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Home My WebLink AboutSEPA EPIC-SA-9 - SHORELINE MASTER PROGRAMSHORELI \E MASTER PROGRAM EPIC -SA -9 P v RT OF SEATTLE P. O. BOX 120.9 SEATTLE, WASHINGTON 98111 August 16, 1974 Mr. Rod Mack Shoreline Management Program Department of Ecology SUBJECT)._ Tukwila Shoreline Olympia, Washington 98504 `i Master Program (TSMP) Dear Mr. Mack: The City of Tukwila is proposing to annex the land along the Duwamish River between its existing northern boundary and the southern boundary of the City of Seattle. The area is roughly as shown on the enclosed map. It encompasses about 1 -1/2 miles of navigable waterway along which are located several marine transport facilities, including a Port of Seattle barge terminal (T -128). These circumstances create an obvious Port interest in the sub- stance of the TSMP, which is now being reviewed by your office. A Port staff analysis of the TSMP is enclosed. The conclusion of that analysis is: "In short, the TEMP regulations would effectively prevent the development or expansion of marine transport facilities." It is recognized that the im- plications of annexation were probably not considered during preparation of the TSMP. Nevertheless, the TSMP does not conform to the Shoreline Management Act or the Final Guidelines prepared in accordance with the Act. Both the Act (RCW 90.58.020) and Guidelines ['RAC 173 -16- 060(10)] establish port and water - dependent industries as priority uses. The Department of Ecology staff review of the TSMP should recognize the above deficiencies. We ask that the DOE comments and recommendations on the TSMP incorporate amendments which will allow for the development and expansion of maritime uses on the Duwamish River. This appears to be a necessity in order for the TSMP to conform to the Act and Guidelines. Do you agree? We will look forward to your response. Also, please send us a copy of your comments and recommendations on the TSMP when it is forwarded to the City of Tukwila. Sincerely, Keith Christian Environmental Affairs Specialist Planning and Research Department kc Enc. I-4'C: City of Tukwila Planning Department bcc: Messrs: Ford, Yoshioka Commission MERLE D. ADLUM /JACK S. BLOCK /PAUL S. FRIEDLANDER /HENRY L. KOTKINS /HENRY T. SIMONSON /General Manager J. ELDON OPH' 5 = 1 1• ' ' + J ��S LC —_ KENNYD -- La 4..e, IT T'TV a s /zing-ton • a14gi.C5 Sl '!;ainitr • — 1,300 i 1• - .'.`,,l — L5 ,_ :,, k;,Iii . ql, .1 , 1) 1 1. • • ;:x I: -_: 1 I- :41 -1 t• % • J.' PORT OF' SEATTLE STAFF APS AL`s StS rte snoRmarnt MASER PROCRAf (VW) ) ( AUG. a, tan f) The proposed City of Tukwila annexation would e;reaatly expand the city northward along the Duvaninh River Valley. The annexation area includes the east bank of the river between the 16th Avenue South brides and the head of navigation —a distance of about 1 -1/2 riles. Future development of shoreline facilities there would have to conform to the Tukwila Shore - line Plaster Program (TSMP) when (and if) annexation takes place. Terminal 128 (T -128) is the gable stretch of the river. north of T -128, has a barge may dock smaller vessels at of voter transport by other Company operations. only existing Port facility along this nevi - Monsanto Chemical Company, located immedietely pier in use. Taaaacson Structural Steel Company its bulkhead during hinh tide. Vo use is made waterfront land uses, which are mainly Boeing The circumstances create an obvioui Port interest in the substance of the TSMP. The TSMP has, therefore, bean reviewed in terms of its possible effect on water- dependent uses a3uch as T -128. The context in which the TSMP was prepared by the city nay be reflected by the following quote from the historical background section (p. 1.2): "In the early 1950's, planners for the Port of Seattle suggested an ambitious scheme to turn the Ilenvameiah and, Creen River Valley into a larete industrial complex, com- plete with a chipping canal to service the area. Tukwila citizens countered this proposal by incorporating large land areas into the City and imposing their own industrial zone on the land." The TSflP, an it stands, would indeed "counter" development of most water- dependent uses in the .area to be annexed. Such uses have apparently been given little, if any, consideration. Relevant provisions of the TSMP are summarised below: 1.' All ahorelines are placed in one environment -- Qrrae (p. $.1). 2. There is a set of general regulations (p. 6.1) applicable to the entire shoreline area. Regulation 4 prohibits 'disruption of existing trees or vegetation . . . unless necessary for public safety or flood control." A Port facility would probably not .cone under either exception. nreedeing for nevi.r ationnl i rover entss is alloyed by Regulation 12. Regulation 3 does allow etructuroo to be located over the river, if needed to -pro- tect or promote the public interest." It is difficult, however, to Imagine hear land asses to ouch a structure could be provided without violating the River Zone regulations summarized below. 4' Arthur R. Yoshioka tractor, Planning and Research ,artment August 2, 1974 3. The 200 foot wide shoreline area adjacent to the river and under the • jurisdiction of the T.SRY is divided into three strips (zones) parallel to the river. The width of end* shoreline one ie an follows (with dintances c asured landward ,fron mean high water): a. River Zone -- 0 to 50 feat (adjacent to the river). b. Lew tract Zone --- 50 to 100 feet. e. Riph, Imact Zone --• 100 to 200 feet (edge of jurisdiction) . 4. The only uses al /owed in the River Zone are access made, railroad "lead tracks," foot paths, recreational facilities and structures, trolatnesnt ponds, signe sign and flood eontxol dike • Thee is a 15 foot height limitation on structures. Landscapins, is required (p. 6.2). S. The Gam uses an in 4. above are allowed in the Cesar Ia*pnct_ Zone. In addition, structures under 35 feet in height, parking/loading and etorane facilities, railroad npurn, utilities and signs aro allowed. Screening is required between the river and several of the latter uses (p. 6.4) . 6. All uses aalloared by the eeieting city coning ordinance and nap are else allowed is the tTich Fact " yore (p. 6.5) . F=isting city zoning along the river in Tukwila is all industrial -- industrial park, light industry or heavy industry (p. 3.11). In abort, the TSP!P ro'ulations would effectively prevent the developnent or expenaion of marine transport facilities. The present form of the Tii!4P wag evidently net by the end of last April. Following Planning CeisRaiorn and City Council heearin'a, it was submitted in late Junes to the Department of Ecology (DOE) for revues. Representatives of the City wars asked to attend a Federal /State Task. Force neetint on July 31 to answer questions concerning the TSf1P. nc)i nest couplet° its review and either approve or reject the program by the end of September. The experience of other local govein ;amts has generally be ea that DOE rejects the subritted master' program and asks for a number of changes or amondr ants. The Port should impress its views concernine the TSY.P to DOE and ask that changes be :We to allow water -- dependent uses. The Inn unfie of the Shoreline Act and Guidelines provides us with gcod grounds far such a request. f hould annenntion take place, there could be no e:cpanaion of T -128 or other ,water -dap dent uaae unlesa the `T`. T is amended. It would take considerable time to eo throu*:;h the procedural tam's involved, even if the City of Tukwila is willing. The city probably did not consider the inplications of possible annexations vhen preparina the TSMP.; _ - - - - kee S8 /08 ce: R. D. Ford. Fred Salingor, Paul Chilcote DANIEL J. EVANS GOVERNOR STATE OF WASHINGTON Office of the Governor OFFICE OF COMMUNITY DEVELOPMENT OLYMPIA, WASHINGTON 98504 June 25, 1974 File No. 498 Gary Crutchfield 6230 South Center Blvd. Tukwila, Washington 98067 Dear Mr. Crutchfield: This letter is to acknowledge receipt of the environmental impact statement on Shoreline Master Program. The statement title has been circulated among all Divisions within this agency. We have no comment on the statement at this time. Sincerely, Nick Pettit, Policy Analyst Policy & Planning Division NP : lh RICHARD W. HEMSTAD DIRECTOR SERVING: KING COUNTY 410 West Harrison St. Seattle, 98119 (206) 344 -7330 PUGET SOUND AIR POLLUTION CONTROL AGENCY 410 West Harrison Street, Seattle, Washington 98119 (206) 344 -7330 June. 21, 1974 Gary Crutchfield, Planning Technician -City of Tukwila 6230 Southcenter Blvd. Tukwila, Wash. 98067 Subject: Draft Environmental Impact Statement Tukwila Shoreline Master Program Dear Mr. Crutchfield: We have reviewed the Tukwila Shoreline Master Program draft environmental impact statement received May .17,.1974.. The large number. of recent actions authorized by. City of Tukwila include .industrial parks, shopping and business parks, office complexes, . etc. In the aggregate these actions could be responsible for concentrated, adverse air pollution :effects. We suggest that an overall assessment of the air pollution effects from these projects be undertaken in connection with this statement; or if this is not .appropriate., in connection with other master. planning undertaken by your city. Thank you. for the opportunity to. comment.. Yours truly, KITSAP COUNTY Dial Operator tor Toll Free Number Zenith 8385 . Bainbridge Island, Dial 344 -7330 PIERCE COUNTY 213 Hess Building Tacoma, 98402 (206) 383 -5851 SNOHOMISH COUNTY , 506 Medical - Dental Bldg. Everett, 98201 (206) 259 -0288 ARD:JRP:mfr A. R. Dammkoehler Air Pollution Control Officer BOARD OF DIRECTORS CHAIRMAN: Gene Lobe, Commissioner Kit`sap County; VICE CHAIRMAN: Gordon N. Johnston, Mayor Tacoma; I N. Richard Forsgren, Commissioner Snohomish County; Patrick J. Gallagher, Commissioner Pierce County; Harvey S. Poll, Member at Large; John D. Spellman, King County Executive; Wes Uhlman, Mayor Seattle; Robert C. Anderson, Mayor Everett; Glenn K. Jarstad, Mayor Bremerton; A. R. Dammkoehler, Air Pollution Control Officer. DATE ARTWORK BINDING COVERS QUICK -COPY ENLARGING REDUCING VELO BIND SPECS TAX TOTAL- 4 ��nX AVENUE :} cas a 98101 copy center division of superior reprographics ) �� / 7 DUE NI!, �A'� ,?�jS - V " �C;Y %� BY / l 14/dh h4 `r�• WASHINGTON //JJ,��, !/Y % 6/7 • G ' '��i�f • 1922 4T1-1 SEATTLE. 447 -6930 d1 f f /�Le�! PHONE Z 452g6 T E M ORIGINAL COPIES TYPE DESCRIPTION RATE TOTALS 1 77 50 f-. ittlao-eh jkleant,7 4,,"1",,,,,_ /4 qo 2 / 47 v.1.4. 6Adi= . ri) 3 /J 5-d //. /7 Z' w ' WilLgO 4 r/ 7 } 7 . 1St JP./ 6 2 5 G .._ uu.,., '2.57 6 � �u • k r c, 3 7 2) PRINTING COLLATING FOL ING INDEX TABS SUB TOTAL 299 y y 291 ARTWORK BINDING COVERS QUICK -COPY ENLARGING REDUCING VELO BIND SPECS TAX TOTAL- DANIEL J. EVANS GOVERNOR ROOM 115, GENERAL ADMINISTRATION BUILDING • PHONE 753 -6600 OLYMPIA, WASHINGTON 98504 June 12, 1974 City of Tukwila Planning Department 6230 Southcenter Boulevard Tukwila, WA 98067 Gentlemen: THOR C. TOLLEFSON DIRECTOR We have been requested to review a draft Environmental Impact Statement (DEIS) for approval of the proposed Shoreline Master Program for Tukwila. Fol- lowing are our comments: 1. The DEIS prepared by the Wilsey and Ham consultant firm is an excellent assessment of what we anticipate will be a superior Master Program, judging from the suggested revisions that are presented. Hence, most of our comments on the DEIS are only for emphasis, but the Master Program will be reviewed more critically. 2. Page A -4 - The following quotations point out two of the most important features of the Shoreline Management Act: "....cooperative and unified effort by our governmental agencies to achieve a use policy consistent with the provisions of the Act lands adjacent to shorelines must be taken into consideration if the consistency stressed in the Act is to be achieved." 3. Page A -7 - We particularly appreciate Overall Goal No. 8: "Recognize, protect, and improve aquatic habitats and spawning grounds of the Green River which are an invaluable natural resource." 4. Pages A -9 through ■-22 - Although the Tukwila Citizen Advisory Committee designated the Green River shoreline as an Urban Environment, we trust that the proposed 50 -foot "river zone" will accomplish the general objectives of the Conservancy Environment, i.e., " to ensure a con- tinuous flow of recreational benefits to the public and to achieve sus- tained resource utilization." The authors of the DEIS are to be com- mended for their careful analysis of the present status of the Master Programs for contiguous jurisdictions (Kent, Renton, and King County) which must ultimately be compatible. No mention was made, however, of compatible jurisdiction over Green River itself and the riverbed below the line of ordinary high water, unofficially defined as that level created by a flow of 6,500 cfs at Tukwila. 3 City of Tukwila Planning Department June 12, 1974 Page 2 5. Page B -14 - Since the last sentence states that there appears to be no premium paid for industrially zoned land with river frontage, it would seem logical to assume that the "river zone" therefore could be wider than 50 feet inland from the mean high water mark. This possibility should be considered in view of the statements on page C -2 that "the deleterious effects of industrial development will be continued" and that "the controls over the limited areas contained within the shore- line zones will have little effect on urban storm run -off which will continue to create water quality problems in the Green River, which will in turn have negative consequences for fisheries resources." 6. Pages C -3 through C -12 - The discussion of impacts of the regulations in the Master Program was very helpful, especially in relevance to existing laws and need for revision of proposed regulations. 7. Pages C -13 through C -23 - The benefit -cost analysis and summary of socio- economic impacts give excellent perspective and raise issues deserving full consideration on a state-wide basis with respect to favorable recreational benefits for shoreline areas and securing the integrity of a combined shoreline and river system. We appreciate the opportunity to comment upon a very comprehensive Environ- mental Impact Statement. Sincerely, Gilbert A. Holland Fisheries Research Coordinator cc: D. L. Lundblad - Dept. of Ecology E. S. Dziedzic - Dept. of Game Rod Mack - Dept. of Ecology Mr. Gary Kucinsky Planning Director City of Tukwila Planning Department 6230 Southcenter Boulevard Tukwila, Washington 98188 King County State of Washington John D. Spellman, County Executive Joseph L. McGavick, Director, Department of Budget and Program Planning LONG RANGE PLANNING DIVISION Stan Rosen, Manager Room 400 King County Courthouse Seattle, Washington 98104 (206) 344 -3900 June 12, 1974 Dear Mr. Kucinsky: The Draft Environmental Impact Statement on the City of Tukwila's Proposed Shoreline Master Program is well done. Some specific comments have been made by the Land Use Management Division. This is the extent of our comments. SR:PT:jk Enclosure Since ,., 4-c-c-\,_ Sta' 'Rosen, Manager Long Range Planning Division NFL ;` ORAN Date: May 31, 1974 Department of Community and Environmental Development LAND USE MANAGEMENT DIVISION EDWARD B. SAND, DI RECTOR W217 King County Courthouse Seattle, Washington 98104 m6-344, 4292 c. "'`'StoN TO: Paul Tschirley, Budget & Program Planning . Long Range Planning Division From: Edward B. Sand, Director Tit -')- Subject: Tukwila Master Program EIS ptANNiNG p1V1 .JUN 3 1974 LAND USE SECTION The historical background of the Shoreline Management Act of 1971, on page A -4, is misleading. As written, it implies that this Act was not .drafted until after failure of Initiative 43. Actually, the initiative did first fail in the legislature, but then was submitted to the electorate as provided by the state constitution when initiatives are not- adopted by - the - legislature. Simultaneously, the legislature sub- mitted its own bill; the present law, to the voters'as "43 -B ". At that time 43 -B had been.in effect about six months. This impact statement is generally excellent. Of particular merit is the discussion on pages C -4 to C -24, and the.discussion relating the proposed master program to other plans and programs. The.biophysical impact summary on C -1 and C -2 is probably accurate and speaks well for the forthrightness of the EIS, but leaves some questions about the master program itself. ( "...the•deleterious effects of industrial development will be continued," "...the proposed °master program will have little net impact on Tukwila's natural setting," and "....these regulations will have little consequence for established trends of industrial development in the valley. ") The weakness may be due to the 50' -50' -100' zonation described on page A -9, which has little legal or natural systems basis. Were the intent of the Shoreline'Act more rigorously pursued within the full jurisdictional area of the law, there might be a more substantial pre- dictable impact. Thus, expansion of the "River Zone" and "Low Impact" Zone" should be discussed as possible "Alternative Modifications within the Proposed Program," pages E -4,5. EBS:RST: js .. .._- 115, GENERAL ADMINISTRATION BUILDING 0 PHONE 753 -6600 OLYMPIA. WASHINGTON 98504 . �iti.. W��1 .....i.....s�s'i.i_:...�.ke _�a.a: r�i'u'1:�...1...,...i�::5 a:ai.��iw�..;e•- :.e+...;.k.' ��: THOR C. TOLLEFSON DIRECTOR DANIEL J. EVANS ROOM GOVERNOR June 12, 1974 City of Tukwila Planning Department 6230 Southcenter Boulevard Tukwila, WA 98067 Gentlemen: We have been requested to review a draft Environmental Impact Statement (DEIS) for approval of the proposed Shoreline Master Program for Tukwila. Fol- lowing are our comments: 1. The DEIS prepared by the Wilsey and Ham consultant firm is an excellent assessment of what we anticipate will be a superior Master Program, judging from the suggested revisions that are presented. Hence, most of our comments on the DEIS are only for emphasis, but the Master Program will be reviewed more critically. 2. Page A -4 - The following quotations point out two of the most important features of the Shoreline Management Act: "....cooperative and unified effort by our governmental agencies to achieve a use policy consistent with the provisions of the Act lands adjacent to shorelines must be taken into consideration if the consistency stressed in the Act is to be achieved." 3. Pape A -7 - We particularly appreciate Overall Goal No. 8: "Recognize, protect, and improve aquatic habitats and spawning grounds of the Green River which are an invaluable natural resource." 4. Pages A -9 through A -22 - Although the Tukwila Citizen Advisory Committee designated the Green River shoreline as an Urban Environment, we trust that the proposed 50 -foot "river zone" will accomplish the general objectives of the Conservancy Environment, i.e., " to ensure a con- tinuous flow of recreational benefits to the public and to achieve sus- tained resource utilization." The authors of the DEIS are to be com- mended for their careful analysis of the present status of the Master Programs for contiguous jurisdictions (I:ent, Renton, and King County) which must ultimately be compatible. No mention was made, however, of compatible jurisdiction over Green River itself and the riverbed below the line of ordinary high water, unofficially defined as that level created by a flow of 6,500 cfs at Tukwila. 3 City of Tukwila Planning Department June 12, 1974 Page 2 5. Page B -14 - Since the last sentence states that there appears to be no premium paid for industrially zoned land with river., frontage, it would seem logical to assume that the "river zone" therefore could be wider than 50 feet inland from the mean high water mark. This possibility should be considered in view of the statements on page C -2 that "the deleterious effects of industrial development will be continued" and that "the controls over the limited areas contained within the shore- line zones will have little effect on urban storm run -off which will continue to create water quality problems in the Green River, which will in turn have negative consequences for fisheries resources." 6. Pages C -3 through C -12 - The discussion of impacts of the regulations in the Master Program was very helpful, especially in relevance to 'existing laws and need for revision of proposed regulations. 7. Pages C -13 through C -23 - The benefit -cost analysis and summary of socio- economic impacts give excellent perspective and raise issues deserving full consideration on a state -vide basis with respect to favorable recreational benefits for shoreline areas and securing the integrity of a combined shoreline and river system. We appreciate the opportunity to comment upon a very comprehensive Environ- mental Impact Statement. Sincerely, Gilbert A. Holland Fisheries Research Coordinator cc: D. L. Lundblad - Dept. of Ecology E. S. Dziedzic - Dept. of Game Rod Mack - Dept. of Ecology gE A D # 4:7..-‘ • Department of Community and Environmental Development LAND USE,MANAGEMENT DIVISION EDWARD•B. SAND, DIRECTOR W217 King County Courthouse Date: May 31, 1974 Seattle, Washington 98104 206 - 344 - 4292 Paul Tschirley, Budget & Program Planning Long Range Planning Division ;{ `' "1 °�' ®' �, From: Edward B. Sand, Director Subject: Tukwila Master Program EIS LAND USE SECTION The historical background of the Shoreline Management .Act of 1971, on page A -4, is misleading. As written, it implies that this Act was not .drafted until after failure of Initiative 43. Actually, the initiative did first fail in the legislature, but then was submitted to the . electorate as provided by the state constitution when initiatives are not adopted by the legislature. Simultaneously, the legislature sub - mitted its own bill, the present law, to the voters as "43 -B ". At that time 43 -B had been . in effect about ' six months. This impact statement is generally excellent.- Of particular merit is the discussion on pages C -4 to C -24, and the.discussion relating the proposed master program to 'other plans and programs. The.biophysical impact summary on C -1 and C -2 is probably accurate and speaks well for the forthrightness of the EIS, but leaves some questions about the master program itself. ( "...the deleterious effects of industrial development will be continued, "...the proposed master program will have little net impact on Tukwila's natural setting," and ".-.these regulations will have little consequence for established trends of industrial. development in the valley. ") The weakness may be due to the 50' -50' -100' zonation described on page A -9, which has little legal or natural systems basis. Were the intent of the Shoreline Act more rigorously pursued within the full jurisdictional area of the law, there might be a more substantial pre- dictable impact. Thus, expansion of the "River Zone" and "Low Impact" Zone" should be discussed as possible "Alternative Modifications within the Proposed Program," pages E -4,5. EBS:RST:js Frank Todd, Mayor CI op T K ILA 6230 SOUTHCENTER BLVD. TUKWI LA, WASHINGTON 98067 PLANNING DEPARTMENT STAFF COMMENTS SHORELINE MASTER PROGRAM 10 June 1974 The following are staff comments in response to comments received during the Public Hearing held by the City Council regarding this matter on 5 June 1974. Each question is stated and is followed by the Staff's response. 1. WHAT ARE THE "ENDANGERED SPECIES" REFERRED TO ON PAGE 1,3? COMMENT: The words "endangered species" refers to the Green River shorelines. Obviously, the natural character of much of the shorelines has been lost for perpetuity due to rock rip -rap and dikes. However, the Shoreline Management Act is certainly not aimed at protecting only. the river. banks. It must consider, in addition to the river banks specifically, the associated wetlands. By definition within the Act itself, the term 'wetlands' includes the first 200 feet inland from the ordinary high watermark as measured,on a horizontal plane.' 2, WHAT CHARACTERISTICS QUALIFY THE GREEN RIVER AS A "SHORELINE OF STATEWIDE SIGNIFICANCE "? COMMENT: The fact a river or lake is determined to be of "statewide significance" should not be construed to infer that the recreational value of the particular water body is such as to be of "statewide significance ". One of the most important qualifications is its flow capacity and the well -known fact that it serves as the major drainage channel for the entire Green River Valley, which, in consideration of all current trends, will continue to Staff Comments, 10 June 1974 Page 2 grow economically, thereby serving an ever - growing economic region. Certainly the Green River Valley is of significant economic importance to the State of Washington. 3. GENERAL USE REGULATIONS ARE NOT DEFINITE ENOUGH, COMMENT: The General Use Regulations provide general rules for all developments which can be used as a guide- line in reviewing development plans and their related Environmental Assessment Summary to ensure the intent of the Shoreline Management Act is furthered. Only one of the General Use Regulations is considered by Staff to be ambiguous; #7. The following rewrite of that regulation is offered to clarify any uncertainty which might arise through interpretation. No effluent shall be discharged into the Green River which exceeds the water quality classification as established by the State Department of Ecology for the adjacent portion of the River. 4, THE SPECIFIC REGULATIONS ARE TOO SPECIFIC, COMMENT: It is the purpose of these regulations to distinctly define the intended restrictions and Staff feels this section of the Program cannot be too specific. 5. UNIQUE CIRCUMSTANCES ARE NOT DEFINED. COMMENT: The original Master Program, as recommended by the Citizen's Advisory Committee, included a section titled Conditional Uses and, for the most part, simply referred to Section 18.64 of the Tukwila Zoning Code regarding the allowance of conditional uses. However, the Planning Commission, during their Public Hearing, received input declaring the Conditional Use approach as a poor attempt to provide some flexibility in site design. In actuality, the original Conditional Use section merely allowed the development of those uses included in Section 18.64 in conformance with the criteria and procedures of that Section, but did not allow any flexibility in the use regulations of the Master Program. Thus, the Planning Commission deleted the Conditional Use section from the Master Program and replaced it with a provision for the determination as to the extent of variation which should be allowed in any development Staff Comments, 10 June 1974 Page 3 which may need such flexibility to permit reasonably effective use. The Unique Circumstances section of the Master •Program, .however general in nature, certainly defines the proper procedure. It cannot, however, hope to define every circumstance or situation to which this section would apply. That question would simply be answered by the Planning Commission during the Public Hearing required for application of this Section. 6, WHERE IS THE "OUTSIDE TOP OF DIKE`? COMMENT: The phrase "outside top of dike" attempts to define the landward edge of the top of the dike. It is a common term used by engineers to define such a point. The only possibility of further clarifying that phrase would be to include it within the Definitions Section. 7. THE RIVER ZONE SETBACK SHOULD CONSIST OF THIRTY (30) FEET. COMMENT: This claim was considered several times by the Citizen's Advisory Committee as well as the Planning Commission during formulation and review of the Master Program. As noted early in the. Program, the Shoreline Management Act is directed at enhancement of shorelines. To accomplish this goal, a setback was determined to be the most feasible route by both the Citizen's Advisory Committee. and Planning Commission. The Citizen's Advisory Committee determined that fifty feet, as measured from the mean high water mark, should comprise this setback. The basic reason for fifty feet was if and when diking was accomplished throughout the length of the River, fifty feet would be the minimal amount of setback to accomplish the intended goal. However, it made no pro- vision for those areas where there is no dike and may never be one. Thus, the Planning Commission determined that an optional provision should be included. In determining the minimum extent of setback, the Planning Commission noted the manner of measuring such a setback. In consideration of the fact the mean high water mark would normally be a point some five to ten feet beyond the top of the bank, it was determined that the bare minimum setback to accommodate enhancement of the shore- lines would be forty (40) feet. This would create, in most instances, an effective setback area of approximately thirty to thirty -five feet from the top of bank. To ensure that this setback area was used to enhance the shorelines, the Commission restricted the use of it to Staff Comments, 10 June 1974 Page 4 landscape enhancement. To retain some flexibility, in design standards, the Commission retained the fifty (50). foot setback but included additional uses deemed not to have a detrimental effect on the shoreline enhancement.. Thus, in consideration of several points, including the intent of the Shoreline Management Act, the manner of measurement, the effective setback area'and flexilility in development design, Staff supports the Planning Commis- sion recommendation as the minimum setback required to fulfill the intent of the,Shor.eline Management Act, } S, ADDITIONAL TYPES OF GROUNDCOVER, OTHER THAN LIVING,. SHOULD BE INCLUDED IN RIVER ZONE STANDARDS. COMMENT: It was the expressed intent of both. the Citizens Advisory Committee and Planning Commission that .landscape enhancement of the shorelines consist of living ground - cover to attain as much a natural.character as is feasible. The problem of maintenance can be solved by using one of the live groundcovers not requiring continual maintenance in those areas such as dike slopes where natural grass would be somewhat difficult to maintain., Thus( Staff must recommend that groundcovers be limited to those which_ are live. 9. PARAGRAPH #2 AND PARAGRAPH #3 ARE CONFUSING, COMMENT: Staff agrees with the expressed confusion bred by paragraphs #2 and #3 on page 6.4 and recommends the following revision to clarify the intent of the original standards. #2. Access roads shall be located no closer than ten (10) feet to buildings, spur tracks or parking / loading and storage facilities and the effective setback area shall be suitably landscaped. This shall not prohibit access and egress points between the access road and the described facilities. #3. (DELETE) 10. ADDITIONAL MINOR CORRECTIONS, COMMENT: Staff has noted a few minor corrections and recommends the following: Staff Comments, 10 June 1974 Page 5 1. Revise paragraph #3, page 6.3 to read as follows: #3. The River Zone shall be landscaped with suitable plant material from the appropriate setback line or edge of road or track to the river, consistent with flood control measures, as follows: a. Large hardy shade trees at a maximum of 30 feet on center such as sycamore ... b. One of the following: 1. Live groundcover at a maximum of 18 inches on center ... 2. Delete all of paragraph #7, page 6.4. 3. Revise paragraph #2, page 6.4 to read as follows: #2. Access roads shall be located no closer than ten (10) feet to buildings, spur . tracks or parking /loading and storage facilities and the effective setback area shall be suitably landscaped. This shall not prohibit access and egress points between an access road and the described facilities. 4. Delete all of paragraph #3, page 6.4. 5. Revise paragraph #4, page 6.5 to read as follows: #3. Where access roads exist, parking /loading and storage facilities shall be appro- priately screened as follows: A. A solid evergreen screen of a minimum six (6) foot height. OR B. Decorative fence six (6) feet high. (NOTE: Chain link fence shall be planted with ivy or other trailing vine.) OR . C. Large hardy shade trees as per require- ments for access roads. OR Staff Report, 10 June 1974 Page 6 D. Earth berms at.a minimum four (4) feet high suitably planted with live groundcover or natural grass. 6. Revise paragraph #5, page 6.5 to read as follows: #4. Lead tracks shall be no closer than fifteen (15)-feet to parking /loading, and storage facilities and shall be suitably landscaped. 11. THE MASTER PROGRAM CONTAINS NO IMPLEMENTATION SECTION. COMMENT: Upon conferring with the State Attorney General's Office as well as the City Attorney, it is Staff's recbm- mendation that the Master Program not include the implementation section but that the Master Program be adopted by ordinance and within that enacting ordinance there be included a section stating implementation of not only the Master Program but the Shoreline Management Act as well. Moreover, the enacting ordinance should include a section charging the Planning Department with the responsibility of establishing procedures for the imple' mentation of the Act and the Program both. Sincerely, 7 if a 'ary ',Crutchfield Planning Technician GC /lt .t EMO N U Department of Community and Environmental Development LAND USE 'MANAGEMENT DIVISION EDWARD B.'SAND, DIRECTOR W217 King County Courthouse Date: May 31, 1974 Seattle, Washington 98104 206' : 344 4292 i >t� ;vf ::ft <� J;Vt5i7� Long Range Planning Division . From: Edward B. Sand, Director E L r 'USE J {CilOal LA.aD To: Paul Tschirley, Budget & Program Planning ,Subject: Tukwila Master Program EIS The historical background of the Shoreline Management.Act of 1971, on page A -4, is misleading. As written, it implies that this Act was not .drafted until after failure of Initiative 43. Actually, the initiative did first fail in the legislature, but then was submitted to the electorate as provided by the state constitution when initiatives are not adopted by the legislature. Simultaneously, the legislature sub -. .mitted its own bill, the present law, to the voters as "43 -B ". At that time 43 -B had been.in effect about six months. This impact statement is generally excellent. Of particular merit is the discussion on pages C -4 to C -24, and the.discussion relating the proposed master program to other plans and programs. The biophysical impact summary on C -1 and C -2 is probably accurate and speaks well for the forthrightness of the EIS, but leaves some questions about the master program itself. ( "...the deleterious effects of industrial development will be continued," "...the proposed master program will have little net impact on Tukwila's natural setting," and "....these regulations will have little consequence for established trends of industrial development in the valley. ") The weakness may be due to the 50' -50' -100' zonation described on- . page A -9, which has little legal or natural systems basis. Were the intent of the Shoreline Act more rigorously pursued within the full jurisdictional area of the law, there might be a more substantial pre- dictable impact. Thus, expansion of the "River Zone" and "Low Impact" Zone" should be discussed as possible "Alternative Modifications within the Proposed Program," pages E -4,5. EBS:RST:js r Grand Central on the Park • First and So: Main • Seattle, Washington 98104 • 206/464 -7090 Puget Sound Governmental 'Conference May 28, 1974 Mr. Gary Crutchfield, Planning Technician City of Tukwila Planning Department 6230 Southcenter Blvd. Tukwila, Wa. 98067 Dear Mr. Crutchfield: Subject: Shoreline Management Master-Program for lthe City of Tukwila The Puget Sound Governmental' Conference has received your Draft Environmental Impact Statement submitted for comments pursuant to the National Environmental Policy Act /State Environmental Policy Act and has assigned log number 2/303/74 to it. Please refer to this number in future correspondence regarding this statement. Ms. Barbara Hastings (phone: 464 -6928 ) will be responsible for the coordination of review on this impact statement. Every effort will be made to transmit our comments to you by the end of your . designated review period. Very truly yours, Mart Kask Executive Director PSGC Form R -6 (Revised 5/20/1974) Frank Todd, Mayor CITY OF � , U WI ,. , 6230 SOUTHCENTER BLVD. TU KWI LA, WASHINGTON 98067 PLANNING DEPARTMENT ADDRESSEE: 15 May 1974 Please find enclosed one. copy of the Draft Environ- mental Impact Statement regarding the proposed Shore- line Management Master Program for the City of Tukwila. Although many of the revisions suggested in the discussion of impact of the regulations have been made, we would appreciate any comments you may have in response -to this Impact Statement. Please return any comments to this office within 30 days of the date of this letter. GC /lt Encl: as Sincerely, t t';',A, Y Cary/Crutchfield Planing .Technician Frank Todd, Mayor CITY or TUKWILA 6230 SOUTHCENTER BLVD. TUKWI LA, WASHINGTON 98067 PLANNING DEPARTMENT Mayor Frank Todd City of Tukwila Tukwila, Washington 98067 RE: Proposed Shoreline Management Program Environmental Assessment Dear Mayor: 28 March 1974 As you are aware, the Citizen's Advisory Committee has recommended for adoption the Shoreline Management Master Program drafted by the consultants, Jones & Jones. During the initial Public Hearing held by the Planning Commission on 21 March 1974, it was determined by this department that an Environmental Assessment Summary, in accordance with Section 18.98.010 (g), is required to assess the impact of the proposed program. Although the Assessment Summary is required to provide an . environmentally - informed decision, it is urged by this office that the Assessment Summary be completed soon enough to provide an environmentally - informed recom- mendation from the Planning Commission. In keeping with this thought, I have contacted the two consulting firms that have sufficient experience in preparing Environmental Assessments as well as some background in Tukwila. Although both the Murray- McCormick Environmental Group and Wilsey & Ham have considerable experience in the preparation of Environmental Assessment, Wilsey & Ham certainly has much more background regarding Tukwila in particular. Upon discussing the necessary contents of the report and the severely restricted time frame, I have received the following proposals in the form of cost ranges dependent upon the degree of detail required. Murray - McCormick Environmental Group Minimum (Brief) 3,500 Optimum (Detailed) 6,500 Mayor Todd Page 2 Wilsey & Ham, Incorporated Minimal. (Brief) 5,500 Optimum (Detailed) 8,500 Upon comparison of relatively similar reports prepared by both firms, and in light of the extremely sensitive nature of the report, I must recommend that the City Council employ the firm of Wilsey& Ham, Inc., for a maximum fee of $7,500. I have complete confidence in the ability of the recommended firm to prepare an objective, detailed analysis which the report must be. Although I have recommended the costlier of the two proposals, I consider the monetary difference to be insignificant in relation to the service which will be provided by a thorough analysis, and hope that the City Council will similarly view the cost versus benefit. GC /lt Sincerely, Gary Crutchfield Planning Technician THE MURRAY- McCORMICK FIR ENVIRONMENTAL GROUP Ibil ECOSYSTEMS ANALYSIS • PLANNING • LAND SURVEYS • ENGINEERING March 28, 1974 Gary Crutchfield Planning Department City of Tukwila 6230 Southcenter Blvd. Tukwila, Washington Dear Gary: The Murray- McCormick Environmental Group appreciates the opportunity to present the following. proposal to you on the socio - economic assessment. Regarding the impact of the Shorelands Management Act on the water front ori- ented property in Tukwila, our firm has done several studies along this line during the last few years, and has the personnel and expertise with which to put this report together for you within the time frame you mentioned. Not knowing at this point exactly how detailed an analysis you want, we propose the following ranges. A minimum study, to cover the subject that you have outlined, would run $3000 - $3500. An in -depth study covering these items, and still maintaining the time frame you mentioned, would run $6000 - $6500. If the City Council would be interested in sitting down with us and going over some of the similar reports that we have done recently, we would be glad to do so, and could on one day's notice. If you have any questions, please don't hesitate to give me a call. Sincerely, THE MURRAY - McCORMICK ENVIRONMENTAL GROUP C Howard C. Cornell HCC /cp 1309 -114TH AVENUE, B.E., SUITE 31B /BELLEVUE, WASHINGTON 98004 /2O13- 4813-21380 SACRAMENTO RENO PORTLAND BELLEVUE OAKLAND NEWPORT BEACH NOVATO BENICIA BANTA CLARA LAKE TAHOE WILSEYa HAM, INC. Earl P. Wilsey (1892 -1957) 15 SOUTH GRADY WAY, EVERGREEN BUILDING • RENTON, WASHINGTON 98055 • Telephone (206)228 -1080 • Cable "WHINT" March 27, 1974 File No. L- 999-5611 -00. Mr. Gary Crutchfield Planning Technician City of Tukwila 14475 - 59th Avenue South Tukwila, Washington 98607. Dear Gary: RE: PROPOSED SHORELINE MASTER PROGRAM ENVIRONMENTAL ASSESSMENT - SUMMARY OF SOCIO- ECONOMIC FACTORS In accordance with our discussion yesterday afternoon, March 26, 1974, I am pleased to submit the following proposed scope of services for the above referenced project. As you are aware, through our subsequent discussions this morning, 1 have attempted to develop a study team capable of addressing the needs that you have outlined. This team is comprised both of our own in -house personnel and two key subconsultants. The first of these subconsultants is the Market and Economic Research Firm, Northwest American of Seattle, who would assist us with analysis of the proposed Master Program's impact on economic factors in Tukwila. The other subconsultant has not yet been specifically identified but will be a well known attorney who specializes in land use matters. We have the names of three attorneys that we are considering at this time. We would ask the selected attorney to review the proposed Shoreline Master Program in light of recent statutes and land use court decisions in order to deter- mine the legal implications of the Master Program. Wilsey & Ham's involvement in the study would begin with providing sufficient land use inventory and property ownership data to Northwest American in order for them to begin their analysis. In addition, we would conduct a review of the Citizen Advisory Committee hearings and other activities which have lead to the preparation .of the Master Program and evaluate the completeness of that process; we would conduct a detailed literature review with regard to establishing the value of retaining recreation and open space opportunities within urban areas; and after accumulating all the above mentioned data, we would assimilate it into our final assessment summary report. The following is an itemized estimate providing you with a fee range for each task that we propose to undertake. tv A. SUBCONSULTANTS 1. Economic Analysis - Northwest American $ 3,000.- 3,500.. 2.. Legal Review 500.- 1,000. engineering • planning • surveying • landscape architecture • mapping • systems • • Mr. Gary Crutchfield March 27, 1974 Page Two B. WILSEY & HAM 1. Land Use Inventory (input to Economic Study) a. Property Ownerships (Assessor's Map Research) $ 70 - 140 b. On -Site Inventory 70 - 140 c. Inventory Map 130 - 160 2. Research Open Space & Recreation Values 640 - 975 3. Write Assessment (includes meetings with subconsultants) 570 - 900 4. Administration and Clerical 575 - 1,150 5. Miscellaneous Expenses 265 - 580 TOTAL $ 5,820 - 8,545 I trust this will give you enough information to discuss this matter with the Planning Commission. We would be prepared to enter into a time and materials agreement based on a mutually acceptable fee for this work when you have received approval from the Commission. In the meantime, if I can be of further assistance or can answer any questions, please don't hesitate to call. As you know, Wilsey & Ham is anxious to serve Tukwila in any appropriate capacity for which you have need. Very truly yours, WILSEY & HAM, INC. /1&/e Michael J. Brooks, ASLA Program Director MJB /kmb WILSEI'& HAM, INC. Earl P. Wilsey (1892 -1957) 15 SOUTH GRADY WAY, EVERGREEN BUILDING • RENTON, WASHINGTON 98055 • Telephone (206) 228 -1080 - Cable "WHINT" March 27, 1974 File No. L- 999-5611 -00 Mr..Gary Crutchfield Planning Technician , City of Tukwila 14475 - 59th.Avenue South- Tukwila, Washington 98607 • .Dear Gary: RE: PROPOSED SHORELINE MASTER PROGRAM ENVIRONMENTAL ASSESSMENT - SUMMARY OF SOCIO - ECONOMIC FACTORS In accordance with our discussion yesterday afternoon, March 26,V1974, I am pleased to submit the following proposed scope of services for the above referenced project. As you are aware, through our subsequent discussions this morning, 1 have attempted to develop a study team capable of addressing the needs that you have outlined. This team is comprised both of our own in -house personnel and two key subconsultants. The first of these subconsultants is the Market and Economic Research Firm, Northwest American of Seattle, who would assist ur; with analysis of the proposed Master Program's impact on economic factors in Tukwila. The other subconsultant has not yet been specifically identified but will be .a well known attorney who specializes in land use matters. We have the names of three attorneys that we are considering at this time. We would ask the selected attorney to review the proposed Shoreline Master Program in light of recent statutes and land use court decisions in order to deter- mine the legal implications of the Master Program. Wilsey & Ham's involvement in the study would begin with providing sufficient land use inventory and property ownership data to Northwest American in order for them to begin their analysis. In addition, we would conduct a review of the Citizen Advisory Committee hearings and other activities which have lead to the preparation of. the Master Program and evaluate the completeness of that process; we would conduct a detailed literature review with regard to establishing the value of retaining recreation and open space opportunities within urban areas; and after accumulating all the above mentioned data, we would assimilate it into our final assessment summary report. The following is an itemized estimate providing you with a fee range for each task that we propose to undertake. A. SUBCONSULTANTS 1. Economic Analysis -- Northwest American 2.. Legal Review $ 3,000 - 3,500.. 3,500 . 500. - 1,000. . l 1 00` engineering. • planning • surveying • landscape architecture • mapping • systems Mr. Gary Crutchfield March 27, 1974 B. WILSEY & HAM 1. Land Use .Inventory (input Study) • Property Ownerships Map Research) ▪ On -Site Inventory • Inventory Map. Page Two 70._. . 70 7 140. • Research Open Space & Recreation Values Write Assessment (includes .meetings with subconsultants) 4. Administration and Clerical 5. Miscellaneous Expenses TOTAL 130 640 160 /e o 975 .776- 570 - 900 575 - 1,150. 265 - ' 580 $ 5,820.- 8,545 1 trust this will give you enough information to discuss this matter with the Planning Commission. We would be prepared to enter into a time and materials agreement based on a mutually acceptable fee for this work when you have received approval from the Commission. 7 73 %!--� In the meantime, if I can be of further assistance or can answer any questions, please don't hesitate to call. As you know, Wilsey & Ham is anxious to serve Tukwila in any appropriate capacity for which you have need. Very truly yours, WILSEY & HAM, INC. Michael J. Brooks, ASLA Program Director MJB /kmb