HomeMy WebLinkAboutPlanning 2019-02-28 ITEM 4 - INFORMATIONAL MEMORANDUM - CRITICAL AREAS REPORTCity of Tukwila
Allan Ekberg, Mayor
INFORMATIONAL MEMORANDUM
TO: Planning Commission
FROM: Minnie Dhaliwal, Planning Supervisor and Andrea Cummins, Urban
Environmentalist
DATE: February 19, 2019
SUBJECT: Update of TMC 18.45, Environmentally Sensitive Areas
ISSUE
Periodic update of the critical area regulations to reflect current best available science (BAS) as
required by the Growth Management Act.
BACKGROUND
Staff had a work session with the Planning Commission on this item on November 8, 2019. The
staff report for the November 8, 2018 meeting is available online. Here is the Il,iiin,k.
At the Nov 8, 2018 meeting, the Planning Commission asked for some additional information on
the following topics:
1. Mitigation plans and monitoring costs:
At the last work session, the Planning Commission did not make a final decision on wetland
buffers; and asked staff to provide examples of mitigation plans and associated monitoring
costs. See Attachment A for a mitigation plan for buffer reduction of a stream. See Attachment B
for a mitigation plan for filling some wetlands and doing offsite mitigation. Also, included in these
attachments is the cost estimate for the mitigation and monitoring.
The Department of Ecology recommends the buffers listed in table below. It should be noted
that the buffer widths shown in the table below assume that the buffer is vegetated with native
plants and minimization measures listed in the second table are implemented. If the buffer is
unvegetated, sparsely vegetated, or vegetated with invasive species, the buffer would need to
be re -planted or the buffer width increased to provide adequate buffer functions.
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Category
Wetland
buffer
width
(ft),
current
TMC
Wetland buffer width (ft), Ecology 2014, high -intensity land use impact
Habitat
score
<6
Habitat
score
<6
Habitat
score
6-7
Habitat
score
6-7
Habitat
score 8-
9
Habitat score
8-9
Standard
Buffer
Alternate
Buffer if
impact
minimization
measures
taken
Standard
Buffer
Alternate
Buffer if impact
minimization
measures
taken, plus 100
feet vegetated
corridor
between
wetland and
priority habitats
Standard
Buffer
Alternate Buffer
if impact
minimization
measures taken,
plus 100 feet
vegetated
corridor between
wetland and
priority habitats
I
100
100
75
150
110
300
225
II
100
100
75
150
110
300
225
III
80
80
60
150
110
300
225
IV
60
50
40
50
40
50
40
Listed below are the impact minimization measures that may allow 25 percent reduction from
the upper range of recommended buffers:
Disturbance
Required Measures to Minimize Impacts
Lights
•
Direct lights away from wetland
Noise
•
Locate activity that generates noise away from wetland
•
If warranted, enhance existing buffer with native vegetation
plantings adjacent to noise source
•
For activities that generate relatively continuous, potentially
disruptive noise, such as certain heavy industry or mining,
establish an additional 10' heavily vegetated buffer strip
immediately adjacent to the outer wetland buffer
Toxic runoff
•
Route all new, untreated runoff away from wetland while
ensuring wetland is not dewatered
•
Establish covenants limiting use of pesticides within 150 feet
of wetland
•
Apply integrated pest management
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Disturbance
Required Measures to Minimize Impacts
Stormwater runoff
•
Retrofit stormwater detention and treatment for roads and
existing adjacent development
•
Prevent channelized flow from lawns that directly enters the
buffer
•
Use Low Intensity Development (LID) techniques where
appropriate (for more information refer to the drainage
ordinance and manual)
Change in water regime
•
Infiltrate or treat, detain, and disperse into buffer new runoff
from impervious surfaces and new lawns
Pets and
disturbance
human
•
Use privacy fencing OR plant dense vegetation to delineate
buffer edge and to discourage disturbance using vegetation
appropriate for the ecoregion
•
Place wetland and its buffer in a separate tract or protect with
a conservation easement
Dust
•
Use best management practices to control dust
Based on the field work done to categorize the wetlands north of 1-405, majority of the wetlands
are Category III wetlands, with a low habitat score of 3-5. Buffer quality at the vast majority of
wetlands is unhealthy (too narrow, dominated by invasive species, or sparsely vegetated.) Initial
comparison of buffers required under the existing code and buffers recommended by the
Department of Ecology indicates that buffers will increase for some wetlands while a few
wetlands may see reduction in the required buffer width.
Policy Options for buffer widths:
Pros
Cons
Option 1
Adopt the standard buffer widths
The larger buffers
Buffer widths will
recommended by the Department
will provide better
significantly increase
of Ecology
buffer function given
majority of the
buffers are sparsely
vegetated; easier for
the developer as no
replanting or
monitoring required
which could limit
development potential;
quality of buffers will not
improve as no replanting
required.
Option 2
Adopt the standard buffer widths
Provides options for
Quality of buffers will not
recommended by the Department
of Ecology; but allow alternate
buffer if impact minimization
measures are taken. This option
assumes that the existing buffer is
vegetated with native plants. It
should be noted that most existing
buffers are not vegetated with
native plants, therefore standard
buffer widths would apply under
this option.
the developer
improve as no replanting
required. Also, since the
state of existing buffers
is degraded, it is likely
that under this option
standard buffers will
apply so this option will
likely be similar to
Option 1 during
implementation.
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Option 3
Adopt the standard buffer widths
Provides options for
Requires monitoring of
recommended by the Department
the developer with
the replanted buffer for
of Ecology; but allow alternate
buffer if impact minimization
measures are taken AND buffer is
replanted
incentives for buffer
enhancement
at least five years
At the November 8, 2018 meeting the Planning Commission did not make a final decision on
this item. Staff recommends Option 3.
2. Exempt wetlands:
The existing code provides an exemption for certain wetlands that are under 1,000
square feet. The exemption is from sequencing (showing that the impact cannot be
avoided or minimized). Mitigation of the impacts is still required per Ecology. Exempt
wetlands have to meet the following criteria:
a) habitat score under five;
b) are not associated with a riparian habitat or Shorelines of the State;
c) are not part of a wetland mosaic, and
d) do not contain priority habitat.
Per Ecology guidance, this exemption may be extended to isolated Category IV
wetlands under 4,000 square feet. Here are policy options that the Planning Commission
considered at the November 8, 2018 meeting:
Pros
Cons
Option 1
Keep the existing
code and exempt
wetlands up to 1000
sq. ft with mitigation
for wetland impacts
These are exempt under
the existing code. Code
language could be
clarified that wetland
impacts still need to be
mitigated.
Some larger
wetlands that could
qualify for
exemption would
not qualify.
Option 2
Exempt wetlands up
to 4000 sq. ft. with
mitigation for wetland
impacts
Increase the exemption to
the highest allowed under
BAS. Wetland impacts
are mitigated
Mitigation is off site
or by fee in lieu.
Loss of wetlands in
Tukwila. Buffer
impacts are not
mitigated.
Option 3
Exempt wetlands up
to 1000 sq. ft. with
mitigation for wetland
impacts; exempt
wetlands up to 4000
sq. ft. with mitigation
for wetland and buffer
impacts
Increase the exemption to
the highest allowed under
BAS. Two tiers of
mitigation: wetland and
buffer impacts are
mitigated for wetlands
larger than 1000; and
only wetland impacts
mitigated for wetlands
smaller than 1000 sq. ft.
Mitigation is off site
or by fee in lieu.
Loss of wetlands in
Tukwila.
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At the November 8 work session, the Planning Commission recommended Option 3, but
asked staff to do some additional research and provide data on how many wetlands
would be impacted under Option 3.
See Attachment C for the map of known wetlands in Tukwila that are less than 1000
square feet; and those that are between 1000 to 4000 sq. ft. Here is the data:
1,000 square feet or less: 5 wetlands
1,001-4,000 square feet: 17 wetlands; all are part of a mosaic except for 4 of them.
It should be noted that 13 out of 17 wetlands that are between 1,001 to 4,000 square
feet in size would not qualify for the exemption as they are part of a wetland mosaic.
Based on this additional research staff recommends Option 1.
3. Non -conforming provisions:
At the last work session, the Planning Commission asked staff to do additional research
to establish new non -conforming thresholds for development in the wetland and stream
buffers; and tie the new thresholds to incentives for improving the buffer and/or water
quality.
Tukwila Municipal Code 18.70.040 and .050 addresses code provisions for any non-
conforming uses or structures in Tukwila. See Attachment D for Tukwila's code. See
Attachment E for comparison of non -conforming provisions of other cities. Attachment F
is an excerpt from Kirkland's code that has very specific guidelines for expansion of non-
conforming structures in the critical area buffers.
The policy options for the Planning Commission to consider are:
A. Vertical Expansion
Pro
Con
Option 1
Allow existing buildings
Allow
Reduces
to expand vertically to
improvements
future potential
add upper stories in
to existing
of the non -
exchange for buffer
buildings and
conforming
enhancement
achieve buffer
enhancement
structure to
come into
compliance
Option 2
Do not allow vertical
Preserves
Restricts
expansion
potential for
non-
conforming
structure to
come into
compliance
with critical
areas code in
the future.
development
potential.
Missed
opportunity for
buffer
enhancement
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B. Lateral Expansion
Pro
Con
i) Expansion to the
building side
that is opposite
of critical area
Option 1
Allow expansion on side
of the building opposite
of critical area in
exchange for buffer
enhancement; but limit it
to one time expansion
Allow
improvements
to existing
buildings and
achieve buffer
enhancement
Reduces
future potential
of the non -
conforming
structure to
come into
compliance.
Harder to
administer
Option 2
Do not allow expansion
in the buffer
Preserves
potential for
non-
conforming
structure to
come into
compliance
with critical
areas code in
the future.
Easy to
administer
Restricts
development
potential.
Missed
opportunity for
buffer
enhancement
Staff recommends
Option 1
ii) Expansion along
the sides
provided that
existing
distance from
the structure to
the buffer's edge
is not reduced.
Option 1
Allow expansion along
the existing building
lines in exchange for
buffer enhancement; but
limit it to one time
expansion and limit the
sq. ft. of new intrusion
into the buffer to less
than 50 percent of the
current intrusion.
Further this option could
be limited to situation
where the buffer width is
at least 75 percent of
the required buffer
Allow
improvements
to existing
buildings and
achieve buffer
enhancement
Reduces
future potential
of the non -
conforming
structure to
come into
compliance.
Harder to
administer
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Option 2
Do not allow expansion
in the buffer
Preserves
potential for
non-
conforming
structure to
come into
compliance
with critical
areas code in
the future.
Easy to
administer
Restricts
development
potential.
Missed
opportunity for
buffer
enhancement
Staff recommends
Option 1
iii) Enclosing within
existing
footprint (such
as enclosing
carport, adding
roof over decks)
Option 1
Allow enclosing within
existing footprint
Less
restrictive. No
additional
impact to the
buffer.
Option 2
Do not allow enclosing
within existing footprint
Restricts
development
potential
without much
gain to the
critical areas.
Staff recommends
Option 1
4. Geologically Hazardous Areas
Planning Commission had asked if there could be a minimum setback established from a
steep slope in lieu of preparing a geotechnical report for the property. This section of the
code is administered by the City's Public Works Department and their opinion is not to
establish one standard setback for all slopes. Instead the setback should be established
by the geotechnical engineer after evaluating site conditions for each site.
RECOMMENDATION
Consider policy options identified above and identify any additional research needed. Staff will
then prepare an underline strike out of the code that addresses the gaps identified by the review
of best available science. The Planning Commission will then hold a public hearing and send a
recommended draft to the City Council for review and adoption.
ATTACHMENTS
A. Stream buffer monitoring report
B. Wetland monitoring report
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C. Map of known wetlands in Tukwila that are less than 4000 sq ft.
D. Tukwila's non -conforming code provisions
E. Comparison of non -conforming provisions of other cities.
F. Kirkland's non -conforming code provisions
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