEPARTMENT OF THE ARMY SEATTLE DISTRICT, CORPS OF ENGINEERS 1519 ALASKAN WAY SOUTH SEATTLE, WASHINGTON 98134. 28 NOV 1973 NPSEN -PL -ER Mr. Delbert F. Moss Planning Coordinator City of Tukwila 14475 -59th Avenue South Tukwila, Washington 98067. Dear Mr. Moss: We have reviewed the draft Environmental Impact Statement (EIS) on the Trillium Business and Commercial Complex proposed for develop- ment in Tukwila, Washington. We concur with your statement that "While the net affect of this particular project is small, it is part of a continuing deleterious trend in accommodation of increased storm water flows by direct discharge into the existing natural systems," (page 67, item b - Impact on Hydrology and Water Quality). In view of this expressed concern, we suggest the EIS be revised to include the following data: a. Existing Conditions, Section B.c(2) - Water Quality. Suggest paragraph 3 indicate summer month water quality analyses were made and reason month was selected. If month does not reflect period of maximum stress -on aquatic organisms, suggest that period be sampled and included in the EIS. b. Environmental Impact of the Proposed Action, Section C.1.c - Impact on Terrestrial and Aquatic Biology. EIS does not discuss impact of project on aquatic biology. In view of expressed concern for Green - Duwamish Waterway, suggest EIS discuss subject in relationship to affected water quality. Thank you for the opportunity to review this statement. Sincerely yours, A. LEE WAi:ONGT"ON • ASST. CHIEF, PLANNING BRANCH Director / Carl N. Crouse Assistant Directors / Ralph W. Larson Ronald N. Andrews Game Commission Arthur S. Coffin, Yakima, Chairman James R. Agen, LaConner Elmer G. Gerken, Quincy Claude Bekins, Seattle Glenn Galbraith, Wellpinit Frank L. Cassidy, Jr., Vancouver DE PARTMENM OP' GAME 600 North Capitol Way / Olympia, Washington 98504 November 28, 1973 Delbert F. Moss, Planning Coordinator City of Tukwila Planning Department 6230 Southcenter Blvd. Tukwila, Washington 98067 Dear Mr. Moss: Your draft environmental impact statement for Development of the Trillium, A Business and Commercial .Complex, City of Tukwila., has been reviewed by our Seattle region and Olympia staffs; comments follow. Your description of project location, developmental history and projected commercial activities constitutes an excellent representation of Proposed Action. Your portrayal of Existing Conditions was equally concise and complete except for a few inadequacies which can be corrected. In reference to Green River fishery you stated (page 39) "Although some natural spawning occurs in the river the majority of anadromous fishes are released as fry and fingerlings from the Washington State Department of Fisheries Hatchery ". The phrase "some natural spawning" should be :corrected to read 'substantial natural spawning ", as a very significant natural spawning escapement has been recorded for the Green River to date. Your explanation of potential project impact on water quality was accurate but it did not contain an account of project impact on the Green River fishery. You have outlined several serious pollution factors, in your discussion of hydrology and water quality, such as a potential increase in natural runoff containing hydrocarbons, oils, and particulates to the Green: River and a possible increase in river temperature. It should be stressed that each of these impacts will have a concomitant adverse effect on the Green River fishery. Moreover, the cumulative deleterious effect which this, along with other projects, will have on the fishery should be emphasized.. In the interest of protecting our valuable steelhead fishery in Green River (an average of 83,500 summer -run smolts planted 1970 -72; 113,500 winter -run smolts in 1971; an average of 14,539 steelhead taken in 1970 and 1971), we strongly urge that the water- quality criteria promulgated by the Department of Ecology be adhered to. The interrelationships of temperature, dissolved oxygen, nutrients and rearing and passage of anadromous fish are far too complex to describe here, but criteria developed by the Department of Ecology were designed to protect fishery interests, among others. Delbert F. Moss -2- November 28, 1973 We feel you made a conscientious effort to evaluate existing conditions of the area for wildlife. Tables on vegetation and wildlife area complete and accurate. However, an unfortunate weakness which will affect decisions'on this proposal is that this statement was written after the site was covered with fill. A significant commitment of wildlife habitat and related public benefits was made at:that time. Therefore, one cannot argue with your statement that there: will be "... aTeplacement of.one man -made habitat with another ". But, one can argue that an analysis of the'consequences should have been made before the natural marsh was changed to a "man- made" fill. We can not agree with your conclusion (p. 79) that "At.present there are no known :techniques for retaining wildlife in an intensively developed area." The vicinity of the.proposal under consideration contains remnant wetlands that are used.by large numbers of. waterfowl. Also data from your EIS (Table 7, page 36) shows that wildlife does.occur on the site. even in its present marginal state. Wildlife can exist, therefore, if habitat is available to it. . Also your conclusions that, " A portion of a foraging habitat will be removed from.resident birds as well as migratory birds" and that ": ..existing birds will probably be displaced to more remote reaches of their habitats ", are too optomistic. Remaining habitats are at their carrying capacity anethe so called "displaced" creatures will be lost. We agree that there will be a "dimuniti.on of habitats. But. to be accurate we must all recognize that a great deal.of "Dimunition" has and is taking place in the Green River Valley. When all. this:piecemeal erosion of habitat is added up the impact on.wildlife has been substantial and .if present activity continues it will border on being catostrophic. We recognize that points we made above cannot be.directed entirely at your proposal or statement,. However,. it seems, that the cumulative, long range, irretrievable commitment of 'a broad range of natural valuesnust be recognized. This recognition, we think, should appear not only in individual impact statements, but also somewhere in the overall planning process for the future, of Green River Valley. Thank you for sending us your statement. We sincerely hope our comments will prove Of value to you. ESD:jb cc: Chitwood Agencies Sincerely, THE DEPARTMENT OOFF� GAME ec Eugene S. Dziedzi:c, Asst. Chief. 'Environmental Management Division • Seattle -King County /DEPARTMENT OF PUBLIC HEALTH Public Safety Building Seattle, Washington 98104 (206) 583 -2550 LAWRENCE BERGNER, M.D., M.P.H. Director of Public Health City of Tukwila Planning Department 6230 Southcenter Blvd. Tukwila, Washington 98067 November 20, 1973. Attention: Steve Hall, Acting Planning Coordinator Gentlemen: NOV 261973 CDY OF TUKWILA A.01.thig Re: Trillium Impact Statement Members of my staff have reviewed the draft of the environmental impact statement for the development of "Trillium ", a business and commero.ial complex, to be located in Tukwila, Washington. Field investigation revealed that storm and sanitary sewers and an approved public water supply are available to the site. The summary of proposed action as listed on page 2 of the statement is to undertake all review and permit procedures for the construction of a commerical complex. This office will work with the Tukwila Planning Department to ensure that food establishment plans, plumbing installations and other related environmental concerns meet local and state laws. On the basis of these determinations the department recommends the necessary permits be granted to allow the proposed const uction. JBC /et cc: Carl &gerser DISTRICT HEALTH CENTERS: NORTH 1600 N. E. 150th Seattle 98155 363 -4765 Ver awrence Bergner, M.D., Director of Public Health EAST SOUTHEAST 15607 Northeast Bellevue - Redmond Road Bellevue 98008 885 -1278 3001 N. E. 4th St. Renton 98055 228 -2620 SOUTHWEST 10821 8th Avenue Southwest Seattle 98146 244 -6400 GOVERNOR DANIEL J. EVANS COMMISSIONERS: JEFF D. DOMASKIN THOMAS C. GARRETT MRS. KAY GREEN RALPH E. MACKEY JAMES G. McCURDY JAMES W. WHITTAKER WILFRED R. WOODS DIRECTOR CHARLES H. ODEGAARD WASHINGTON STATE PARKS & RECREATION COMMISSION LOCATION: THURSTON AIRDUSTRIAL CENTER PHONE 753 -5755 P. O. BOX 1128 OLYMPIA, WASHINGTON 98504 City of Tukwila Planning Department 6230 Southcenter Boulevard Tukwila, Washington 98067 November 2, 1973 Attention Delbert F. Moss, Planning Coordinator Gentlemen: Draft Environmental Impact Statement Trillium, A Commercial And Business Complex The Washington State Parks and Recreation Commission has reviewed the above -noted draft environmental statement and does not wish to make any comment at this time. Thank you for the opportunity to review and comment. Sincerely, £/� David W. Heiser, Assistant Chief Research, Planning, and Acquisition DWH:1jh 3 WASHINGTON STATE • HIGHWAY COMMISSION DEPARTMENT OF HIGHWAYS Highway Administration Building Olympia. Washington 96504 (206) 753 -6005 Mr. Delbert F. Moss, Planning Coordinator City of Tukwila 14475 - 59th Avenue South Tukwila, Washington 98067 Dear Mr. Moss: Daniel J. Evans- Governor G.H. Andrews - Director November 23, 1973 Re: Trillium, Business and Commercial Complex City of Tukwila Draft Environmental Statement Reference is made to your transmittal letter dated October 30, requesting our review of the Draft Environmental Statement for the above referenced proposal. We have completed our review and find the proposal will not be in conflict with any existing or proposed facilities in thid area. Thank you for the opportunity to review this information. GHA:yw HRG A. H. Parker Chairman Bremerton Harold Walsh Everett Sincerely, G. H. ANDREWS Director of Highways By: H. R. GOFF Assistant Director for Planning, Research and State Aid Baker Ferguson Virginia K. Gunby Howard Sorensen Harold L. Boulac Walla Walla Seattle Ellensberg secretary U. S. DEPARTMENT OF TRANSPORTATION FEDERAL HIGHWAY ADMINISTRATION Room '412 Mohawk Building 222 S.W. Morrison Street Portland, Oregon 97204 November 28, 1973 Mr. Delbert F. Moss Planning Coordinator City of Tukwila 6230 Southcenter Boulevard Tukwila, Washington 98067 Dear Mr. Moss: IN REPLY REFER TO 10 -00.33 Our Washington Division and Regional office staffs have reviewed the draft environmental statement for Trillium, a business and commercial complex to be located within the corporate limits of Tukwila. Our review indicates the draft environmental statement to be adequate in our areas of concern.. Thank you for the opportunity to review your proposal'. Very truly yours M.`ELO.N REEN Deputy Regional Administrator STATE OF WASHINGTON , De ta'ctmeat a6' 11,arcetai Red-of-aced COMMISSIONER BERT COLE DON LEE FRASER SUPERVISOR November 20, 1973 OLYMPIA, WASHINGTON 98504 Delbert F. Moss, Planning Coordinator City of Tukwila 14475 59th Avenue South Tukwila, WA 98067 Dear Mr. Moss: My staff has reviewed the Draft Environmental Impact Statement for the proposed Trillium, a business and commercial complex. We have no comments to make regarding this project. Please direct all future statements to Mr. William Baxter, Environ- mental Forester for the Department of Natural Resources. We appreciate having an opportunity to review this statement. BERT L. COLE Commissioner of Public Lands BLC:wbs 0200 RIMY MUND G°OW ° oAMOOa COrtiTUDIL MV ? SERVING: KING COUNTY 410 West Harrison St. Seattle, 98119 (206) 344 -7330 KITSAP COUNTY Dial Operator for Toll Free Number Zenith 8385 Bainbridge Island, Dial 344-7330 PIERCE COUNTY 213 Hess Building Tacoma, 98402 (206) 383 -5851 SNOHOMISH COUNTY 703 Medical - Dental Bldg. Everett, 98201 (206) 259 -0288 410 West Harrison Street, Seattle, Washington 98119 (206) 344 -7330 December 17, 1973 Mr. Gary Krutchfield, Planning Technician Public Works Department City of Tukwila 6230 Southcenter Boulevard Tukwila, Washington 98067 Subject: The Trillium Commercial and Business Complex Draft Environmental Impact Statement Dear Mr. Krutchfield: As the local regulatory Agency, we have looked particularly at. the air pollution control aspects of the proposal and have consequently limited our comments to air pollution. Our air quality control jurisdiction in this area is shared with the State Department of Ecology. With regard to motor .vehicles, the State has assumed jurisdiction and, currently with the Environmental Protection Agency, has the authority. ;to limit ,and-control this source of air pollution. . Under. a parking management plan, application to the Environmental Protection Agency, Region X (1200 Sixth Avenue, Seattle, Wa 9810.1) is required for any addition of 50 or more parking spaces. Alternative transportation,methods are mentioned in the statement as possible mitigating measures for the expected increase in auto air pollutant concentrations. Traffic flow measures are also suggested which would .reduce auto congestion air pollution effects. These proposals would be of some value in improving the air quality of the region with or without the Trillium project. We are aware that air quality studies will be made in con- nection with the transportation control strategy so that this question may best be left until after the results of these studies are known. BOARD OF DIRECTORS CHAIRMAN: Gene Lobe, Commissioner Kitsap County; Patrick J. Gallagher, Commissioner Pierce County; John D. Spellman, King County Executive; VICE CHAIRMAN: Robert C. Anderson, Mayor Everett; N. Richard Forsgren, Commissioner Snohomish County; Glenn K. Jarstad, Mayor Bremerton; Gordon N. Johnston, Mayor Tacoma; Harvey S. Poll, Member at Large; Wes Uhlman, Mayor Seattle; A. R. Dammkoehler, Air Pollution Control Officer. • Gary Krutchfield December 17, 1973 Page 2 Another source of air pollution discussed in the statement, construction dust, can be controlled by following this Agency's Guidelines which are enclosed. It should be noted, particularly on page 40 of the statement, that this Agency's ambient air quality standards for suspen- ded particulate are that the concentration, averaged over any 24 -hour period, shall not exceed: 1. 60 ugm /m3 annual geometric mean, or 2. 150 ugm /m3 more than once per year. In addition, the section allowing 15% of the samples to exceed standards has been removed from Regulation I. Very truly yours, A. R. Dammkoehler Air Pollution Control Officer ARD /JKA:km Enclosure: Guidelines cc: Mr. John C. Raymond Washington State Department of Ecology Olympia, Wa 98504 Mr. James L. Agee, Region X Administrator Environmental Protection Agency 1200 - 6th Avenue Seattle, Wa 98101 Puget Sounli Air Pollution Con41)ol Agency Tacoma Branch Office The Hess Building, Room 213 901 Tacoma Ave. S. Tacoma, Washington 98402 Telephone (206) 383 -5851 ENGINEERING DIVISION Plan Review Section 410 W. Harrison Seattle, Washington 98119 Telephone (206) 344 -7334 Everett Branch Office 703 Medical Dental Building 2730 Colby Avenue Everett, Washington 98201 Telephone (206) 259-0288 GUIDELINES FOR CONTROL OF AIR POLLUTION FROM ROCK PROCESSING Air pollution from rock processing equipment and adjacent roads must be controlled so as to meet the requirements of Regulation I, includ- ing Sections 9.03, 9.04, 9.09, 9.11, 9.12 and 9.15. Pursuant to Sec- tions 9.12 and 9.15 of Regulation I the Control Officer has established the following control measures as reasonable requirements and precau- tions to prevent particulate matter from becoming airborne: ROCK PROCESSING - CONTROL MEASURES 1. Hooding of dust emission points on belts, transfer points and crushers and ducting the collected air to a baghouse or water scrubber, or 2. Application of a water or chemical mist near emission points, (a pressure above 90 pounds per square, inch and special noz- zles may be required.to produce a mist that is both effective and yet not cause plugging of screens), or 3. A combination of 1 and 2 (as shown in Figure 3), or 4. Other control measures such as enclosure which comply with Regulation I. Visible dust emissions from rock processing equipment are usually in- dicative of improper design or operation. ROADS, PILES, TRUCK LOADING, AND ROCK DRILLS - CONTROL MEASURES 1. Dust coming from in -plant roads shall be controlled by paving, or surfacing treatment which will control both air pollution and mud carry out. A wheel wash system may, be required to prevent mud carry out under some conditions. 2. Dust coming from fines piles shall be controlled by the use of a dust suppressant or by providing covering to prevent exposure to wind. 3. Dust coming from rock drills and truck loading shall be con- trolled by hooding or application of a mist. NOTTCE' OF CONSTRUCTTON REQUIRED An approved Notice of Construction is required prior to the installa- tion or alteration of rock processing and /or control equipment. The necessary Notice of Construction forms can be obtained by calling the Plan Review Section (344- 7334). 5/73 MAINTENANCE AND HOUSEKEEPING 1. The spray system shall be protected fromi.freezing during cold weather by insulation or a change in spray feed formulation. 2. Fugitive dust shall be controlled by gold house- keeping, including, but not limited to, the following: a. Sweeping and flushing of paved roads. b. Wetting or chemical coating of unpaved low traffic areas. c. Chemical coating bf exposed areas to prevent windblown dust. CONTROL METHODS Figure 1 shows the arrangement of atomizing nozzles which develop a flat mist spray pattern. The nozzles are placed on each end of a rubber shield to suppress dust emissions from the bottom of the crusher discharge. Two nozzles which form a cone shape mist spray are often used on the top of a crusher to control dust caused by crushing. Figure 2 illustrates how a flat mist spray can be applied ahead of a transfer point to eliminate dust. The mist should be applied to the rock before the dust is airborne. Figure 3 shows a combination mist and baghouse system for crushing plants. The baghouse is believed to. be 99% efficient in reducing the emissions from a rock crusher. Figure 4 shows a mist system for a rock crusher plant. The use of a wetting agent reduces the quantity of liquid required for effective control. TIO FLAT ATOMIZING-TYPE SPRAY NOZZLES. ONE EACN ENO OF RUBBER SNIELD -3- • NAND RUBBER SNIELD TOO FLAT ATOBIZING-TYPE SPRAY NOZZLES. ONE EACH •- • - - -•- ENO OF RUBIEN SNIELD CONVEYOR BELT BELT CONVEYOR ROLLERS Figure 1. Nozzle arrangement for control of dust emissions upon discharge of crusher.* *Air Pollution Engineering Manual. AP40, f —Mist Nozzle .1�II •1111 .1111 BELT CONVEYOR PP. VIDE -ANGLE CONE -TYPE SPRAY NOZZLE 341 Figure 2. Nozzle arrangement for control of dust emissions from the inlet to the shaker screens. TRUCK DUMP AND FEEDER, • BAGHOUSE • INDICATES MIST APPLICATION PRIMARY CRUSHER SECONDARY CRUSHER SCREEN SCREEN BIN AND TRUCK LOADING STATION •S • STORAGE PILE TERTIARY CRUSHER TYPICAL COMBINATION MIST & BAGHOUSE SYSTEM FOR CRUSHING PLANTS Figure 3 TRUCK DUMP PI (MARY CRUSHER SURGE PIL ROCK CRUSHING PLANT MIST DUST CONTROL SYSTEM SECONDARY .CRUSHER • "IAll ri TERTIARY CRUSHER INCOMING WATER LINE 1 PROPORTIONER Figure 4 WETTING AGENT DRUM \N4 STgTS 2�Ayr c w rn O O 3cl‘ +lgC PROSE° • U.S. ENVIRONMENTAL PROTECTION AGENCY REGION X 1200 SIXTH AVENUE SEATTLE, WASHINGTON 98101 December 14, 1973 REPLY ATTN OFO:: 10MEI - M/S 325 Mr. Delbert F. Moss. Planning Coordinator City of Tukwila ,14475 59th Avenue South. Tukwila', Washington 98067 Dear Mr. Moss: We have reviewed the draft environmental impact statement for the Trillium Business Complex, Tukwila, Washington. The impact of additional vehicle travel on the existing transportation system and on air quality should be more fully analyzed and any mitigating measures necessary indicated. We have discussed with the developers of Trillium and their consultants the general type of air quality impact, analysis that should be carried .out. Because of the high pollutant concentrations that may currently existiin the area of the project and because, of the size of the project, we feel a detailed analysis of the impact of the project, substantiated by ambient air quality monitoring, is necessary. The parking facilities associated with the proposed development will require a permit from EPA to comply with the transportation control plan:' for. the State of Washington (38-Federal Register 32668), and to assure the implementation of national ambient air lity standards. The proposed development may also be subject to EPA indirect source regulations which will be promulgated shortly._ Whether the development will be subject to the regulations depends upon the effective date of the regulations and upon the date construction of the development is commenced., These regulations were proposed for the State of Washington on October 30, 1973 (38 Federal Register 29893) . Copies of both the. EPA parking management regulation and the proposed indirect source regulations for. the State of Washington are attached. In addition, the EIS should address the impact, of the proposed development on all existing public utilities and on the need, for additional .public services as a result of growth generated by the proposed development. • 2 Thank you for the opportunity to review this statement. Sincerely, X4A14 e Hurlon C. Ray Assistant Regional Administrator for Management Attachments cc: P. Millam • 107//&--a,L § 52.2486 Management of parking Ply. (a) Definitions: (1) "Parking facility" (also called "facili y ") means a lot, garage, - building, or structure, or combination or por- . tion thereof, in or on which motor ve hicles are temporarily parked. (2) "Vehicle trip" means a single • movement by a motor vehicle that origi- nates or terminates at a parking faciii'y. (3) "Construction" means fabrication. erection, or installation of a parking fa- cility, or any conversion of land, build- ings, or structures, or portions thereof. for use as a facility'. (4) "Modification" means any change to a. parking facility that -increases or may increase the motor vehicle capac::y of, or the motor vehicle activity associa- ted with, such parking facility. (5) ''Commence" means to underta :e a continuous program of on -site con- struction or modification. (6) "Parking space" means any area or space below, above, or at ground level. open or enclosed, on- street or off - street. that is used for parking one motor ve- hicle at any time. (7) "Residential parking facility" means a parking facility the use of which is limited exclusively to residents (and guests) of a residential building or R 27, 1973 • 32676 ES AND REGULATIONS group of buildings under common con- ambient air quality standard at any time mitted in the application and with ap- trol and in which. no commercial park - within 10 . years from the date of plicable rules, regulations, and permit ing is permitted. application; and • • conditions. - (8) "Seattle central business district" (3) For facilities to be located within (j) Within 30 days after receipt of an. means the area enclosed by Yesler Way, the Seattle or Spokane CBD, the con- application, the Administrator or agency the I -5 freeway, Eighth Avenue, Virginia struction or modification of such facility approved by him shall notify the public. Street. and the Alaska Way Viaduct. will not cause a violation of paragraphs by prominent advertisement in the Re- Streets forming boundaries (excluding (k) through (m) of this section. . gion affected, of the receipt of the appli- the I -5 freeway and the Alaska Way Via- (f)• All applications for approval under cation and the proposed action on it duct) shall be part of, the central busi- this section shall include the following (whether approval. conditional approval. ness district (CBD), information: •or denial), and shall invite public • (9) "Spokane central business dis- (1) Name and address of the comment. • (1) The application, all submitted in- . Avenue,- means the area enclosed by A Trent applicant. formation, and the terms of the proposed Aventte; ;4lonroe Street, Third Avenue, (2) Location and description of the " action shall be made available to the and Division Street. Streets forming parking facility. public in a readily�adee available place with- e boundaries shall be part of the central (3) A proposed construction schedule. in the affected air quality region. business district. (4) The normal hours of operation•of (2) Public comments submitted within (b) This regulation is applicable in all the facility and the enterprises and • 30 days of the date such information activities () that it serves. is made available shall be considered (5) The total motor • construction capacity -in making the final decision . on the before and after the construction or mod- application" ification of the facility. appli The Administrator or agency ap- (g) The Administrator may require an ap- application for a facility of between 50 proved by him • shall take final action and. 249 spaces to include the informa- (approval, conditional approval, or deni- tion required by subparagraph (h) (1) al) on an application within 30 days after through (7) of-this section. • close of the public comment period. (h) All applications under this section (k) In addition to the foregoing re- for new parking facilities with parking quirements, paragraphs (1) through (o) capacity for 250 or more vehicles, or for of this section shall be applicable within any modification which, either individ- the Seattle and Spokane CBD. . ually or together with other inodifica- (1) There shall be no increase in the tions since August 15, 1973, will increase number of non - residential parking .capacity by that amount, shall, in addi- spaces within the Seattle and Spokane tion to that information required by CBD above the number :present as of paragraph (f) of this section, include the November 19, 1973. Any parking facility . following information unless the appli- which provides or would provide.vehicu- counties included in the Puget Sound Intrastate AQCR and in the county of Spokane, in the Eastern Washington- Northern Idaho Interstate AQCR. • (c) The requirements of this section are applicable to the following parking facilities in the areas specified in para- graph (b) of this section, the construc- tion or modification of which is corn menced after August 15, 1973: (1) Any new parking facility with parking capacity for 50 or more motor vehicles; -(2) Any parking facility that will be modified to increase parkin_ g capacity by 50 or more motor vehicles; (3) Any parking facility constructed or modified in increments which individ- ually are not. subject to review under this section, but which, when all such • cant has•received a waiver from the pro- lar ingress or egress to or from a street ,increments occurring since August 15, visions of this paragraph from the Ad- forming a boundary of a CBD • shall be 1973, are added together, would as a total ministrator or. agency..approved .by. the .. considered ..included within such CBD. administrator: Any• parking facility beneath a street subject the facility to review under this . section; and (1) The number of people using or en- (4) Any parking facility, regardless of gaging in any enterprises or activities size, to be located within the Seattle or that the facility will serve on a daily basis Spokane central business districts. Any and a peak hour basis. (2) A projection of the geographic parking facility that provides or would areas in the community from which peo- provide street lar forming ss or egress to or pie and motor vehicles will be drawn to from a street forming a boundary of a the facility. Such projection shall include CBD shall be considered included withi o data concerning the availability of mass • such CBD. Any parking facility beneath ' transit from such areas. a street forming a boundary shall be (3) An estimate of the average and considered included within such CBD. peak hour vehicle trip generation rates, (d) No person shall commence con- before and after construction or modifi- struction or modification of any facility cation of the facility. . subject to this section without first ob- (4) An estimate of the effect of the taining written approval from the Ad- facility on traffic pattern and flow. ministrator or an agency designated by (5) An estimate of the effect of the him; provided, that this paragraph shall facility on total. VMT for the air quality not apply to any construction or modifi- control region. . cation for which a general construction (6) An analysis of the effect of the fa- spaces in such CBD, unless and until contract was finally executed by all ap- cility on site and regional air quality, in- such person or entity has obtained from , propriate parties on or before August 15, eluding a showing that the facility will the Administrator erS entity yr asom a -an agency fr 1973. - be compatible with the applicable imple- approved by the Administrator -a a permit (e) No approval to construct or modify mentation plan. and that the facility will approved that the Administ, for a permit a facility. shall be granted unless the not use any national air quality standard stating enlargement that co st ucch facility will be applicant shows to the satisfaction of the to be exceeded within 10 years from date in compliance with such facapy (1) of . Administrator or agency approved by of application: The Administrator may this section. him that: prescribe a standardized screening tech- (o) By May 31, 1974, each owner or (1) The design or operation of the nique to be used in analyzing the effect facility will not cause a violation of the of the facility �n ambient air quality. • operator of any parking facility located control strategy that is part of the ap- . (7) Additional information, plans, within the Seattle and Spokane CBD plicable implementation plan, and will specifications, or documents required by shall reserve 10 percent of the parking be consistent with the plan's VMT the Administrator. spaces in such facility for vehicles reduction goals: (1) Each application shall be signed by transporting three or more occupants (2) The emissions resulting from the the owner or operator of the facility, between the hours of 7:00 a.m. to 7:00 design or operatiton of the facility will whose signature shall constitute an m Monday through Friday, oc7:00 not prevent or interfere with the attain- agreement that the facility shall be oiler- p ment or maintenance of any national ated in accordance with the design sub - ing legal holidays. On or before • FEDERAL REGISTER, VOL. 38, NO. 227 — TUESDAY, NOVEMBER 27, 1973 forming a boundary shall be considered to be included within such CBD. (m) On a semiannual basis, beginning • February 15, 1974, the City of Seattle and the City of Spokane shall report to the Administrator the total number of nonresidential and the total number of residential an- street and off-street park- ing spaces in their respective CED's. Thereafter, such cities shall report any reduction in the number of such parking spaces to the Administrator. (n) No person or entity, after Novem- ber 19, 1973, shall commence construc- tion or modification of any new non -resi- dential parking facility in the Seattle or Spokane CBD, nor shall any person or entity take any action having the effect of creating new non - residential parking • •- • • • March 1, 1974, each such owner or op- erator shall.submit to the Administrator a detailed compliance schedule showing the steps it will take to assure compliance with this paragraph. (p) The City of Seattle and the City of Spokane shall report to the Adminis- trator on a semiannual basis beginning August 15, 1974, the average daily oc- cupancy of the spaces reserved for ve- hicles transporting three or more occu- pants. • • • • TUESDAY, OCTOBER 30, 1973 WASHINGTON, D.C. Volume 38 L Number 208 ENVIRONMENTAL PROTECTION • AGENCY [4t)crR Part 52j APPROVAL AND PROMULGATION OF STATE IMPLE-MENIATION PLANS Review of Indirect Sources On June 18, 1973 (38 FR. 15834) , the •Administrator of the Environmental Protection Agency (EPA) promulgated amendments to 40 CFR Part •51, Re- quirements for Preparation, Adoption, and Submittal of State Implementation Plans, under section 110 of the Clean Air Act, as amended. Those amendments were designed primarily to I :,rovide• for long -term maintenance of the national ambient air quality standards: Among other requirements, States were directed to expand their present procedures for review of buildings or other .facilities prior to construction or modiflcat.iou in order to include consideration of the air quality impact rot only of pollutants emitted directly from stationary sources, but also of l.o)huton arising from mo- bile source activity associated with such • buildings or facilities (termed indirect • sources). Pursuant to an order of the U.S. Court of Appeals for the.District of Coltunbia • Circuit: in the case of Natural resources Defense Council, Inc. et al v. EPA, 475 P. 2d 968 (D.C. Cir. 3973) entered on January 31, 1973, and modified March 12 and July 27, 1973, States were required to submit plan recisions to comply with the new requirements involving indi- rect source review by August 15, 1973 (38 FR 12920). Thus far, EPA has received plan revisions from Alabama, Florida, Puerto Rico, Guam, Maine, New York, and Oregon; they will be made available for public comment before EPA acts to approve or disapprove them. Since EPA will not tal :e action on these revisions until the 30 -day public comment.:. period has expired, and since the Court order requires the Administrator to approve or disapprove such plan revisions by October 15, 1973, the disapproval of all State implementation plans with respect to maintenance of the national stand- ards, as published March 8, 1973 (38 FR • C270), and amended May 17, 19';3 (38 FR 12920), remains in effect. The Court further requires the Ad- ministrator to promulgate regulations by December 15, 3973, where a State fails to subruit indirect source review r;aala- . Lions or the regulations submitted are unar'l)rol'able. The Adinint trator Is now )m :)Posi:ng such regulations. Biased on a preliminary rendie-,c of the plan revisions submitted to date, the Administrator has. • • 29891- • determined that the regulations submit- ted by Alabama, Florida, and Guam ap- pear to satisfy the requirements of 40 C1'R Part 51: Accordingly, the regula- tions proposed below would not be appll- . cable to these three States unless further review should reveal deficiencies in their submittals. Preliminary indications •are that a number of other States will be submitting plans prior. to December 15, 11973, which may, in these cases, elirni- nate the need to promulgate the regula- • tions proposed below. Should any State submit plan revisions for indirect source review which are approvable after De- cember 15, 1973, the Administrator will revoke his promulgation. The regulations proposed below pro- vide that the review procedures will be carried out by State or ..local agencies designated by the Governor. It is recog- nized that many States do not yet have adequate legal authority to approve or disapprove construction or .modification of indirect sources. EPA regulations in 40 CF'R 52.02(d), published May 31, 19'12, (37 FR 10842) provide that any regula- tory provisions of a State implementa- tion :Plan approved or promulgated by EPA are enforceable by EPA and the :State and by local agencies in accordance with their assigned responsibilities under the State plan. Thus, these proposed reg- ulations would be .enforceable by State local agehhciesdesignated by. a Governor to be responsible fair indirect source re- - viewaSin.ce the decisions which Will have to he made pursuant to these proposed regulations are pertinent to local situa- tions, the Administrator encourages and strongly supports the. exercise of ibis au- thority at the State and local level. Where States are unwilling or unable to iniple= went these procedures, however, it will be necessary for EPA to assume the re- sponsibility. States are particularly in- vited to indicate, in their comments on these proposed regulations, whether they can and will implement these regula- tions. It should be noted that these pro- posed regulations do not in any wvay'af- fect previously approved or promulgated regulations applicable to review' of sta- tionary sources. The regulations pro- posed below specify the use of various analytical techniques which are consid- ered reasonable and appropriate for de- termining . the impact of an indirect source on air duality. The type of analy- sis specified varies with types of indirect sources and-is dependent on the capabili- ties and limitations of existing analytical techniques. • For example, analysis of carbon mon- oxide emissions, using a diffusion model, is considered appropriate for analyzing the air quality impact. of roads, high- ways, and parking areas. Existing diffu- sion Modeling techniques do not permit sucli an analysis of the impact of hydro -• carbon or nitrogen oxides emissions. The impact of these laollutants is most ade- quately evaluated on an area -wide basis, using the proportional modeling' tech - nique previously utilized for demonstrat- ing the adequacy of centre/ strategies. Thin technique yields meaningful results PROPOSED RULES • primarily''in cases where the additional emissions re.sult)ng from an indirect, Source are significant in relation to exist- ing area -wide omissions. Accordingly, this technique is considered.most appro- priate for analyzing the air quality im- pact of airports, including associated .commercial and industrial growth, and major highway 'projects. Depending • on the existing omissions in the area under consideratlon and the size of the area, the proportional model may still yield inconclusive results and thus may not be applicable in all si't iathons. As improved analytical techniques become available, the types of analyses specified below should be augmented or replaced by such techniques. • .. The regulations proposed below include 'criteria for- .cletcn in.ing- which sources will be subject to the review procedures. These criteria are based on the follow - ing parameters:- For roads and high - ways, the expected traffic volume; for airports, the number of aircraft opera- tions by regularly scheduled air carriers; and for other indirect sources, the size of the parking facility or the number of induced vehicle trips. Although other in- dicators of induced mobile source activity could be used, these parameters are con- sidered to be most directly related to the air pollution potential of these sources. The size Of a source which, under the- proposed . regi lations, would be exempt from review varies, depending on whether it is located in an area where there may be a potential for exceeding a national arnbient air quality standard within the next 10 years. The Administrator con- siders it necessary to devote more at- tention to such areas by reviewing - smaller sources than are reviewed in non - problem: areas. A list of these areas will be published by the Administrator .'by June 18. 1974• in accordance with the Jtme 18, 1973, amendments (38 FR 15334) to 40 CFR, Part 51. Until this list becomes available, all Standard Metropolitan Sta- tistical -Areas Neill, for the purposes of this regulation, be considered to have a potential for exceeding the national standards. The size of an indirect source subject to review has been determined in a nation- wide context and therefore does not nec- essorily reflect special local conditions which may cause more comprehensive review procedures to be desirable. The Administrator strongly encourages States to analyze their own local situations con- cerning the • desirability of reviewing smaller sources than 'those specified be- . low.. in this regard, States which have submitted plans or are in the process of adopting plans for indirect, source 'review should not construe the regulations pro- posed below as bell..• optimalfor all situ- ations. • It is particularly important that States and 'other interested parties recognize that much more comprehensive require- ments are necessary in. areas where transportation control measures will be needed to meet national arnblent air quality standards. In such- areas,' pre - .construction review of even .relatively small indirect sources clearly is justified. Toward this end, parking supply man- agement regulations will to included in many of the transportation control plans. To the extent that transportation con- trol. plans do not include such rc, ula- bolls, they will be included In final regu- lations for indirect• source review and they generally will be more comprehen- sive than this proposal, in terms of the . facility. sizes which will he subject to reviews. 'The preceding factors ind.icate'why an individual State inlay, find it desirable to develop regulations which 'differ from those proposed below, and .why a State should make every effort to submit its own indirect: source review regulations designed to fit into its strategy for long- -term maintenance of air quality stand- Ards. States may also wish to broaden such review to consider other environ- mental or social considerations. It is the Administrator's intent to hold hearings on these proposed reguia.tiens • in each State where no State hearing has previously been held on this subject. These hearings will he held no sooner than November 29, 1973. The time and location of such hearings will be an- nounced in a subsequent 3?r•. fans; REGIS- TER. . Interested 'persons may also partici- pate in this rule making by submitting written comments in triplicate to the ap- propriate Regional Administrator. All comments received by November 29..1973 will be considered. Receipt of comments Will be acknowledged, hut the 3ieg ional Ahninistrators will not. provide sub- ' stantiv rczpenses t:o il•e�iiri:i fill) C6n.i- merits. All comments will be available for public' inspection . during nolinal bu.si- llcss hours at each Regional Office and at the Freedom of Information Center, EPA. Room' 329, 401 M Street SW., Washing- • • ton, D.C. 20460. Following consideration of. public com- ments, these regulations, with any mod- ifications which may be appropriate, are to be promulgated by December 15, 1973, pursuant to the order of the Court, of .Appeals. The regulations will be effective • 180 days after promulgation. This defer- ral of the effective date is considered • necessary to give State and local agencies an adequate opportunity to Inane prep- - arat.ions for iinplementing' the pro'e- •dures prescribed by these proposed regu- lations. Since the proposed regulations are intended primarily to ensure long- . term maintenance of the national ambi- ent air quality standards, and since the Clean Air Act emphasizes that it. is State and local goi'erninents that have the pri- mary responsibility for developing and carrying out implementation pt:uls, lane: deferral of the effective date is consid - cred consistent With the purposes of the Act. This notice of proposed rule making is issued under the authority of section 110(c) of the Clean Air Act, as amended 142 U.S.C. 1857c -5(c) ). .Dated: October 25, 1973. RUSSELL E. TiaAm, . -- Administrator. FEDERAL REGISTER, VOL. 30, ivO. 200---- TUh•SDAV, OCTOD1C 30, 1973 It is proposed to amend Part 52 of Chapter I. Title 40 of the Code of Fed- eral Regulations as follows: In § 52.22, the first paragraph Is des - ignated as paragraph (a) and paragraph (U) is added. As amended, § 52.22 reads as .follows: { :2.22 i4rninten.ance of national stand - ards. (a) Subsequent to January 31; 1973, the Administrator reviewed againn. State implementation plan provisions for in- suring the maintenance of tho national standards. The 'review • indicates that State plans generally do not contain regulations or procedures which ade- quately address this problem. Accord- ingly, all State plans are disapproved with respect to maintenance bec.ause such plans lack enforceable • procedures or regulations for reviewing and pre - venting construction or modification of facilities which will result in an increase of emissions from other sources of pol e lutants for which there are national standards. The disapproval applies to all States listed in Subparts 13 through DDD of this part. Nothing in this sec- tion sluall .invalidat.e or otherwise affect the 'obligations of States, • emission sources, or other persons with respect: to •all portions of plans approved or promul- gated under this part. Pursuant to an order of .the U.S. Court of Appeals for the District of Columbia Circuit entered. on January 31, 1973, and modified on March 12, 1973, State plaits providing for maintenance of the national stand- ards must be submitted to -the Admin- istrator ro later than August 15, )973. (b) Regulation. for review of new or modified: indirect sources. (1) All terms used in this paragraph but not specff3- cnlly defined below shall have the mean - ing given them in § 52.01 of this chapter. (1) The term "indirect source" means a facility, building, structure, or instal- lation, or combination thereof, which causes or may cause mobile source ac- tivity that results in emissions of a pol- lutant for which there is a national standard. Such indirect sources shall in- clude, but not. be limited to: . (a) Highways and roads. .(b) Parking lots and garages. (c) Shopping centers. (d) Recreational centers and amuse - Spent parks. (c) Sports stadiums. (f) Airports. • (g) Commercial or industrial devel- 'aliments. • • (11) The term "vehicle trip" means a single movement by a motor vehicle which originates or terminates. at an indirect source. (iii) The term "Director" means the director of the State or local agency designated by the Governor of the State to carry out_this paragraph. (iv) The term "associated parking area" means a parking lot or garage owned and /or operated in conjunction with an indirect source. (v) The terns "aircraft operation" means an aircraft tai :e -off or lancing. (vi) The term "modification" means any physical change to an indirect source which increases or may increase the mobile source activity associated with such indirect source. (vii) The tern "Standard Metropoli- tan Statistical Area" means such areas as designated by the U.S. Bureau of the Budget in the following publication: "Standard Metropolitan Statistical Areas," issued in 1967, with subsequent amendments. (viii) The term "designated arca" means any area designated pursuant to § 51.12(1) of this chapter as having the potential for exceeding any national standard within the subsequent 10 year period. . (ix) The term "area -wide air quality analysis" means a n croseele analysis utilizing • the techniques specified in § 51 :14(c) of this chapter. (x) The term "commenced" means that an owner or operator has under- taken a continuous program of construc- tion or modification or that a binding general construction contract has beeu entered into Which obligates one party to such contract to perform the Physical Work involved in such program of con= str•uctfon or modification. - (2)• The requirements of this para- graph are made part of Subparts 13 through DDD, except Subparts 13, K, and AAA, and are applicable to'the following indirect . sources,- the construction or modification of which . is commenced after the cllective .date of this ,Para- graph: - . (i) Any indirect source which is lo- cated in.a designated area and which: (a) Is a new parking_ lot or F :arage with a parking capacity of 1,000 cars or more,' or has a new associated parking area with a parking capacity of 1,000 cars or more; or • (b) Is a parking lot or garage being modified to increase paring capacity by more than 500 cars, or has an associated parking area being modified. to increase parking capacity by more than 500 cars; or (c) Induces 1,000 or more vehicle trips in any one. -hour period or 5,000 or more vehicle trips in any eight -hour period. (ii) Any indirect source located out- side a designated area which: .(a) Is a new parking lot or garage with a parking capacity of 2,000 cars or more, or has a new associated parking area with a parking capacity of 2,000 cars or more; or (b) .1s a parking lot or garage being modified to increase parking capacity by more than 1,000 cars, or has an associ- ated parking area being modified to in- crease parking capacity by more than 1,000 cars; • (c) Induce: 2,(u0 or more vehicle trips in any one -hour period or 10,000 or more vehicle trips in any eight-hour period. . (iii) Any road or highway kacated.in.a .designated area with folloWing antici- pated average annual daily traffic vole times within ten ycars..of construction or modification: (a) New road or highway: 20,000 or more vehicles per day. -(b) Modified road or highway: In- crease of 10,000 vehicles per day or u:or • over existing traffic volume on such roar or highway. • (iv) Any airport with the following expected aircraft operations within to years of construction or modification: (a) New airports: 50.000 or more or. erations per. year by regularly schedule air carriers. (b) Modified airport: Increase of 50, 000 operations per year by regular) scheduled air carriers over the existtn r volume of operations. (v) Where an indirect source is con- structed or modified in increments which individually are no subject; to retee.: under this paragraph, MI such incre- ments occurring since the efTective date of this. regulation shall be added to- gether for determining the applicabfiits.- of this paragraph. • (vi.) Until' the • Administrator disig- notes, pursuant t0 §51.12(f) of this chapter, areas which may have the po- tential for exceeding a national stand - .rd within the subsequent 10 -year pe- riod, "Standard Metropolitan Statistical Area" shall be used in place of "desig- nated area" for the purposes of •fhis paragraph. (3) No owner or operator of an indi- rect source subject- to this paragraph shall commence construction or modift- .cation of. such source after the effective date of this paragraph without first de tabling approve) from tape Director. Ap- plication for approval to . cans iract • ^r modify shall be by means prescribed by . the Director, and shalll inchrde .bit% no`.• be ).invited tb the following in.formaticn: • (1.) For airports, a description of aver - age and maximum number of aircraft operations per clay by type of aircraft. The description shall also include new. conunercial, industrial, and transporta- tion-related development expected to occur within three miles of the air port • for the 10 -year period folio -Mtn; cea structfon or 'modification. (ii) For road and highway's, a description of the aver- age arid maximum traffic volume for one, eight and 21 -hour time periods expected within 10 years of construction or modi- fication. Such description shall inciuc" an estimate of vehicle speeds for average and maximum traffic volume conditions. (fit) For indirect sources other than airports. and highways, a description the location and design of such - source. including its relation to surrounding roadways stair) highways and an estimate of the average and maximum number of vehicle trip; generated by such indirect source for one and eight -hour time periods.. • (iv) Upon request of the..Director, the owner or operator shall also provide: . (a) .Estimates of the effect of the con- struction or modification of the indirect source on traffic, patterns and flow in the vicinity of the source. • (b) Measured or cstimated air quality data rat the, site of the indirect source prior to construction or modification. &EDCRAL MOISTER, VOL. 30, NO, 208- -- TUESDAY, OCTO8rr. 30, 1973 298 1.) v ' PROPOSED KGttf 5 (c). e n - estimate of air quality after construction or modification of rho indi- rect' source. (d) An estimate of the effect of the construction or modification of ;the indi- rect. source on total vehicle miles of travel (VMT) and additional residential, 'commercial and industrial development .which may occur PS a result of such con- struction or modification. (c) Any additional information, plans, Specifications, evidence or documenta- tion that the Director may require.- ' (4) (1) No approval to construct or modify shall be Granted unless the appli- cant shows that: • (a) The indirect source will not cause a violation of the control strategy which is part of the applicable plan, and (b) The indirect source will not pre- vent or interfere with the attainment or. maintenance of a national ambient air quality standard. .0i) In connection with the determina- tion required by paragraph (b) (4) (i) of this section, the showing required -of the - applicant shall be limited to the impact on air quality from the indirect source proposed to be constructed or modified, and shall reflect consideration of exist - ing'crnissionsc from other Sources. It :.ball be the responsibility of the Director to • determine the impact on air quality of future growth and development or other factors affecting emissions and air qual- ity over which the applicant has no • control. . (iii) The Director shall, prior to anal;- . ing any determination not to approve the. construction or modification of an indi- rect source pursuant to paragraph (b) (4) (1) of this section consider any al- teration of the proposed construction or modification which. would pcnnit ap- proval. The .Director shall condition any approval on such alteration being incor- • orated in the construction or modifica- tion. In choosing among possible alters - Lions, the Director shall give appropriate consideration to any expenditures - of time or money Made by the owner or operator of the indirect source prior to the effective date of this paragraph. (5) For roads and highways subject to this paragraph, the determination re- quired under paragraph (b) (4) (ii) of this section shall he glade as follows: (1) The impact of a road or highway on the total VmiT in an appropriate area selected for an area-wide air quality - analysis shall he used to determine the change in emissions for such area. Such area -wide air quality analysis shall then be used to determine expected ambient concentrations of carbon monoxide, . photochemical oxidants, and nitrogen • oxides following construction or modifi- cation. (ii) Using an appropriate diffusion model, the air quality impact of carbon monoxide einissions resulting from the expected •rriaximurl traffic. volume on. a 'road or highway shall be evaluated at reasonable receptor or exposure sites in the vicinity of - such road. (0) For airports subject to this para- graph, the determination. required under pia aph (b) (4) (11) of this section Shts tie made as follows: A (1) All emissions from stationary and .mobile sources at the airport, along with emissions from all new commer'c'ial, in- dustrial, and transportation- related development expected to occur within three miles of the airport, shall be added together in order to determine the ag- 'grega.te impact on air quality. (ii) An area -wide quality analysis shall be used to determine the expected ambient concentrations of carbon monoxide, photochemical oxidants, and nitrogen oxides following construction or modification. • . (7) For indirect: sources other than roads and airports, the determination re- quired under paragraph (b) (4) 01) of this section shall be made using an appropriate diffusion model. to evaluate the intact of em-bon monoxide emis- sions resulting-from expected nia:;imurn vehicle trips to or from such source. Such irinpa.ct shall be evaluated at reasonable receptor or exposure sites in the vicinity of such indirect source.. . (8) Within 30 days after receipt of an application, the Director will notify the • public, by prominent advertisement in the region affected, of the opportnnity for puhl c comment on the information submits a by the owner or operator. (i) Such information, as well as the Director's.analysis of the effect of the in direct • source on air quality and the Director's proposed approval or disap- proval, shall be available in at least one lo cation in.the region affected. (ii) A copy -of the notice required pursuant-to this subparagraph shall be sent to the Administrator tlu'ough the appropriate regional- office; to all other State and local air pollution control agencies having j'u'isdie.tion in the region where the indirect source will be located; and to any other agency in the region having responsibility for implementing the procedures required under this pares.; graph. • (iii) Public comments submitted with- in 30 days of .the date such information is made available shall be considered by the Director in malting his final decision on the application. (iv) The Director shall take final ac- tion on an application within 30 days after the close of the public comment pe- riod. The Director shall notify the ap- plicant in writing of his approval, con- ditional approval, or denial of the appli- cation, and .hall set forth his reasons for conditional approval or denial. • (9) The Director may impose any rea- sonable conditions on an approval, In- chiding conditions requiring the indirect source owner or operator to conduct am- bient air quality monitoring in the vicinity of the site of the source for e reasonable perice prior to commence • mcnt of construction or .modification. and /or for any specified period alter the source has commenced operation. ()A) Approval to construct or modify shall not relieve any owner or operator • of the responsibility to comply with the . control strategy and all local, State and Feder.' ilations which are part of the applicac. plans. (11) The Governor of the State shall designate the State or local agency which will carry out this regulation in each area of the State within 30 days from the date of final promulgation. 'rile Gov- ernor shall notify the Administrator which agency or agencies be has desig- nated through the appropriate Regional Administrator. Where the agency desig- nated is not an air pollution control agency, such agency shall consult with the appropriate State or.local air pollu- tion control agency prior to snaking any determination required by paragraph (b) (4) of this section. i)'R Doc.73 -23174 Piled 10- 29- 73;8:45 tun) i•EDERAL REGISTER, VOL. 3S, NO. 208-- TUESDAY, OCTOSER 30, 1973 • • Frank Todd, Mayor CITY of TUKWILA 14475 - 59TH AVENUE SOUTH TUKWILA, WASHINGTON 98067 14 December 1973 MEMORANDUM TO FILE SUBJECT: Draft E.I.S. - Trillium Received telephone request from Mr. Keith Anderson, Puget Sound Air Pollution Control Agency, for seven day extension for comments regarding the Draft Environ- mental Impact Statement filed for the project known as Trillium. Mr. Anderson assured me that his comments would be received by this office within the extension period. The request was granted with the notation that all comments received by 5 p.m. Friday, 21 December 1973 will be promptly forwarded to Wilsey & Ham, the responsible consultants. Gary , rutchfiel Planning Technician Frank Todd, Mayor CITY oF'TUKWILA 14475 - 59TH AVENUE SOUTH TUKWILA, WASHINGTON 98067 29 October 1973 Gentlemen: PLANNING DEPARTMENT Please find enclosed . herewith a copy of the Environmental Impact Statement prepared for a project entitled Trillium, a business and commercial complex to be located within the corporate limits of Tukwila. The statement has been reviewed by this office in accordance with the National and State Environmental Policy Acts as well as in regard to Federal, State, regional and local plans and programs. This office would appreciate any comments regarding this Statement within forty -five (45) days from date of this letter. Please relate your comments in writing and direct them to this office at 6230 Southcenter Boulevard, Tukwila, Washington 98067. GC /lt Encl: as Sincerely, 74-- Delbert. F. Moss Planning Coordinator • Frank Todd, Mayor CITY of TUKWILA 14475 - 59TH AVENUE SOUTH TUKWILA, WASHINGTON 98067 26 June 1973 Wilsey & Ham, Inc. ATTN: Mr. Michael Brooks Evergreen Building 15 Grady Way Renton, Washington 98055 Dear Mr. Brooks: PLANNING DEPARTMENT This correspondence is in reply to our telephone conver- sation earlier this afternoon regarding an Environmental Assessment Summary for the proposed Maguire development to be located immediately south of the Doubletree Inn, Tukwila. While Tukwila Ordinance #759, unlike the State Environ- mental Policy Act, establishes an Environmental Assessment Summary which may be used at the discretion of the Tukwila Planning Coordinator, it has normally been employed when a determination was difficult as to whether or not a project was a "major" action which may have a "significant adverse environmental effect ". As I stated in our earlier conversation, this office has only received what may. be termed conceptual or preliminary site plans and from those have determined the proposal to be of such magnitude as to require a detailed Environ- mental Impact Statement which must be completed in accordance with the State Environmental Policy Act Guidelines. The preparation of an Assessment Summary would only cause a delay in the procedures of a full Impact Statement. Any further information regarding this matter will be gladly provided upon your request at this office at 242 -2177. Si rely, ry Plan ng Technici chfield GC /lt. WILSEY& HAM, INC. Earl P. Wilsey (1892 -1957) 15 SOUTH GRADY WAY, EVERGREEN BUILDING • RENTON, WASHINGTON 98055 • Telephone (206) 228 -1080 • Cable "WHINT" January 3, 1973 File No. 3 -2012- 0101 -30 Mr. Richard B. Hansen Acting Planning Coordinator City of Tukwila Planning Department 6230 Southcenter Boulevard Tukwila, Washington 98067 Dear Mr. Hansen: Enclosed are copies of the reviewing agency comments to The Trillium Draft Environmental Impact Statement and our responses. The letters from the EPA Region X, the Washington Department of Fisheries and the Department of Game required further information which is provided. -The comments from the other agencies are also well taken and can be incorporated by reference. Sincerely, WILSEY & HAM, INC. A. Llewellyn Matthews Environmental Resource Planner ALM /kb Enclosures cc: Pat Colee engineering • planning • surveying • landscape architecture • mapping • systems Frank Todd, Mayor CITY or TUKWILA 6230 SOUTHCENTER BLVD. TUKWI LA, WASHINGTON 98067 PLANNING DEPARTMENT Wilsey & Ham, Inc. ATTN: Ms. Llewellen Mathews 15 South Grady Way Evergreen Building Renton, Washington 98055 Dear Ms. Mathews: 21 December 1973 This office, on 29 October 1973, disbursed some twenty copies of the Draft Environmental Impact Statement for Trillium to concerned Federal, State and regional agencies. The forty -five day review period is complete as of this date and we have received several comments. Please find enclosed a copy of each comment. None of the. comments appear to be very critical and we assume a final statement will be forthcoming very soon. Please keep in mind the recent Transportation Control Plan promulgated by the Environmental Protection Agency. GC /lt Enc l : 1. Ltr, 2. Ltr, 3. Ltr, 4. Ltr, 5. Ltr, 6. Ltr, 7. Ltr, 8. Ltr, 9. Ltr, 10.Ltr, Richard B. Hansen Acting Planning Coordinator Dept of Fisheries, dtd 13 Nov 73 Corps of Engrs, dtd 28 Nov 73 Dept of Game, dtd 28 Nov 73 K. C. Dept of Health Dept, dtd 20 Nov 73 State Pks Comm, dtd 2 Nov 73 State Hwy Comm, dtd 23 Nov 73 Fed Hwy Admin, dtd 28 Nov 73 State Dept of Nat Res, dtd 20 Nov 73 P.S.A.P.C.A., dtd 17 Dec 73 U.S. Env Protection Agny, dtd 14 Dec 73 cc: Mayor Todd DANIEL J. EVANS GOVERNOR ROOM 115, GENERAL ADMINISTRATION BUILDING o PHONE 753 -6600 THOR C. TOLLEFSON OLYMPIA. WASHINGTON 98504 DIRECTOR November 13, 1973 City of Tukwila Planning Department 6230 Southcenter Boulevard Tukwila, Washington 98067 Attention Mr. Delbert F. Moss, Planning Coordinator Gentlemen: Your letter of October .29, 1973 requests our review of an Environmental Impact Statement for a project entitled Trillium, a business and commercial complex to be located in. Tukwila. Following are our comments: 1. On page 16, reference is made to the Tukwila Comprehensive Plan, adopted in 1962, "....which is still somewhat applicable today ". As pointed out in our reviews of other similar projects recently proposed for this area, the'Environmental Impact Statements have not indicated whether the proposed developments follow any up- dated plan or are consistent with all other plans and policies. 2. One of our major concerns in this project, as in the others, is the increased quantity of storm water runoff and degradation of water quality in the Green - Duwamish River. Incidentally, on page 1 the project site is located as 1/4 mile from the river and on page 23 as one mile away. 3. The third and fourth sentences on page 39 should'read: "Most of the chinook runs are produced from fry or fingerlings released from the Washington State Department of Fisheries' hatchery . located on the Soos Creek. tributary. Mud' •natural spawning by chinook and other species of salmon also occurs." ' 4. In Table 10, the generic name for dace should be spelled Rhinichthys and the scientific name for starry flounders should be listed as Platichthys stellatus. I have pointed out the latter error in the other statements prepared for the City of Tukwila by Wilsey and Ham. We appreciate the opportunity to comment upon this project. Sincerely, / Gilbert A. Holland Fisheries Research Coordinator cc: D. L. Lundblad - Dept. of Ecology E. S. Dziedzic - Dept. of Game Wilsey and Ham, Inc. - Renton., RESPONSE TO DEPARTMENT OF FISHERIES 1. The proposed development is consistent with both the City Comprehensive Plan and current Regional Plans. 2. Erratta: The subject site is located 1/2 mile from the Green.River. 3 & 4. These comments are accordingly incorporated. DEPARTMENT OF i ii ;E ARMY SEATTLE DISTRICT, CORPS OF ENGINEERS 1519 ALASKAN WAY SOUTH SEATTLE, WASHINGTON 98134. 28 NOV 1973 NPSEN -PL -ER Mr. Delbert F. Moss Planning Coordinator City of Tukwila 14475 -59th Avenue South Tukwila, Washington 98067. Dear Mr. Moss: We have reviewed the draft Environmental Impact Statement (EIS) on the Trillium Business and Commercial Complex proposed for develop- ment in Tukwila, Washington. We concur with your statement that "While the net affect of this particular project is small, it is part of a continuing deleterious trend in accommodation of increased storm water flows by direct discharge into the existing natural systems," (page 67, item b - Impact on Hydrology and Water Quality). In view of this expressed concern, we suggest the EIS be revised to include the following data: a. Existing Conditions, Section B.c(2) - Water Quality. Suggest paragraph 3 indicate summer month water quality analyses were made and reason month was selected. If month does not reflect period of maximum stress on aquatic organisms, suggest that period be sampled and included in the EIS. b. Environmental Impact of the Proposed Action, Section C.1.c Impact on Terrestrial and Aquatic Biology. EIS does not discuss impact of project on aquatic biology. In view of expressed concern for Green - Duwamish Waterway, suggest EIS discuss subject in relationship to affected water quality. Thank you for the opportunity to review this statement. Sincerely yours, 6 A. LEE VilAR NGTON ASS' T . CHIEF, PLANNING B RANCrfi RESPONSE TO DEPARTMENT OF ARMY a. The data is a summary of data gathered by W.R.M.S. (Water Resource Management Study) from mid -July through mid- September. The data was retrieved from computer data banks in such a manner as to represent a typical month during the summer. The data thus reflects maximum stress to aquatic organisms. b. The Department of Game letter stresses the fact that the water quality impacts resulting from development adjacent to the river has a concomitant adverse effect on Green River Fishery.. By way of further note, the water quality problems experienced by the Green River which were, identified by the E.I.S. are substantiated by the RIBCO Water Quality Management Study, Summary of Interim Report (October 1973). As this study indicates the Green River has a problem of high temperature due to its shallow depth and inadequate shading, and low dissolved oxygen which is attributable to high temperatures and to oxygen consumption by bottom organisms (benthos). The Green River also has high coliform counts. The Duwamish Estuary suffers from phyto -. plankton blooms, caused in part by nutrients brought in by the Green River, and from low dissolved oxygen which is consumed by the algae and benthos. While such effects are serious and'it is the function of the Environmental Impact Statement process to identify such effects, it is beyond the scope of the present study to quantifiably analyze the effects to fishery. Director / Carl N. Crouse Assistant Directors / Ralph IV. Larson Ronald N. Andrews (rake coy. -.. Arthur S. Collin, Yakima, Chairman . James R. :1,gen, LaConner Elmer G. Gerken, Quint:). Claude .Bckins, 'Seattle Glenn Galbraith; 1l�ellpinit Frank L. Cassidy, Jr., Vancouver DM ID I T M 7.17 ®P Al 600 North Capitol Way / Olympia, Washington 98504 November 28, 1973 Delbert F. Moss, Planning Coordinator City of Tukwila Planning Department 6230 Southcenter Blvd. Tukwila, Washington 98067 Dear Mr. Moss: Your draft environmental impact statement for Development of the Trillium, A Business and Commercial Complex, City of Tukwila, has been reviewed by our Seattle region and Olympia staffs; comments follow. Your description of project location, developmental history and projected commercial activities constitutes an excellent representation of Proposed Action. Your portrayal of Existing Conditions was equally concise and complete except for a few inadequacies which can be corrected. In reference to Green River fishery you stated (page 39) "Although some natural spawning occurs in the river the majority of anadromous fishes are released as fry and fingerlings from the Washington State Department of Fisheries Hatchery "...The phrase "some natural spawning" should be corrected to read "substantial natural spawning ", as a very significant natural spawning escapement has been recorded for the Green River to date. Your explanation of potential project impact on water quality was accurate but it did not contain an account of project impact on the Green River fishery. You have outlined several serious pollution factors, in your discussion of hydrology and water quality, such as a potential increase in natural runoff containing hydrocarbons, oils, and particulates to the Green River and a possible increase in river temperature. It should be stressed that each of these impacts will have a concomitant adverse effect on the Green River fishery. Moreover, the cumulative deleterious effect which this, along with other projects, . will have on the fishery should be emphasized. In the interest of protecting our valuable steelhead fishery in Green River (an average of 83,500 summer -run smolts planted 1970 -72; 113,500 winter -run smolts in 1971; an average of 14,539 steelhead taken in 1970 and 1971), we strongly urge that the water- quality criteria promulgated by the Department of Ecology be adhered to. The interrelationships of temperature, dissolved oxygen, nutrients and rearing and passage of anadromous fish are far too complex to describe here, but criteria developed by the Department of Ecology were designed to protect fishery interests, among others. Delbert F. Moss -2- November 28, 1973 We feel you made a conscientious effort to evaluate existing conditions of the area for wildlife. Tables on vegetation and wildlife are complete and accurate. However, an unfortunate weakness which will affect decisions on this proposal is that this statement was written after the site was covered with fill. A significant commitment of wildlife habitat and related public benefits was made at that time. Therefore, one cannot argue with your statement that there will be .. a replacement of one man -made habitat with another ". But one can argue that an analysis of the consequences should have been made before the natural marsh was changed to a "man- made" fill. We can not agree with your conclusion (p. 79) that "At present there are no known techniques for retaining wildlife in an intensively developed area." The vicinity of the proposal under consideration contains remnant wetlands that are used by large numbers of waterfowl. Also data from your EIS (Table 7, page 36) shows that wildlife does occur on the site even in its present marginal state. Wildlife can exist, therefore, if habitat is available to it. Also your conclusions that, " A portion of a foraging habitat will be removed from resident birds as well as migratory birds" and that "... existing birds will probably be displaced to more remote reaches of their habitats ", are too optomistic. Remaining habitats are at their carrying capacity and the so- called "displaced" creatures will be lost. We agree that there will be a "dimunition" of habitats. But to be accurate we must all recognize that a great deal of " Dimunition" has and is taking place in the Green River Valley. When all this piecemeal erosion of habitat is added up the impact on wildlife has been substantial and if present activity continues it will border on being catostrophic. We recognize that points we made above cannot be directed entirely at your proposal or statement. However, it seems that the cumulative, long range, irretrievable commitment of a broad range of natural values mast be recognized. This recognition, we think, should appear not only in individual impact statements, but also somewhere in the overall planning process for the future of Green River Valley. Thank you'for sending us your statement. We sincerely hope our comments will prove of value to you ESD:jb cc: Chitwood Agencies Sincerely, THE DEPARTMENT OOF GAME ec Eugene S. Dziedzic, Asst. Chief 'Environmental Management Division RESPONSE TO THE DEPARTMENT OF GAME These comments are well taken and are accordingly incorporated by reference. In order to clear up a possible misunderstanding in regard to a comment on Page 2, it should be noted that the subject site was filled many years ago. and prior to the present developer's formulation of plans. for the site. Seattle -King County DEPARTMENT OF PUBLIC HEALTH Public Safety Building LAWRENCE BERGNER, M.D., M.P.H. Director of Public Health Seattle, Washington 98104 (206) 583 -2550 City of Tukwila Planning Department 6230 Southcenter Blvd. Tukwila, Washington 98067 Attention: Steve Hall, Acting Planning Coordinator Re: Trillium Impact Statement November 20, 1973. CATY OF V U(V`.,,,A . c.;,1/4 Gentlemen: Members of my staff have reviewed the draft of the environmental impact statement for the development of "Trillium ", a business and commercial complex, to be located in Tukwila, Washington. Field investigation revealed that storm and sanitary sewers and an approved public water supply are available to the site. The summary of proposed action as listed on page 2 of the statement is to undertake all review and permit procedures for the construction of a commerical complex. This office will work with the Tukwila Planning Department to ensure that food establishment plans, plumbing installations and other related environmental concerns meet local and state laws. On the basis of these determinations the department recommends the necessary permits be granted to allow the proposed const uction. JBC /et cc: Carl a.gerser awrence Bergner, M.D., P '.•. Director of Public 'Health - DISTRICT HEALTH CENTERS: NORTH B=AST SOUTHEAST SOUTHWEST • ^vyr .J GOVERNOR DANIEL .1. EVANS COMMISSIONERS: JEFF D. DOMASKIN THOMAS C. GARRETT MRS. KAY GREEN RALPH E. MACKEY JAMES G. McCURDY JAMES W. WHITTAKER WILFRED R. WOODS • DIRECTOR CHARLES H. ODEGAARD • • s //�� ��++. AA�� WASHINGTON �TSTATE Rt�� ��. 7.11 ►7- 1TC.?,w�l G.G MECPEATZO COMMISGZO LOCATION: THURSTON AIRDUSTRIAL CENTER PHONE 753 -5755 P. O. BOX 1128 OLYMPIA, WASHINGTON 98504 City of Tukwila Planning Department 6230 Southcenter Boulevard Tukwila, Washington 98067 November 2, 1973 Attention Delbert F. Moss, Planning Coordinator Gentlemen: Draft Environmental Impact Statement Trillium, A Commercial And Business Complex The Washington State Parks and Recreation Commission has reviewed the above -noted draft environmental statement and does not wish to make any comment at this time. Thank you for the opportunity to review and comment. Sincerely, DWH:1jh David W. Heiser, Assistant Chief Research, Planning, and Acquisition WASHINGTON. ON. STATE • HIGHWAY COMMISSION DEPARTMENT OF HIGHWAYS Highway Administration Building Olympia, Washinacon 98504 (206) 753 -6005 Mr. Delbert F. Moss, Planning Coordinator City of Tukwila 14475 — 59th Avenue South Tukwila, Washington 98067 Dear Mr. Moss: Daniel J.. Evans - Gorernr: GP, Andrews - Direc(r;r November 23, 1973 Re: Trillium, Business and Commercial Complex City of Tukwila Draft Environmental Statement Reference is made to your transmittal letter dated October 30, requesting our review of the Draft Environmental Statement for the above referenced proposal. We have completed our review and find the proposal will not be in conflict with any existing or proposed facilities in this area. Thank you for the opportunity to revieww this information. Sincerely, G. H. ANDREWS Director of Highways x"eaeeze-te By: H. R. GOFF Assistant Director for Planning, Research and State Aid GHA :yw' HRG U. S. DEPARTMENT OF TRANSPORTATION FEDERAL HIGHWAY ADMINISTRATION Room 412 Mohawk Building 222 S.W. Morrison Street Portland, Oregon 97204 November 28, 1973 Mr. Delbert F. Moss Planning Coordinator City of Tukwila 6230 Southcenter Boulevard Tukwila, Washington 98067 Dear Mr. Moss: IN REPLY REFER TO '10-00.33 Our Washington Division and Regional office staffs have reviewed the draft environmental statement for Trillium, a business and commercial complex to be located within the corporate limits of Tukwila. Our review indicates the draft environmental statement to be adequate . in our areas of concern. , Thank you for the opportunity to review your proposal. Very truly yours Deputy Regional Administrator HARBOR AREA • k,....))/\•,bir • -] • .; -r/ • V. 'V STATE OF WASHINGTON- VeAdtteotege Redemditeed • -7-zaer,„eze COMMISSIONER BERT COLE DON LEE FRASER SUPERVISOR November 20, 1973 OLYMPIA, WASHINGTON 98504 Delbert F. Moss, Planning Coordinator City of Tukwila 14475 59th Avenue South Tukwila, WA 98067 •Dear Mr. Moss: My staff has reviewed the Draft Environmental impact Statement for the proposed Trillium, a business and commercial complex. We have no comments to make regarding this project. Please direct all future statements to Mr. William Baxter, Environ- mental Forester for the Department of Natural Resources. We appreciate having an opportunity to review this statement. Since5bly, /‘ BERT L. COLE Commissioner of Public Lands BLC:wbs 0200 4 ru •re>t riarrison Street, Seattle, �`•. . December 17, 1973 • Mr. Gary Krutchfield, Planning Technician Public Works Department City of Tukwila 6230 Southcenter Boulevard . Tukwila, Washington 98067 Subject: The Trillium Commercial and Business Complex Draft Environmental Impact Statement. Dear Mr. Krutchfield: As the local regulatory Agency, we. have looked particularly at the air pollution control aspects. of the. proposal. and •have consequently limited our comments to air pollution. Our air quality control jurisdiction in this area is shared with the State Department of Ecology. With. regard to motor - vehicles, the State has assumed jurisdiction and, currently with the Environmental Protection Agency, has the•authority to limit and control this source of air pollution.. Under a parking management plan, application to the Environmental Protection Agency, Region X (1200 Sixth Avenue,. Seattle, Wa 98101) is required for any addition of 50 or more parking spaces. Alternative transportation methods are mentioned in the SERVING: statement as possible mitigating measures for the expected K;NG COUNTY increase.in auto air pollutant concentrations.. Traffic' 410 West Harrison St. flow measures are also .suggested which would reduce auto Seattle, 98119 gg (206) 344 -7330 congestion air pollution effects. • These proposals would KITSAP COUNTY be of some value in improving the air quality of the region Dial Operator for Toll with or without the Trillium project. Free Number Zenith 8385 • Bainbridge Island, Dial 344 -7330 . We are aware that air quality studies will be made in. con- PIERCE COUNTY 213 Hess Building Tacoma, 98402 (206) 383 -5851 ENOi-iOMiSH COUNTY • 703 Medical- Dental Bldg. Everett, 98201 (206) 259-0288 nection with the transportation control strategy so that this question may best be left until after the results of these studies are known. BOARD OF DIRECTORS CHAIRMAN: Gene Lobe, Commissioner Kitsap County; Patric+ J. Gallagher, Commissioner Pierce County;, •• .� 5,•r.. -,an; King County E+ecutivo; VICE CHAIRMAN: Robert C. Anderson, Mayor Everett; N. Richard Forsgren, Commissioner Snohomish County; Glenn K. Jarstad, Mayor Bremerton; Gordon N. Johnston. Mayor Tacoma; Harvey S. Poll. Member at Large: Wes Uhlman, Mayor Seattle; A. R. Dammioehler, Air Pollution Control Officer Gary Krutchfield December 17, 1973 Page 2 Another source of air pollution discussed in the statement, construction dust, can be controlled by following this Agency's Guidelines which are enclosed.' It should be noted, particularly on page 40 of the statement, that this Agency's ambient air quality standards for suspen- ded particulate are that the concentration, averaged over any 24 -hour period, shall not exceed: 1. 60 ugm /m3 annual geometric mean, or 2. 150 ugm /m3 more than once per year. In addition, the section allowing 15% of the samples to exceed standards has been removed from Regulation I. Very truly yours, " 7C1) � r \�1k :N A.R. Dammkoehler Air Pollution Control Officer ARD /JKA:km Enclosure: Guidelines cc: Mr. John C. Raymond Washington State Department of Ecology Olympia, Wa 98504 Mr. James L. Agee, Region X Administrator Environmental Protection Agency 1200 - 6th Avenue Seattle, Wa 98101 Tacoma Branch Office The Hess Building, Room 213 901 Tacoma Ave. S. Tacoma, Washington 98402 Telephone (206) 383 -5851 ENGINEERING DIVISION Plan Review Section 410 W. Harrison Seattle, Washington 98119 Telephone (206) 344 -7334 Everett Branch Office 703 Medical Dental Building 2730 Colby Avenue Everett, Washington 98201 Telephone (206) 259 -0288 GUIDELINES FOR CONTROL OF AIR, POLLUTION FROM ROCK PROCESSING Air pollution from rock processing equipment and adjacent roads must be controlled so as to meet the requirements. of Regulation I, includ- ing Sections 9.03, 9.04, 9.09, 9.11, 9.12 and 9.15. Pursuant to Sec - tions 9.12 and 9.15 of Regulation I the Control Officer has established the following control measures as reasonable requirements and precau- tions to prevent particulate matter from becoming airborne: ROCK PROCESSING - CONTROL MEASURES. 1. Hooding of dust emission points on belts, transfer points and crushers and ducting the collected air to a.baghouse or water scrubber, or 2. Application of a water or chemical mist near emission points, (a pressure above 90 pounds per square inch. and. special noz- zles may be required to produce a mist.that.is both effective and yet not cause, plugging of screens), or .3. A combination of 1 and 2 (as shown in Figure 3), or 4.' Other control measures such as enclosure which comply with Regulation I. Visible dust emissions from rock processing equipment are usually i dicative of improper design or operation. ROADS, PILES, TRUCK LOADING, AND ROCK DRILLS - CONTROL MEASURES 1. Dust coming from in -plant roads shall be controlled by paving, or surfacing treatment which will control both air pollution and mud carry out. A wheel wash system may be required to prevent mud carry out under some conditions. 2. Dust coming from fines piles shall be controlled by the use of a dust suppressant or by providing covering to prevent exposure to wind. 3. Dust coming from rock drills and truck loading shall be con - trolled by hooding or application of a mist. 0TICS OF CONSTRUCTION REQUIRED An approved Notice of Construction is required prior to the installa- tion or alteration of roc'c processing and /or control. - equipment. The ,ccf7nry Notice of Construction forms can -be obtained by calling the Section (344- 7334). -2 MAINTENANCE AND HOUSEKEEPING 1. The spray system shall be protected fromi.freezing. during cold weather by insulation or a change in spray feed formulation. 2. Fugitive dust shall be controlled by godd house- keeping, including, but not limited to, the following: a. Sweeping and flushing of paved roads. b. Wetting or chemical.coating of unpaved low traffic areas. c. Chemical coating of exposed areas to prevent windblown dust. CONTROL METHODS Figure 1 shows the arrangement of atomizing nozzles which develop a flat mist spray pattern. The nozzles are placed on each end of a rubber shield to suppress dust emissions from the bottom of the crusher discharge. Two nozzles which form a cone shape mist spray are often used on the top of a crusher -to . control dust caused by crushing. Figure 2 illustrates how a flat mist spray can be applied ahead of�a transfer point to eliminate dust. The mist should be applied to the rock before the dust is airborne. • Figure 3 shows a combination mist and baghouse system for crushing plants. The baghouse is believed to be.99% efficient in reducing the emissions from a rock crusher. Fi ure 4 shows a mist system for a rock crusher plant. The use of a wetting agent reduces the quantity of liquid required for effective control. -3- CRUSHER NARD RUBBER SHIELD TEO FLAT ATi"lIZINS•TYPE SP ^AY eJZZUS, DBE EACH END OF RU »ER SHIELD TRO FLAT ATOSIZINS•1YPE SPRAY NOZZLES. CHE EACH END OF RU.2ER SHIELD CCSVEYOR FELT BELT CONVEYOR ROLLERS Figure 1. Nozzle arrangement for control of dust emissions upon discharge of crusher.* *Air Pollution Engineering Manual..AP4.0, pp. 341 '� -Mist Nozzle pis .veil 41111 '11', o 1 o I 1 ' : ; I BELT CONVEYOR [IRE -ANGLE CONE -TYPE SPRAY NOZZLE Figure 2. Nozzle arrangement for control of dust omissions from the inlet to the shaker screens. �. • TRUCK DUMP AND FEEDEV, tom' INDICATES MIST APPLICATION PRIMARY CRUSHER SECONDARY CRUSHER SCREEN BIN AND TRUCK LOADING STATION TERTIARY CRUSHER TYPICAL COMBINATION MIST & BAGHOUSE SYSTEM FOR CRUSHING PLANTS Figure 3 TRUCK DUMP ROCK CRUSHING PLANT MIST DUST CONTROL SYSTEM Pg. IMARY CRUSHER SECONDARY CRUSHER SURGE PIL INCOMING WATER LINE �+ WETTING AGENT DRUM PROPORTIONER Figure 4 ccSO ST,I), Z') YU U.S. ENVIRONMENTAL PROTECTION AGENCY REGION X 1200 SIXTH AVENUE g ��:? ' SEATTLE, WASHINGTON 98101 % December 14_ 1973 tilq� PROSE ATTN OFO 10MEI - M/S 325 Mr. Delbert F. Moss Planning Coordinator City of Tukwila 14475 59th Avenue South Tukwila, Washington 98067 Dear Mr. Moss: We have reviewed the draft environmental impact statement for the Trillium Business Complex, Tukwila, Washington. The impact of additional vehicle travel on the existing transportation system and on air quality should be more fully analyzed and any mitigating measures necessary indicated. We have discussed with the developers of Trillium and their consultants the general type of air quality impact analysis that should be carried out. Because of the high pollutant concentrations that may currently exist in the area of the project and because of the size of the project, we feel a detailed analysis of the impact of the project, substantiated by ambient air quality monitoring, is necessary. The parking facilities associated with the proposed development will require a permit from EPA to comply with the transportation control plan for the State of Washington (38 Federal Register 32668), and to assure the implementation of national ambient air quality standards. The proposed development may also be subject to EPA indirect source regulations which will be promulgated shortly. Whether the development will be subject to the regulations depends upon the effective date of the regulations and upon the date construction of the development is commenced. These regulations were proposed for the State of Washington on October 30, 1973 (38 Federal Register 29893). Copies of both the EPA parking management regulation and the proposed indirect source regulations for the State of Washington are attached. In addition, the EIS should address the impact of the proposed development on all existing public utilities and on the need for additional public services as a result of growth generated by the proposed development. 2 Thank you for the opportunity to review this statemen Sincerely, Attachments cc: P. Millam Hurlon C. Ray Assistant Regional Administrator for Management • rl:l:i o .Ei) aa.11. . c. 1• t � '1 :, ^.nil (h) a.) WI of tlti;; S Ctit).'t .•,r (. air (jt;nli y rat::: 1. 'a;1r. ( C. C•;:: : :('.,.. ;t..'t Cr', 1n:; ;tC11ti : :1 or (il. i,i,ij- x) :;,111)(: ta:!::'..> ibli ✓ : \ ") :: r (1) fart C1 ?)i.'. ..',1S 1rU, ;l st :.t!c'Ih.hi rut([ ?!' Of t!? -Z CfjCC. of the ]nplla:' tif•i i'i :i :•; .ii :.aTpc.: ,::1':' r,it!t .,• ! :n !i1 - .i� •1i, :1:: fri: :T' :?.111 )'.C. �'.. •. •,• ^I't'i;t i, fit_ CCri`: ' a " " •_ .._ O•' ..•(iaaalCf.tlJ❑ GI l :(; C'it. .. C•'7' f.)` ^) \'CT1i, Of Cli..:t:1i.,, a:.. P.nci r. ;Lit! :)• :l Ic : :( :..!S.i;Ll, (iC' \'!+: :•IC1 ?1 ('':t'�C :( :i!',. ) (.'•::Cli: .;lilt:.. Cr2i1tL..,,.:.. ii_l i; :Cl: ?mot :'i ::1 < :i:':C', :;.;1•:` ?t• tt- :'i':. .11:!:i !Ii .- :j, ::1't,. .. v,-h4,1, rr :i 'i:•...'.1' fi_, P. 1'wiltt of Sl :t:!) C.):.l^ t :)i;; :a. a ) (i:(Yt'.i `t6 C` :'l; "Li:. the st tit • 1 ..,, tio• f�1'= , :'I(C if':"' :1r't r'.1 ^'1' ' tii., - (e) .L': .(i:t i,)nal information, i ten :• (ii) An - :. -':'I 1. :tv r„a lyri , 2 _ec it cri le1C :C O: (':.. n_i:t,a- 1.11 ^.1l bT -' t_, ::1 1:, C1:t :- :...1..,. i'. : :'. C :•:f) 2Ca!41 t1011 1•'.t.. .L:.,, 1)•!':'_iltC)r may l'C':.lilri:. F'.)it'J:C:)o co::-ii_at'f.i.'Il: of C."+ (-1) (i)• 1,7o tkpproyr.1 to CC':? :.!1•3.'.ct or ino114 : :idc, 1':Ic.;;oclheitli %•: :; JS11:..ilt:;, It:ttl 3 ^.C':iiil• S!1 11 he rri:lht.Cd Unless the 3j)lt•• 1)it.0('.t'il O >:!d C3 foilo; :: ,;; construction c:t:zit. ,liov:s 15!':t: • or li ?:1C1fiiC (lOt. • . (() '1.'11,-.: 1:r;i::Cit 50i1CC 1'!11 L ^! : C`, *.e. (7) )Cl 1� C rcCt , o1i. t:3 other hPn i violation of the cont red „'. atc, ;y .hick roads and a(-,x, t.s, t•' : ?1in_2t'oel rt. Is part of the i :pplic :.ble pi'_3U, and . quirccl Under 1':]gr:l.ph `(b) ('i) (it) of (b) The ini :irCct source will not pre- this sect; ^a shall h;, alii :(1.s. using trl rfcre with the Stt:li111i1C))t apprOprizlio diffusion j'r(!i•1. tf. ev2t.lu:t-;` or IllnjnIC:7,.,11CC of a !ulti0_111 ambient the ill}12r ct of CZL1•i)C•'.1 li]Clr:c. :•lt7$ crnis- air (i;.,1.ia)' :•1 ::l:C...rd. Sions 1c.- ..uh23 )io:it C%,ii:.ia:ii :d1 :: :-;.ii lh:;l1 .(ii) In connection with tha c1eterm1na- vehicle trips to or from such Lonrco. Such Con 1ellu:r(:i: h:• paragr::?ll (b) (4) (1) of ',Impact shall t:; e1-a3 •te.i. _t reasona!,!a this . ion, the s11ov.in1;: regulred.c'f the rec. -!tor or expo -ure si.tcc3 in the-vicinity • applicant sha11 be limited t0 the impact, of such indirect. Source. on air (!UC.)jty fi•i• :n the indirect source: (g) Within 30 di(ys 1!f ter re:eipt of on proposal to be constructed or modified, rpplicrttion, t)'^ Director will notify the f_ti(i , 1,•. TCi. t CO 1 t t.on of exist- . public, by pl'OiilCtlt• ftlliCitiS:':11 Ilt in lag CS:)1Ci_U1:S from outer Source:. it.' :..tall the TC ^,loll affected, of' the o ;)?)irtl:lhity be tile - e3i-'.)I'i ibillty Of the Director t0 for t.. c ccment• on tae i'ift.•1'nictti0r1 d.:iermii :e t)' impact on air cjtlzlit•;; of .)„, a ,.- , c $oomitt(:o oy the own 1 O� °pme.. or. future p•0\',-t'1 and development or other (1) $UCT l(f0_m?.171, ^, v :Cil fS the fe.etor: c..Necting emissions and stir (1u 1- Director's analysis cf talc. of C . of the 111 ity n'; CP F')T1Clh the ap;)l.Carlt has no Cliroot • source on air (Ui :iity r:I1Ci the control.. : Director's prof }3sE.ti ap •ror; al or (i.(S_^.1)- . (Li) 'ii--: Director Eltall, prior to ma k- rill;: c'ctcrlltinac.ion rotr to approve Inc • pro:'al, shall be a i ails.blc in at least one • low? ti0111_,.1•1]:1 IC 1011 •i�fCC: d. const1.-oc.:`Q1 of modification of an mth.- . . •ret:t :-1.,::r (: pursuant to 1?arageaph (b) (ii) A..c :.iii:' -of the notice re ulrc-I (4) (1) 0( t•:is seet)(if C(ilsii.er 1ti) \' al- Pursuant-to this sUbpa.ra:,,:"1 :ba.i. he •111,.n n` t:ln 1-,,,:-.,,-?,:.:?‘) (-o`1Str1tction or sel]t to the I.Cart(11ist•P: iar through the r0Ca:' ':ti:.11 •:iitcl}_ v.o1ld pSrinit a)- aPi)r0iris L regional. (ilce; 16 all other .pro: t) he Director shall condition any Stat•:: and i'?3:t1 air p :l!: ?:Foil control. approval (:11 r•UCl1 alteration bfli)'1 • torn'- agencies having jurisdiction 1 1 the re- , •Cir.- the t• i T r.•• where the indirect 5On:rC(: C,•iil be 10- :1.t! -C; } :.Ora'.t�Yi is -a,' C.01•aStl'UC dCta or r_ OCii,i_.•..- ti0n,. L' (1. :' sill,; among poSsiUle [A'rc'h.,- 'and t0 any other ;,..7.en. y iii the rei•cion. t'on'-1, the Director th:,.11 give ap?r01)r 1 rte 112\'1:1~ responsibility for 1. plc! }Mini:: c0•r •idcr t :O'1 t0 any e:-fi)cnditUres of the prOCedure3 require-' under thi.=.. para- tl-'_e or inc,ncy Iluidc by the o-:;..[ ..r or rCrap11. , h• ,' (iii) Public- Comincn s sub_ Sated with- Cie a< the indirect .o.arC.c pr. :'r to ( ) "'t• . (11e ('('"ec.1.. :' Gate Of this pnri'.ITph. . hi. 30 days Of.i•ie et.t-n such information (5) For I.':. (-1Ii and 1?i.;Ihwf :)'s st:bjmt is !made avah^ble Sl}. ^.17 he co 1St .i :red 1;Y 1 11 �• mating final decision to this i) :(ii''a)i'l, the d.'.'tfriYliartt!GII 1'.'.- the 1JffcL ^ ^(, in 1)'. :.il; t1i5 (Eire: v::. .r.. par: (b) (4) (:i) of on the nil, 1ic-at:iall. tl :i, :1 ^:h: :ll be Ili..a,,. r.: fill!(,'. :s: (iv) The Diro :'to_ shall tat-; final ;G- (1) '1'i. _ ^1!'aet of a. 1-0 a:1 or 1]' 1\ =.'0Y lion on •r!n t1 ;die;- :,tf3r1 v :itlin a0 days on the t`-Y?.: v +'•r.l' in :\t1 r- pprOpli::t: -r1:a r..ftC' the ('10 the public :'CSCi1t•1)^- ;3?h;tf_d. 1Cs' an area..-wide air C :aa)it: liod. The jD :rL -ctor shall notify the np- .:1)•tt, sh-,Y.1 b: u:;Cti to (1.etermi: the p)iCant 1:1 v :. :t '.11g of hi, 'ipravP1, con.;- cllsar cc ,ir.. ei :.::icls for such ..eels Such eiti:, )rc•; ra, , ic;:i i of •h ), t- 1rez!-,.l1' • :'t (!11 :311' :..11..1-1Y:=1;; 511::11 1 ^n+1 cation, and shall S• forth his reiteso'.s for t`; :o detel'Ini :1C c ; ctt'd ra)ti)! :,]t conditional ai:pr07(t) or C--L' i1. c C•neei. . a. . _ 'Of carbon nion ):ii.20 (9) The Director ISIP. \• ,' 1;iCz•e.. ra \• r(': l) ::1t;,C1- .,c1 :l o:<i(1';tit`, and lit: `:C1 '.: ?a )i' C one! (DS 0:1 ) pro';. 11:- OxiG_. IC•1... lt( Cfilt :tdt(tol or 1`11i,an1• Clti(lil),; & ,,!l :_1!i1 3.,..,,..i.....„-, illcinciii :- t cation. source ...,', ..C'1' or op :-i C: .O C!;11C•. `Ct f?.. (ii) 11. en ':1 :•0j,,1 ?(c. till •lf,1•' :) . built ::1r ( ;l1 :'1't;' M:' :':it GSin in the t :- . f t:., ,... •cC rlcdrl .. ryir c;:lrlltt.; 1 ^1 ^sets pa c:: ;nn viii, :it.j oi: 1_ .i1r c'' tit•: :".,..t for r 3110:10..:. tat, _•l(.:1S ri.:;'., ills ^. fi'0 : :l ilIC . nn v.,01-.;.1).10 port: pr!Cr to coin 1 ?ei1'"•_. c.`'i- i:...•a •... :: :.,U(t1 troff1- \i3 ,, (!:1, n•. .I1,,r,t of c -: StrU::'.!c -'. t,.. 1 ? :^ 1r' :t :o :1. roa(i. of 1,'.1..:11','..r''.," S)?,:!i 1 C- ,...'•i •.,'(i I-,1.-. ati:i.or for .. t)' •,11!.A..1.1.1.::•:1 1 ;' -i"i ! -tt'e, 111) :: ri•_,_ !, 1i:CCi)t.)'• G: ( :. . ..it :., in s ',. 0; t t a f 11.0: •' ' + :1; f tilt; `C';.', ;;• C' .., 1'i,.._.• Ofj) i\li;'�;G :2il to C4:.. . ... Or l?](. ,.y (G) 1':. ... •'rlr . :Il)i` :Ct to (1315 )2. shall not rC1,. iii o :`:..•a or cp r, :to . i. :)i_ -i, t_:. (1''•'•111''• •ti .. riC1'- );r( <1 iii,. er ('f ti?', )'E :.•I "' :IS ;1i :li'•.r t0 C1 !•'t \'iit!I t!' :C' . con1 -r*)i stn:1••: : }' T' -!)ti i'.li ii•". :'.:, :i :1t0 encl. ions \. i1.ilh i i•(• port a Cf f; )iti1CiCl : :r' 1)ia. LS, (11) The (,io••••: -I2or of the S tfttc•..,.1111. thi:.t :arc ii: 1 :' :o: P :21 ` \:lti•'_ carry 0: :t. this r.' `lIi1.i - :`)It 1'r of (1,(' :;i f.i; \':1!)1:11 •o G: "� !ii. :'.: the (late 0f :`... :•i ' :. it :Tl i :l;• tiJ:1. 'i' „•(i < +'r_ C' : :('C :.:i('1• I2u 2f{ t', i1C.,,..•:t,: +t O. ^.!:.heft 1:: 11 (: - 12 ^tt.! throu -h i!: , a: !,i,3p 1 i:.te 1;( i+Ci;:1!rti°'trat2) :•. \`•'11"re the •t•iicy ,i,: ;- I1at..x1 15 11:-.4 an. air 1i!'•!1t :(10 :1 • cgt•Ilc ', such, roc :C 6!1':'•1 G? :1= -11ii i... the :ilprapri' :te -St :hte or, l: _ %1 i :u bail .- t:0:1,(:C'l1i- (:. °rite:} prior 10 - d-- t•n_: ?I1inati'• al'C(juirr:(iby i)arr -r .!ill (:t1 (4) of this section. )oo.73 2317: 1'1 :ed 30-20-7;;;8:45 nrnl VOL. 3S, NO. ... - :t! %$ AY. OCiC ::11. ;.0, 1973 It Is )!O 1.0 (•) amend. Part 52 c,f Choptor "I, !o) oi Co;lo of 1"t-....,1• ero.1 iZoio;o:ro.: follows: f• 5f..2o t:o.; foot parograplt 1o:tooted porooto,po oo root, porfoo fool (11) is r..Ooto,.-;.. A n:cooled, t,i 52.22 rtools Es.S . - 52.22 Yi33:-,t(-ii:o.b,:c of niitie.mol . (a) Sub000ticut to January 31, 1t173, Ado-tto:st2lor cr:ain State 1:nplontontotion pion provisions for in- suring t.li• riviotononoe of tho nationol stanclards. rel•inv:" indicates that State pions to-otoroKy do not contant 3-efazIalion3 or procedureo which ode:- cloately oetri'SS this problcm. P.ccord- . all State. plans arc disa1)provcc.1 Avith ros000t to ito:htiononoe beccio.so such plans lack cnioroeante 'proccetares • or reottlations for reviewh no. olici pre- vent:rig construction or mo:lification. of which, 1,:111 result, ilt tfl lucroase of ernissior,s from other sources of pol- lutants for the are national stzndards. The eitsaoproval opplics to t.11. States listed in Sub;iarts 13 through DDD• cf. this part. Nothing In tills soo- t:on sl-ioll.irn'allelato or ot.licrorise, vffect the "obligations of Stotes, • emission sourcoo:, or other persons with respoot to 'all portions of plans opprovcei or prontul- tiate.d under this p..ert. Pursuant to an order of .tho, U.S. Court of Appeals for t•lie District of Columbia, Circuit entered on January 31, 1073, and nrodificel on 1..ii-arel.1 12. 11173, Stote plans providing -for ruointenance of tho national stand.- . sorts roost- bo sulmiitted to the Admin- . Lstrotor no into:- tlion Attg-ust: 15, 30'13. . (b) .):.ccrolationi for revicil of rieto or toodified: ir direct source. (1) All ternts • noed in this pora,;roph but not sproolfl- co.11y defloorl holow shall have the moan- lug ivein them in 52.01 of this clito)t-cr. (1) The. tern 'indirect source" means 2. fac3iy, building, structure, or litstol-. btion, or conabirratiori thorcof, which causes oo may rousc inabilei source ac- tiO,qtY that yu to in etillsslons of a pol- lutant for which. l'oc.•ra is a l'ott.lonal , Standard. Suoh izidiree:t sources shill In- • elude. bot not belirnitod to: (c) .13=f7.11.woys told roads. ..(b) J'arldno lots ond oorages. (c) sh000'ing ccnters. .(d) Po:Lotion:11 conters and. aniuse- Trion t parlo3. (c) Sports s'•o.diooss. (1) Airports. • (g) Corrinorcial or industrial etc.:vol- . Cpoicnts. . • Te. leo:, "s.-ehiclii trip" mcoos ;Anglo froo•cnic.;.:1, r. rotor voitic•Ic. v..hich co-17.:O.o.o.o.s, or tormtriotes r..t itn scoiroo. • (in) loom "Dircotor" moans tho clircotor C tioO Stole or looal of the-Slot; to c000y out. ttos p.irr-oroph. (iv) teon o.1ci onirlOng oyes." inenos lot or io.lroo cooncci coonoo.-.0.. 1i coojuro.tioo. v.-ith io:Ocet z000ce. (v) Tiie 01-5-3rf,soolio • z'r n o'ircroft t1;-off or landing. • • f`01'0ED • (v1) '1'ho term "loo;l:ficotion" csits au1" d':onoc to on to,-;Irect. sourco or. incriou:e the sow ec octivit.y tIc)t irolOct. (vii) 'rho V:rot "Stmidard 7,1"Otropoll- tan Stotislicol .4.ror.." yr:to-to!: 1.1:01 areas no (ol by the U.S. )ojrcou of )314't in the. folio:oho: poillication: 'St ant.lard Metropoliton .F;tattsticaI .Arcs." Ooreel vcith subsequent otoonciments. (yin-) 12 o2. t-erm "cicortatecl aca" r000.ns poly aroa de..;:o,natod pursuant to § 51.12(i) of this chapter os /taxing the potential for e::cccdiu any roltion-.il standa-rcl Nvitliin the stil;-,;eouent 10 year period. (ix) The torm."area-wide air finality r.ro"000lz" moan:: a no.loro:ele • ano'osis IttiliAng -the tociutiouos spriciiiod in 51.14(c) of lids chapter. • (x) '.['lo terrro "ce»nmenced" moans that an owner or operator. has 'under- - token a continuous prooratit of construc- tion or )e±fiCatft11 or that a' binclinf,r general construction contract hrs been entered into NVItch olilioatos one party to such contract to porf.ornt the phoysic.a.1 Wor N' k ' 1 i,VV. -r 1 such proo:rain of con- struction or modification. • •(2)• requirements of this parr,- gropli are triad:: part of Sublv.1-ts )3 through DDD, except Sttbports 13, K, end AAA, ond are applicable; tothc following indirect sourcea.• the constrticUon . or ntodificotion of wine?). . L counoonced aftc.r -the offoctive clate.ef this liara- traph: • (i) Aloy indiroct souroo which is lo- cate.id in a dosignated area snd which: (a) Is a new parking lot or ioArgoe with a pexiiing capacity .of. 1,000 cars o: more, or has a ilew.associatod. area with a parking cepocity of 1,000, oars or )(lore; or • (b) Is i parking ]o or garage being modificd to increase parking caliacity by more thrin 503 cars, or hos Prl sxited larking area b,aiag to inorcose Parking oapocit., by more than 500 cars; or (c) Induces 1.000 or Inoro vebtc1e trips in any on-hour porioci or 5,000 or more Veld el c trips .1i oriy cioht•-hour period. (ii) Any indireot source leonted out-: side f'.desionated area Nvliich: . (a) Ic a new parhing lot or garage with porkino copaciiy of 2.,e)00 oars or 11:15 parkin aroa tvith R ealVCit.r. of 2,000 cars or inc.'‘re; or (b) Is a p: it: lot or being moditleci inr:o.-ase capocily tOott LOOG eoro or loo • ot-eo aroo loAng roodiflod to in- cree T capaz.:ity rotwo than 1,000 c•ors.: • . -(o) 1-tolioo:3 2,C,i0 or oie:::o trips In ony one-hour period or 1.0,100 or moro follicle trips in o.tty cioht -hour • Any To.:,..r.1 or hijol000..., in a :loot NVitli :011..;.01- crtroo-.1 eolly oroos tio't years 07 consty!yOixt ••• • (a) New road or Itif.:11vooy: 20.000 or inore volitev• oor (Toy. • . .00 lYioci:ficd road or hiolvooly: •crenso of 15,0:1!0 pr (lay or - over c):O-.iii)o, tritfile volume on such rool - or ltiohway, • (iv) Any ;;!i.p;qt e):pL,Cti..11 0701-.1A01V; Within '• years of constniction or 111:XiiliC.:1;1011: . (a) IZew airporls: 50.000 oo more or: eratir.ms por year by rcuularly air carriers. • (b) OCodifieci. airport: -Increaso of 50. 000 oporations per year by reo.,_!)::•.ri schoduleci air earriotss over the exisLitt rOitira?.01 o;)crat.ion. (v) NV1-tere en inriiroc.l, source is con-. strocted or ir.ofi i fled in increments whIci, • indivicloolly are no subject to reN-:e.•-: • too-lor this prograpil, st11 such incro- nient.o occurring isinCe til ; eirective dato •of this 1-e0ulation shall be. edded to- gether for deter.mining the .:Ipi)lic..o.t•iiitY Of .t.his parogra.1.111. • • (vi) Until the - Aclinintstrator clisig- nato3, purstotrit- to §.51.12:1) of this chapter, arees which may have the 1-----1- tetitial fer -exceoding a national stanri- ard subequent•10-yenr . riod, "Strattiard Metropolitan Stottstic::.1 Arca" shall be 'used- in place O.T. "eleoig-.. natod rca" for tho proi.:.o.,-es of -this paragraph. • (3) No owner or operator of an root sonrce subject- to this parago-o.;.:,h shall cornincrice construction or raot3i1-1"- . •cotion of such source after the effectfca dote- of this 1)ara5rapli without Enit &)- taillIng approval' f rota tic Dircei coo A o plicatioo fro: al)pOc..vol to . constrtict• or toodi.fy shall be. by ritoans proseribod 1>y • the Director, and sh11 iociude but no • be'iirnited . (i) Tor.v.irports, a eleserilition of Lvov- ge and moo:Linton in-amber cf oporat-tolts per clay by t•ype Of tiirco.,-ft'.. T1,' descript.ion. F13.311 also- include conuneocial. industrial, and trai)a;.-tr.o:to- tion-relakcl- expectod to moue within three io_ilos of the mirror: for the 10-year 1,oriod followt»g• coo- . structioo. er n-rocliflootion. (u) and hiohoor.yS, a elesez-iption of the toe and rria);i11111112 tr.:111C VOIIIII1V for one. ciglit :Ind 21-hour Vote po.rioiis c-xpOctoo: • within )0 years of construct:On or ir.o..1.1- fication. Such description incloc an esti:noto of N"cliioir.! spc:ecis for aveo-noo. an ioxrinni traff,c voloroe COPiii1;0!1,. (iii) For indirect sourcos other ...hoz,. airports.and hi..s.lo,voys, a descriotioo looation and dio.ir.n of such •sotiVC-2. l0r.:;11Ciirtg its roiatio5 . t- surrouncIO:o rcouivolys'olo-.1 1:Zol000ys arid .tfl cJoroo: o,; too over,00. find rooxiroura iooO!-..ter of voltiolo triYr-; E.r.wric.ed by such iocl!ro- -source for one. and eigot-hour ,oroo periods.. • (iv) 1.7oon roc.o.y.st or the. owncr or opottor- r.1-s' poovie.o: • (0) - -,f....to.irooto: of the effector co:-.-• struction or incolificf:tion of tho ro.oirco on pattortis and or in Cho li;•111!.t .1' of Ula • constric:tion or roo,,i;fricat•ion.. ; • cieterminiei tloit reauliit lens rulmill- ted by Al:di:owe l'ioricia, and Guinn tO t nit!. 1,0 . CFR ;■1: !corm'?, the reeule- iC1115 propo.ied lielov.• v. ould not be noon- eitati-'..SunIcisii reviev‘.• should reven1 deficiencies. in their stibreiticile. Preliminary indicatione tV that. a monliiir of other States teiil be submit; iite Wen:, pei.or to Decerober 15, ;197'3, cihieli may, in thceir..: eaecis, coon- rate the need to pi•conuliiate the propased beice.e. Should fin•i stote sulymit pion evisions for indirect source review are. apprceable after lie- cembc:r 15, •1973, the Administrator %vitt revoke his promulgation. The ye :t proposed below pro- Vide that the review procedures will be carried mit by F.1f.'It-C or .lecal alienzies designated by the Governor: It is riiceei- thet many States clo not yet-, have ruleciitate 1eiI authority to approve or disapprove construction or modification of indirect sources. EPA regulations in 40 Clilt 52.02(d). published May 31, 197, (37 Fit 10342) provide that any regula- tory provisions of a State. implementa- tion Plan approved or promulgated by EPA are enforceable: by EPA and the State and by local agencies in accordance with their assigued responsibilities tinder the State plan. 7 bus. these proposed reg- ulations would be enforeeable by St.at-e • local agencies. •ciesignated by a Governor to be responsible for hid-heel source re- • view:Since the decisions which Will have to be made pursuant td these proposed regulations ere pertinent to local. situ-A-, . Ulan% the Administrator encourages and • strongly suoporis the exercise of tins ait1- thority at the St ate nncl local V'here States are Unwilling or unable to imple-. ment these procedures., however, it will be necessary for EPA to assume the re- sponsibility. States are particularly in- . vited inclieate. in their corninepts on these propo:ied regulations, whether they • can. and implement. these regula- • Lions. It slionld be noted that these pro- po:ied renailotions do not in any way af- fect previonsiy iipprciveci or promulgated regulations applieatile to review- of sta- tionary sources. • The reguiations pro- Pose1 . helor: sOceific the use of various analytical t 'inch are consid- ered reasonable end appropriate for de- terminine the inn-fact of an indirect souree. on eir th, typo of nnino_ sis specired veries with types of indireet sou:sc.:0; and is .cic.pendent on the capabili- ties and i a1 ions of existing analytizal technicoies. • • For examole, analysis of carbon mon- oxide c'; •••:•: vaing n diffueion model, cceridecoe for the air rio.iiity impact. of roods, -waYs. and :.1.4-Nts. Existing diffu- sion iTC/iniglIC'S 0.0 not permit onelysis. of the inipaet of hydro- carbon co :coiden The; heipaet. of theco piiitants is most role- CU:tCy i.e,iiiiated fill an ar.sei..-wide boois, iog the proeinitonill tcc-h- p: •.-;. 'y :e1 for er.-r'.11t- th vv cf control strabieies. ri•etilts PROPOSED PULES • • • primarily-no eneiis Nellare the adilitional emissions resulting feoni in nut :reel. s.ouree ra-e Siencant in relation to es N.- into orea-veide this tc•hnieue is conni,iered. most appro- peictic fiir.aiiiilyeing the air quality nil-- pact of aliiiiprio„ commercial and inclestrial ceovith, and jor hielnedy -projects. Doliending on the existing- cmis:dons in the area under consideration and the size of the at the propeiivtiens.1 model may still yield ineonelusive reiallts and thus may not be applicable in all sitoations. As improved analytical teclmiques bccorne available, the types of analyse.s speeified below should be augmented or replaced by such techniques. The regulations proposed below include criteria for \ehich !:aces will be. subject to the review procedures.- These criteria are based on the follow- ing parameters:• For roads and high- ways, the expected traffic volume; for airports, the number of aircraft opera- tions by regularly scheduled air carriers; and for other indirect sources, the-size of the parking facility or t-he number of .incluced vehicle tripsi, Although other in- • clica toes of inciececl mobile source activity conlci be. used, theoe parameters are con- sidered to be most directly related to the air pollution potential of these sources. -The size of a source which, limier' the- propesed . regulations, watild tie exempt front review varies, depending on whether it is Iodated in an area Where there may be a potential for exceeding a national ambient air quality standard within the' next 10 years. The 'Administrator con- bietOrS it necessary . to devote More at- tention to such a.reas by reviewhoin smaller sources than are reviewed in non-problem' areas. A list of these areas will. be published by the Administrator • by June 13, 1974. in accercianee with the -June 18, 1973, amendments ($3 P13- to .10 Cl"1 Part 51. Until this list becomes available, all Standard 'Metropolitan Sta.-. tistical • Areas v:ill, for the purposes of this regulat1on, be considered to have a potential for exceeding the national standards. The size of an-indirect source subjeet to review has been determined in a nation- wide context and therefore does not, nee- ecsarily reflect; special lucel conditions which may cause more comprehensive review proce.clures tc. bo desirable. The Administrator stronaly el.:cot:rages States to analyze their own local situations con- . cei•ning the desirability of reviewing smaller sources than the-e speciiieci be- In this regard, Siates have submitted plans or are in the. proeess of adopt inie Piiins for eotoee 'review should not construe :illations pro- posti-ci below as bah.. oPtinial.for all situ-. ations. • . • It is partici:lolly important that Stoles and other intereeted pertics reeoinibie tiiet inore co:non:to:I:sive require- ments are Le,: C.'.5;.11-Y in crcas tieincoortation contre.1 iiviiiceres -.ell! lie neeilecl to meet 5.t:' emhient air ntelidar. 1n tircos. of cet ,:u C: is Toward thin end, paring supply • egiemeUt reaulations tail t included in many of the traneportation con.tre.,1 the extcni-, that trarinportattcoo con- trol. plans do riot include reeieloi- Lions, they will be included in'tilei) teen- lations for indirect source. review an-•i they generally will be more conlorchen- sive than this proposal, in terms o: tile. sizes v:Iii.ch will he subject to . • e pr co:di:lg./actors: indicateiwby individual State may End it desirable to develop reel:lot-ions differ nem. those proposed below, and v:liy .e... should make every effort to submit, its own indirect source review- reetdations designed to fit into its strategy for lone- •t_cirm maintenrinee of air quality stand.; ards. Eitates may also wish to broadcn such review to consider other environ- mental or social considernitions. - It is .the Administrator's intent to held hearings_ on these proposed ref:Illations in each St-ate where no State hearing has previously been 11•21d on this subject.- These hearings will be held no seoner than November 29, 1973. The time ancii locatioti . of such hearings nil/ be an- nounced in ft Subsequent VEDrAit.I. RECIS- . • • Interested 'persons may also part ici rsa. pate in this rub e! makine by submitting written comment:: in trip-livate to the ap- propriate' Re.gional Administrator. All - comments received by'Noveinber 20. 19-i3 will be considered. Receipt of •commenis - Will be acknow•ledged, but the Regional- . • Alministratiors will not .provide sub- ..stantivc rcepenses to-. irldiviclual too:, incints. Al} comments will be available ftir public inspection • during normal bus:- • ' ness hours at each Regional Office an: l :it the Freedom of information Center, • Room- 329,-401 M Street SW., Washing-' • ton, D.C. 20-1G0,. Following consideration of public com- mcnts, these regulations. %vitli•any incations which may he approp:•iate, are to be promulgatc,d by DeceMber 15, )973, purSuant to the order of tile- coin'', of . Appeals. The reaatlatio.ns 111 be en:eel:ye. 180 days after promulgation. Thi clefei-- • i•al of the . effective date is ceinsidea ed micessary to give State and )oral agenciEs an ridequftte opportunity to make peep- _ orations for linplementing -the Proee-- .durcs priiScri b rid by these proposed r u - t ions. Since the proposed regulations are intended Inlutarily •to ensile(' 'clog_ term maintenance of the national aniiii- cnt air quolity standards, and since tie:. • . Clean Air Act emphasizes the it is and lore- governments that the lir:- ',nary respolmil.:Ility for developing and eilrrying 0!_lt p!anS, deferral of the ctiective daie creel consistent with the purpiscs if tine , • Act: . • - This notice of proposed role inc,iiino 13 iFeated under the mithority of seetien 110(c) or_ the: C!'al A(:l as amended. . U.S.C. I EKc-ii(e) ). Ootobeei 23, 3973. ituEelit et000i-e, :it!, un-). \., ocroe i, V:: .` UEsuAV, CC'TCl'tI.J. : :i 30,. 1973. WAS; iiI C 1'.'N, 3L; C72 Numbor 203 • ENVIRONMENTAL PROTECTION . AGEUC'f [ 4o CFR P rt s21 • • • APPROVAL f•.;\:) PROMULGATION OF STATE IMPLU.,t:P :'iATION Review ci Indirect Sources On June 16, 1973 (33 )7R 15S34), the it rnilr'.tr•a;or• of the E wiro:tnientl Frotection .Agency (EPA) promulgated amendments to 40 CFR Part 51, Ite- quireinents for Preparation. Adoption, and Submittal of State Implementation Plans, under section 110 of the Clean Mr Act, as amended. Those amendments were designed primarily to provide for long -term- nnail:te :t trice of the notional . - Ernbtent air quality standards. Among -. other requirements, States were clir eted to expand their present procedures for review of buildings or other .facilities prior to construction or inodilleation in order to include consideration of the air . quality impact not only of pollutants emitted directly front stationary so 1 es, but also of poliut'.o:i arising front coo- - bite source activity a..sociatecl with such buildings or facilities (termed indirect sources). Pursuant to an order of the U.S. Court of Appeals for the.District of Columbia Circuit in the case of Natural 'Resources Defense Council, Inc. et al v. Ei'A, 475 . P. 2d 956 (D.C. Cir. 1973) entere. on January 31, 1973, and modified March 12 and July 27, 19'i3. States \:ore roc aired to submit plan revisions to corrply with the new rcC,ti ran nts involving i :i it- rc: t. source review by August 15, 1973 (30 Flt 12920). 'Thus far. EPA has received plan recisions from Alabama. Florida, Puerto Rico, Gl!. rn, Maine, New 'York. and Or Egon; they will be- made , vo.ii;:L..e for public cominent before EPA acts to. 'approve or disapprove them. Since i' /. will not tale action on these •revi:,ianzt. until the 30 -day pr :5lic c:nlmen'.:. period has expired, ;,m1 sin. the Court order requires ti:c: Ati :nitt':t .'-c: to prove or dis :_p•)rove su•:?: plan revitirr: by Octobar 15, 19 , tire. disapproval of all State impiementation plans with rc.sp •et .. to maintenan ~c of ;rational :,t IirttS, v.s Published March 8, 15373 Q'S !'• R. (:•.?j l), a:-d :.ir5'' vied .'ray 17, (28 12,20), r'c;... . : in effect. The Court. lu: this: reriuires, the Ad- ninisE.r;ltor to pre,:f tl fate rlgul;:t : `_Zs by 11:...r&Je 15, 19 3, :. here a Sf ax, f :.iLs Bons: or the r('! :t!l,. :!C'n 1, -.1•;trevable.'sill_ t:c:irii;'li;.t ^:E ,: Is r :wr l; :r, >,;:"•r such ri.;t'_'1;,tic,Ps. l :i:'.d on n 1.:1-ic -,f of h.? plan revl.--.1 ^J^ • • • March 1.-1074, each such owner or op- erator shall submit to the Administrator n detailed compliance schedule showing the steps it will take to assure compliance Rlth this paragraph. • (p) The City of Seattle and the City of Spokane shall report to the Adminis- trator on a semiannual basis beginning August 15, 1074, the average daily oc- cupancy of the spaces reserved for ve- hicles transporting three or more occu- pants. 32G7G ' . - RULES AND REGULATIONS • group of bt:which no commercial park- within 10 pears) from • diet any of plicable rules, application with rapt trots permitted. in .vans application: and conditions. ing is petlnit.tcd. (3) "Seattle central i)rsircss district" (3) For facilities to be located within (j) Within 30 days after receipt of an means the area enclosed by Yesler Way, • the Seattle or Spokane CBD. the con - • I: the Adntil notify or a e icy the 1-5 freeway, u;lith Avenue. Virginia struction or modification of such facility approved by Street. and the Alaska Way Viaduct. will not cause a violation of paragraphs by ominent adve riseme t the the Re- - Strets forming boundaries (excluding • (k) through 1u1) of this section. g low the I -5 freeway and the Alaska Way Via- (f) All applications for approval under a approval, the proposed actiapproval. duct) shall be part of the central busi- this section shall include the following (whether denial), • and shall invite publ. riess district (CBD). information: or na (9) "Spokane central business dis- (1) Name and address of the (1) The application, all submitted in trict" means the area enclosed by Trent applicant. formation, and the terms 1 ube ittedind Avenue; Monroe Street, Third Avenue, • (2) Location and description of the - action shall be made available to the and Division Street. Streets' forming parking facility. public in a readily accessible place with- business boundaries shall be part of the central • (3) A proposed construction schedule. in the an a re dir quality region. business district. (4) The normal hours of operation of (2) ftecte comments submitted within . (b) This regulation is applicable in all the facility and the enterprises and • 30 days of the date such fitted wit i • counties included in the Puget Sound activities that it serves. is made available shall be considered Intrastate AQCR and in the county. of (5) The total motor vehicle capacity in making the final decision on the Spokane, in the Eastern Washington- before and atter the construction or mod- application: Northern Idaho Interstate AQCR. . ification of the facility. pll e Administrator or agency ap- (c) The requirements of this section (g) The Administrator may require an roved The him shall take o final action ap- are applicably to the following parkin, application for a facility of between 50 (approval, conditional approval, or deni- facilities in the areas specified in- para- and. 249 spaces to include the informa- al) on an application within 30 days after graph (b) of this section, the construc- tion required by subparagraph (h) (1) tion or modification of which is com through (7) of•this section. • . close of the public comment period. • menced after August 15,1973: • (h) All applications under this section . (k) In addition to the foregoing re- (1) Any new parking facility with for new parking facilities with parking quirements, paragraphs (1) through (o) parking capacity for 50 or more motor capacity n'modification or more either individ- the Seattle and Spot ane CBD. within vehicles; the •(d) Any parking facility ikg c that will be tons since August 15, 1973, willlincrease numberlle of shall non-residential increase parking modified more increase parking capacity by 50 or more :rotor vehicles; .capacity by that amount, shall, in adds- spaces within the Seattle and Spokane (3) Any panting facility constructed • tion to that information required by CBD above the number .present as of u modified in increments which inunde following include the which provides or would protiide.vehicU- paragraph (f) of this tally are not subject , review under this scctio:n, but which, when all such cant alas receivea a waiver from the pro- far ingress or egress to or from a street increments occurring since August 15, visions of this paragraph from the Ad- forming a boundary of a CBD• shall be 1973, are added together, would as a total rninistrator or. agency. approved .by .the considered . included within such CBD. • • subject the facility to review under this Administrator: Any parking facility beneath a street (1) The number of people using or en- forming a boundary shall be considered section; and parking facility, regardless of gaging in any enterprises or activities to be included within such CBD. • • (4) Any that the facility will serve on a daily basis (m) On a semiannual basis, beginning • . • size, to be located within the Seattle or and a peak hour basis. February 15, 1974, the City of Seattle Spokane central business districts. Any (2) A projection of the geographic and the City of Spokane shall report to parking facility that provides or would areas in the community from which peo- the Administrator the total number of • provide vehicular-Ingress or egress to or pre and motor vehicles will be drawn to nonresidential and the total number of from a street forming a boundary of a the facility. Such projection shall include residential an- street and off-street pal.: - CBD shall be considered included within data concerning the availability of mass such CBD. Any parking facility beneath ' transi ing spaces in their respective CLD's. t from such areas. Thereafter, such cities shall report any a street forming a boundary shall be (3) An estimate of the average and reduction in the number of such parking . • considered included within such CBD. peak hour vehicle trip generation. rates, spaces • (d) No person shall commence con- before and after construction or modifi - struction or modification of any facility cation of the facility. • . subject to this section without first ob- (4) An estimate of the effect of the taining v: ritten approval from the Ad- facility on traffic pattern and flow. ministrator or an agency designated by (5) An estimate of the effect of the him; provided, that this paragraph shall facility on total VMIT for the air quality not apply to any construction or modifi- control region. . cation for which a general construction . (g) An analysis of the effect of the fa- contract was finally executed by all ap- . cility on site and regional air quality, in- such person or entity has obtained from propriate parties on or before August 15, clucling a showing that the facility will the Administrator for from .an agency 1973. be compatible with the applicable imple approved by the Administrator a permit (e) No approval to construct or modify • mentation plan, and that the facility will stating that construction, modification. a facility shall be granted unless the not use any national air quality standard or enlargament of such facility will be applicant shows to the satisfaction of the to be exceeded within 10 years from date in compliance with paragraph (1) of - Administrator or. agency approved by of application The Administrator •may this section. hitri that: prescribe a standardized screening tech- (o) By, May 31, 1974, each owner or . • ' (1) The design or operation of the nique to be used in analyzing the effect operator of any parking facility located facility will not cause a violation of the of the facility on ambient air quality. . control strate,;y that is part of the ap- (7) Additional information, plans, within the Seattle and Spokane CI3D plicable implementation plan, and will. specifications. or documents required by shall gs reserve 10 percent facility of for veh clew be consistent with the plan's VMT the Administrator. reduction goals: (D Each application shall be signed by transporting three or • more occupants .(2) The emissions resulting from the • the owner or operator of the facility, between the hours of 7:00 a.m. to 7:00 design or oPeratitoi of the facility will • whose signature shall constitute an m., Monday through Priciay, exclud- not prevent or interfere with the attain - agreement that the facility shall be of cr- p' legal.. holidays. On or before • ment or maintenance of any national atcd in accordance with the design sub - ing • FEDERAL REGISTER, VOL. 38, NO. 227 — TUESDAY, NOVEMBER 27, 1973 to the Administrator. (n) No person or entity, after Novem- ber 19, 1973, shall commence construc- tion or modification of any new non -resi- dential parking facility rn tha. Seattle or Spokane CBD, nor shall any person or entity. take any action having the effect of creating. new non - residential parking spaces in such CBD, unless and until § 52.2486 Management of parking sup. ply. . (a) Definitions: (1) "Parkin; facility" (also called • "facili y ") means a lot, garage, .building, • or structure, or combination • or por- tion. thereof, in or on which motor ve- • hicles are temporarily parked. (2). "Vehicle trip" means a , movement by a motor vehicle that or i i- .nates or terminates at a parking facility. (3) "Construction" means fabrication. • ' erection, or installation of a parking fa- cility, or any conversion of land, build - ings, or structures, or portions thereof. for use as a facility. ' (4) "Modification" means any charga • to a. parking facility that .increases cr • may increase the motor vehicle capac: :y of, or the motor vehicle activity associa- ted with, such parking facility. . • (5) 'Commence" means to undertake a continuous program of on -site con- struction, or modification. • (6) "Parking space" means any are:L or space below, above, or at ground 1evJ'.. open or enclosed, on- street or off - street. that is used for parking one motor ve- hicle at any time. (7) "Residential parking facili:y" means a parking facility the use of is limited exclusively to residents (and guests) of a residential building or R 27, 1973 CITY OF TUKWILA DRAFT ENVIRONMENTAL IMPACT STATEMENT FOR TRILLIUM A COMMERCIAL AND BUSINESS COMPLEX TUKWILA, KING COUNTY, WASHINGTON PURSUANT TO: WASHINGTON STATE ENVIRONMENTAL POLICY ACT OF 1971 Chapter 43.21C.RCW CITY OF TUKWILA, WASHINGTON_ Ordinance No. 759 Date FRANK TODD Mayor • By. DELBERT F. MOSS Planning Coordinator SUMMARY SHEET Nature of this Report: Draft Environmental Impact Statement Sponsor: City of. Tukwila Planning Department 6230 Southcenter Blvd. Tukwila, Washington 98067 Delbert F. Moss Planning Coordinator Type of Proposed Action: Administrative decisions by the City of Tukwila in review of proposals and permit approval, for the construction of. Trillium, a commercial and business complex, by the Maguire Partnership. Official *Title of the Proposed Action and Summary of the Proposed Action: Official Action — Permits to be granted: Building_ Permit Sewer and Water Permits Permits to power, natural gas, and telephone utility companies for use of City rights-of -way in providing service .. to the subject area. b. Other Official Action.- Review: . Review of the State Department, of Ecology Flood Zone :. Permits by Public Works Director. 2. Review of the State Department of Ecology Air Quality Division. 3. Review of plans, site plans, elevations and landscaping plans by Board of Architectural Review. 4. Review of curb cut locations by Planning Commission. c. Summary of Proposed Action The purpose of the proposed action is to undertake all review and permit procedures necessary for the construction of a commercial complex in Tukwila, Washington. Summary of Environmental Impacts: Topographic /Geologic Impact. The topography of the subject site was previously altered when the site and the contiguous lands were committed to urban uses. Land - fill on the subject site was placed in a manner consistent with good engineering geologic practices. b. Hydrological Impact Increased impervious surfaces will increase storm runoff quantities, contributing only in small part to the overall drainage problems associated with the Green River System. Runoff from the project site will contain hydrocarbons, oils and particulates washed from paved surfaces. c. Biological Impact The biological impact of the proposed project, although identifiable, will be small compared to previously completed projects in the Valley. A bird foraging habitat will be eliminated; however, elimination of the habitat can be viewed essentially as a replace- ment of one man -made habitat with another. . Air Quality Impact Concentrations of suspended particulates in the atmosphere can be expected to temporarily increase during the construction phases. Increased traffic resulting from the completed project will cause increases in all vehicular contaminants. e. Noise Impact The ambient noise levels of the surrounding commercial community . will be increased both during the construction phases and when the proposed complex is fully operational. Social Impact The commercial and business development that will result from the proposed action represents a deviation from present development in the immediate vicinity in that the proposed project will integrate a diverse but functionally related group of commercial and business activities within a single complex. The resulting office building, hotel, financial center, shopping, recreation and entertainment complex will be unique to the region and will offer the benefit of reducing dependence on vehicular transportation necessary to, participate in the same activities in dispersed locations. Impact on present traffic conditions in the immediate vicinity, however, will be significant and will necessitate the upgrading of street . signalization and possibly channelization. "The complex will be the most exciting and unique major development in the Northwest. The close proximity of the project site to major vehicular systems,. the Seattle-Tacoma International Airport, and to a growing commercial, industrial and retail - center suggests development of a unique combination of enterprises and functions. The complex will combine first class office space, commercial /retail space. for banks, savings and loans, brokerage firms, etc. A first class hotel of 300 rooms, and a multi - level retail and enter- tainment concourse. The concourse will contain theaters, an Ice Capades Skating Chalet, restaurants, specialty shops, a recreation facility containing handball /racquet ball courts, exercise rooms, and sauna /jaccuzi facilities. This mixed use concept will provide an urban vitality to the entire region that otherwise might not occur, given the present trend of land use. Furthermore, by combining functions, a synergistic effect is possible. The interaction of people, parking systems, landscape, building masses, and other functions taking place on one relatively small site will create urban excitment not ordinarily fbund in most cities. Imple- mentation of the mixed use concept will enable each enterprise to command a higher economic return in a collective manner than standing alone. The planning concept of the developers and the architect was to develop separate but interdependent functions: connected and related by a series of landscaped pedestrian plazas and malls. The specific . site planning objectives were to insure that each use would function in all aspects (identification, parking, and servicing), without compromising any other use, yet in the final result would effectively act as a completely interrelated unit. A coordinated palate of materials has been selected for the entire project. All opaque surfaces (walls, parapets, land - scape elements) will be of a muted warm tone masonry. All glazed surfaces will be solar bronze glass with flush fenestration. All public spaces.(i•nterior and exterior) will be treated uniformly with respect to landscaping, lighting and paving, the objective being to create a natural, humanly scaled expression of the basic project materials. Signing and advertising will be restricted to only basic major . functions and will be subdued. As an indication of the intended construction specifications, the office structure will be a fire -proof steel structure with composite beams and an anodized aluminum curtain wall. Mechanical systems will provide control and temperature response equal to or better than general northwest standards. All public spaces will be finished consistent with the overall project description. Tennant spaces will.. be provided with ceilings, partitions, electrical, lighting, and surface finishes, consistent with or better than presently offered in the Seattle market area. Elevators will be geared with a maximum interval of 30 seconds with cab finish consistent with the.overall project criteria, i.e., warm materials, ample lighting, etc., The Gallery will be of fire - proof . exterior masonry wall construction, steel.frame roofs, with air conditioned mall and retail space, entirely sprinklered:" Figure B gives a general illustration of the overall project design and Figures C.D, E and :F depict the plans in greater detail. The phases of the planned development and the available square footage of the different facilities is listed in Chart 1. • - • FIGURE B = B R / A R F W A 4111 71A‘ 'X't 10A ■ NO rel.- • n . s...: r� ....tro:t::'h.Sii�:..!Ji�4a���.� �.Y NJ'e!`:;...0(.ti- ...f•.�'#�l BURKE KOBER NICOLAIS ARCHULETA &&&&& 11111 t0O•• •.t.A. • •••OLO J. MO". A.J.A. Mt 11S 1 No MAW& 01■.J..t. 1.88 .tW.1 Lumeir _/ ONO1 Ot NWT MOM W1 IWO.a CM/OWA A,i_ SWAM W so. s 4.7 1O79 c. v.& T/ T PA3 Y L CCMPLEX SCUTHCENTER Tyr t. A.'AABMIM OTC. suu W _Moo 1M._ FI -GURE C BURKE SOBER NICOLAIS ARCHULETA •I ••• 1•• • •e•u•• f•■•• •.t.•. •I••r••• •.B.•. w w. ••••• wear was c.1 — I IN= •• POW wen. w •■•■m t••• w. i ww•• — . N POCK �i'M��Y R .E re[. MAGUIRE COMPLEX SSSQJT- CENTER fnsn.G.o,+ . mom. __. doe SO MI• FIGURE D = = bang BURKE KOBER NICOLAIS ARCHULETA • SSSSSS• SO••O •.•.•. . •IO••••• •.I.•.' MI ww•• •••w•IVA. w /MM. O••ew• MIR i MIMS as von men, w 1YQY Or•ar / M.+ u IL AZA L. EYGL �LhN o•c•2111 n •.� • SFDT MTS T1- IEMAGUI2ECOAP_L -.x .i1'4:__� +• Tl1KWILA , NOSHING row • FIGURE E K'COW t CM r;ON pOATM .n TN .RdTlas' • •- 00K'^10 N2°•7"Z OTCL ATIGG ALA, •nrcwo BURKE KORER NICOLAIS ARCHULETA •••• I••1 1•• 1.1••1•• ••.1•• O.•.L.• go... •.1.4. ■IOOL•t• •.l.•. • VI O •• mamma 1•• maw* ...or / fl /•C 1T T w 1•1x1.. fl r / w.= CGG ✓r• r /OWS ANO Cr /ON O® Or ..n � StDT 1975 Ti-E MAGUIRE COMPLEX O SCUTHCENTER TUKW141 WASI/IJOTON . . r••d M.011.02116. I.• FIGURE F CHART FACILITY AREAS OR CAPACITIES Development Phase Land Use Area (S.F.) Gross Net 1. Office Building 22,500 s.f. /floor x 9 upper floors 88% efficiency 202,500 178,200 Commercial Bank 6,500 Other Financial 6,400 Lease around Motor 1,606 Core Commercial 112.191 1 11. Other Commercial Facing Street 2,400 Within Mall 2,100 Within Mall. 8,215 12,715 Retail Retail Area - 75,000 • Restaurants (3 @ 5000) 15,000 Theatre - 1100 seats 15,000 Commercial (Health Club) 10,000 Ice Rink 25,000 140 , 000 II1. Other Commercial Under Hotel 2,100 Hotel - 308 rooms 308 rooms Coffee Shop 110 seats Dining Room 150 seats Cocktail Lounge 125 seats Specialty Restaurant 180 seats Ballroom 500 seats Meeting Rooms (4) 4,000 s.f. IV. Office Building "A" 200,000 Office Commercial - ground floor Retail Office Building "B" 200,000 Office Commercial - Ground floor -10- 185,000 15,000 30,000 185,000 15,000 4. Justification for the Proposed Action The proposed action is in accordance with and represents the lawful implementation of previously determined City of Tukwila policies as embodied within official plans, ordinances and resolutions. 5. Proposed Method of Financing and Financial Sponsors The proposed action, as a series of administrative actions, will entail no expenditure of public funds outside of those normally required to support city administrative processes for a project of this size. The commercial and business development of the project site, occurring as .a consequence of the proposed action, will be financed with private capital. 6. Historical Background and Past Planning Decisions a. Land Use The subject area lies within the lower Green River Valley. Farming began in the Nineteenth Century with dairying as the predominant land use in the valley. Truck farming was also carried on, but high water table and poor drainage minimized this use. Agricul- tural use remained dominant until the 1950's when industrialization of the valley lands began. This industrial growth was stimulated by a number of factors, but one of the most important was the proximity of transportation systems which have historically been routed through the Green River Valley. Geography sets severe constraints on the location of transportation routes in the Puget Sound Region. Seattle responded to the early predominance of Tacoma as the major rail -. road terminus on Puget Sound with the building of the Seattle and Spokane Railroad Line which later became part of the Chicago, Milwaukee, St. Paul and Pacific Railroad's main line up through the Duwamish, and the lower Green and Maple Valleys. In the late 1800's and early 1900's other railroads, i.e. the Northern Pacific and Great Northern, and the Milwaukee and Union Pacific built nearly parallel tracks through the Green River Valley on routes connecting Tacoma and Seattle. These railroads were supplemented by a system of highways constructed in the first quarter of this century. The move toward industrial development in the valley began when - planners for the Port of Seattle suggested an ambitious scheme to turn the Duwamish and Green River Valleys into a large industrial complex complete with a. shipping canal to service the area. Local communities countered this proposal by annexing large land areas and imposing their own industrial zoning on the land. This zoning in the valley, plus high increases in residential and commercial development on the adjacent hillsides, and the subsequent building of the freeway system (again to some extent dictated, by geographic and topographic features) all contributed to the present rush of industrial and commercial development that is not expected to abate for several more years. b. Flood Control Prior to 1900, the Green River, with two tributaries, the White and Black Rivers, flowed northward through, and frequently across, the valley floor. The Black River was the outlet for Lake Washington, Lake Sammamish, and the Cedar River basin. In 1906 the White River changed course during a flood and was thereafter permanently diverted into the Stuck and Puyallup Rivers. Construction of the Lake Washington Ship Canal in 1916 resulted in the lowering of Lake Washington, permitting the Cedar River to be turned north into the lake and shutting off flow through the Black River. With flow through the Green River Valley thus drastically . reduced, use of the valley floor for farming became more feasible. Farm owners, individually and by districts, constructed low dikes along the Green River, which, while not effective against major winter floods, did permit the land to be worked earlier in the and later in the fall. Drainage District No. 1 serves the area within which the subject site occurs. In 1962, Howard A. Hanson Dam was completed about 30 miles up- river from Auburn. The Eagle Gorge was the best available site for storage and was utilized to its maximum practicable capacity. Major floodflows were reduced to the maximum capacity: of the river channel within its existing dikes, which is less than 12,000 second - feet at Auburn. By the way of comparison, a natural flow of 24,000 second -feet occurred in. 1933. -12- During the 1960's, the Soil Conservation Service, in conjunction with the Green River Flood Control Zone District (administered by King County), completed planning for a valley drainage system. The network of channels, large capacity pumping plants in the Valley and selected land selected hand treatment measures operate to preserve favorable hydrologic conditions in the upland. During storm periods interior valley drainage will be pumped into the Green River at several locations. The main pumping plant at the mouth of the Black River, was completed in 1972. In the near future, as the drainage discharge from this and other pumping plants adds to the controlled flood release from Hanson Dam, the existing river channel capacity could be exceeded during extreme flood conditions and simultaneous- abnormal valley storm runoff. This was recog- nized in the Soil Conservation Report on the drainage system. The U. S. Army Corps of Engineers was authorized by Congress to initiate a flood control study of the Green - Duwamish River in 1960. In 1966, with the cooperation of King County, the study was revised to include investigation of the possibility of reducing flows as controlled by Hanson Dam and increasing channel capacity from Auburn to the Duwamish turning basin to accommodate increased flows resulting from the SCS project. Study funding terminated in. 1968, but resumed in July 1970. The Corps has investigated alternative flood control measures and integration of ..these with enhanced opportunity for recreation. Further action awaits a King County investigation of the potential influence of flood control implementation upon land use patterns in the valley. c. History of Commercial and Industrial Development Historically, the growth 'of the City. of Tukwila has:related closely to the growth and economic prosperity'of the Seattle . metropolitan area. At the time of incorporation in 1:908, Tukwila was a small, thriving trade center astride the main Seattle - Tacoma. Highway, but construction of alternate routes by passing Tukwila, the East and West Highways and Route 99, left this town with a declining.commercial base. The construction of two interstate freeways converging in Tukwila provided excellent: accessibility to the. study area The annexation of a large area of bottom land to the south of the city dramatically increased the potential for industrial and commercial development. During the interval of 1966 through 1968, the Seattle metropoli- tan area as a whole experienced accelerated economic and population growth in part due to the Boeing Company's decision to establish three new centers employing 7,000 to 20,000 persons. Two of these centers were located in the Green River Valley. This increase in employment and rising land values created a more accelerated urban spatial growth pattern in the vicinity of the study area than might otherwise have occurred had the area not received this input. Also during the last six years, construction was completed on the. Southcenter Shopping Center, and construction was initiated for Andover Industrial Park. Thus, within the Green River. Valley, the present pace of urban expansion is due to: i) a flood control dam on the upper Green River in 1962, ii) the existence of a freeway and rail corridor, iii) The Boeing Company aerospace facilities, and iv) the Southcenter regional shopping center and the contiguous industrial park. Relationship with Existing Laws, Policies and Plans a. City Laws City Ordinances prescribe that the following permits be issued and the following review procedures be undertaken with regard to any proposed land. development: 1) Permits a) Building Permits (ORD. 578, S.1, 1969; ORD 678 (part), 1971). Sewer and Water Permits (ORD. 264, S.2, 1958;. ORD. 342, 1961). Permits to power, natural gas, and telephone utilities for use of City rights -of -way (ORD. 486, S.3 (A), 1967). -14 Reviews:. a) Review of State Department of Ecology Flood Zone Permits by Public Works Director. Review of storm drainage system discharge by Public Works Director. Review of plans, site plans, elevations, and landscaping plans by Board of Architectural Review at a public meeting (ORD. 635, ORD. 251). Review of curb cut locations by Planning Commission at a public meeting. The proposed development meets the requirements of the City Zoning Ordinance. It is located within CM Zone (Planned Industrial Zoning District) and all construction is subject to the controls of that district. Other Laws An compliance with R.C.W. 86.16, Flood Control Zones have been established throughout the state. The proposed site is within the Green River Flood Control Zone District (Flood Control Zone 11). All projects within this zone must be issued a flood zone permit by the State Department of Ecology. The King County. Department of Public Works, Division of Hydraulics, has traditionally reviewed applications for flood zone permits in King County on behalf of the Department of Ecology. Development in this zone, including the proposed site, is guided by a comprehensive storm drainage plan for hillsides and valley floors. Also,the Department of. Ecology (DOE) has passed an amendment to Chapter 18.24 of the Washington Administrative Code which will review of complex sources of motor-vehicle related air contaminants. Complex sources are facilities, buildings, structures or installations which may result in violations of ambient air quality standards for contaminants emitted by :motor vehicles. Under the proposed amendments, .. if the construction or modification would present a substantial likelihood of motor vehicle related air quality violations, permission to build would be denied. _15_. c. Policies and Plans The commercial complex that will occur as a result, of the proposed action Will be consistent with local land use policies and plans. . The Tukwila Comprehensive Plan notes that Tukwila is part of the Seattle Metropolitan area, and its growth is predicated on the continued growth and prosperity of this larger region. Tukwila is once again becoming a trading center and is serving a regional market with the construction of several industrial parks and the Southcenter Regional Shopping Center. The Tukwila Comprehensive Plan adopted in 1962 provided.a basic rationale for development along the Green River which is still somewhat applicable today. At the time of adoption, the Tukwila Comprehensive Plan recommended use of the Green River Valley Flood Plain, including the project site, for industrial purposes. It was noted that while filling is usually necessary to develop these sites, large valuable, flat . industrial sites can be created. As noted previously, several industrial parks and a regional shopping center have been built within the last .6 years. Development on two of the largest remaining sites is scheduled in the near future. . The development of the project site for commercial . purposes will also be consistent with current regional plans. The Puget Sound Governmental Conference (PSGC) has shown that the proposed site lies on land designated for commercial development on the interim.. Regional Land Use Plan.. 8. Public Participation Incorporated within the administrative procedures which comprise the proposed action are a number of public hearing requirements. The proposed action implements adopted City Policies as embodied primarily in Council Resolutions, the Comprehensive Plan, the Comprehensive Zoning Ordinance and other provisions of the Municipal Each of these has been subjected to public review during the normal course of adoption. Public participation has been an important part of the decision making and policy adoption by other agencies having for planning and implementation of policies influencing development in the Green River Valley. As an example, the Corps 'of Engineers has conducted a series of public hearings in conjunction with their investigations of alternative flood control measures for the Green- Duwamish River described above. The Puget Sound Governmental Conference, the regional planning agency, has invited citizen input in the formulation of the Interim Regional Development Plan. Actions Remainind for Implementation The actions remaining for implementation of the proposed development of commercial and business complex are the administrative reviews previously described. B. Existing Conditions 1. Existing Natural Conditions a. Topography and Geomorphology The subject site is situated on the western border of a mature floodplain which expresses itself topographically as a broad flat - floored valley delimited by Tukwila and Riverton Heights uplands on the north and west as well as the Renton Highlands area on the east. Relief on the floodplain is generally less than three feet. Regional relief is 400 to 600 feet. The project area has a mean elevation of approximately 35 feet. In addition to extensive and ongoing filling for land development, the valley's natural topography has been altered by construction of flood control levees. Highway cut and fill, and railroad . embankments constitute additional alterations. . Geology (1) Geologic History During a portion of pre - glacial time, the Puget Sound lowland a subsiding basin along a broad coastal plain that extended eastward and covered part of .the .area . now occupied by the Cascade Mountains. After a period of marine sediment deposi- tion the seas retreated and continental rocks were deposited. Initially volcanic rocks were abundant; however, as volanic activity subsided, a broad plain similar to modern deltas developed. Peat, which later became the coal that has been mined in the lowland, was formed adjacent to rivers on this plain. After at least two periods of uplift and erosion, glacial sediments began to be deposited during. the Pleistocene Age. At least four great ice sheets advanced over North America during the Pleistocene Age. The Puget Lobe of these ice masses advanced to just south of Olympia. During the last glaciation (Vashon) approximately 3,500 feet of ice covered -18- the subject site, and obscured much of the rock record of . older glacial events. Glacial erosion deepened pre - existing river valleys and produced the Lake. Washington and Lake Sammamish basins. Puget Sound near the subject site was deepened to as much as 1000 feet below the present sea level. Where the ground was not markedly excavated by the overriding ice, it was shaped. Within the Puget Lowland, many of the elongate hills owe their form to glacial shaping. As the Vashon ice retreated, ice - marginal rivers flowed into ice - dammed lakes. The ice continued to retreat, and when the Strait of Juan de Fuca became ice -free the ocean invaded the lower Green River Valley. Sediment from the Green and Cedar Rivers kept filling the valley; however, an arm of the sea remained until about 5000 years ago. With the retreat of the last ice sheet the Green River again flowed northwesterly into Puget Sound. This river developed a broad floodplain with small tributaries draining upland areas. Drainage of the ice - sculptured uplands was sluggish and vegetation thrived as evidenced by peat bogs and the relatively low relief on the plateaus. The floodplain of the Green River also developed numerous boggy areas. (2) Soils The entire study area was covered to.a depth of approximately .ten feet several years ago. The fill materials are a fairly compact mixture of gravel, sand,•silt, and clay... Locally, less compact wet spots are present where depressions in the fill have allowed ponding of surface water. Along the western margin of the study area Rifle Peat andv Puyallup Silt Loam underlie the fill. The remainder of the area is underlain by Woodinville silt loam except for an exposure. of Sultan Silt Loam near the southern boundary (see Figure G). -19- 8 Li 17-Te. .i Pe' 4ran4er 61 vc1 Wocachnv1116, -1- )Darn /11•••1 ®•■■■.e ®o0•••••• _ air ■■■■■■■■■■.....- .-r One. SUBJECT SITE SOILS FIGURE G -20- Virgin Rifle Peat soils are water - saturated and support swamp vegetation. Typically the upper 16 inches consist of dark reddish -brown woody peat with abundant roots in the upper few inches. Between 16 and 24 inches the organic matter is more highly decomposed and ,.colloidal than in the surface. layer. From 48 to 70 inches the peat is more compact and consists largely of sedge, reed, and root remains surrounded by colloidal organic matter. Below 70 inches the soil is even more highly colloidal. The depth to mineral soil is highly variable. When drained, Rifle Peat is one of the most productive soils for leafy vegetables. When drained, peat areas often settle several feet. Puyallup Silty Loam soil is . characteristic of low valley bottom lands, but contains less organic matter than peat soils. The upper ten inches of this soil is smooth and loamy with a fairly high content of organic matter.: Below ten inches there is an abrupt change to light gray-brown colored inter- stratified sand, silt, and clay, with blue and gray mottling. Between. 24 inches and 70 inches,1ight bluish - gray sands mottled by reddish iron stains are common. This soil has high fertility and is especially suited to growing leafy vegetables. The sandy portions of the soil profile.. enhance the effectiveness of drainage ditches. Woodinville Silt Loam is another low bottom soil. It is frequently flooded and may remain saturated for a large portion of the year. The upper 12 inches of the soil has a dull -brown color with finely divided organic matter.com- prising 25 to 50 percent of the soil. Beneath the surface layer up to a depth of 24 inches is a laminated light- brownish- gray silty loam, mottled with iron stains, and containing brown organic remains. Below 24 inches is -a thick- bedded light brownish silty clay. Local interstratified peaty layers are common. It is difficult to drain this soil; however, when it is drained, it can be as agriculturally productive as the Puyallup Silt Loam. Sultan Silt Loam soil occurs in small areas distributed throughout larger stream valleys. Surface drainage is fair to good, however, internal drainage may be slow. The surface ten inches tends to be a grayish or medium brown silt loam. Between 10 and 24 inches brownish -gray silty clay loam mottled with iron stains predominates. Below 24 inches the soil is light brownish gray, laminated silty clay loam mottled with yellow and rust brown colors. This soil is moderately to highly productive for grain and vegetable crops. Even with the low rate of water intake of artificial fill, the subject area is moderately useful as a groundwater recharge. area. Good water - bearing strata (aquifers) are present beneath the site. c. Hydrologic Conditions (1) Surface Drainage During the rainy portion of the year., a number of areas on the subject site are subject to ponding. Such evanescent ponds are indicated by cracked and lined surface depressions as well as plant species which are typical of wet areas. However, no standing water was observed on or near the subject site during the period of observation in July 1973. Drainage of the surface water off of the subject site is through culverts and drainage ditches to the Green River in accordance with the Flood Control District and the Master Plan of the City of Tukwila. (2) Water Quality Since the subject site lies within the Green- Duwamish River watershed, and surface runoff from the site eventually enters the river system, which flows about one mile to the east. The Green-Duwamish River undergoes its most critical bio- logical, physical and chemical stress in summer months. In the vicinity of the proposed project, the river's high summer temperature and low flows result in major physiological stresses on aquatic organisms. During a one -month study period in the summer of 1972, water quality analyses were made at two locations on the Green River. The first location was at the Kent 212th Street Bridge, which lies upstream from the project site. The other location, the Renton Junction Bridge, lies downstream from the project site. The data obtained provides a basis for ascertaining what changes occur in this stretch of the river and also aid in an assessment of the river's capacity to absorb these as well as future changes. The stretch of river between the above two sampling locations is classified as Class A waters by the Washington State Department of Ecology. Whether or not a water body meets the classification is dependent on an analysis of individual parameters. Data for this river stretch and analyses for individual parameters are included below. In order to meet Class A water temperature requirements, temperature values must not exceed 18.3 °C (65 °F). The data in tables 2 and 3-- variable 1, show a temperature of 15 -20 °C with a mean value of 17.5 °C at the. Kent station and 17.7 °C at the Renton station. However, with temperature values reaching. 20 °C at both stations during the study period, it may be concluded that the river often exceeds thermal capac- ity limits as defined by the Department of Ecology. Mean temperature values are only slightly within the standards. Average dissolved oxygen values, Tables 2 and 3 -- variable 2, exceed the Class A water standard value of 8.0 mg /1 (milli- grams /liter). Since the average value'for.the upstream (Kent) station (8.5 mg /1) is slightly higher than the downstream (Renton) value (8.2 mg /1), an average oxygen loss of 0.3 mg /1 occurs as the water passes through this stretch of the river. Average biological oxygen demand (BOD) values, Tables 2 and 3-- variable 7, of 2.3 mg/1 at Kent and 1.9 mg /1 at Renton, although within tolerable limits, indicate .a 0.4 mg /1 average loss occurring between these two stations. Since both the average dissolved oxygen value and average BOD value at the Renton station are lower than the Kent station values, this supports the hypothesis that this stretch of the river may be loaded slightly beyond its natural BOD tolerance. The drastic BOD fluctuations occurring in the river suggest that BOD load discharges into the upstream part of the river are periodic rather than constant. Average Kjeldahl (total), nitrite and nitrate nitrogen con- centrations, Tables 2 and 3-- variables 9, 11, and 12, are relatively low at both sampling locations. Similarly average total phosphate, hydrolizable phosphate and orthophosphate. concentrations (Tables 2, 3, 4, and 5-- variables 13, 14, and 15, are also relatively low. Average chlorophyll A values, Tables 4 and 5 -- variable 22, are relatively high. While blue -green nuisance algae (Figures G and H ) do not dominate algal species populations during summer months, their presence in substantial numbers is of some concern since they reflect eutrophic conditions. An analysis of the above parameters, except temperature, supports the following conclusions: Most of the . decrease in average oxygen values between sampling locations (0.3 mg /1) is due to biological uptake since there is also a net decrease in average BOD values at the downstream site (0.4 mg /1). Since a river renews its oxygen content via photosynthesis in the waters and gaseous diffusion from the . aerial environ- ment, it appears that the input rate from these two processes is less than the biological uptake rate in this stretch of the river. Further, while nitrogen and phosphate concentra- tions are relatively low, chlorophyll A values are quite high. This indicates that uptake rates of these inorganic nutrients must be relatively high otherwise these large chlorophyll A values could not have been attained. Also the presence of substantial blue -green algal populations is of concern since an increase in their populations would impart a "slime" appearance to the river and, subsequent to their death, would reduce dissolved oxygen concentrations by increasing BOD loads and at the same time cause an unpleasant odor to be released from the river. Thus, it appears that the river is slightly beyond its natural BOD tolerance and that any increase in the discharge of inorganic nutrients (nitrogen and /or phos- phorous) or organic matter into the system from any source could be detrimental to the viability of the river. STATION 4 RENTON JUNCTION Variable Standard No Variable Number Average Deviation Maximum Minimum Median Range 1. TEMP 30 17.657 1.264 20.000 15.000 17.800 5.000 2 DO 30 8.188 0.339 8.890 7.480 8.210 1.410 3 PH 30 7.385 0.104 7.600 .7.140 7.380 0.460 4 TOT ALK 29 40.369 3.226. 44.200 . 31.200 41.100 13.000 5 BICARB A 29 40.369 3.226 44.200 31.200 41.100 13.000 6 COND. 30 128.667 21.103 175.000 78.000 129.500 97.000. 7 BOD 18 1.922 0.919 4.200 0.410 1.765 3.790 - N 8 TURBID 30 3.630 , 2.448 14.000 1.300 3.300 12.700 v. 9 KJ NIT 27 0.447 0.374 2.200 0.180 0.350 2.020 10 NHO 30 0.075 0.1.03 0.590 0.020 0.050 0.570 11 NO2 -N 13. 0.016 0.014 0.060 0.010 0.010 0.050 12 NO3 -N 30 0.364 0.094 0:600 0.210 0.380 0.390 13 TOT PO4 13 0.126 0.029 0.190 0.030 0.120 0.110 14 HYD Poo 30 .0.149 0.056 , 0.390 0.090 0.130 0.300 Table N STATION 5 KENT.212st BRIDGE Variable Standard No Variable ` Number Average Deviation Maximum Minimum Median Range 1 TEMP 30 17.543 1.406 20.000 14.500 17.500 5.500 2 DO 30 8.545 0.510 9.700 7.360 8.555 2.340 3 PH 30 7.380 0.110: 7.600 7.100 7.370 0.500 4 TOT ALK 29 37.228 3.039 41.700 29.100 38..100 12.600 5 BICARB A 29 37.228 3.039 41.700 29.100 38.100 12.600 6 COND 30 110.367 13.512 137.000 78.000 112.500. 69.000 7 BOD 18 2.309 0.957 4.280 0.420 2.245 3.860 8 TURBID 30 3.577 3.442 19.000 0.600 2.400 18.400 9 KJ NIT 27 0.422 0.236 1.370 0.100 0.400 1.270 10 NHO 29 0.081 0.034 0.190. 0.020 0.080 0.170. 11 NO2 -N 13 0.012 0.004 0.020 0.010 0.010 0.010 12 NO3 -N 30 0.316 0.119 0.830 0.140 0.320 0.690 13 TOT PO4 13 0.134 0.036 0.190 0.090 0.120 0.100 14 HYD PO4 30 0.140 0.047 0.230 0.060 0.130 0.170' TABLE 3 STATION 4 RENTON JUNCTION Variable Standard No Variable Number Average Deviation Maximum Minimum Median Range 15 ORTHO P 30 0.110 0.057 0.330 0.060 0.100 0.270 16 COPPER 29 0.020 0.015 0.070 0.010 0.020 0.060 17 LEAD 2 0.100. -0.000 0.100 0.100 0.100 0.000 18 ZINC 29 0.009 0.006 0.031 0.002 0.008 0.029. ,;, 19 MERCURY 2 0.200 0.000 0.200 0.200 0.200 0.000 oo 20 T COLIF. 30 39959.000 69858.125 215000.000 400.000 4125.000 214600.000 21 FECAL CO 29 763.379 2304.716 12000.000 15.000 130.000 11985.000 22 CHLORD A 30 4.300 2.145 9.810 0.910 3.770 8.900 TABLE 4 STATION 5 KENT 212st BRIDGE Variable Standard No. Variable Number Average Deviation Maximum Minimum Median Range 15 ORTHO P 29 0.105 0.044 0.240 0.060 0.090 0.1.80 16 COPPER 29 0.028 0.035 0.190 0.010 0.020 0.180 17 LEAD 2 0.100 -0.000 0.100 0.100 0.100 0.000 18 ZINC ' 29 0.010 0.009 0.045 0.001 0.008 0.044 N 19 MERCURY 2 0.200 0.000 0.200 0.200 0.200 0.000 ' 20 T COLIF 28. 39145.105 88073.750 445000.000 250.000 3500.000 444750.000 21. FECAL CO 26 .659.039 1357.757 5500.000 24.000 187.000 5476.000. 22 CHLORO A 30 5.095 3.317 11.900 1.070 3.965 10.830 TABLE 5 0 - , >; es - . i. .1 • i. ' • 1. - ., :..__ /- ‘ _ - - /- %... : ..r- w tr i 1 . i -.- % . i 1 r:- : I:;. :::Q:..::: • tom'; / _._ :: _.I -_- -1- _ _ } -.. - -- - -1 - -- r -: -- - Figure - _.l- _.__t-.... • -_ t...;- 1_ •3_:- 1 • t . 1 7/26 7/27 7/28 7/29 7/30 .7/31 8/1 8/2 8/3 '8/4 8/5 8/6 8/7 8/8 8/9 Study Dates - 1972 F IGU;RE H s• Renton Juactis.. Algal cell cc•r.ts. ■No observat` -cr.s: c'.:-= - 8/10/72) - -0 -- Ce. ^._-_e4 - �-- C=---i' - ----Green • - 0 - Plue --_ __.. - d - Pe n-ales 8/10 8/11 8/12 8/13 8/14 8/15 8/16 8/17 8/18 8/19 2120 5-/2_ c;22 • • ' .._ • - 177-- --- • • -4 r4 r4 4-1 4 . 1 -4 • 2 • .. - . . A • • 1 • -; • ; ; ; • r" : : /.1 • T7 • .r:••••;-1.;•:_:-'7.7.. • • " I -7'7-7' • - ;— ' . s /..••• S. : - • c? • •• . . . :1 Figure t Kent 212th St. Bridge System • • • V--P k • • ; i • .•; .1 . ' • - • •4 •- . •-•\ Algal Cell Counts. (No obser- vations: 8/10/73). Centrales • Coccold Blue-Green - 0 - Filamentous Blue-Green t ! 1 - a- Pennales • i ____ \ ...—;...„ 71 I . • i -1-- i ,-- • _ so. , .___-- ,--- i • , - 41,...,... , _ -,./.. -\ .... . - __ i ! t . _,-- fi - . ; 1 . i :_ _74_ .1. - LI —.-1. ....— _. ‘ _ _,.....„74....._ _./...__i . __,___. .. _, _ ___l_t_r___11 ____4.._A,____3_....., „., t - 1.....1_ ..1_. _ ... ', i . .1 - -"*.. _:, ; .:/. ‘,1 1 7 ' . 1— ! : _I. ‘‘.. ./. I. .-:_i 1 .. : ii 7. .., 1 _ .7., _ _. • 1 - - - '77- • . - .,, - - • 7-77-1 . - - ' % -: ./ \ ; • 1 ' - I . ' • ' - , - 1 , , i ,'.- . -• ; ':- I .:L: j ._ A i : ! .11-j:I .._.i_.J.....1..:7.__:_. _.___. .1: . :. I " % I 7H ' L. i --.=:'-j--..-1 j " - - - -.- - . • - --- -----__- _ . ...i_.- _ . • .. --- . , j • • --. t • - • - 'I-, r,1 t; , :,•1 ---,17-2■ 1 --r--4 ...--•-1 .- --- ••• -- • • • -,-7- -.4- - - I -1— _ - - ---7,.. .1-: ;7.... -7-1-'1-- 7.7 7-7'.7. • 7 7-- -_-_"-' -:--'1-7C• 7t-7j- II .. *-1-: 71-7 : • -,- -- . ,-,;••:' . • 7/26 7/27 7/28 7/29 7/30 7/31 8/1 8/2 8/3 8/4 8/5 8/6 8/7 8/8 8/9 8/10 8/11 8/12 8/13 • 8/14 8/15 8/16 8/17 8/18 8/1; 8/21 8/:2 F I GURE I Study Dates - 1972 Concentrations of copper and lead, Tables 4 and 5-- variables 16 and 17, do not appear to be at levels which would cause any major biological impact at the present time. However, as a result of increased runoff from newly paved vehicular surfaces in the area and the continued use of leaded gasoline, lead concentrations could increase to levels which are .sig- nificant in a biological sense. Zinc and mercury values (variables 18 and 19) are also quite low. Total and fecal coliform values, Tables 4 and 5- -variables 21 and 22, do not even meet Class C water requirements. This poor condition is due, in part, to the influence of livestock and human activities throughout the Green River watershed. In 1969, the Washington State Department of Ecology published an Information Bulletin on Intrastate Waters. The river stretch discussed in this report met Class A requirements specified by that bulletin for temperature and pH only. However, based on 1973 revised water quality standards, the river stretch no longer meets the Class A water require- ments for temperature. The Department of Ecology has lowered its temperature standard while the average temperature of the river may be increasing. d. Biological Conditions (1) Botany Today the Green River valley is characterized by scattered remnants of the large freshwater marshland that once extended throughout the area. The subject site is a filled and graded field covered with grasses, clover,' thistle, yarrow, and a few scattered willow and alder saplings. Some of the living as well as dead plant species are typical of wet areas, which indicates that surface water collects on the subject site earlier in the growing season. Along the south side of the subject site is a small stand of alder and . willow in a dry ditch. The ditch contains water during the -32 -. wetter portion of the year, but is at present dry. Across the South Center Parkway bordering the west edge of the site is a -stand of maturing alder and willow. To the east of the site is another open field covered with introduced weeds, . a. small stand of alder and willow and a large dried -up freshwater marsh filled with cattails. The presence of alder and willow in patchy distributions along the east, south and west margins of the project site provides some cover for bird populations. In general, however, the vegetation on the proposed project site is composed largely of introduced Eurasian weeds and indicates a complete disruption of the original plant com- munity. No rare or irreplaceable plant species are found on the project site. See Table 6 for plants found on the project site.. (2) Zoology i) Birds The subject site lies within the Green River watershed, which is part of the Pacific Migratory Waterfowl Flyway. The site has an interesting and important relationship to the previously mentioned cattail marsh areas found to the east and southeast. When these marsh areas are wet, they provide a resting place for spring and fall migrants, esPacially waterfowl. Contiguous meadows and fields, including the subject site, serve as foraging areas for migrants as well as winter residents. The marshlands also provide a breeding habitat for Red- winged Blackbirds in spring. The surrounding meadows are rich in insect life necessary for the blackbirds to feed their young. The environment of the proposed subject site is also considered quite good for other foraging seed- eating and insectivorous bird species. The Savannah Sparrows COMMON NAME GENUS SPECIES Scotch broom *Cytisus scoparius, Common vetch *Vicla sativa Wild sweet pea *Lathyrus sp. White sweet clover *Melilotus alba Stinking mayweed *Anthemis cotula Red clover *Trifolium pratense Least hop. clover *Trifolium dubium White clover *Trifolium. pratense Wild lettuce Lactuca sp. Sow thistle *Sonchus sp. Pineapple weed Matricaria matricarioides Canada thistle *Cirsium arvense Common thistle *Cirsium vulgare Smooth hawksbeard # *Crepis capillaris Hairy cat's ear *Hypochaeris radicata Common tansy *Tanacetum vulgare Canada goldenrod Solidago canadensis Pearly everlasting Anaphalis margaritacea Ribwort * Plantago .. lanceolata Nippleseed Plantago major Fireweed Epilobium. angustifolium Sourdock *Rumex crispus Spotted ladysthumb Polygonum persicari`a Creeping buttercup *Ranunculus repens Black cottonwood #Populus trichocarpa Willow #Salix sp. Red alder Alnus rubra. Himalayan blackberry *Rubus procerus Field horsetail Equisetum arvense Horsetail Equisetum telmateia Cattail #Typha latifolia Water plantain #Alisma plantago- aquatica Rush #Juncus sp.. Sedge #Carex sp.. Yellow weed #Parentucellia viscosa Grass Festuca sp. Grass Poa sp. Grass Agrostis sp. Grass Phleum sp. Grass Lolium sp. Grass #Phalaris sp. *Introduced weed #Species indicating standing water at some time during a year. Table 6: Floral assemblage of project area in'July, 1973. breed in the weed field and the American Goldfinches'. and Song Sparrows probably breed in various thickets around the site. A survey of bird species present on and near the project site on July 30, 1973, is presented in Table 7. No uncommon or rare species were. observed. The most abundant species were Song Sparrows and American Gold- finches, usually found in thickets, Savannah Sparrows and Brewer's Blackbirds, usually found in the weed field and four species of Swallow in the air above the project site. In addition to resident bird species, a number of bird species forage on the site but reside elsewhere. Based on the work of Dr. R. Taber, College of Forest Resources, University of Washington and Dr. D. Paulson, Department of Zoology, University of Washington, it is possible to project what species of birds might be seen in a particular .. area based on habitat types available. A list of common species which might be seen in and around the project site if an extended survey were conducted, is presented in Table 8. ii) Mammals A survey of mammals in the general vicinity indicates few exist. Two young eastern cottontail rabbits, Sylvilagus floridanus, were present on July 30, 1973. Based on the work of Dr. R. Taber, College of. Forest Resources, University of Washington and Mr. John Garcia, College of Forest Resources, University of Washington, it is possible to project what species of mammals might be seen in a particular area based on habitat types available. A list of mammals which might be seen imand around the project site if an extended survey were con- ducted is presented in Table 9. . -35- COMMON NAME 'GENUS SPECIES SEASON* . ABUNDANCE* Mallard, male and female Anas platyrhynchos R California Quail, 3-females Lophortyx 'californicus Ring - necked. Pheasant,, . l female adult and Phasianus colchicus 8 -10 young. Herring Gull. Larus argentatus Band - tailed Pigeons Columba fasciata Barn Swallows Hirundo rustica Violet Green Swallows Tachycineta thalassina Tree Swallows Iridoprocne bicolor. Rough- winged Swallows Stelgidopteryx ruficollis Robin . Turdis migratorius Yellow Warbler, female Dendroica petechia Yellowthroats Geothlypis trichas Western Meadowlarks Sturnella neglecta Brewer's Blackbirds Euphagus cyanocephalus Brown- headed Cowbird Molothrus ater American Goldfinch. Spinus tristis Savannah Sparrow Passerculus sandwichensis Song Sparrow Melospiza melodia *C = Common R = Resident S = Summer R S R Table 7: Birds seen on the project site, July_ 30, 1973. -36- -C C COMMON NAME GENUS SPECIES SEASON' 'ABUNDANCE* Red- tailed Hawk Buteo jamaicensis R C Rough- legged Hawk Buteo lagopus W C Sparrow Hawk Falco sparverius R C Killdeer Charadrius vociferus S C Common Snipe Capella .gallirago W, R C California Gull Larus californicus M C Ring - billed Gull Larus delawarensis M C Mew Gull Larus canus W C Rock Dove (feral) Columba Livia R C Mourning Dove Zenaidura macroura S Barn Owl Tyto alba R C Short -eared Owl Asio flammeus R C Common Nighthawk Chordelies minor S C Cliff Swallow Petrochelidon fluva Common Crow Corvus brachyrhynchos Starling 'Sturnus vulgaris House Sparrow Passer domesticus Red- winged Blackbird Agelaius phoeniceus White- crowned Sparrow Zonotrichia leucophrys a R. = Resident S = Summer W = Winter S R S M = Migrant C = Common Table 8: Birds which might be seen on the project site. (Based on the work of Dr. R. Taber, College of Forest Resources, University of Washington and Dr. D. Paulson, Department of Zoology, University. of Washington). -37- COMMON NAME GENUS SPECIES . Vagrant. Shrew Sorex vagrans Coast Mole Scapanus orarius Townsend's Mole Scapanus townsendii Deer Mouse Peromyscus maniculatus Oregon Vole Microtus aregoni Mountain Beaver Aplodontia rufa Norway Rat Rattus norvegicus Pacific Jumping Mouse - Zapus trinotatus Striped Skunk Mephitis mephitis Townsend's Vole Microtus townsendii Raccoon Procyon lotor Table 9: Mammals which might be seen on the project site. (Based on work of Mr. John Garcia, College of Forest Resources, University of Washington.) -38- . iii) Fish The subject site lies within the. Green - Duwamish River watershed. This river supports significant fish runs. Although some natural spawning occurs in the river, the majority of the anadromous fishes are released as fry or fingerlings from the Washington State Department of Fisheries Hatchery located on the Soos Creek tributary. Principal fish species known to be present in the river in the vicinity of the project site are listed in Table 10. COMMON NAME GENUS SPECIES Chinook salmon Oncorhynchus tshawytscha. Coho salmon Oncorhynchus kitsutch Chum salmon Oncorhynchus keta Cutthroat trout Salmo clarki Steelhead trout Salmo gairdneri Dolly Varden trout Salvelinus malma Prickly sculpin Cottus asper Threespine stickleback Gasterosteus aculeatus Longnose dace Rhinichtays cataractae Speckled dace Rhinichtays oculus Mountain whitefish Prosopium williamsoni Starry flounder (juveniles) Prosopium stellatus Table 10: Fish Species of the Green - Duwamish River in the vicinity of the project site. e. Atmospheric Conditions (1) Existing Air Quality The following discussion is. based both on air quality measurements made on site and data obtained from nearby monitoring stations maintained by the Puget Sound Air Pollution Control Agency and the Department of Ecology. Measurements of suspended particulates and sulfur dioxide (SO2) were performed at the subject site on August 2 and 3, 1973. Twelve hourly measurements of SO2 were. made. Each con- centration in Table 11 -A is an average of three readings. The 24 -hour average for SO2 was .038 ppm. These results are in general agreement with data obtained by the Puget Sound Air Pollution Control Agency (PSAPCA).which are given in Table 11 -6. SO2 is well within the standard and does not present any known problems at the present time. The concentration of suspended particulates was 67.7 micrograms per cubic meter of air (ugm /m3) as measured at the subject site. The ambient air quality standards as adopted by the. Puget Sound Air Pollution Control Agency for suspended particu- lates are 60 ugm /m3 (micrograms per cubic meter) annual geometric mean and 160 ugm /m3 24 -hour average never to be exceeded. For implementation purposes, the standard value for suspended particulates can be exceeded 15% of the time in a given month without violating the ambient air quality standard for the year. Thus the measurement at the site of 67.7 ugm /m3 probably does not alone constitute a violation. Elsewhere in the Duwamish, data gathered from the Department of Ecology monitoring station on Marginal Way indicates that 23% of the 24 -hour reading for suspended particulates have exceeded 150.ugm /m3 in the last year. These high readings . are probably a reflection of the intensive industrial activities in the lower Duwamish Region. -40- Average Concentration Date Time Parts Per Million (ppm) 8/2/73 11:30 a.m. .040 12:30 p.m .040 1:30 p.m. .035 2:30 p.m. .018 3:30 p.m .027 4:30 p.m. .041 5:30 p.m. .045 7:30 p.m. .026 8:30 p.m. .023 8/3/73 7:15 a.m. .111 8:15 a.m. .037 9:15 a.m. .022 10:15 a.m. .032 11:15 a.m. .037 Table 11 -A: Average atmospheric concentration of sulfur dioxide. Sulfur Dioxide July Dec. Jan. Feb. Mar. (ppm) 1972 1972 1973 1973 1973 Standard Value Monthly mean .004 :002 • .002 .005 .006 .02 annual mean • Daily maximum .04 .01 .01 .02 .02 ..1 daily average Hourly maximum .24 .08 .08 .11. .11 .4 hourly average TABLE 11 -B: Sulfur dioxide data obtained by the Puget Sound Air Pollution Control Agency at Andover Park Table 12 indicates that suspended_ particulate concentrations tend to increase from Renton to the Duwamish Industrial Area of Seattle, so that a value of 67.7 ugm /m3 is probably typical of the area. The above mentioned table also indicates that the concentrations of suspended particulates have increased in the area in the last two and one -half years. This trend will probably continue to increase in the future. Particle fallout (see Table 12) is also high, reflecting the large amount of particulate matter in the air. This will mean a soiling problem for any structures, cars, clothes, etc., in the area. • The one sulfation rate reading of.0.46 (Table 12) is not unusual for an urban area. no standards have been set for this measurement. 1973 Suspended Particulates (4 mo.) 1972 1971- Standard. Value (Renton) Annual average in ugm /m3 (Duwamish) 53.9 97.6 48.1 89.6 46.9 76.4 60 ug /m3 . Annual Geometric Mean. 150 og /m3 24 -Hour Average.. Sulfation Rate (Renton) 2 (milligrams of S03 /100 cm per day) .46 No Standard Particle Fallowt 0 (Renton) gms /m /mo. 5.2 10 Industrial 5 .Residential and Commercial TABLE 12: Suspended particulates, sulfation rate and particle fallout values -42- A summary of motor vehicle related air contaminants is presented in Table 13. Of the summarized pollutants, carbon monoxide is the most problematical. The air quality standards for the other pollutants resulting from motor vehicles (hydrocarbons and photochemical oxidants) are not projected to be exceeded in 1975, the congressional deadline for meeting the ambient air quality standards. The number of days the 8 hour carbon monoxide standard would be exceeded is projected to drop in Seattle from 107 days in 1972 to 38 days by 1975. The maximum 8 -hour concentration will be between 16 and 17 parts per million on these days. As per conversations with the Department of Ecology, air quality conditions related to carbon monoxide at the subject site are somewhat analogous to downtown Seattle. Sources of Air Contaminants The sources of the air contaminants are the Seattle indus- trial area, the 1 -5 Freeway and the Southcenter shopping area. Although continuing efforts are under way to reduce emission from both industrial and automotive sources, the air quality at the site will probably remain marginal due to the number of sources in proximity to the site and the difficulty of enforcing control measures. -43- ®. AIR CONTAMINANTS RESULTING I-RUM MUIUK VtiILLt� AS RECORDED BY THE DEPARTMENT OF ECOLOGY MONITORING STATION IN THE DUWAMISH Carbon Monoxide (CO) PPM Hydrocarbons PPM Oxidant Parts Per Hundred Million • Average Maximum Minimum Average Maximum Minimum Average Maximum Minimum 1972 June 1 4 .0 2 3 2 1 4 0. July .1 4 0 2 4 1 2 13 0 Aug. 1 7 0 2 5 1 1 4 0 Sept. 1 8 0 3 6 1 1 5 0 Oct. 3 10 0 3 7 2 1 4 0 Nov. 3 15 0 2 6 1 1 4 0 Dec. 2 23 0 2 6 1 .1 3 0 1973 Jan. 3 21. 0 2. 7 2 1 4 0, Feb. 3' .. 12 0 2 7 2 .1 _4 0 r March 2 9 0 2 . 5 2 . 1 3 0 April 2 6 0 2 5 2 0 2 0 May 2 8 0 2 4 2 0. 5 0 June 2 10 0 2 4 1 1 2 0 Ambient air. quality Standards not to be exceeded more than once per year. ugm /m3 PPM ugm /m3 PPM ugm /m3 PPM 8 -Hour Average- 10 1 -Hour Average 40 35 3 -Hour . . 1 -Hour Average 160 0.24 Average 160 0.08 Meterology i) Temperature /Precipitation Temperature, precipitation, and solar radiation values for the subject site are given in Table 14. These values are for Seattle - Tacoma International Airport and represent averages of all available data. Table 15 indicates the amount of rain falling in a given time period for various recurrence intervals. For instance, on the basis of past records, this area can expect to receive 3 inches of rainfall in a 24 hour period once. every 5 years. Wind Wind data (Table 16) are for Tukwila. Winds are light and variable 16.1% of the time in this area. South and south- southwest are the most frequent wind directions. -45- • = • J F M A M J J A • S 0 N D ANNUAL Temp.( °F) Ave. '38.3 40.8 43.8 49.2 55.5 59.8 64.9 64.1 59.9 52.4 43.9 40.8 51.1 Precip. (in.) 1 5.73 4.24 3.79 2.4 1.73 1.58 0.81 0.95 2.05 4.02 5.35 6.29 38.94 Precip. Extremes I Greatest monthly :12.92 9.11 8.40 3.75 4.76 3.90 2.10 2.18. -4.60 8.95 9.69 9.50 55.14 Least monthly 0.86 1.66 0.57 0.33. 0.35 0.13 T 0.17 0.32 1.00 1.11 3.75 23.78 'Greatest Daily . 2.22 .3.4.1 2.19 1.85 1.66. 1.53 0.74 1.36 1.77 2.27 3.41 2..52 3.41 Ave. no. r of days a` 1 „ 1 1. 1. 0 0 0 0.. . 0 0 0 0 1 1 4 with precip. Snowfall 4.3 1.3 .8 T 0 0 0 0 0 T 0.5 0.6 7.5 .01" ' 19 . 15 16 13 11 9 . 5 6 8 14 • 17 19 151 . 1 " .5" 12 10 10 8 5 4 3 4 8 14 13 93 4 2 1 1 0 0 0 2 4 3 18 Ave. Daily ;765 135. 259 418 531 534 580 ' 475 330 191 104 62.5 Solar Rad- iation .25 0.2 .75 . .0 75 0.0 . 0.2 0.5 0.0 0.6 (cal /crn2) ' Table 14 : Temperature precipitation and solar radiation values from Sea -Tac Airport. Duration/ Recurrence. Interval 2 yr. 5 yr. 10 yr. 25 yr. 50 yr. • 30 min. .4 .5 .6 .6 .7 1 hour .5 .6 .7 .8 .9 2 hour .7 .8 1.0 1.2 1.5 3 hour .9 1.2 1.5 • 1.7 2.0 6 hour 1.5 1.8 2.0 2.5 2.8 Duration / Recurrence Interval 12 hours 24 hours 48 hours 96 hours 2 yr. .5 yr. 2.0 2.5 10 yr. 25 yr. 3.0 3.2 .50 yr. 3.5 2.5 3.o 3.5 4.o 4.2 3.0 4.0 4.5 - 5.0 5.5 4.0 4.5 5.5 6.0 7.0 Table 15: Amounts of rain falling in a given time period for various recurrence intervals. -47- WNW 0.5 0.6 wsw 1 .6 NNW 9.3 N 9.3 ISTATION LOCRTION- 'INCLUSIVE Of TES - ITOTHL OBSERVATIONS- SSW 30.0 SSE 17.5 S 5.7 21.4 HOUR AVERAGE SURFACE WINDS PERCENTAGE FREQUENCY OF OCCURRENCE PUGET SOUND AIR POLLUTION CONTROL AGENCY 227 ANDOVER PARK E, TUKWILA ALL MONTHS 1972 8536 Table 16 1.1- 4.0- 7.0-- 11.0- 17.0- 0V.6 3.9 6.9 10.9 16.9 21.9 . 21.9 KNOTS 6 t 4 $ 4 4 0.0 3.0 6.0 9.0 62.0 15.0 PERCENT f. Noise In the.subject site noise survey, information was gathered from a variety of different sources. Ambient and background noise levels on and around the subject site were measured. Traffic statistics such as volume, speed, percentage of trucks, etc., were obtained from a professional engineer. Existing and proposed noise ordinances affecting the subject site are included as a frame of reference. (1) Noise. Survey On the morning of July 17, 1973, between 10:30 a.m. and 12:00 noon,.a preliminary daytime noise survey (Table 17) on and around the subject site was carried out.- The maximum (10% level or L10) noise levels were taken at pre- selected positions with a General Radio Model 1565 -A calibrated Sound Level Meter. The locations of the measurements are indicated in Figure J. A similar nighttime survey was conducted (Table 17) on the night, between 10:00 p.m. and 11:00 p.m., of July 20, 1973. It is evident from these noise level data that the major contributor to background or ambient noise environment is the steady motor - vehicle traffic on Interstate 5. The noise levels that were recorded on the west and north sides of the project site were closer to the noise sources and therefore gave higher decibel (dB) readings. The maximum noise level readings were recorded when heavily loaded trucks would pass by along the Southcenter Parkway Boulevard (35 MPH road) and along the Stander Boulevard (between the Doubletree Inn and the subject Site). Again, the shorter the distance between the source-and receiver, higher were the measured noise level readings. These intermittent near -field truck noise levels had a tendency to mask the . far -field steady freeway noise. -49- Lora rt, ..esaala c's nder 15Ivd. 0 Figure J 0.e 110)&6 Lode) %lui614 reh et45 MICROPHONE LOCATION POINTS MEASURED AMBIENT NOISE LEVELS NIGHTTIME DAYTIME DBA dBC dBA dBC 1 64 78 53 64 , 2 57 72 52 64 3 56 72 53 65 4 � . 52 68 51 63 5 53 '65 50 61 6 54 67 52 63 7 63 77 54 65 8 62 72 54 64 9 . 57 73 51 62 10 66 78 52 64 MICROPHONE LOCATION MEASURED MAXIMUM. NOISE. LEVELS 1 78 98 66 78 2 75 96 65 76 8 79 99 66. 79 NOTE: • The above readings in dBA represent L90 (background) levels due to normal traffic flow and L10 (maximum) levels due to truck traffic flow on roads surrounding Maguire Site. Table 17: Ambient Noise and Maximum Noise Levels for. the Maguire Site. _51_ The average increase in the noise level due to a nearby passing truck corresponded to 20 dBC and 15 dBA when compared to the background or ambient level. The maximum noise level, L10, recorded at a point 10 feet from the passing truck along the Southcenter Parkway Boulevard was 99 dBC and 79 dBA. This indicates that the predominant noise Lies in the low - frequency range, a well known characteristic of the truck exhaust noise. Because of this fact, the truck noise can be detected even at great distances from the road. Because of the random distribution of truck noise sources in the overall traffic noise environment, it is necessary to use L10 and L90 levels in the determination of a single - number rating (e.g. dBA level) for both existing and predicted property line values. (2) Existing and /or Proposed Noise Ordinances: i) City of Tukwila Ordinance 251 (revised by 11635, 1970), Section 18.32.030, page 2731 Paragraph "C ", which reads, "No use shall be permitted if it results in industrial noise above 5 sones as measured at the outer boundary of this district "(Commerci.al - Manufacturing) for industrial park purposes. ii) Proposed King County Noise Ordinance, Section 703 (Stationary Sound Sources) and Section 704 (Non - Stationary Equipment). The relevant noise level information is as follows: "Section 703, Article (3), Commercial or Business Areas: Period of Use Maximum allowable sound levels as measured on the property the sound source is located Between the hours of 0700 -2200 Between the hours of 2200 -0700 65 dBA 65 dBA Section 703, Article (4), Industrial Areas: Between the hours of 0700 -1800 Between the hours of 1800 -2200 Between the hours of 2200 -2700 70 dBA 70 dBA 70 dBA Section 704, Articles (a) and (b): a) No person shall operate any of the following non-stationary equipment in a manner to produce a noise in excess of the following limits at a distance of 50 feet from the equip- ment operation or the property line on which it is operated, whichever is greater. b) Types of Equipment 1) Construction and industrial machinery such as crawlers, tractors, dozers, rotary drills and augers, loaders, power shovels, crances, derricks, graders, off highway trucks, ditchers, trenchers, compactors, compressors, pneumatic powered equipment, etc., but not including pile drivers. Noise Limits 90 dBA 3) Portable powered equipment of 20 HP or less primarily intended for commer- cial use in varying locations in support of construction or maintenance activities; such as chain saws, pave- ment breakers, log chippers, powered hand tools, etc. Noise Limits 88 dBA Measurement will be taken in both dBA and dBC with the . allowable limits being 20 dB higher with the dBC measurement. . Proposed King County Noise Ordinance, Section 701, "Licensed Motor Vehicle" - Allowable noise levels: b) No person shall operate a licensed motor vehicle or combination of vehicles at any time or under any condition of grade, load, acceleration or deceleration in such a manner as to exceed the following noise limit for the category of - vehicle, as measured at a distance of 50 feet from the center of the lane of travel within the speed limits specified: Speed Limit Type of Vehicles 35 MPH or less Speed Limit over 35 MPH Motor vehicles of gross weight of 6,000 lbs. or more. 86 dBA 88 dBA Motorcycles 82 dBA 85 dBA All other motor vehicles 76 dBA 82 dBA -54- iii) Federal Highway Administration (FHWA) of the U.S. Department of Transportation approved Policy and Procedure Memorandum (PPM) 90 -2 under the Draft Environmental Statement on Noise standards and Procedures for Implementing Section 109 (i) Title 23 U.S.C., effective from July 1, 1972: Design Noise Level /Land Use Relationships Land Use Design Noise Category Level - L10 Description of Land Use Category B E* 70 dBA. (Exterior) 55 dBA (Interior) Residences, motels, hotels,, public meeting rooms, etc. Residences, motels, hotels, public meeting rooms, etc. *The interior design noise level in category E applies to . indoor activities for those situations where no exterior noise sensitive land use or activity is identified. (Reference 4). - Note: L10 is the sound level (statistical in nature) that is exceeded 10 percent of the time for the period under consideration. This value is an indicator of both the magnitude and frequency of occurrence of the loudest (maximum) noise events. iv) General Services Administration (GSA) specified 'Construction Noise' Standards, effective from July 1, 1973• Spec: Equipment to be employed on the development site shall not produce a noise level exceeding the following limits in dBA at a distance of 50 feet: Earthmoving truck 91 Impact Pile Drivers 101 Concrete Mixture 85 Impact Jack Hammers 88 Stationary Compressor 81 Saws 78 -55- (3) Summary of Existing Noise Levels The existing average ambient (background or L90) noise level due to truckless traffic along the west boundary (adjoining the Southcenter Parkway Boulevard) of the subject site is 63 dBA. This value seems to be consistent when compared . with the City of Tukwila noise ordinance (5 sones or equiva- lent 70'dBA) and .those proposed by the King County 65 .dBA). However, when a standard truck passes by, the maximum noise level (L10) is approximately 15 dBA higher than the average ambient level. This 78 or 79 dBA level at the western boundary of the subject site would then violate the proposed U.S. Departments. of Transportation (DOT) and Housing and Urban Development (HUD) exterior noise level criteria (Max. 70 dBA). However, if the nearest commercial or office building, hotel, motel, etc., are built several hundred feet away from the truck noise source and towards the center of the subject site then there will be approxi- mately 4 to 5 dBA reduction in noise by every doubling of the distance away from the source, assuming a free - field (no obstruction to sound waves) environment. The predicted noise levels due to the increase in overall traffic (normal) and increase in the truck traffic is mainly a function of traffic volume and traffic speed according to the model described. From the existing traffic count information (assuming that trucks, comprise lanbf total) 'both on Interstate 5 and along the Southcenter as well. as Strander Boulevards (adjoining the site), the predicted 10 percentile level (L10) noise levels on the western edge of the property would be 82 dBA (1 -5) and 86 dBA (Southcenter Blvd.) respectively. The peak traffic volumes used in the prediction analysis were.4,000 /hr. on the Interstate 5 freeway and 600 /hr. on the Southcenter. Boulevard. However, because of the elevation (approximately 50 ft.) and tree - covered slopes of the 1 -5 with respect to the subject site, one can assume a 6 to 8 dBA reduction in the 1-5 generated -56- truckless noise (from 82 dBA down to 74/76 dBA), which, in turn, would make the truck traffic noise (86 dBA) a predominant noise source along the subject site. B. Existing Conditions (Cont'd.) 2. Human Use, Development and Values a. General Development The following is a summary, performed by the Tukwila City Planning Department, of generalized human use and development within the 8 square mile planning area surrounding the subject area: Residential (8 square miles surrounding the area) 1) Single Family Dwelling 3,484 (Average Household Size 2,3) 2) Two Family Dwellings 2 3) Three or Four Family Dwellings .. . . . 3 4) Five to Eight Family Dwellings . . . . . . . 0 5) Nine or More Family Dwellings . . . 59 6) Hotels, Motels and Tourist Homes . . 3 7) Mobile Homes 0 Commercial 1) Wholesale and Distributors 34 2) Retail a. Southcenter 108 1. Shopping Population (daily.) - 28,600 2. Shopping Population (peak) - 92,000 3. 1971 Total Shopping Population - 11,500,000 b. Other than Southcenter 10 Industrial 1) .Mining 2 2) Construction• 2 3) Manufacturing a. Southcenter 7 b. Other than Southcenter 24 Employment.- Large, Major Sources 1) Southcenter 1,700 peak (3,000 ) 2) Andover Industrial Park a. Distribution Firms 607 b. Manufacturing Firms 275 3) City Administration 106 Recreational 1). Minor Parks (Less than 5 Acres) a. Picnic Tables b. 2 Tennis Courts 2) Golf Courses 3) Tukwila Community Club 4) Race Tracks (Longacres) 5 Numerous Fishing Sites Along the River -58- 1 1 1 Transportation 1) Railroads (BNSF Burlington Northern, Union Pacific, Milwaukee a. Passenger b. Freight 2) Taxi Cab Services 3) 405 and 1 -5 Intersections a. Cars to Southcenter (daily average) - 13,000 b. Cars to Southcenter (peak daily average) - 40,000 4) Truck Transportation - 2,500 daily a. Terminals b. Freeway Accesses. 5) River Transportation 6) Employees (Southcenter) 7,500 7) Cars (Southcenter) - 5,013,600 yearly) Education 1) Elementary 4 2) Jr. High 1 3) Sr. High 1 Religion 1) Churches 10 Tukwila has grown to become amajor trade center in the last few years. The City' is unusual in that it has become a major urban area with a population of only 3,128. Tukwila had a population density of 2 - 4.99 persons per acre in 1970 and is projected to have the same density in 1990. This is a relatively low growth in population compared to other communities in South King County such as Kent, Renton and Highline. On the other hand, the City's assessed valuation has increased from $1,872,000 in 1961 to $68,000,000 in 1971 and to $89,641,130. in 1972. By official estimation, the City has become a "$90 Million Dollar Corporation" and by. 1975 the assessed valuation will increase to $120,000,000. The largest portion of the City revenue comes from real and personal property taxes, and general sales and use taxes, $491,576, and $134,553, respectively in 1973. -59- so O 0 m D• .°00.0.O O00 ° • 0 0 0 0 O e e 0•• 0• 0 0 0 0 O 0 0 0 0 0 0 0 0 0 0 O 0 0 0 0 0 0 0 0 0 0 O 0 0 0 0 0 0 0 0 0 0 e a. oe°o••••• �0 0 0 0. .0 �""y"0„3 0 0 0 0 0 0 • 0 00 rD+^ 0 O0 ./t) Y 0 7 • o O 0 0-t:;0 0 0 0 �✓ "-o O O D O O O O° O O O m O m 0 0 0 0 0 0 0 0 0 t.j-" . 9000 -9O ° O 0 0 0 0 0. 0 ° 0 0 0 0 i 0 0 0 0 0 0 0 0 0 0 0° O O p0000O°0G °° r. 00000000°0000000°0 O0o 0 0 0 0 0 0 0 o m o 0 0 ``{�� C //. ^{ 0 0 00 0 0 0 O 0 0 0 m 1)0‘.9° ° % 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 '.ia °O °O °O °O °O °O °O ° °�I �f°!a °o O °O °0 0 °0 0 0 °• m 0 0. 0 0 0• 00 0 0 0 0 0 0 0 0• 0 0 0 0 0 0 �� 0 °0 °00 0 0 006 . 0 °0 °0 °0°0 °0 °0 °0°0 0 °eFFF.;,y; „" "m 0 o 0 0 9moo 0 0000 °0 °0 °0 °0 °0 °O -0 0000 °0 °• 0 °0 °0 °0 °0 .700.0.0.0000000.0.0.000000000.90000.000000000 0 0 °°0 0 0 0 0 °°° ° 0 00•00 0 0 0 0 0 0 O 0 0 0 0O ° 0 0°O °0°• °0 0 °0 0 °0 0°• °0 °0 0 °O °0 °0°O °0 °0 0000 0 000000° °0° ° ° ° ° ° °• ° °°° ° ° 00 0 0 m 0 0 0 0 • 0 0O 0 0 ° °0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 • 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 . 0 . 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 °0 °0 °0 °0 °0 °0 °00 °0 °0 °0 °0 °0°0°0 0 °0 • °• ° ° °0 0 °0 00 0. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0. 0 0 0 0 0 0 0 0 0 0 0 0. 0 0 0 0 0 0 0 0 0 0 0 6 0 0 0 0 0 0 0 0 0 0 o 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0• v a o• 0 e m o 0 0 o e o e o o e o o< 0 0 0 0 0 0. 0 0 0 0 o0 ° 0 o 0 0 0 0 0° e° o o ° °° o 0 °° o° m o m o ° 0.0.0.0..0..0_0_O_0 0 °0000 °0 °0 °0° 0 0 0 0 0 0 ■ • • - - - • b. Traffic The subject site is located to the southwest of the intersection of Interstate 5 and Interstate 405. Access to the area is provided by Tukwila Parkway, Southcenter Parkway and Strander Boulevard. Freeway on -ramps to 1 -5 and I -405 are in near proximity to the project site. Vehicle counts at Southcenter range from 27,000. to 45,000 vehicles per day. Figure L shows existing average daily traffic and peak hour volumes in the vicinity of the subject site,as derived from the Washington State Highway Department measurements taken in March and June of 1973. The percentage of the daily traffic at various hours of the day (Figure M) are for arrivals only and show a typical noon time peak and a small midnight peak. The percentage of total weekly traffic occurring on each day of the week is presented in Figure N. The traffic volumes experienced on Thursday most correspond to the average daily volume. y�5z ] • 373 LS ZZ 1 1.11s 1 zZl "!�t'W� iSCFI(K.f6RiTP: Ai+awN.Y�st -�feN1 i'R�M�'� �Al• YW, 4iMs� '::si'".VG`�x74.4,1761..,4.01S! -�'ca�Wila Parkway si- raruke 131vd p�« ..s,�.s�,r.�x:�w:�� ^.�wm.,.�!.w rxrm�ur,. �te• a..: xaca« ��.:a:zr�•��`...;- x��+ss�•vzwcs x Off ram P 19. \ 13 7171 f.glAti Ira- fic- 0°773) 5oarce : - Factoreu 4 om W L rm"'Ali � ;bk. itlgh y NIA 4. Legend: `450 aveva e ally i rah #lc, von mak- r►'t Peak- a) E 0 0 4— 0 as() 6:00 A.M. Noon TIME OF DAY 6:00 P.M. 419. tri - rva -ific Charade risli�, of . Pa1l5 Traffic, vu(us f'tagtr of fire. bay -64- Midnight 1.20 1.10 1.00 0.90 0.80 FIGURE N TRAFFIC CHARACTERISTICS Percent of Weekly Traffic Versus Day of Week Sunday 1.04 Monday 0.75 Tuesday 1.14 Wednesday 0.87 Thursday 0.99 Friday 1.06 Saturday. 1.14 fo > • >, -0 (o fo >. >. (0 V1 -0 T T) f0 f0 "0 a) to (0 L. "0 -a n c L - • 3 C C a) -0 3 .— +-) 7 0 3 0 ..0 L f0 V) E 1- 3 1— Li N -65- Average Week Day Volume Note: Thursday is an "average" day. C. Environmental Impact of the Proposed Action A consideration of impacts must address all possible positive and negative changes in the existing environment that willfo!llow as a conSequence of the development resulting from the proposed action. Particularly, seemingly minor impacts which might be cumulative in nature must be assessed at least briefly. Often it is not the immediately recognizable impacts which can be anticipated that cause long range problems; rather, it is the small and seemingly inconsequential impact which surfaces later as a sensitive problem. Careful analysis of all possible impacts will result in a determination of those which will cause adverse effects. Such an analysis, in conjunction with the planning process, can be utilized to identify measures which will mitigate such adverse effects. Implementation of mitigating measures is limited only by the physical constraints imposed by the project site and the degree of flexibility imposed by the program requirements of the development resulting from the proposed action. Environmental impact is not limited to changes in the bio- physical environ- ment but necessarily extends to a wide range of changes in the socio- economic environment. Such socio - economic impacts take on a great significance since the development resulting from the proposed action is to occur in an area already extensively altered from the natural condition and utilized for other types of human activities. Furthermore, it is recognized that the various impacts are not severable from one another and such inter - relatedness is reflected in this discussion. Quantifiable occurrences within the bio- physical and socio - economic environ- ments cannot be dealt with as discreet events, but rather must be considered within the context of the total systems which give rise to such occurrences. 1. Changes in Natural Characteristics a. Impact on. Topography and Geology The topography of the subject site was altered when the site, and the contiguous lands were committed to urban uses. The Green River Valley had undergone some minor alterations during previous farming activities, but for the most part, it retained the characteristics of a mature flood plain until recent urbanization. The Howard Hanson Dam and the levees on the Green River help prevent flooding of this area. The subject site is bounded by Southcenter Mall, Interstate Highway 5, and a warehouse. The subject site itself has been raised above the original flood plain of the Green River by landfill. Landfill on the subject site was placed in compacted layers and left to settle and further compact the underlying soil over an extended period of time. This is consistent with good engineering geologic practice. b. Impact on Hydrology and Water Quality Covering the subject site with asphalt and buildings will increase the amount of rainfall that runs off the site. This will prevent groundwater recharge and will tend to increase the burden on existing drainage facilities. The most marked impact on water will be the increased runoff from the paved -over areas of the project. Paved portions of the site will inhibit groundwater recharge and will result in a small, but probably measurable drop in the local water table. While the net affect of this particular project is small, it is part of a continuing deleterious trend in accommodation of increased storm water flows by direct discharge into the existing natural systems. Runoff from the paved areas will be in greater volumes and at higher temperatures than natural runoff and will contain hydrocarbons, oils and particulates. As noted previously, the receiving water body, the Green- Duwamish River, is already at its thermal capacity, based on Department of Ecology standards. While the total impact of the project is small, taken together with other nearby planned projects or those currently underway which will also discharge into the river, an even more serious deterioration in water quality is possible. c. Impact on Terrestrial and Aquatic Biology As previously mentioned, the proposed site is located in an area of the Green River Valley which has already experienced major biological changes. Construction of Andover Industrial Park and Southcenter Shopping Plaza are just two of the many urban developments which have completely changed the natural environment formerly found in the valley. Comparatively speaking, the biological impact of the proposed project, although identifiable, will be small compared to previously completed projects in the valley. Development of the project site as a commercial complex will eliminate a foraging habitat for the summer seed- eating birds and insectivorous swallows. Further, some reduction of food supply for winter residents and migrants will occur. However, since the project site is at present quite artificial because the former marshland has already been filled in, elimination of the above mentioned habitat can be viewed essentially as a replacement of one man -made habitat with another.. If the proposed project was not undertaken, plant species succession on the site would be very slow due to poor soil conditions. It would take many years before one could observe native, non -weedy trees growing in the area. No seedlings of such trees currently exist on the site. Further, a reversion to the original marsh community is impossible since the project site has already been filled and graded. d. Impact on Air Quality Concentration of suspended particulates in the atmosphere can be expected to temporarily increase during the construction phase resulting from the proposed action. Increased traffic flow during and after construction will increase the concentrations of carbon monoxide, carbon dioxide, unburned hydrocarbons, oxides of nitrogen, lead and bromine aerosols, and other pollutants. The air quality impact due to increased vehicular traffic will be noticeable particularly since activities on the proposed project site will attract large numbers of cars during the same periods of time when peak hour traffic occurs at Southcenter. The air quality impact will occur due to both the increased numbers of vehicles and the traffic patterns of the area. The most problematical vehicular air contaminant will be carbon monoxide. e. Impact on Noise During the early development period of the subject site, the most objectionable noise to the existing business community would be from construction activities. Special acoustical measures should be utilized on common construction equipment during the preliminary development at the site to protect nearby business community from annoying construction- generated noise. There are proposed construction noise specifications of General Services Administration and King County, which should be followed closely. Traffic flow will increase as a result of the commercial and business activities to be located at the project site. This traffic increase will have an impact both on the internal environment of the project as well as on the surrounding commercial enterprises, and such noise sensitive businesses as the adjacent motor hotel. The noise impact to the surrounding community which will result from the subject site upon complete development can be determined from noise level predictions and existing noise ordinances. The actual noise level predictions should take into account specific character- istics of the final development such as roadway characteristics (configuration, pavement type and grades), traffic characteristics (volume, speed, percentage of trucks), topography (vegetation, barriers, height and distance). The following factors will affect measurable noise levels in a positive or negative manner: Distance: -4 to -5 dBA for doubling (distance between the noise source and receiver) Traffic Volume: +3 dBA for doubling Traffic Speed: +9 dBA for doubling (a very important consideration) Ground Cover: 0 - to -3 dBA per 100 ft. Barriers: Typically -5 to -15 dBA, depending on height, thickness, material characteristics and slope. -69- The existing noise levels and predicted levels due to increased traffic and other commercial activities must be considered by the designers and architects to meet the 55 dBA interior noise level criteria as proposed by DOT and HUD. All four edges and boundaries of the subject site should be lined with trees and shrubs. In particular, special acoustical barriers and earth berms should be constructed on the western edge of the property to reduce traffic generated noise. These precautions will help to protect the surrounding community from any noise generated within the site as well. -70- 2. Changes in Human Use a. Land Use Patterns Land use patterns established by the Southcenter Commercial/ Industrial Complex dominate the immediate vicinity of the subject area. The development that will result from the proposed action represents a continuation of urban expansion that has occurred in this area in recent years. In light of the land uses which have occurred around the site, it can be said that this acreage is destined to be utilized for a high caliber of urban purposes. The site has long been dormant as a result of the preclusion of former farming uses by commercial and industrial expansion. Previous policy decisions by the Tukwila City. Government initiated this change of use. These policies assign greater value to indus- trial expansion than the former agricultural uses and they were implemented directly by granting C.M. (Industrial Park) zoning classifications to the area. Indirect policy implementation was achieved by the higher assessed evaluations on the land which resulted from these zoning changes, thus making farming less profitable. The proposed action will stimulate construction of new industries and businesses. This will lead to more employment, increased tax base, and a slight increase in. the City's population. The existing trend of urban growth in the area, of which the proposed project is part, is projected to greatly increase the assessed value of the City of Tukwila in the next few uears. The proposed project will also entail additional expenses to the City in terms of administrative and other support services such as police, fire and first aid protection. In terms of human use within the completed structure, many needs will be met that are not currently satisfied. A variety of leisure time activities will be possible in close proximity to one another. For example, recreational pursuits will be available to those brought along on business or shopping trips. Furthermore, pro- fessional, commercial and recreational activities will be combined in an integrated manner not previously planned in the region. Short -term impact on human use will occur during the course of construction when earth hauling equipment will add to automobile traffic congestion in the subject area. Ultimate development, when complete, will increase loading on the traffic circulation system and other elements of the infrastructure, but this loading has been anticipated in the planning and design of these facilities and will be accommodated. b. Traffic Impact The overall traffic impact resulting from the project upon completion of phases 1 through 4 is presented. in Figure 0 which indicates projections of peak hour traffic and average daily traffic. (Figure P), based on the parking analysis prepared byROTI and Associates for the Maguire Partnership and the parking demand that can be expected to be generated by the various functions within the complex. Based on a comparison of net leaseable floor space, traffic generated at the completed complex will be approximately two- thirds of the traffic volumes experienced at Southcenter; however, the character of the traffic will be somewhat different. Traffic on Saturdays and Sundays will be 38° (based on a ratio of commercial space to total space) of that which will be generated on a weekday due to decreased activities in the office buildings. From this data it may tentatively be concluded that Southcenter Parkway at Strander Boulevard will have manageable traffic operations. South of Strander, Southcenter Parkway will also be capable of handling increased flows, because of lack of medial or marginal friction (i.e., it now has controlled access on both sides). The greatest impact on traffic resulting from the proposed project will occur between Klickitat Avenue and Strander Boulevard, as indicated in Figure 0. Southcenter Parkway north of Klickitat will experience 663 vehicles northbound in the evenings; and. Klickitat Avenue will experience 1,293 vehicles in the evenings westbound. The northbound average daily traffic on Southcenter Parkway north of Klickitat. Avenue upon completion of Phases 1 through 111 (Construction Phase 1) of the proposed project will ► -405 `JS?Y.WrS:` 'W :21SX. , ■14f.Y{•�}.' N *'1' .•. ,q� . .. HYYn11VJ6'wvC^!' V..:C.%WYt1... Tht.0 t a. Park 'iay L7g6) I9s4,7 (3S8) Tr.z.sj 6) &Frande.r 151vd 1.:=10)0) ► X k reak Hour I ra f k 4. u (5 4 n cva5 e £1Z -73- �.eap2 ( -4475) am Peak c ,r _5] feak. MJZ:7417T3.4 V■i;:a17177.7.77.i 01,z%) 1-46361, 0e1.0 izsio 63040 • 1'590 (100) -7 005 54-rancle% 105.5 , • .4x.-.A.V.P.t. • Tukwila Plvel. "C19- P eZuI d 15 1iu a I-74 - 7I - `," V.,v141.-411,17,e411,,e0X..V.A.V.W (OW) 0121". {-br Pbtoes 1-11E 7391 i2-r -Pot- Phioes 1-1Y" be about 12,365 vehicles per day (v.p.d.). This will rise to approximately 15,790 vehicles per day on completion of Phase IV. The location of the traffic congestion, namely at Southcenter Parkway and Klickitat, will be the same for completion through Phase III (Construction Phase I) as for completion of the total development (Construction Phase II). These heavy traffic volumes going away from the area, in addition to the existing signal system (if not altered) would serve to make the intersection of Klickitat and Strander Boulevard incapable of facilitating the resultant traffic flows. Funds have been budgeted for the implementation of alternative design proposals by the City of Tukwila and the Washington State Highway Department. Several possible solutions to remedy the potential traffic congestion are presented in Section D (6). The percentage of arrivals by direction is as follows: from east via Strander (minimal) 5% from north via Southcenter Parkway 39% from south via 1 -5 24% from west via Klickitat 32% 100% Upon completion of Phases I through IV the total trips to the complex will be 5.5% of the average daily traffic during the A.M. peak (1,130 vehicles per hour). Trips from the site during the P.M. peak will be 7.0% of the average daily traffic (1,430 vehicles per hour). Approximately 12,200 trips per day on com- pletion of the first construction phase and on completion of the project 20,400 total trips per day can be expected as shown_ in the table below. Typical trip generation factors used for estimating total trips for the four phases of development are'shown in Table 18. Lastly, a consideration of traffic impact from the proposed project may be affected positively by three events. First, a significant . portion of the project will consist of office functions which will not share a.coincident peak hour with the shopping center. Second, the traffic impact would be significantly different should the normal 8 -hour work day be changed to four l0 -hour days as is now • TRIP GENERATION FACTORS (Per 1,000 Square Feet) Trips per Construction Planning Gen. Factor Trips per Planning Phase Phase Phase Type Area (S.F.) per 1000 S.F. Planning Phase (Rounded Off) 1 2 Office 202,500 20.5 4,151 Comm. 18,900 22.6 427 II Other 12,715 22.6 287 Retail 140,000 22.6 3,164 III Hotel 194,000 21.6 4,190 Sub-Total 12,219 12,200 IV Bldg A 200,000 20.5 4,100 B 200,000 28.5 4,100 TABLE 18 Sub -Total 8,200 8,200 GRAND TOTAL 20,400 being experimentally performed by some departments of the City of Seattle and others, or should the work week become a four- and -a- half day week. Third is the positive aspects of the new county- wide transit system and the doubtless evolvement of innovative systems such as Dial-a-Bus or Subscription bus. D. Any Unavoidable Adverse Environmental Effects.' The following is a discussion of possible adverse effects resulting from the aforementioned environmental impacts, and the measures which could be employed to mitigate such effects. 1. Effects on Geology The preparation of the subject site for commercial purposes is not expected to result in any new adverse geological effects. The impacts due to landfill operations occurred at an earlier phase of the development of the subject site and lands in the immediate vicinity. Some siltation in runoff waters could occur as earth is moved in the final site preparation; however, this impact is relatively minor compared to the impact which occurred during the initial placement of fill. Post construction floor slab settlements will be prevented in that the requisite period of . time for surcharging has been completed. 2. Effects on Hydrology and Water Quality The hydrology of the subject site will be affected in that covering the subject site with impervious surfaces will reduce the amount of runoff percolating into the water table. Drainage of surface water from the site is through culverts and drainage ditches to the Green River in accordance with the Flood Control District and the Master Plan of the City of Tukwila. These plans are designed to accommodate a project such as will result from the proposed action. Runoff from the paved surfaces will contain hydrocarbons derived from motor vehicles, as well as an increased heat burden. These effects could be investigated by skimmers, or separators, or . other pollutant control facilities could be designed for the drainage facilities. -78- 3. Biological Effects Development of the subject site will have an unavoidable effect on bird behavior and feeding patterns. A portion of a foraging habitat . will be removed for resident birds as well as migratory birds. Since the project site probably does not represent a complete habitat for most of the observed birds, the existing birds will probably be displaced to more remote reaches of their habitats. The net effect is likely to be a dimunition rather than a complete removal of bird habitats. Small animals which exist in the area are not likely to be displaced to other locations due to the unavailability of suitable alternative habitats. At present there are no known techniques for retaining wildlife in an intensively developed area. 4. Atmospheric Effects The proposed development will result in unavoidable increases in all motor vehicle related contaminants. The effect may be particularly acute during peak hour traffic volumes which may produce stop and go traffic. Such traffic patterns will produce localized increases in all vehicular pollutants; however, the increases in carbon monoxide are most critical. This effect can be partially mitigated by giving primary consideration to efficient traffic flow patterns signal optimization or by greater utilization of mass transit to transport users of the proposed facility. The effective implementation of mass transit is contingent on major concentrations of buildings such as will occur with the proposed project. 5. Noise Effects The ambient noise levels of the surrounding commercial community will . be increased both during the construction phases and when the proposed complex is fully operational. Noise generated on the project site will also have an impact in terms of the internal environment of buildings. Measures are available to control noise during construction phases, and design measures are available which could be undertaken to . control noise levels of the developed project. The existing noise levels and predicted levels due to increased traffic and other commercial activities will be considered by the designers and architects to meet the 55 dBA interior noise level criteria as proposed by DOT and HUD. 6. Traffic Effects The traffic impacts and potential problems of traffic congestion that could arise from implementation of the proposed project were fully described in Section B. Several alternate traffic proposals ranging from intersection modification to large scale traffic re- 'routing in the vicinity are some of the tools available to alleviate traffic operations problems that might be occasioned by the project. The completion of the project through both Phase III and Phase IV (construction sequence 1 and 2) will cause manageable traffic oper- ations on Southcenter Parkway if mitigating measures are undertaken. Klickitat Avenue and the northbound off- ramp,,due to severe restraint capacity, will be congested in the noon and P.M. peak periods, however recognition of this has been given by the Washington State Highway Department which is currently reviewing alternate design proposals. Also, improved traffic signals on Southcenter Parkway and the relocation of the northbound off -ramp to Klickitat Avenue have been budgeted for by the City of Tukwila and the State Highway Department. Also, the alleviation of potential traffic congestion can be partially accomplished by the improvement of Strander Boulevard and Southcenter Parkway to accommodate a five lane roadway. On Southcenter Parkway and on Strander Boulevard the number of lanes within the existing curb line could be increased. Since heavy truck traffic is not mixed with normal traffic, smaller lane widths may be tolerated with no adverse effect to traffic. Strander Boulevard is 52 feet wide from curb to curb and is presently stripped for four 13 foot lanes. This boulevard can be painted for five lanes in an 11- 10-11-10 -10 foot configuration. The middle 11 -80- foot lane would be a two-way left -turn lane. The westbound approach width to the suggested signal at Southcenter Parkway would thus be 31 feet. Note that the eastbound curb lane on Strander Boulevard would be 11 feet wide since this lane may accept dual left -turn movements. Likewise, Southcenter Parkway is stripped for four lanes. This could also be made into five lanes in an 11-10- 12 -10 -10 foot configur- ation. Naturally, while traffic operations can be facilitated with the five lane section of dimensions noted, better operations would result if additional width were made available. Of the above revisions, the relocation of the northbound off -ramp from 1 -5 to Klickitat Avenue, as proposed by the Washington State Highway Department, will establish alternate traffic patterns and will eliminate one of the existing signals on Southcenter Parkway. A more effective solution might be the relocation of the 1 -5 off - ramp to a location coincident with Strander Boulevard, which would also eliminate one of the three existing signals on Southcenter Parkway and provide for simpler traffic control. As noted by the Washington State Highway Department, the relocation of the 1 -5 off -ramp to Strander may be limited by steep grades and high costs. In either case, Klickitat Avenue (bridge) will ultimately require widening. In conclusion, potential traffic congestion will be similar in location but greater in magnitude for completion of Phases I through III as for completion of Phase III. Several measures are possible which will alleviate the potential problems and result in manageable traffic flows. Currently funds have been budgeted for improvements both by the City of Tukwila and the Washington State Highway Department. E. Alternatives 1. Alternative Projects or Programs A realistic consideration of substantially different alternative actions or non - actions must be based ultimately upon alternative and use policies both at a city level and at a regional level. To make such alternatives viable, means must be found to coordinate priorities among different governmental jurisdictions. Also, a meaningful consideration of alternatives must be developed within a framework of existing socio- economic parameters and predictions of future social trends. One such trend affecting a discussion of alternatives is made apparent by existing land use policies. City of Tukwila land use policies have favored commercial and industrial uses over other potential uses. As a result, the rapid urbanization of Tukwila has occurred, and a trend of economic development has been established. Due to the high quality of commercial and economic development, remaining open spaces within the City have been rendered even more valuable for similar future uses, and thus, the established trend will be perpetuated into the future. Although regional land use policies as established by the Puget Sound Governmental Conference do not generally favor development of river valleys,, the location of the proposed project site is recog- nized as an exception. The continued commercial use of this area is recognized as the best and use, due to its relationship to transpor- tation systems and the longtime commitment of this area as an employment and shopping center. Lastly, a consideration of alternatives is limited by prior human activities on the site. For example, since the highly productive alluvial soils were covered some time ago by the placement of landfill, conversion of the project site to agricultural uses is eliminated as an economically infeasible alternative. With these factors in mind, several alternative actions are possible and can be evaluated in terms of their relative costs, accomplishments and environmental impact: ... No further land development (do- nothing alternative). ... Development of the site for other uses, such an industrial complex. -82- a. Do- nothing Alternative A "do- nothing" alternative could result in costs to both the private and public sectors in the form of lost investment and tax revenues for each, respectively. The taxes which would continue to be levied on the unusable property would be burdensome to the owners who would have no means available to earn a return on the land in order, to offset these taxes. The resulting tax burden could be partially, but not completely, offset by the classification of the project site as open space for assess- ment for tax purposes. The accomplishments of a "do- nothing" alternative would be the preservation of the subject site for future alternative uses which are unascertained at this time. Loss of the subject area as an available commercial resource could very possibly shift the burden of demand for this resource to another part of the region not guided by commitments to commercial development to the extent that Tukwila is. Other portions of the region may not, at this time, have adequate fac- ilities, i.e., transportation systems, to support a commercial complex and may experience such development as a burden. Tukwila, on the other hand, is located at the nexus of two major freeways. The environmental impact of a do- nothing alternative would be a continuation of the existing conditions which arerecognized to have been altered from their natural state some ago. A bird for- aging habitat would be retained. Plant progression to another stage of ecological succession would be relatively slow since the quality of existing fill for growing vegetation is low compared to the alluvial soils of the Green River Valley. In addition, all of the environment impacts associated with the development process would not occur. b. Development of the Project Site for Other Uses 1) Industrial The development of the project site for industrial purposes similar to those of adjacent areas would have many of the environmental impacts as would the proposed action. If. -83- however the project site were developed as a well maintained industrial park, there would be less impact in terms of air contaminants related to motor vehicles. As previously shown, the development of the project site for a commercial complex . will attract about two - thirds as many customers as does Southcenter. The resulting increase in air contaminants will thus be two - thirds again as much as those presently generated by motor vehicles. at Southcenter. The probable net effect will be an increase in air contaminants during all times when activities occur both at Southcenter and on the project site. If the subject site were utilized for industrial purposes, potential increases in vehicular related air contaminants could be avoided. Air quality would be affected by trucks used for distribution purposes and by the number of cars necessary to transport employees to the site. The air quality impact associated with the vehicles of approximately 27,000 to 45,000 customers per day (depending on the season) could be avoided. It should be noted that while use of the subject site for industrial purposes would avoid some air quality problems; the tax revenue to the city would be less than one - fourth as much with the proposed project. Furthermore, regional land use needs do not justify further industrial sites. According to PSGC studies, enough vacant land exists in areas currently being used for industrial purposes to satisfy the projected regional needs for most types of industry until the year 2000. Thus an industrial alternative is not justified at this time. 2. Alternatives Within the Proposed Project In formulating the proposed project design, various different internal uses were considered. Many of these internal alternatives uses were incorporated into the project plans in order to achieve an integrated unity of diverse functions that will be most compati- ble with existing land uses and social needs in the vicinity. Internal alternatives might also consist of plans for a project of a lesser magnitude, but such a project would not bring such a high degree of organized urban interest and economic vitality to this area. Thus, the proposed project incorporates the most possible alternative uses in the most viable fashion. -85- F. Relationship Between Local Short -Term Environmental Uses and the Maintenance and Enhancement of Long -Term Productivity. Short -term uses of the subject site constitute the transition time in which the area will be converted to commercial and business purposes. The long -term productivity of the involved and non- renewable resources largely involved the land itself, in that choices of use available in the future will be limited by the urbanization of the project site. The proposed development will preclude the land being used for agricultural purposes, except if market conditions determine that the need for land for commercial purposes in this area is not critical. This may be the case farther south in the Green River Valley but is not likely at this location. Potential long -term or future economic porductivity will depend largely on the commercial growth trends in the Central Puget Sound region. G. Any Irreversible and Irretrievable Resource Commitments with the Proposed Action. The proposed action will result in the commitment of the subject area to commercial and industrial land uses, which, in turn, will commit finan- cial resources, construction materials and labor to achieving such use. This will, in turn, result in some preclusion of optional future land uses and loss of the intrinsic resource of fertile soil.