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HomeMy WebLinkAbout2012 Addendum to Final Environmental Impact Statement-NE Auburn Robertson Properties Special Area Plan NORTHEAST AUBURN / ROBERTSON PROPERTIES SPECIAL AREA PLAN Environmental Impact Statement (EIS) Addendum Addendum Prepared for City of Auburn November 2,2011 Final Environmental Impact Statement July 2004 This Page Intentionally Left Blank NE Auburn/Robertson Properties Special Area Plan EIS Addendum November 2011 i ESA Table of Contents Project Background ............................................................................................................. 1 Purpose of this Addendum .................................................................................................. 2 Addendum to Affected Environment, Impacts, and Mitigation ....................................... 13 Water Resources ....................................................................................................... 13 Plants and Animals ................................................................................................... 21 Transportation ........................................................................................................... 43 Environmental Elements not Analyzed .................................................................... 55 References ......................................................................................................................... 58 List of Figures Figure 1. Planning Area ..................................................................................................... 5 Figure 2. Auburn Gateway Project Area............................................................................ 7 Figure 3. Parcels in Auburn Gateway II ............................................................................ 9 Figure 4. Site Plan ............................................................................................................ 11 Figure 5. Stream and Wetland Map ................................................................................. 27 List of Tables Table 1. City of Auburn Wetland Categories (ACC 16.10.080) ..................................... 21 Table 2. City of Auburn Stream Class (ACC 16.10.080) ................................................ 22 Table 3. City of Auburn Minimum and Maximum Wetland Buffers (ACC 16.10.090) ............................................................................................................... 23 Table 4. City of Auburn Minimum Stream Buffers (ACC 16.10.090) ............................ 23 Table 5. City of Auburn Wetland Mitigation Ratios (ACC 16.10.110) .......................... 24 Table 6. Summary of Wetland Characteristics ................................................................ 30 Table 7. Department of Ecology Functions Summary ..................................................... 31 Table 8. Summary of Wetland and Buffer Impacts ......................................................... 36 Table 9. 2020 Office/Retail; PM Peak Hour Level of Service ....................................... 47 Table 10. 2020 Retail Only; PM Peak Hour Level of Service........................................ 48 Table 11. Road Mitigation Summary............................................................................... 52 This Page Intentionally Left Blank NE Auburn/Robertson Properties Special Area Plan EIS Addendum November 2011 1 ESA PROJECT BACKGROUND In July 2004, a Final Environmental Impact Statement (EIS) was published for the Northeast Auburn/Robertson Properties Special Area Plan. The special area plan was developed to address a designated ‘special planning area’ and implement policies in the Auburn Comprehensive Plan. The EIS also covers an application by Robertson Properties Group (RPG) to redevelop their property located in the area designated as the “Northeast Auburn Special Plan Area.” The Northeast Auburn Special Area Plan was provisionally adopted in June 2008 (Ordinance No. 6183). To be implemented the approval was conditioned on subsequent adoption of a development agreement and a “planned action” ordinance under Revised Code of Washington (RCW) 43.21C.031. (A more detailed description of the planning history can be found in the 2004 EIS.) The Northeast Auburn Special Area Plan covers approximately 90 acres of land (referred to in the EIS as the “planning area”). The planning area is bordered by Auburn Way North, South 277th Street, 45th Street NE, and the undeveloped right-of-way of I Street NE (Figure 1) as it existed within parcel number 0004200006 in 2004. A portion of the I Street NE right-of-way has been vacated as part of the implementation of the plan. Within this planning area, RPG owns the Valley Six Drive-in Theater and several adjacent properties. In addition to a “no action” scenario, the 2004 EIS evaluated three redevelopment options for the RPG properties to retail, office, and multifamily residential uses. RPG named its redevelopment proposal “Auburn Gateway”. A core area of RPG’s holdings together with other properties that RPG was considering acquiring or that could be cooperatively developed was defined in the EIS as the Auburn Gateway project area. This area totaled approximately 60 acres. The boundaries of the planning area and the Auburn Gateway project area as evaluated in the 2004 EIS are shown in Figure 2. The EIS evaluated the impacts associated with the implementation of the Northeast Auburn/Robertson Properties Special Area Plan and the Auburn Gateway project. In addition to the retail, office, and multifamily residential uses, development in this area would include new roads and utilities, surface parking, and stormwater detention and water quality facilities. The existing drive-in theater and other structures on the RPG property would be demolished. Alternatives evaluated in the EIS of the Auburn Gateway project involved up to 720,000 square feet of retail development, 1,600,000 square feet of office, 500 multi-family residences, and 6,133 parking spaces. All alternatives evaluated the area outside the Auburn Gateway project area (the remaining portions of the planning area) as developing in accordance with existing zoning. This would include multifamily residential development to the south and east and heavy commercial development to the west. NE Auburn/Robertson Properties Special Area Plan EIS Addendum 2 November 2011 ESA PURPOSE OF THIS ADDENDUM Since the 2004 EIS, RPG has purchased four additional parcels located outside of the Auburn Gateway project area but within the boundaries of the planning area. The additional area is located west of D Street NE, north of 49th Street NE and south of South 277th Street. The purchased parcels are shown in Figure 3. The additional properties would expand the Auburn Gateway project area by approximately 11 acres. The Stein property, McKee property and SE corner property have not been acquired by RPG, but remain part of the Auburn Gateway project area in the NE Auburn Special Plan Area. Therefore, the total size of the RPG holdings is approximately 71 acres. The original RPG project area evaluated under the 2004 EIS is referred to in this addendum as “Auburn Gateway I” and the newly acquired properties are referred to as “Auburn Gateway II.” The Auburn Gateway I and II comprise two parts of the same Auburn Gateway project. This addendum does not discuss any changes to the plans for the Stein property, McKee property and SE corner property compared to those covered in the 2004 EIS. The Auburn Gateway I and II project areas would still involve the same potential amounts of retail, office, and multi-family residential development evaluated in the 2004 EIS but the development would be spread over a larger geographic area. While retail development may be the most likely component to develop, other options were studied at the applicant’s request to preserve the ability to a mixed-use development should market conditions change. The transportation analysis in this addendum examines both Alternative 1 (evaluated in the 2004 EIS as 1,600,000 square feet of office with 200,000 square feet of retail development) and Alternative 2, assuming a site plan modified to include Auburn Gateway II and a revised roadway layout as described below. Alternative 1 represents the worst case scenario. While Alternative 2 represents the applicant’s preferred alternative, Alternative 1 is included to preserve flexibility for the applicant should market conditions shift toward more office development. One proposed change in the road network from the 2004 EIS is that D Street NE north of 49th Street NE is proposed to be vacated and converted to an internal circulation aisle serving the project. As evaluated in the EIS, D Street NE at Auburn Way North would be closed with a cul-de-sac. In addition, the applicant requested that the eastward extension of 49th Street NE east of the proposed I Street NE, which was included in the final EIS to serve development to the east of the RPG property, be evaluated to determine impacts from the road not being extended. This addendum includes an assessment of the traffic impacts of eliminating the northern portion of D Street NE and of not constructing the eastward extension of 49th Street NE. Also, since the EIS was prepared, phasing has been proposed for the Auburn Gateway project. Although the project has always been planned to be built out over a period of approximately 15 years, the applicant had not previously identified any phasing of the project or infrastructure for the project evaluated in the EIS. Infrastructure for drainage, wastewater, and other utilities would be constructed as needed to meet City regulations as NE Auburn/Robertson Properties Special Area Plan EIS Addendum November 2011 3 ESA development progresses. Transportation infrastructure needed to accommodate the project, in particular development and widening of several roads and providing signals as needed, is not specified by Code, so it is important to understand what the traffic demands would be for any interim stages of development. The project could either be constructed in two phases - one phase would occur north of 49th Street NE and one south of 49th Street NE - or as a single phase of full site development. The physical location of the phases does not coincide with the Auburn Gateway I and Auburn Gateway II area designations. The order in which the phases would occur has not been determined; therefore the traffic analysis in particular examined several scenarios for phasing to proceed. RPG has indicated that the order of development (all at once or in two phases, north or south phase first) is expected to be determined by market conditions once entitlements are in place. Also, since the 2004 EIS was prepared, development of nearby properties has proceeded and City of Auburn regulations and policies have changed. The most notable regulatory changes affecting the Auburn Gateway Project are the city’s adoption of Ordinance No. 5894, Critical Areas Ordinance, May 2005; Ordinance No. 6283 for the adoption of City of Auburn Public Work’s Surface Water Management Manual, November 2009; Ordinance No. 6295, Floodplain Management Regulations, April 2010; and Ordinance No. 6280 which adopted policy amendments to the City’s Comprehensive Transportation Plan, December 2009.The purpose of this addendum is to evaluate impacts associated with adding Auburn Gateway II area to the project and to evaluate the impacts of constructing in two phases. Neither of these was evaluated as part of the 2004 EIS. The following environmental elements warrant a detailed discussion of the changes that have occurred in the affected environment and an evaluation of new impacts associated with the Auburn Gateway II area and project phasing: • Water resources • Plants and animals • Transportation. These elements require a detailed discussion because Auburn Gateway II involves additional floodplain fill, increased impervious surface, fill placed in wetlands, and changes in vehicle circulation that were not previously evaluated. The purpose of identifying project phasing is to determine the impacts of constructing less than the full project at one time and to evaluate what mitigation is associated with each phase of the project. The amount of development associated with each phase could vary, depending on market conditions. In order to address the possibility that the majority of development could be located either in the north phase area or in the south phase, the transportation impact analysis looked at scenarios allocating to each phase, up to 60 percent of anticipated development to test whether additional mitigation would be needed. Impacts on the remaining environmental elements evaluated in the 2004 EIS (Geology/Soils, Air Quality, Noise, Hazardous Materials, Cultural and Historic NE Auburn/Robertson Properties Special Area Plan EIS Addendum 4 November 2011 ESA Resources, Land Use, Aesthetics, Recreation, Utilities and Public Services) are not expected to be different from those evaluated in the 2004 EIS and are discussed briefly at the end of this addendum. The following sections only assess the changes that have occurred in the affected environment, environmental impacts, and mitigation measures resulting from changes in the project plans and/or the environment since the 2004 EIS was published. In all other instances, the 2004 EIS analysis and conclusions have not changed and the mitigation measures in the 2004 EIS continue to apply. The analysis discussed below did not find any significant impacts that were not disclosed in the 2004 EIS. The information contained in this addendum is provided to allow the revised project to be evaluated by the City and other regulators, in order to determine appropriate mitigation for development applications making use of the planned action EIS. NE Auburn/Robertson Properties Special Area Plan EIS Addendum November 2011 5 ESA Figure 1. Planning Area This Page Intentionally Left Blank NE Auburn/Robertson Properties Special Area Plan EIS Addendum November 2011 7 ESA Figure 2. Auburn Gateway Project Area This Page Intentionally Left Blank NE Auburn/Robertson Properties Special Area Plan EIS Addendum November 2011 9 ESA Figure 3. Parcels in Auburn Gateway II This Page Intentionally Left Blank NE Auburn/Robertson Properties Special Area Plan EIS Addendum November 2011 11 ESA Figure 4. Site Plan This Page Intentionally Left Blank NE Auburn/Robertson Properties Special Area Plan EIS Addendum November 2011 13 ESA ADDENDUM TO AFFECTED ENVIRONMENT, IMPACTS, AND MITIGATION Water Resources Applicable Laws and Regulations Since the 2004 EIS, the City of Auburn has adopted critical area regulations and codified them in Auburn City Code (ACC) Chapter 16.10 Critical Areas. In addition, ACC Chapter 15.72 Drainage Plans was repealed and replaced with Ordinance No. 6283 - Surface Water Management Manual, effective February 16, 2010. The drainage requirements that would apply to the project are based on equivalency to the Department of Ecology’s 2005 Stormwater Management Manual for Western Washington (Ecology 2005). Since the 2004 EIS the National Flood Insurance Program (NFIP) of the Federal Emergency Management Agency (FEMA) on September 28, 2007 released preliminary draft Federal Insurance Rate Maps (DFIRMs) that when adopted will revise the extent of the Green River floodplain in the planning area. Revised preliminary DFRIRMs were published November 2010. These draft maps indicate a larger and deeper 100-year floodplain area than the maps that are currently in effect. Since the DFIRM maps have not been adopted by FEMA the 1995 maps remain in effect from a regulatory standpoint, based on City code. In September 2008, a Biological Opinion issued by the National Marine Fisheries Service (NMFS) determined that the NFIP causes jeopardy to Puget Sound salmonids and Southern Resident killer whales listed under the Endangered Species Act (NMFS, 2008). In response to the Biological Opinion, the City of Auburn instituted a moratorium on all development located in the floodplain per the FEMA maps currently in effect (Resolution No. 4416). The resolution establishing the moratorium required that applications for development within floodplain areas may be approved if the applicants meet FEMA and NMFS requirements for providing adequate protection to endangered species (City of Auburn, 2008). On April 5, 2010, the City of Auburn approved interim floodplain regulations (Ordinance No. 6295; City of Auburn, 2010) which replaced the city’s previous floodplain regulations and repealed the moratorium. The city received written notification from FEMA dated September 21, 2011, that FEMA reviewed the City’s interim regulations and concur they are consistent with FEMA’s model ordinance; the regulations are no longer interim. The regulations incorporated federal habitat protection requirements and created a new City floodplain development permit to replace the previous flood zone control permit. The changes include requiring new developments to prepare a habitat impact assessment which must include one of the following: NE Auburn/Robertson Properties Special Area Plan EIS Addendum 14 November 2011 ESA • A Biological Evaluation or Biological Assessment that has received concurrence from USFWS or NMFS; or • Documentation that activity fits within Section 7 or Section 10 of the ESA; or • An assessment prepared in accordance with Regional Guidance for Floodplain Habitat Assessment and Mitigation, FEMA Region X, 2010. New development must be designed and located to minimize the impact on flood flows, flood storage, water quality and habitat. Stormwater and drainage features must incorporate low impact development techniques that mimic pre-development hydrologic conditions. If the project involves more than 10 percent impervious surfaces within the regulatory floodplain, then the project proponent must demonstrate that there will not be a net increase in the rate and volume of the stormwater surface runoff that leaves the site. Structures must be located as far from the waterbody as possible or on the highest land on the lot (City of Auburn, 2010). After completion of the Port of Seattle’s compensatory flood storage and wetland mitigation project located to the south and east of the planning area, and in response to FEMA’s release of draft Federal Insurance Rate Maps (DFIRM), King County and the valley cities of Auburn, Kent, Renton and Tukwila (appellants) commissioned NW Hydraulics Consultants, Inc. to analyze and map the 100-year floodplain for the area. The report was submitted to FEMA for their consideration during the public appeal period on the draft floodplain maps. At the time of this writing, the appellants expect that the DFIRM maps for the planning area will be changed to more closely reflect the NW Hydraulics Consultant’s study and that ultimately FEMA will adopt the revised maps in lieu of the DFIRM maps. The timing of FEMA’s adoption is uncertain. Surface Water The surface water conditions on the Auburn Gateway I project area were described in the 2004 EIS and have not changed. There have been changes to applicable regulations and to the adjacent areas that affect surface water. A “Preliminary Feasibility Study” was developed by RPG’s civil engineers, BCRA Engineering, in December 2007 describing stormwater conditions at the Auburn Gateway II site (BCRA 2007). Since then, there has been a new gas station development at the adjacent property to the northwest. Additional site exploration and a field report by BCRA were completed to review site conditions that relate to drainage (BCRA 2010). A complete ALTA/topographic survey was completed by Barghausen Consulting Engineers, Inc. (September 2009) to obtain accurate existing condition information and update the assumptions and conclusions from the BCRA 2007 preliminary feasibility study. The stormwater conditions described by BCRA are summarized in this section. Green River Floodplain Since the 2004 EIS, the Port of Seattle has completed construction of the compensatory flood storage and wetland mitigation project described in the 2004 EIS. That project was designed to compensate for fill of the entire FEMA-identified floodplain area south of South 277th Street in northeast Auburn based on the 1995 FIRM maps. According to the NE Auburn/Robertson Properties Special Area Plan EIS Addendum November 2011 15 ESA 2004 EIS this was roughly 60 acre-feet in the planning area. A subsequent report: “Federal Emergency Management Agency Conditional Letter of Map Revision”, July 2007 by Parametrix, Inc. prepared for the purpose of application to FEMA identifies approximately 66.2 acre feet of storage was constructed within the Port of Seattle Property. The report also indentifies that the volume of fill for areas south of S 277th St and East of Auburn Way North, below the 45 foot elevation would be less than the volume of the constructed flood storage, again based on the 1995 FIRM maps. FEMA’s processing of the Conditional Letter of Map Revision (CLOMR) has not been completed. However, depending on the final FIRM maps, and if they show a greater floodplain volume, there may not be adequate compensatory flood storage to mitigate for any additional flood volume as a result of filling and development in the floodplain. The City of Auburn and the Port of Seattle are in the process of amending an existing City and Port Interlocal Agreement to allow the Port’s wetland mitigation property to be used to compensate for filling nearby properties located in the floodplain including the project site based on the 1995 FIRM maps. Storm Drainage Runoff from the Auburn Gateway II site sheet flows towards the northeast portion of the site, along the elevated roadway of South 277th Street. The north edge of the site consists of a roadside ditch running along its entire length. The topographic survey shows the ditch generally sloping slightly to the east. Auburn Way North has curb, gutter, and storm conveyance system along the west side of the site. Most of the site is approximately 4 to 6 feet lower in elevation than the road level of Auburn Way North (BCRA, 2007). See also Figure 8, Existing stormwater drainage and Green River floodplain conditions, page 73, Draft EIS. The Auburn Gateway II site appears to receive offsite surface waters from the following sources: • A 36-inch culvert under D Street NE which conveys stormwater from Auburn Gateway I towards the northeast corner of the Auburn Gateway II site. The culvert under D Street NE has been damaged by the weight of the road. • The developed property located to the northwest of the Auburn Gateway II site (at the southeast quadrant of the Auburn Way North and South 277th Street intersection) that conveys surface runoff to the S 277th Street roadside ditch site via an overflow pipe. The offsite property has a storm drainage control structure and an apparent water quality treatment device installed. The offsite property is elevated about 6 feet above the site. • Surface water runoff from Auburn Way North which enters the site at the northwest corner. Approximately 800 feet of roadway runoff from Auburn Way North is conveyed via underground storm pipe north to South 277th Street, turns east and then discharges into the ditch along the north edge of the site along South 277th Street (BCRA, 2007). NE Auburn/Robertson Properties Special Area Plan EIS Addendum 16 November 2011 ESA Surface runoff from Auburn Gateway II exits the site through a 48-inch culvert near the northeast corner, flowing underneath South 277th Street. Some of the site runoff also collects in the northwest corner of the site (BCRA, 2007). As described in the Draft EIS, the surface runoff continues from South 277th Street and the 48-inch culvert along the west side of 86th Avenue South, then under 86th Avenue South within a 7-foot by 5-foot concrete box culvert conveying water to the north to the Green River. The ditch is known as Auburn Creek (Stream Number 0056), although it has been channelized for most of the distance to the Green River. Since the 2004 EIS was published, a residential subdivision and planned unit development (PUD) was constructed on a 40.9-acre site east of the planning area. The Trail Run (previously called River Sands) development involved the construction of houses, townhouses, roadways, and stormwater facilities. Stormwater runoff from the site is retained and treated on-site, and then directed west to the roadside ditch along South 277th Street which continues north along 86th Avenue South in Auburn Creek to an outfall at the Green River. According to the Supplemental Downstream Storm Drainage Analysis for River Sands PUD the pre-development rate of runoff from Trail Run during the 100-year design storm is 8.5 cubic feet per second (cfs) and the 100-year post- developed conditions would be 7.57 cfs (DBM Consulting Engineers, 2005). Therefore, assuming the system is working as designed, the rate of stormwater runoff from the Trail Run property has decreased since the 2004 EIS was prepared. The City has determined that the ditches along the south side of South 277th Street are not regulated as streams under the City’s critical areas ordinance, but are regulated by the City’s Flood Hazard Area regulations as typed waters using the DNR water typing system. These water bodies are therefore referred to as drainage ditches in this EIS addendum, to distinguish them from water bodies that the City regulates as streams. Surface Water Quality The EIS refers to the 1998 Ecology 303(d) list when describing water quality conditions for the Green River. Since that time, Ecology has issued two more 303(d) lists, one for 2004 and one for 2008. According to the 2008 Ecology 303(d) list the Green River adjacent to the planning area is still listed as having elevated temperature. The 303(d) list also indicates that fecal coliform bacteria and temperature still do not meet standards in the Green River reaches located several miles downstream. Dissolved oxygen has been added as not meeting standards. The Green River in the project area is no longer listed as not meeting standards for chromium (Ecology, 2008). In addition to the pollutant loadings from the Auburn Gateway I site that were described in the EIS, the site containing the proposed Auburn Gateway II likely contributes pollutants associated with agricultural production such as herbicides for weed control, similar to those expected on parts of the Auburn Gateway I site. NE Auburn/Robertson Properties Special Area Plan EIS Addendum November 2011 17 ESA Impacts Short Term Construction Impacts Project construction phasing was not evaluated in the 2004 EIS. The applicant may develop Auburn Gateway I and II in two phases; one phase north of 49th Street NE and one phase south of 49th Street NE or as a single phase. If phased, the order in which the phases would occur has not been determined. Short term impacts associated with construction would be similar to what was described in the 2004 Draft EIS. While Auburn Gateway I and II may be constructed in two phases, the cumulative impacts associated with incremental development would be limited. The 2004 EIS estimated approximately 650,000 cubic yards of fill and 250,000 cubic yards of excavation would be necessary to allow for proper drainage of stormwater using a combination of gravity and pump systems. If the stormwater system was designed to function by gravity alone, 650,000 cubic yards of fill would be necessary. Based on the current site plan and addition of the Auburn Gateway II property, RPG is currently proposing to fill approximately 600,000 to 750,000 cubic yards for the Auburn Gateway I and II sites. Since the type of stormwater detention facilities have yet to be determined, this volume of earthwork should be considered an estimate. Grading for the Auburn Gateway project would consist of importing and placing fill material sufficient to allow for proper drainage of stormwater and to elevate the building pads out of the 1995 100-year FEMA floodplain as a minimum. Grading would accommodate a gravity system that has an outlet to the existing ditch along South 277th Street or as modified. Any phasing that would occur would be required to address floodplain regulations in effect for each phase. Impacts associated with fill would be similar to those described in the 2004 EIS, except that additional trucks would be involved in importing and exporting material. With the additional 11 acres of development, there could be a higher potential of soil and sediment deposition on the streets in the project area. Placement of more imported fill material in the project area could increase the potential for erosion. These potential impacts would be avoided by implementing best management practices and complying with Washington State Department of Ecology requirements for temporary erosion control, grading, and drainage, as described in the 2004 EIS, the City of Auburn Surface Water Management Manual, November 2009, and the Washington State Department of Ecology 2005 Stormwater Management Manual for Western Washington. The contractor will also be required to obtain a Construction Stormwater General Permit through the Department of Ecology and the National Pollutant Discharge Elimination System permit. NE Auburn/Robertson Properties Special Area Plan EIS Addendum 18 November 2011 ESA Long Term Operational Impacts Surface Water Green River Floodplain Volume of Floodplain Storage Affected Because the Port of Seattle wetland mitigation site provided floodplain compensation for filling the floodplain in the entire floodplain area south of South 277th Street, the filling of floodplain on the Auburn Gateway II site can be compensated for based on the 1995 FIRM maps. The 2004 Final EIS estimated Up to 27.5 acre-feet of floodplain storage volume would be filled within the Auburn Gateway project area based on the 1995 FEMA floodplain. The Auburn Gateway II site would require approximately 6.23 acre- feet of floodplain fill, for a total of 33.73 acre feet (BCRA 2011) Because the calculations regarding volume of flood storage available in the Port’s property were based on the adopted 1995 100-year floodplain maps, these calculations do not consider the differences in floodplain volumes that would result based on the proposed DFIRMs. Therefore, additional floodplain compensation may be needed for filling the floodplain if the floodplain volumes established by the DFIRM maps once they are adopted are higher than the current 1995 FIRM maps. Additional floodplain compensation would be provided in compliance with applicable city regulations pursuant to a flood development permit and habitat impact assessment. Connection of Wetland Flood Storage to Existing Floodplain According to the 2004 EIS, the Port of Seattle was obligated to construct a flood conveyance channel from the newly created wetland north to the roadside ditch along the south side of South 277th Street. After a flood event, excess water stored in the newly created wetland mitigation/floodplain storage site would drain along the flood conveyance channel to the roadside ditch. The provision of this channel was a requirement in the interlocal agreement between the Port of Seattle and the City of Auburn in order to make sure the wetland is connected to the remaining Green River floodplain located north of the roadway. The Port of Seattle constructed the flood conveyance channel as required by the interlocal agreement to make connectivity to the floodplain. At the time of the 2004 EIS, the Port reported that the capacity of the roadside ditch on the south side of South 277th Street that connects to the Port’s flood conveyance channel is not sufficient to convey the 100-year flood volume (Wessels 2003 personal communication). Once the Auburn Gateway project site is filled and areal extent of the floodplain is reduced, the capacity of the roadside ditch along the south side of South 277th Street would need to be increased to adequately manage the flood waters being conveyed from the wetland mitigation /floodplain storage to maintain connectivity to the floodplain which originates within unincorporated King County to the north. The roadside ditch would be relocated as part of the roadway widening proposed for South 277th Street. RPG has indicated that the relocated roadside ditch and culvert system will be designed to accommodate the 100-year 24-hour peak flow rate and fish passage criteria (if required) per Chapter 3 of the City of Auburn Surface Water Management Manual November 2009. NE Auburn/Robertson Properties Special Area Plan EIS Addendum November 2011 19 ESA In the 2004 EIS, the roadside ditch along 277th Street was considered to be several interconnected wetlands (Wetland Ditches H, I and J). Washington Department of Fish and Wildlife (WDFW) determined that the wetlands are actually a stream (J.S. Jones and Associates letter to WDFW, dated June 15th, 2009, confirming results of site visit with WDFW), however this determination may not affect determinations of other regulatory agencies. In the 1990s, as part of a 272nd / South 277th Street improvement project, west of Auburn Way North, the City of Kent created wetland mitigation credit by completing wetland mitigation for the proposed filling of the wetland ditches as they existed then along South 277th Street. The applicant may petition regulatory agencies to apply the wetland mitigation credit that was established at the time to the wetland ditches if the ditches are currently considered to be wetland by the U.S. Army Corps of Engineers (COE). The applicability of the credits would be at the discretion of each permitting agency and the City of Kent, which constructed the mitigation and owns the credits. Any shortfall in wetland mitigation may require additional wetland mitigation. See Plants and Animals-Affected Environment for more detailed information. Storm Drainage Systems The stormwater system for Auburn Gateway I and II would include conveyance systems and the use of either above ground stormwater detention facilities/ponds, underground detention vaults/tanks, or a combination thereof to provide stormwater quality and quantity control. Based on current topography and existing basins, there could be two or three detention systems used to control storm water runoff. Grading on site will accommodate a gravity system that has an outlet to the existing ditch in South 277th Street or as modified. More specifically, for Auburn Gateway II storm drainage connections would be made to the future storm improvements in South 277th Street and to the 48-inch culvert crossing under South 277th Street. It is anticipated that an underground detention tank would be the preferred method of stormwater detention onsite. For example, based on impervious coverage of 80 percent for the total 11-acre Auburn Gateway II site, approximately 200,000 cubic feet of storage would be required for detention (BCRA, 2007), based on the previous stormwater management design standards. Since this time, the City has adopted a new Surface Water Management Manual (November 2009). The impervious surface amount for the Auburn Gateway II site is not known at this time and could be lower than 80 percent, and detention requirements could also be reduced through use of low impact development methods. The project will be expected to meet the design requirements and stormwater management code as required by the City of Auburn. To ensure coordination of the future storm system over the project area in conformance with proposed phasing and city codes, a master storm drainage plan is to be prepared prior to construction authorizations. In addition, if the storm drainage discharge from the project is not as proposed in previous drainage analysis prepared for the purposes of the EIS (“Hydraulic Model Evaluation of Potential Drainage System Impacts Associated with the Auburn Gateway Project”, Herrera, 2003) and the discharge is all directed to either: South 277th Street (EIS Scenario 3a) or split evenly between South 277th Street and D Street NE (EIS NE Auburn/Robertson Properties Special Area Plan EIS Addendum 20 November 2011 ESA Scenario 3b), then additional downstream drainage analysis shall be required as directed by the City Engineer prior to construction authorizations. If all the storm drainage discharge from the project is directed to South 277th Street (EIS Scenario 3a) the applicant shall design the master plan to include the following storm drainage improvements for any phase of development: • Replace the existing storm drainage pipe located in D Street NE with a 36-inch pipe in D Street NE from South 277th Street to Auburn Way North. The master storm drainage plan shall also define which improvements are to be constructed concurrent with each phase of the project (North Phase, South Phase, or Combined North and South Phases). Stormwater for the pollution-generating impervious surfaces on the Auburn Gateway II site would be treated as required by the City of Auburn. Pre-cast water quality vaults with filter cartridges will likely be used for treatment per the current site plan. Other treatment options would include bio-retention facilities, open treatment ponds, and low-impact- development methods (BCRA, 2007). To provide for adequate storm drainage and conveyance to the point of discharge at the northeast corner of the Auburn Gateway II site, the site at the south and southwest ends would need to be at an approximate elevation of 56 feet. There would be significant amount of fill required to allow for draining the site to the northeast. It is anticipated that the site would need to be raised approximately 5 to 7 feet in some areas to allow for gravity drainage to the culvert at South 277th Street and D Street NE (BCRA, 2007). With the construction of on-site detention facilities, stormwater runoff from the Auburn Gateway II site is expected to be the same or less than the current rate of runoff. Stormwater facilities for both the Auburn Gateway I and II sites would be designed to comply with the City of Auburn Surface Water Management Manual, November 2009, effective February 16, 2010. The City’s Surface Water Management Manual is equivalent to the Washington State Department of Ecology 2005 Stormwater Management Manual for Western Washington. Significant Unavoidable Adverse Impacts As stated in the 2004 Draft EIS, no significant unavoidable adverse impacts on water resources would occur if the mitigation requirements and recommendations provided in the Draft EIS are followed. To avoid impacts on ESA listed species and habitats, the development must meet City floodplain development permit standards and FEMA and NMFS requirements for providing adequate protection to endangered species. NE Auburn/Robertson Properties Special Area Plan EIS Addendum November 2011 21 ESA Plants and Animals Applicable Laws and Regulations At the time the 2004 EIS was issued, the City of Auburn relied on adopted SEPA policies and used the SEPA process to identify impacts and mitigation for environmentally critical areas. General guidance from the City of Auburn Comprehensive Plan regarding the protection of critical areas was also used as a guide for assessing impacts. Since that time, the City of Auburn has developed critical area regulations codified in Auburn City Code (ACC) 16.10 Critical Areas. Therefore, the following sections serve as an update to the 2004 EIS and replace the analysis regarding the Mill Creek Special Area Management Plan. The City’s Critical Areas regulations (ACC 16.10) contain the definitions for regulated wetlands and streams, wetland categorization criteria, buffer standards and permit standards and procedures. Wetlands in the City of Auburn are to be classified according to the criteria under ACC 16.10.080, summarized in Table 1. Table 1. City of Auburn Wetland Categories (ACC 16.10.080) Category I  Represent a unique or rare wetland type; or  Are more sensitive to disturbance than most wetlands; or  Are relatively undisturbed and contain ecological attributes that are impossible to replace within a human lifetime; or  Are providing a high level of functions, scoring 70 points or more out of 100 (DOE Wetlands Rating System, 2004); or  Are characterized as a national heritage wetland; or  Are characterized as a bog; or  Are over one acre and characterized as a mature and old-growth forested wetland. Category II  Provide high levels of some functions, being difficult, though not impossible to replace; or  Perform most functions relatively well, scoring 51 – 69 out of 100 points (DOE Wetlands Rating System, 2004).  “Category III wetlands” are those wetlands that are not Category I or II wetlands, and which meet the following criterion:  Provide moderate levels of functions, scoring between 30 and 50 out of 100 points (DOE Wetlands Rating System, 2004). Category III  Provide moderate levels of functions, scoring between 30 and 50 out of 100 points (DOE Wetlands Rating System, 2004). Category IV  Provide low levels of functions, scoring less than 30 out of 100 points (DOE Wetlands Rating System, 2004). Source: City of Auburn, 2009 NE Auburn/Robertson Properties Special Area Plan EIS Addendum 22 November 2011 ESA According to ACC 16.10.080 wetlands that are artificially created are not regulated. “Artificially created wetlands are purposefully created landscape features, ponds and storm water detention or retention facilities. Artificially created wetlands do not include wetlands created as mitigation, and wetlands modified for approved land use activities. Purposeful creation must be demonstrated to the director through documentation, photographs, statements and/or other evidence. Artificial wetlands intentionally created from nonwetland sites are excluded from regulation under this section.” (ACC 16.10.080[C][5]) Streams in the City of Auburn are to be classified according to the criteria under ACC 16.10.080, summarized in Table 2. Table 2. City of Auburn Stream Class (ACC 16.10.080) Class I Streams Natural streams identified as “shorelines of the state” under the city of Auburn shoreline master program. Class II Streams Natural streams that are not Class I streams and are either perennial or intermittent and have one of the following characteristics:  Contain fish habitat; or  Has significant recreational value, as determined by the director. Class III Streams Natural streams with perennial (year-round) or intermittent flow and do not contain fish habitat. Class IV Streams Natural streams and drainage swales with channel width less than two feet taken at the ordinary high water mark, that do not contain fish habitat. Source: City of Auburn, 2009 According to ACC 16.10.080 streams that are intentionally created are not regulated. “Intentionally created streams are those manmade streams defined as such in these regulations, and do not include streams created as mitigation. Purposeful creation must be demonstrated through documentation, photographs, statements and/or other evidence. Intentionally created streams may include irrigation and drainage ditches, grass-lined swales and canals. Intentionally created streams are excluded from regulation under this section, except manmade streams that provide “critical habitat,” as designated by federal or state agencies, for salmonids.” (ACC 16.10.080[D][5]) Regulated wetlands and streams are protected by buffers, defined as a “naturally vegetated, undisturbed, enhanced or revegetated zone surrounding a critical area that protects the critical area from adverse impacts to its integrity and value, and is an integral part of the resource’s ecosystem” (ACC 16.10.020). Table 3 lists the required buffer widths for wetlands in Auburn. NE Auburn/Robertson Properties Special Area Plan EIS Addendum November 2011 23 ESA Table 3. City of Auburn Minimum and Maximum Wetland Buffers (ACC 16.10.090) Wetland Category Minimum Buffer Width Maximum Buffer Width Category I 100 feet 200 feet Category II 50 feet 100 feet Category III 25 feet 50 feet Category IV 25 feet 30 feet Source: City of Auburn, 2009 Table 3 displays the minimum and maximum buffer requirements to be applied to wetlands in Auburn. The maximum buffer may be required if the Planning and Development Director determines that a larger buffer is necessary to protect wetland functions and values based on site conditions, site design, intensity and operational characteristics of the development/land use (ACC 16.10.090[E][1][g]). Buffer width requirements may be averaged where it is demonstrated that: • The wetland contains variations in sensitivity due to existing physical characteristics; • Lower intensity land uses would be located adjacent to areas where buffer width is reduced; • Width averaging will not adversely impact the wetland functional values; and/or • The total area contained within the buffer after averaging is no less in area than contained within the standard buffer prior to averaging. When buffer width averaging is allowed, the buffer reduction cannot result in a reduction greater than 35 percent of the required buffer. Table 4 lists minimum required buffer widths for streams in Auburn. Table 4. City of Auburn Minimum Stream Buffers (ACC 16.10.090) Stream Class Minimum Buffer Width Class I (see subsection (E)(2)(b) of this section) 100 feet Class II 75 feet Class III 25 feet Class IV 25 feet Source: City of Auburn, 2009 The minimum buffer widths established in Table 4 may be increased or averaged by the Planning and Development Director in response to site-specific conditions and based on the information characterizing the functions and values of the stream (ACC NE Auburn/Robertson Properties Special Area Plan EIS Addendum 24 November 2011 ESA 16.10.090[E][2]). Buffer width averaging may be allowed for Class II and Class III streams only when all of the following are met: • One or more enhancement measures are implemented (as listed in ACC 16.10.090 (E)(2)(b)(i) through (iv), which include removing or modifying stream culverts, planting native vegetation within buffer); • The total area contained within the buffer after averaging is no less in area than contained within the standard buffer prior to averaging; • The buffer width averaging will result in stream functions and values equal or greater than before averaging; and • The buffer width is not reduced by more than 35 percent in any location than the required buffer widths. In circumstances where wetland alterations are allowed by the Planning and Development Director, the following acreage replacement and enhancement ratios must be implemented: Table 5. City of Auburn Wetland Mitigation Ratios (ACC 16.10.110) Wetland Category Wetland Creation Ratio (Acres) Wetland Enhancement Ratio (Acres) Category I 6:1 12:1 Category II Forested 3:1 6:1 Scrub/Shrub 2:1 4:1 Emergent 2:1 4:1 Category III Forested 3:1 6:1 Scrub/Shrub 2:1 4:1 Emergent 2:1 4:1 Category IV* 1.25:1* 2.5:1* *Category IV wetlands can either be mitigated by either: (a) meeting one of the replacement ratios; or (b) implementing mitigation which ensures no net loss of values and functions of the larger ecosystem in which the critical area is located. Source: City of Auburn, 2009 The City of Auburn identifies floodplain as a regulated critical area. The City also regulates portions of the site as flood hazard areas under Chapter 15.68 ACC Flood Hazard Area regulations. These regulations require that development be adequately elevated and floodproofed, and that development not reduce effective base flood storage. If a project involves placement of fill in a floodplain, an equivalent compensatory floodplain storage volume must be provided at equivalent elevations to that being displaced and must be hydraulically connected to the floodplain. NE Auburn/Robertson Properties Special Area Plan EIS Addendum November 2011 25 ESA Affected Environment Plant Communities Wetlands Wetlands in the project area were not delineated or categorized in the 2004 EIS. Since that time J.S. Jones and Associates, Inc. prepared a Wetland and Stream Impact Assessment (J.S. Jones and Associates, Inc., 2010). The assessment delineated and categorized Wetlands A, B, C, and D, all of which are located at least partially within the Auburn Gateway I project area. The report also describes Wetland E, which is located in the Auburn Gateway II project area and is discussed in more detail below. Wetland E was not delineated but is described in the J. S. Jones Report (2010). Wetland F is a wetland located on the Port of Seattle mitigation site to the east (Parametrix, 2003). Wetland G located on the north side of Auburn Gateway II project area is considered to be a roadside drainage ditch for stormwater conveyance rather than a wetland, as characterized in the 2004 EIS. As a drainage ditch, it is not considered a wetland or stream in the City code, although alterations to the ditch may be regulated by other agencies, as described below. Wetland ditches H, I, J, and K have been determined by the Washington Department of Fish and Wildlife (WDFW) to be intermittent fish bearing waters rather than wetlands, as characterized in the 2004 EIS (J. S. Jones and Associates, Inc., 2009). Based on information provided by the applicant, in the Stream Determination Request Letters from J. S. Jones and Associates dated September 15, 2009 and December 9, 2009, the City has determined that the roadside ditches on the south side of S 277th Street would not be regulated under the city’s critical areas regulations (Chapter 16.10 ACC). However, the various regulatory agencies have different authority and as a result their determinations may be different. The U.S. Army Corps of Engineers (COE) was consulted to determine if their prior jurisdictional determination, evaluated in the 2004 EIS, has changed given WDFW’s determination that the wetland ditches are streams. The COE indicated in a letter to Mr. Jeffery Jones received May 10, 2010 that ditches identified as Wetlands G, H, I, J and K in the 2004 EIS would be regulated by the COE as “waters of the US”, rather than wetlands, and confirmed the locations of the wetland boundaries for Wetlands A, B , C, and D (COE 2010). The Wetland and Stream Impact Assessment J.S. Jones and Associates, Inc., 2010 evaluated wetland ditches G, H, I, J and K as a stream as discussed in the Stream section below. See Figure 5 for the location of wetlands, streams, and other drainage features in the project area. Wetland E is located in the Auburn Gateway II project area. There is uncertainty about the extent of the wetland. The Mill Creek SAMP identifies wetland as 1.5 acres in size. The Draft EIS identified the wetland as approximately 0.20 acre. In 2008, Ecological Land Services, Inc. (ELS) delineated and categorized the wetland and submitted the report to the COE at the request of the property owner at the time. In 2008, ELS delineated and categorized the wetland as a 1.53-acre Category III wetland (ELS, 2008). NE Auburn/Robertson Properties Special Area Plan EIS Addendum 26 November 2011 ESA The COE conducted a field visit and responded to ELS that the delineation was incorrect. Since ELS did not provide a response, the application was rejected by the COE. The Auburn Gateway II property receives stormwater runoff from an adjoining property to the northwest bringing the actual extent of the wetland under question. Because a similar estimated area was provided for this wetland in the Mill Creek SAMP, the 1.53-acre estimate is used for this addendum, with the understanding that a full delineation will be required prior to development approvals, and mitigation will be required pursuant to the City’s and the COE’s requirements or those of other agencies at that time. The applicant proposes to delineate and categorize the wetland during the City’s permit submittal process. At this time, the wetland is assumed to be a Category IV depressional wetland with a Palustrine Emergent (PEM) vegetation class, as described in the Wetland and Stream Impact Assessment report (J.S. Jones and Associates, Inc., 2010). Wetlands G, H, I, J, and K are described in more detail below under the heading: Streams. In 1996 the City of Kent applied for permits for the 272nd / South 277th Street improvement project. This project involved widening South 277th Street, generally west of Auburn Way North and filling what were considered at that time to be wetland ditches G, H, I and J. A Clean Water Act Section 404 permit was issued by the COE for the project in 1996 that required wetland mitigation for filling the wetland ditches. The City of Kent completed the required wetland mitigation, thereby creating wetland mitigation credit however the Wetlands G, H, I, J, and K were never filled. The wetland mitigation credit may be applied to the wetland ditches as originally intended; if the ditches are currently considered to be wetland by the COE. If the ditches are not considered wetlands, the credits could be used towards other wetland fill, including possibly the Auburn Gateway project. The applicability of the credits would be at the discretion of each permitting agency and the City of Kent, which constructed the mitigation and owns the credits. The Hydrogeomorphic Classification (HGM) of Wetlands A-E varies between riverine, depressional, and slope. Wetland classifications according to the Cowardin system vary between Palustrine Emergent (PEM), Palustrine Scrub-Shrub (PSS), and Palustrine Forested (PFO). The following sections describe the three Cowardin communities that are present within the Auburn Gateway I and II project area as portrayed in the Wetland and Stream Impact Assessment (J.S. Jones and Associates, Inc., 2010). NE Auburn/Robertson Properties Special Area Plan EIS Addendum November 2011 27 ESA Figure 5. Stream and Wetland Map This Page Intentionally Left Blank NE Auburn/Robertson Properties Special Area Plan EIS Addendum November 2011 29 ESA Palustrine Forested Wetland (PFO) Two palustrine forested wetlands are located in the Auburn Gateway I and II project area (Wetland B and D). Wetland B is a Category II depressional wetland that extends beyond the Auburn Gateway I project area. Within the project area it is approximately 0.01 acres in size. The off-site portion of Wetland B was not delineated since permission to access the Stein property was not given. Wetland B is dominated by black cottonwood (Populus trichocarpa), Sitka willow (Salix sitchensis), and unidentified grasses. The on-site buffer north of Wetland B has been enhanced with native vegetation for a width of 35 feet. Wetland D is a Category II riverine wetland that it is approximately 0.06 acres in size. The April 2003 wetland delineation report for the Port of Seattle indicates that this wetland does not extend onto the Port property (Parametrix 2003). Wetland D is dominated by black cottonwood and red-osier dogwood (Cornus stolonifera). The vegetated buffer (as established by ACC 16.10) is disturbed and dominated by black cottonwood, red alder (Alnus rubra), and Himalayan blackberry. Palustrine Scrub-Shrub Wetland (PSS) Wetland B is the only wetland within the Auburn Gateway I and II project area that contains a palustrine scrub-shrub wetland; it also includes portions that are palustrine forested and palustrine emergent. Palustrine Emergent Wetland (PEM) Four palustrine emergent wetlands are located in the Auburn Gateway I and II project area (Wetlands A, B, C, and E). Wetland A is a Category II riverine wetland that is approximately 0.14 acres in size. According to the Parametrix Port of Seattle delineation, Wetland A does not extend offsite (Parametrix, 2003). Wetland A is dominated by meadow foxtail (Alopecurus sp.). Existing buffers (as established in ACC 16.10) are gravel surfaces to the south and west of Wetland A and previously disturbed black cottonwood (Populus trichocarpa), Himalayan blackberry (Rubus discolor) and grasses to the north and east. As discussed above, a portion of Wetland B is palustrine emergent. Wetland C is a Category III slope wetland approximately 0.39 acres in size. The perimeter of the wetland is silt fenced as it was previously delineated. There is a surface water inlet structure near the north end of the wetland that connects to the existing Auburn Valley 6 Theaters’ storm drainage system. The inlet structure controls the peak water levels of the wetland. A 35-foot wetland buffer around the perimeter of the wetland was planted with native vegetation in the fall of 2005. Wetland E located in Auburn Gateway II project area has not been delineated or categorized. It is assumed to be a Category IV depressional wetland. The wetland is dominated by creeping buttercup (Ranunculus repens) and reed canarygrass (Phalaris arundinacea). Table 6 summarizes the wetland areas and classifications for Wetlands A, B, C, D, and E. NE Auburn/Robertson Properties Special Area Plan EIS Addendum 30 November 2011 ESA Table 6. Summary of Wetland Characteristics WetlandA Wetland Classification Wetland Size (acre) CowardinB HGMG EcologyC Local JurisdictionD A PEM Riverine II II 0.14 B PFO, PSS, PEM Depressional II II 0.01E C PEM Slope III III 0.39 D PFO Riverine II II 0.06E E PEM Depressional IVF IVF UnknownF Source: J.S. Jones and Associates, Inc., 2010 A) Refer to Figure 5 for wetland general locations. B) PEM = Palustrine Emergent; PSS = Palustrine Scrub-Shrub; PFO = Palustrine Forested. C) Ecology rating according to Washington State wetland rating system for Western Washington, Revised. Ecology publication #04-06-15. D) Auburn City Code Chapter 16.10.080.C. E) The Wetland continues off-site; only the on-site area is listed F) Wetland has not been delineated or classified, but will be delineated at the time of permit application. G) Hydrogeomorphic Classification (HGM) Functional Analysis Functions were assessed by J.S. Jones and Associates, Inc. (2010) using the Washington State Department of Ecology Wetland Rating Form – Western Washington. Wetland A provides low habitat and moderate water quality and hydrologic functions. Auburn Valley 6 Theaters’ drainage ditches and culverts discharge to the wetland. The wetland is composed of dense grass. Wetland A is a tributary to Auburn Creek and the Green River. Flow-through is rapid. Over bank flooding occurs seasonally. Habitat features and vegetation structure is absent. Wetland B is rated moderate for water quality and low for habitat and hydrology. The presence of invasive plants in the understory and the small wetland size are the reasons for the low habitat and hydrology scores. Water quality is moderate because the ability and opportunity to improve water quality are present. Wetland C is rated moderate for hydrology, moderate for water quality and low for habitat. Wetland C is considered a “slope” wetland because it is not in a depression where it could hold water. For a “slope” wetland, the hydrology value for the Wetland C is the maximum possible. However, “slope” wetlands have less potential points. The grass community limits habitat functions and the small wetland size limits the ability for water retention. Water quality is moderate because the ability and opportunity to improve water quality are present. Off-site Wetland D is rated moderate for water quality, hydrology and habitat. The wetland has seasonal flooding from the adjacent ditch. There is opportunity to improve NE Auburn/Robertson Properties Special Area Plan EIS Addendum November 2011 31 ESA water quality. Habitat values are provided by the vertical vegetative structure and by being adjacent to a stream. Wetland E has not been delineated or fully assessed for functions. The wetland is currently under agricultural use. Although the functions for this wetland have not been formally assessed, initial observations suggest that Wetland E has moderate functions for water quality since it has an unconstricted outlet. It also can treat pollutants from surrounding residential areas since it has un-grazed vegetation. It has moderate hydrologic functions as it has a 2- to 3-foot depression that can store water at peak storm events. Storage prevents excessive flows to the Green River which can potentially damage salmon redds further downstream. It has low habitat functions since it has an absence of intact buffers, connections to open space and habitat features that include standing snags, fallen logs and amphibian habitat. Table 7 provides a summary of the functions assessed for each wetland. Table 7. Department of Ecology Functions Summary Functions Wetland A Wetland B Wetland C Wetland D Wetland E1 Water quality Moderate Moderate Moderate Moderate Not assessed Hydrology Moderate Low Moderate Moderate Not assessed Habitat Low Low Low Moderate Not assessed 1: Although wetland functions have not been assessed for Wetland E, it is likely to be considered moderate for water quality and hydrology, and low for habitat since it is actively farmed. The functions will be assessed at the time of the wetland delineation. Source: J.S. Jones and Associates, Inc., 2010 Streams The wetland ditches described in the 2004 EIS as Wetlands H, I, J and K have been determined by WDFW to be streams as the agency defines them. Wetland ditch G is not considered a stream by WDFW; however, it is anticipated that the COE will regulate the road ditch as a “Water of the U.S.” Based on information provided by the applicant, in the Stream Determination Request Letters from J. S. Jones and Associates dated September 15, 2009 and December 9, 2009, the City has determined that the roadside ditches on the south side of S 277th Street would not be regulated under the city’s critical areas regulations as either wetlands or streams (Chapter 16.10 ACC). However, the various regulatory agencies have different authority and as a result their determinations can differ. The COE has been consulted to determine if their prior jurisdictional determination, evaluated in the 2004 EIS, has changed given WDFW determination that the wetland ditches are streams not wetlands (J. S. Jones and Associates, Inc., 2010). Auburn Creek (Stream Number 0056) is located along 86th Avenue South and is a tributary to the Green River. The roadside ditch along the south side of South 277th Street and the stream along the east property line of the Auburn Valley 6 Theaters and the Stein Property (previously identified as Wetland ditch K) are two tributaries of Auburn NE Auburn/Robertson Properties Special Area Plan EIS Addendum 32 November 2011 ESA Creek. There is a ditch that runs through Wetland A and connects to the east side stream (J. S. Jones and Associates, Inc., 2010). The South 277th Street roadside ditch and the east side stream both have the potential to be fish-bearing (previously identified as Wetland ditches H, I & J). Surface flow is intermittent and seasonal. The roadside ditch and east side stream are classified as Type F waters according to WDFW. The existing buffer of the South 277th Street roadside ditch is road shoulder to the north side and where adjacent to the drive-in theater (Wetland ditch H & I) is a narrow strip, less than 10 feet wide, containing Arborvitae trees and chain link fence on the south side. The understory is Himalayan blackberry, red-osier dogwood, and willow. The existing south side buffer of Wetland ditch J is mixed second growth forest as identified in the 2004 EIS. The ditch through Wetland A is not fish-bearing and carries flowing water intermittently. There is an elevation drop of several feet from the east end of Wetland A to the east side stream (identified as Wetland ditch K). The stream is densely vegetated with grass most of the year (J. S. Jones and Associates, Inc., 2010). Functions Auburn Creek is an intermittent stream that may provide potential spawning and juvenile rearing habitat for salmonids; however, this has not been confirmed. There is a large flap gate at the outfall to the Green River that does not prevent fish passage. The South 277th Street ditch and 48-inch culvert under S 277th Street connects to farm ditches north of South 277th Street, which become Auburn Creek. The farm ditches are annually sprayed and cleaned with a backhoe. Seasonal flows, stream temperatures, sedimentation, water quality, and channel conditions limit the potential of fish usage (J. S. Jones and Associates, Inc., 2010). WDFW fisheries biologist, Larry Fisher, classified the eastern drainage and South 277th roadside ditch, east of D Street NE, as intermittent potential fish-bearing waters. No fish have been observed south of South 277th Street (J. S. Jones and Associates, Inc., 2010). The habitat quality appears to be poor. The source of water is Auburn Valley 6 Theaters’ parking runoff, street runoff, City of Auburn storm drainage pipelines, and runoff from undeveloped properties. This runoff from a pollution-generating surface is untreated. The riparian conditions are poor, particularly along South 277th Street. Threatened and Endangered Species Wildlife Since the 2004 EIS was issued there have been several changes to listing status for several species. The 2004 document identified the bald eagle as threatened. The bald eagle was delisted in 2008 and is now a federal species of concern. The 2004 EIS did not include several species that potentially occur within King County including: gray wolf (federally and state endangered), grizzly bear (federally threatened and state endangered), Canada lynx (federally and state threatened), marbled murrelet (federally and state NE Auburn/Robertson Properties Special Area Plan EIS Addendum November 2011 33 ESA threatened), and northern spotted owl (federally threatened and state endangered) (USFWS 2007). The gray wolf, grizzly bear, and Canada lynx are wide-ranging species that are found in critically small numbers in Washington, most reliable observations are from the North Cascades (Almack and Fitkin, 1998; WDFW, 1999). Marbled murrelets are year-round residents on coastal waters, and they generally nest and roost in mature and old growth forest where preferred nest sites are large flat conifer branches ranging from four to 25 inches in diameter (WDW, 1991). The northern spotted owl primarily nests and roosts in mature/old growth coniferous forests with high canopy closure, a multi-layered, multi- species canopy dominated by large (>30 inches diameter at breast height) trees, tree deformities such as cavities and broken tops, large snags, woody debris, and space for flying below the canopy (USFWS, 1990). Due to their limited range and specific habitat requirements, the gray wolf, grizzly bear, Canada lynx, marbled murrelet, and northern spotted owl would not be expected to occur within the urban areas of King County. The 2004 EIS also identified several federal species of concern that may occur in King County. The list was updated in 2007 to include: tailed frog, Larch Mountain salamander, and northern sea otter (USFWS, 2007). The project area does not contain suitable habitat to support these species at this time. Pacific fisher, as identified in the 2004 EIS, is no longer listed as a species of concern in King County. The 2004 EIS did not include the Oregon spotted frog or yellow-billed cuckoo, which are federal candidate species. The Oregon spotted frog is endemic to the Pacific Northwest, historically distributed in the Puget Trough Physiographic Province as well as the Willamette Valley province and the Cascade Mountains of south-central Washington and Oregon (McAllister and Leonard, 1997). In Washington they were historically distributed through the lowlands of Puget Trough from the Canadian border south to Vancouver Island and east into the southern Washington Cascades (Leonard et al., 1993; McAllister, 1995). Only four populations are extant in Washington today, one in south Puget Sound lowlands (Mason County), one in Thurston County at Dempsey Creek, and two in the Cascade Mountain range in south-central Washington (WDFW, 2000; McAllister and Leonard, 1997). The spotted frog (Rana pretiosa) is nearly always found in or near emergent wetlands within forested areas and is also associated with lakes in the prairie landscape of the Puget Sound lowlands (Slipp, 1940). Though not typically found in locations with a forest canopy, spotted frogs have been found in riparian areas with dense shrub cover (McAllister and Leonard, 1997). The proposed project will impact emergent wetlands and riparian areas; however, given the current range and distribution of the species and the degraded conditions of on-site wetlands and stream, the likelihood of Oregon spotted frog occurring on-site is very low. Yellow-billed cuckoos breed in large blocks of riparian habitats (particularly woodlands containing cottonwoods and willows) (Erhlich et al., 1988). Dense understory foliage appears to be an important factor in nest site selection, while cottonwood trees are an important foraging habitat in areas where the species has been studied in California (66 Federal Register 210). The available data suggest that the yellow-billed cuckoo’s range and population numbers have declined substantially across much of the western United NE Auburn/Robertson Properties Special Area Plan EIS Addendum 34 November 2011 ESA States over the past 50 years. In the Pacific Northwest, the species was formerly fairly common locally in willow vegetation within river bottoms along the Willamette and Columbia Rivers in Oregon; in the Puget Sound lowlands; and along the lower Columbia River in Washington. The last confirmed breeding records were in the 1930s in Washington and in the 1940s in Oregon. This species may now be extirpated from Washington (66 Federal Register 210). There have been documented sightings of yellow- billed cuckoo in King County and the Green River riparian corridor may provide some limited foraging and breeding habitat; however, the proposed site is devoid of mature cottonwood stands of significant size to support the species and their presence is not anticipated. Fish The 2004 EIS identified the Puget Sound/Strait of Georgia coho salmon as a candidate species; however their current federal status has been downgraded to a species of concern. Other listing changes that have occurred since that time includes the 2007 listing of the Puget Sound Distinct Population Segment (DPS) steelhead as threatened under the ESA (72 Federal Register 91), and the 2005 listing of designated critical habitat for the Puget Sound Evolutionarily Significant Unit (ESU) Chinook salmon and Coastal-Puget Sound DPS bull trout in the Green River (70 Federal Register 170; 70 Federal Register 185). Since the 2004 EIS, a Biological Opinion was issued by NMFS that determined the effects of certain elements of the NFIP throughout Puget Sound is likely to jeopardize the continued existence of the following species listed under the ESA: Puget Sound Chinook salmon, Puget Sound steelhead, Hood Canal summer-run chum salmon, and Southern Resident killer whales. The Biological Opinion also determined that NFIP is likely to adversely modify the following ESA designated critical habitats: Puget Sound Chinook salmon, Hood Canal summer-run chum salmon, and Southern Resident killer whale critical habitats. The biological opinion provides a reasonable and prudent alternative which can be implemented to avoid jeopardy and adverse modification of critical habitat. In response to the Biological Opinion, FEMA developed a model ordinance for NFIP participating communities, which includes the City of Auburn. The City of Auburn incorporated substantive terms of the model ordinance into their interim floodplain regulations (Ordinance No. 6295). Once FEMA approves the regulations as permanent measures or as it may be modified in response to FEMA comments, the Auburn regulations will become permanent. The Biological Opinion originally established a 2010 timeline for compliance for all NFIP participating communities within the Puget Sound Basin (NMFS, 2008). On September 10, 2010, the Federal Emergency Management Agency (FEMA) requested and was approved for a one-year extension to the September 2010 date for compliance with a Biological Opinion (BiOp) on the effects of FEMA's National Flood Insurance Program (NFIP) on listed salmon species under the Endangered Species Act throughout Puget Sound. Revised DFIRMs have been issued as of November 6, 2010, The new base flood elevations were published in the Federal Register on February 16, 2011, however the required process prior to adoption of publishing notice twice in a local newspaper and notifying local officials which begins the 90-day public NE Auburn/Robertson Properties Special Area Plan EIS Addendum November 2011 35 ESA appeal period has yet to be completed. Thus, the timing of implementation of revised floodplain maps is uncertain. The City of Auburn amended its floodplain regulations to implement FEMA’s draft model ordinance (Ordinance No. 6295). This interim ordinance establishes requirements for obtaining a permit for development in a floodplain, establishing standards to protect structures from damage and specifying criteria to protect against habitat loss in floodplains due to development, with emphasis on avoiding impacts to endangered species. Impacts Short-Term Construction Impacts Impacts to plants and animals would be similar to the impacts described in the 2004 Draft EIS. Long-Term Operational Impacts Habitat Loss and Fragmentation Wetland Habitat In addition to the impacts discussed in the Draft and Final EIS, the development of Auburn Gateway II would entail filling Wetland E. This would further reduce wetland habitat in the project area. The expanded development area would also involve a larger loss of upland habitat elements which may further limit access to remaining habitat by wildlife. Wildlife that has been listed under the ESA as endangered, threatened, species of concern or candidate species since the 2004 EIS (i.e., grey wolf, grizzly bear, Canada lynx, marbled murrelet, northern spotted owl, tailed frog, Larch Mountain salamander, northern sea otter, Oregon spotted frog, yellow-billed cuckoo) are not likely to occur on-site as described under Affected Environment. Therefore, no new impacts associated with these species are likely to occur. Since the 2004 EIS, wetlands in the project area have been delineated and categorized, except for Wetland E within the Auburn Gateway II project area. Table 8 summarizes wetland and buffer impacts associated with Auburn Gateway I and II according to the Wetland and Stream Impact Assessment (J.S. Jones and Associates, Inc., 2010). NE Auburn/Robertson Properties Special Area Plan EIS Addendum 36 November 2011 ESA Table 8. Summary of Wetland and Buffer Impacts Wetland Wetland Impact Area Minimum Buffer Width (feet)B Buffer Impact Area Permanent Percent Impacted Temporary Indirect Permanent Temporary A 0 0 0 0 50 0.12 0 B 0 0 0 0 50C 0.10 0 C 0 0 0 0 35 C 0 0 D 0 0 0 0 50 0 0 E UnknownA 100 0 0 25 NA NA Total Unknown 0 0 0.22 0 Source: J.S. Jones and Associates, Inc., 2010 A) Entire wetland to be filled. Since the wetland has not been delineated, the amount of wetland impact has not been determined. Wetland E will be delineated as part of the permit submittal process. B) Wetland buffers according to Auburn City Code 16.10.090.E.1 (City of Auburn, 2009). [RPG previously enhanced a 35-foot buffer around the on-site portion of Wetland B and of Wetland C. This was approved by the city and completed prior to the city’s adoption of the CAO, however, it is not anticipated that a greater buffer standard would now apply. By the table’s listing of the city’s current buffer standards, it appears to suggest that the city is seeking to apply a revised standard; which is not accurate. ] C) A 35-foot enhanced buffer has been applied to Wetland B and to Wetland C and previously approved by the City. The 2004 Draft EIS states that 0.5 acres of wetland area along South 277th Street (Wetland ditches G, H, I and J) would be filled as a result of roadway widening. This may no longer be the case if the ditches are not considered wetlands by any agency with jurisdiction. See Stream Habitat below for a description of impacts to the roadside ditch along South 277th Street. The wetland impacts described in the 2004 Final EIS that relate to the extension of 49th Street NE through the Stein and Port of Seattle properties and the extension of I Street NE south of Auburn Gateway I remain accurate. Filling of Wetland E is a new impact not described in the 2004 EIS. The wetland buffers for Wetlands A and B would be impacted due to the proposed alignment of I Street NE as described in the 2004 Draft EIS. The buffer areas that would be impacted are currently a gravel road. The remaining on-site portion of the 50-foot buffer for Wetland A would be enhanced with native vegetation. In 2005, a 35-foot buffer for Wetland B was planted with native shrubs and trees (J.S. Jones and Associates, Inc., 2010). Although Category II wetlands have a minimum 50-foot buffer requirement, pursuant to ACC 16.10.090(E)(1)(b), the city’s regulations also provide that wetland buffer widths may be averaged resulting in a reduced by up to 35 percent provided the buffer is enhanced with native trees and shrubs and the reduction will not adversely impact the wetland (City of Auburn, 2009). Wetland C also has an enhanced 35-foot buffer which was planted in 2005 (J.S. Jones and Associates, Inc., 2010). Auburn City Code now specifies a minimum 25-foot buffer for Category III wetlands such as Wetland C (City of Auburn, 2009). The off-site NE Auburn/Robertson Properties Special Area Plan EIS Addendum November 2011 37 ESA Wetland D would likely have a minimum 50-foot enhanced buffer as required by the city code. Fish Habitat Impacts on fish habitat would be associated with temporary construction impacts. As described in the 2004 Draft EIS, erosion of exposed soils during land clearing, grubbing and grading could occur. Sediment-laden runoff could be transported downstream to the Green River via roadside ditches and drainages. Although this effect would be minimized by the use of best management practices, high levels of sedimentation and low concentrations of dissolved oxygen could alter the respiration of fish, impairing their growth. However, impacts of this magnitude are not anticipated and wildlife should be able to recover from any short-term impairment of water quality. The new ESA listings, including the Puget Sound DPS steelhead, and critical habitat for the Puget Sound ESU Chinook salmon and Coastal Puget Sound DPS bull trout would be similarly affected. To ensure compliance with the NMFS Biological Opinion, the applicant would need to meet FEMA and NMFS requirements for providing adequate protection to endangered species pursuant to a city floodplain development permit. Stream Habitat The South 277th roadside ditch (identified in the 2004 EIS as Wetland ditches H, I and J) located between D Street NE and the eastern boundaries of the project area would be relocated south to make room for expanding South 277th Street. Existing vegetation south of the roadside ditch would be removed. Expansion of the roadway is a planned improvement by both Auburn and Kent to accommodate background increases in traffic. The South 277th Street roadside ditch would be restored to the permitted configuration immediately south of the road right-of-way. A planted buffer with native vegetation would be installed on the south side of the relocated stream. The buffer width would depend on WDFW requirements and those of other agencies with jurisdiction. Construction of road improvements would occur within a six month time frame, during the late spring, summer and early fall seasons when the stream channel is dry (J.S. Jones and Associates, Inc., 2010). Relocation of the South 277th Street roadside ditch and development of Auburn Gateway I and II would result in an improvement in stream habitat functions which are currently in poor condition. The width of the buffer on the south side of the roadside ditch would likely increase from the existing 10-foot buffer. After buffer enhancement invasive plants would be removed from the roadside ditch buffer during the required 10-year maintenance period. The storm water system installed for the Auburn Gateway I and II project would provide some improvements to water quality. One culvert at the intersection of G Street NE and South 277th Street would be removed. The culvert at the intersection of I Street NE and South 277th Street would be replaced with a fish passable culvert as required by WDFW (J.S. Jones and Associates, Inc., 2010). NE Auburn/Robertson Properties Special Area Plan EIS Addendum 38 November 2011 ESA The portion of the ditch along South 277th Street between D Street and Auburn Way North would be piped (identified in the 2004 EIS as Wetland Ditch G). This ditch is expected to be considered a Water of the U.S by the COE. This section of the ditch conveys water across the site to the downstream system. Roadway widening would impact 8,040 square feet of Waters of the U.S. (J.S. Jones and Associates, Inc., 2010). As stated in the 2004 DEIS, roadside ditches can provide some minimal shelter, food, and nesting sites. Also, ditches typically are used to a greater extent by birds and mammals than adjacent agricultural fields. Piping the ditch along South 277th Street between D Street and Auburn Way North would result in permanent impacts to roadside ditch habitat. Relocating the South 277th roadside ditch would result in temporary impacts to roadside ditch habitat during construction. No permanent impacts to the east side stream (identified in the 2004 EIS as Wetland Ditch K) are proposed. The east side stream is almost entirely outside of the Auburn Gateway I and II project and is entirely outside of the footprint of the proposed I Street extension area. As noted in the 2004 EIS, the extension of 49th Street NE through the Stein and Port of Seattle properties would impact the stream. Such impacts could impact fish passage unless designed properly to avoid blocking passage. Mitigation The 2004 Draft EIS on pages 143-145 provided a list of mitigation measures to mitigate impacts both during construction and operation of the planning area. Several mitigation measures no longer apply since the EIS was prepared. The following provides a list of new mitigation measures that are recommended for impacts on plants and animals as a result of the proposed Auburn Gateway I and II development. These mitigation measures replace the mitigation measures provided in the Draft EIS but are very similar. This section discusses the general mitigation measures for impacts due to both construction and long-term operations that apply to development under the Northeast Auburn/Robertson Properties Special Area Plan, including the Auburn Gateway project. As noted above, the project must comply with local, state, and federal regulations that protect wildlife habitat in various ways. This section begins with mitigation required by law for impacts that may occur as a result of the project. The discussion of regulations that provide assurance of mitigation is followed by additional recommendations for mitigation that should be employed by the City and RPG in conjunction with implementation of the project. The Federal Clean Water Act (CWA) Section 404 requires mitigation for impacts on Waters of the U.S. For any impacts anticipated, the design and construction of the Northeast Auburn/Robertson Properties Special Area Plan project must follow the mitigation sequence developed by the Corps for waters of the United States: 1. Avoid impacts on wetland, stream, and wildlife habitats and associated species and their associated species 2. Minimize impacts, if avoidance is not possible NE Auburn/Robertson Properties Special Area Plan EIS Addendum November 2011 39 ESA 3. Rectify and restore areas where possible 4. Reduce the adverse impacts by preservation and maintenance operations 5. Provide compensatory mitigation (i.e., replacement of lost wetlands) 6. Monitor the impacts and mitigation and take appropriate corrective measures. The COE generally requires a 1 to 1.25 replacement of wetlands that are proposed to be filled and may also allow mitigation through wetland enhancement at a 1:3 ratio. An Hydraulic Project Approval (HPA) may be required for potential impacts on Auburn Creek (Stream Number 0056 located along 86th Avenue South), which drains from the project area to the Green River, and the roadside ditch along the south side of South 277th Street. WDFW typically issues an HPA on the condition that approved mitigation measures, determined on a case-by-case basis, and best management practices will be implemented during and after the construction of the project. Impacts on water quality are regulated by the City’s stormwater regulations, as discussed in the Water Resources section of the 2004 EIS. The proposed Auburn Gateway Design Guidelines indicate that native plantings would be used in wetland buffer areas and around detention facilities (BCRA 2003). The guidelines also indicate that trees and other landscaping would be used in the parking areas, around loading areas and in building setbacks, and along public roadways within the Auburn Gateway project area. The following mitigation measures are recommended for impacts on plants and animals: • Prepare a wetland mitigation plan meeting applicable requirements for mitigating potential impacts. The plan should: o Coordinate wetland mitigation conservation requirements of the various agencies with regulatory authority. o Coordinate wetland mitigation conservation with phasing of earthwork and construction to avoid/reduce reoccurrence of disturbance or impacts. o Include information on measures to be employed to avoid impacts on wetland hydrology, as discussed in the Water Resources section of the 2004 Draft EIS. o Stipulate mitigation measures for wetlands affected by dredging or filling in accordance with Auburn City Code Chapter 16.10. Mitigation could be implemented by on-site or off-site wetland enhancement or creation consistent with local, state and federal regulations. o Provide buffers of at least 75 feet standard width for all emergent wetlands (except the wetland ditches along South 277th Street), and buffers of 100 feet average for all forested scrub-shrub wetlands. Buffer averaging could be NE Auburn/Robertson Properties Special Area Plan EIS Addendum 40 November 2011 ESA allowed provided that the minimum buffer is no less than 65 percent (a 35 percent reduction) of the specified buffer width. o Provide a mitigation plan for approval by regulating agencies for the planting or enhancement of wetland buffers with native plant species as soon as possible after initial site grading is completed. o Minimize the clearing of native vegetation and protect remaining onsite vegetation from damage during construction. o Identify the construction boundaries and methods to be employed after completion of project to avoid encroachment on adjacent habitat areas. o Schedule construction within work windows specified by WDFW, the COE, NOAA Fisheries, and/or the USFWS to avoid critical periods (i.e., wintering, nesting and breeding/spawning, and migration) for species of concern listed as present or potentially present in the planning area. o Provide a stormwater pollution prevention plan (SWPPP) that will prevent or minimize sedimentation and potential hazardous spills that could affect both the onsite and offsite water bodies. o Minimize night lighting near wetlands during construction. o Identify locations and types of night lighting to be used for development that minimizes light impacts on wetland habitats and buffers. o Establish a protocol for wetland and hydrologic monitoring to ensure that wetland mitigation and newly planted wetland buffers are thriving after the installation of the plantings is completed. Provide financial security to guarantee monitoring, maintenance and contingency measures. o Wetland monitoring should continue annually for a minimum of 5 years after the project is completed, and should include observations and reporting of native vegetation and hydrologic conditions that may be adversely affected by fill adjacent to wetland areas. o Replace the culvert at the intersection of I Street NE and South 277th Street with a fish passable culvert. • Using innovative designs, protect wetlands and wetland buffers from the intrusion of humans and domestic animals by means of barriers to humans and domestic animals, while still allowing aesthetic enjoyment of these areas. • Require modifications to stormwater and/or groundwater management if adverse effects on wetland hydrology are observed before the end of the wetland monitoring period. NE Auburn/Robertson Properties Special Area Plan EIS Addendum November 2011 41 ESA • Revegetate portions of the project area that are disturbed only for construction purposes (e.g., areas surrounding buildings or construction staging areas) as soon as possible after construction is completed. Establish a protocol for and conduct monitoring to ensure that newly planted areas are thriving. Provide financial security to guarantee monitoring, maintenance and contingency measures. • The construction staging areas should be located on the existing gravel within the drive-in theater so wildlife displacement is delayed. A number of conservation measures are recommended to avoid or minimize potential impacts to streams (including South 277th Street roadside ditch) during construction. • There should be no loss of stream length as a result of relocating the existing stream channel. • In-water construction activities will be regulated by the HPA issued for the project. The anticipated in-water work should occur from July 1 to August 31, or when the water bodies in the project area are dry. This will limit work within the wetted perimeter of the water bodies to the low-flow summer months and reduce potential for impacts to fish species. • Staging areas, stockpiles, equipment storage areas, and other similar facilities should be set back at least 100 feet from the top-of-bank of the stream. • To minimize the effect of dewatering the work area on fish species, the HPA for this project will require that the project proponent capture and safely remove fish and other aquatic life from the portion of stream to be abandoned. Captured fish are required to be immediately and safely transferred to free-flowing water downstream of the bypass following methods outlined in the anticipated HPA for this project. • The project proponent should seek assistance from WDFW to remove fish prior to construction if WDFW personnel are available. If WDFW personnel are not available, the project proponent should arrange for the removal of fish by a qualified fisheries biologist. • The amount of area that is cleared and graded at any one time should be limited, and construction activities should be scheduled soon after an area has been cleared and stripped of vegetation. • Construction areas and limits of work should be clearly identified in the field and on plans to minimize habitat disruption. • A temporary erosion and sediment control (TESC) plan and site-specific BMPs should be implemented as directed by the project engineer in accordance with the City’s standard specifications for erosion control and standard HPA provisions. Site-specific BMPs will include at a minimum: o Washout of construction vehicles, vehicle maintenance, and refueling should be prohibited within 100 feet of the top-of-bank of the stream; and o Construction equipment should be outfitted with emergency spill kits and construction crews should be trained in their proper use. NE Auburn/Robertson Properties Special Area Plan EIS Addendum 42 November 2011 ESA • All disturbed areas should be stabilized to prevent erosion within seven days of the completion of the project. • Where possible, native vegetation removed during construction should be replaced with native tree and shrub species following construction. These actions will increase the water quality, hydrologic, and habitat features associated with these areas. • Stream buffers should be established and planted with a mixture of native tree and shrub species. Establish a protocol for stream mitigation monitoring to ensure that stream mitigation and newly planted buffers are thriving after the installation of the plantings is completed. Provide financial security to guarantee monitoring, maintenance and contingency measures. • In stream habitat features such as large woody debris (LWD) and boulders, should be incorporated into final design to increase habitat complexity and provide cover for fish species. The performance of habitat features should be monitored and reported. • Relocated stream reaches should include fine grading necessary to establish complex habitat types including pool and riffle complexes, which may require the installation of grade control structures. The performance of habitat features and grade control structures should be monitored and reported. • The relocated portion of streambed should allow for placement of spawning sized gravel at a minimum depth of six inches. • The culvert at the intersection of I Street NE and South 277th Street would be replaced with a fish passable culvert (J.S. Jones and Associates, Inc., 2010). • To ensure compliance with the NMFS Biological Opinion, the applicant would need to meet FEMA and NMFS requirements for providing adequate protection to endangered species pursuant to a city floodplain development permit for an alteration within regulatory floodplain. Significant Unavoidable Adverse Impacts In addition to the impacts described in the 2004 Draft EIS, Auburn Gateway II would result in minor loss of wetland functions that would be replaced by mitigation meeting federal, state and local requirements. Although some fragmentation of wetland habitat is unavoidable with filling of the wetlands, the wetland habitat functions on the Auburn Gateway II site are minimal and can be replaced through mitigation measures. As such, no significant impacts to wetland functions are expected. Impacts on ESA listed species and habitats could occur during construction are not likely. If at any time they become more likely, such as if flooding brings fish onto the site, the impacts could be minimized by employing conservation measures established through meeting FEMA and NMFS requirements for providing adequate protection to endangered species. With appropriate measures, no significant impacts are expected. NE Auburn/Robertson Properties Special Area Plan EIS Addendum November 2011 43 ESA Transportation The analysis below is summarized from Auburn Gateway Transportation Impact Analysis (TIA) prepared by Transportation Solutions, Inc, in August 2011. The TIA is attached to this addendum and hereby incorporated into the EIS. The traffic analysis focuses on the applicant’s preferred land use of Alternative 2 (evaluated in the 2004 EIS as 720,000 square feet of retail development) modified to include Auburn Gateway II and to evaluate an optional roadway layout as described in the preceding Project Background. While the all retail alternative is expected to be the most likely use for the site, in order to maintain the applicant’s development flexibility the worst case development condition for traffic under any of the development alternatives is also studied. Of the three alternative land use options evaluated in the 2004 EIS, the Office/Retail Option (Alternative 1) was found to be the most intensive from a transportation perspective. The Office/Retail Option includes 1,600,000 square feet of office with 200,000 square feet of retail development. Thus, both land use alternatives are considered. Because the trip generation of Alternative 3 evaluated in the 2004 EIS (the Residential/ Retail Option) would be less than either Alternative 1 and Alternative 2, it was not re- analyzed for this addendum. The Residential/ Retail Option would have characteristics that are similar to but proportionately less than either of the land use options examined in this addendum with the added land assemblage. The transportation impact analysis for this addendum also assumed development of the site would occur in two phases, with the North Phase located north of 49th Street NE and the South Phase located south of 49th Street NE. Because office development would likely include various density levels, it was assumed that 60% of the Full-build Office/Retail Option could occur on either the north portion of the site or the south portion of the site depending on possible development conditions at the time. Therefore the trip generation within a single phase was never assumed to exceed 60 percent of the cumulative trip generation predicted for the entire project. Accordingly, the following development conditions were evaluated: Retail Only option • South Phase (approximately 236,000 square feet retail space) first; • North Phase (approximately 484,000 square feet retail space) first; • North and South Phases together (720,000 square feet retail space); and Office Retail Option • South Phase with 60% of the office/retail development first; (60% of trip generation) • North Phase with 60% of the office/retail development first; (60% of trip generation) • Full development with 60% of the office/retail in the southerly portion of the property; (60% of trip generation) NE Auburn/Robertson Properties Special Area Plan EIS Addendum 44 November 2011 ESA • Full development with 60% of the office/retail in the northerly portion of the property; (60% of trip generation) Affected Environment Consistent with the 2004 EIS, development related traffic impacts were evaluated under year 2020 traffic conditions. Year 2020 traffic forecasts without the development were refined to reflect actual traffic patterns and recent historical growth trends. Based on this approach, corridor volumes in 2020 were found to be very similar to those forecast in the 2004 EIS. Directional road segment and intersection turning movement volumes in this current analysis differed somewhat from the 2004 EIS but more realistically reflect land use patterns. Background levels of service were found to be improved in this analysis as compared with the 2004 EIS analysis due to the use of refined directional split and turning movement allocations from traffic modeling refinements. One change in the study area that has occurred since the EIS is the Trail Run residential subdivision and planned unit development (PUD) (also formerly known as River Sands) east of the project area, including opening of L Street NE to provide access to that site onto South 277th Street. In the EIS, access to Trail Run was expected to be via a roadway that would have right-in/right-out only access to South 277th Street, and that 49th Street NE would be extended as a two-lane local road east of I Street NE to connect and serve the Trail Run development. On an interim basis, a temporary signal was installed at L Street NE and South 277th ST and monies were collected by the City for the future extension of 49th Street NE east of I Street NE and for I ST NE to serve the Trail Run development and to facilitate the relocation of the temporary signal to the future intersection of I Street NE and South 277th ST. New in this analysis is an assessment of conditions with and without the 49th Street NE extension east of I Street NE to Trail Run and this analysis considers more than one traffic signal on South 277th ST to evaluate transportation options. Impacts Under this traffic analysis, Auburn Gateway is proposed to be a retail commercial mixed use development that could be developed in two phases – one south of 49th Street NE and one north of 49th Street NE or all together. The zoning established for the Auburn Gateway properties would allow for a mix of residential, office and other retail uses. Adjacent property (Auburn Gateway II) has been added to the original project but the developable floor area maximums remain the same as evaluated in the 2004 EIS. The sequence of development is currently unknown so the combinations of the two-phase development were analyzed. Roads adjacent to each development phase are planned to be constructed concurrently so they would be in place when that phase of development is occupied. For a complete description of the assumed roadways and turning movements assumed, see the TIA (2011). The only proposed changes in the road network from the 2004 EIS are at D Street NE north of 49th Street NE and 49th Street NE east of I Street NE being reviewed as a stub end road. D Street NE is proposed to be vacated (subject to a future city council NE Auburn/Robertson Properties Special Area Plan EIS Addendum November 2011 45 ESA decision) and become an internal circulation aisle in the parking lot of the project. Consistent with the 2004 EIS, D Street NE at Auburn Way North would be closed with a cul-de-sac. As discussed above, the analysis also looked at conditions with and without the 49th Street NE connector, east of I Street NE. The roadway improvements that were assumed would be developed include the following: • Widen S 277th Street from 3 lanes to 5 lanes east of Auburn Way N to L Street NE. At the intersection with I Street NE there is likely the need for a 6 to 7 lane wide section including a dual westbound left turn lane. The majority of widening would occur on the south side of the road. • At S 277th Street/ Auburn Way N: o Eastbound: add one through lane and a right-turn lane o Westbound: add one through lane and a right-turn lane o Northbound: add a northbound to eastbound ‘add lane’ • Extend I Street NE from 45th Street NE to S 277th Street. I Street NE will be a 5 lane cross-section with the possibility of an additional northbound right turn lane (Construct the north sections during North Phase and Full-Build development conditions) • Construct S 277th Street/ I Street NE intersection with a traffic signal (during North Phase and Full-Build development conditions): o Eastbound: 3 through lanes and 1 right-turn lane o Westbound: 2 through lanes and 2 left-turn lanes o Northbound: 1 left-turn lane, one right/left shared turn lane and one exclusive right turn lane • Widen 49th Street NE east of Auburn Way N to I Street NE with a 3-lane minor arterial standard. • Install a new traffic signal at 49th Street NE/ Auburn Way North to include left- turn pockets on 49th Street NE. • Construct a traffic signal at the South Phase access off Auburn Way N. The new signal would include separate right-turn and left-turn approaches from the development site. (During the South Phase development condition or at Full- Build development conditions when conditions warrant). • Close and cul-de-sac the intersection of D Street NE at Auburn Way N • Construct a traffic signal at I Street NE and 49th Street NE when warranted • Construct a traffic signal at 45th Street NE and Auburn Way North when warranted • Construct a traffic signal at I Street NE and 45th Street NE when warranted NE Auburn/Robertson Properties Special Area Plan EIS Addendum 46 November 2011 ESA All road improvements would include curb, gutter, sidewalks, street lighting, landscaping and storm drainage provisions except for S 277th Street which would include an all- weather path integrated in the landscape site frontage buffer area. In addition to completing road and utility improvements to adjacent roadways under the City’s half- street regulations, Robertson Properties Group proposes to work with the City through a Development Agreement to construct several major road improvements in the immediate vicinity of the development. The Development Agreement states that some road and utility improvements may be eligible for financial assistance from the City for traffic impact fee credits, mitigation fees collected for other developments in the area and payback mechanisms. See the Transportation Mitigation section for a table regarding roadway improvements and phasing. Trip generation was forecast used the same methodology as used in the 2004 EIS. The PM peak hour trip generation is therefore forecast to be 2,419 PM peak hour trips for Alternative 1 and 1,803 PM peak hour trips Alternative 2. For this analysis, the driveway or primary trips include diverted-link trips. Thus, for the phasing options analyzed, the level of service will remain at or under the levels forecasted for Full-build for either the Retail Only or Office/Retail Options. These development-generated trips were assigned to the road network for each phase and for full development. Refinements to road channelization were developed and level of service was computed. To evaluate the effect of development phasing, LOS tables of the various phasing options for each alternative were prepared. Under either land use alternative, the LOS associated with any of the phases would be better than the LOS with Full-build development. Levels of service with each phase of development were generally found to operate equal to or better than the level of service disclosed in the 2004 EIS. A comprehensive LOS summary under each of the various conditions analyzed is presented in Tables 9 and 10. NE Auburn/Robertson Properties Special Area Plan EIS Addendum November 2011 47 ESA Table 9. 2020 Office/Retail; PM Peak Hour Level of Service Intersection No-Build 2004 EIS Full Build South Phase North Phase Control LOS Delay Control LOS Delay Control LOS Delay Control LOS Delay 277th St/AWN S E 76.0 S F 84.6 S E 63.4 S E 58.9 277th St/D St U F 533.3 U E 39.3 U C 18.1 U C 15.5 277th St/I St S E 73.4 S B 15.7 277th St/L St S A 4.3 S A 6.1 U B 10.1 49th St/AWN U E 30.3 S C 20.6 S B 19.6 S B 13.0 49th St/D St U B 14.4 U B 13.3 U B 11.6 49th St/I St S D 36.6 S C 30.4 Access/AWN S B 12.5 U D 31.3 45th St/AWN U D 24.4 S B 19.0 U D 29.1 U C 22.4 45th St/I St S B 13.7 U B 11.9 Intersection Full-Build (South 1st) Full-Build (North 1st) Full-Build (South 1st) 45th/AWN Signal Full-Build (North 1st) 45th/AWN Signal Control LOS Delay Control LOS Delay Control LOS Delay Control LOS Delay 277th St/AWN S E 63.6 S E 63.7 S E 63.2 S E 63.9 277th St/D St U C 16.9 U C 16.9 U C 16.9 U C 16.9 277th St/I St S C 22.1 S C 23.7 S C 22.2 S C 23.1 277th St/L St U B 10.7 U B 10.7 U B 10.7 U B 10.7 49th St/AWN S B 18.4 S B 18.6 S B 12.6 S B 13.6 49th St/D St U B 13.7 U B 14.1 U B 12.0 U B 14.1 49th St/I St S R C C 27.6 24.0 S R C C 27.8 18.4 S R C C 27.7 24.0 S R C C 29.6 18.4 Access/AWN U D 31.0 U D 26.0 U B 10.3 U A 9.9 45th St/AWN U D 25.2 U C 25.0 S B 11.9 S A 7.8 45th St/I St U B 13.7 U B 13.7 U C 15.3 U C 15.4 Intersection Full-Build (South 1st) I St & L St Signals Full-Build (North 1st) I St & L St Signals Control LOS Delay Control LOS Delay 277th St/AWN S E 64.0 S E 64.0 277th St/D St U C 16.9 U C 16.9 277th St/I St S C 20.8 S C 21.8 277th St/L St S A 3.4 S A 2.9 49th St/AWN S B 18.3 S B 18.4 49th St/D St U B 13.7 U B 14.0 49th St/I St S R B C 13.2 21.8 S R B C 13.0 21.8 Access/AWN U D 31.0 U D 26.0 45th St/AWN U D 25.2 U C 24.7 45th St/I St U B 13.7 U B 13.7 Control = Intersection control (U = unsignalized; S = signal; R = roundabout) Delay = expressed in seconds of control delay NE Auburn/Robertson Properties Special Area Plan EIS Addendum 48 November 2011 ESA Table 10. 2020 Retail Only; PM Peak Hour Level of Service Intersection No-Build 2004 EIS Full-Build South Phase North Phase Control LOS Delay Control LOS Delay Control LOS Delay Control LOS Delay 277th St/AWN S E 76.0 S E 76.9 S D 53.4 S E 61.2 277th St/D St U F 533.3 U E 41.6 U B 12.5 U B 14.9 277th St/I St S E 62.7 S B 14.6 277th St/L St S A 4.3 S A 5.2 U A 9.8 49th St/AWN U E 30.3 S B 19.1 S B 15.0 S B 11.0 49th St/D St U B 12.7 U B 10.5 U B 12.0 49th St/I St S B 15.6 S C 27.9 Access/AWN 45th St/AWN S B 11.6 U C 29.8 45th St/I St U D 24.4 S B 18.4 U D 26.2 U C 23.0 Intersection Full-Build Full-Build 45th/AWN Signal Full-Build I St & L St Signals Control LOS Delay Control LOS Delay Control LOS Delay 277th St/AWN S E 64.9 S E 64.3 S E 65.5 277th St/D St U C 15.6 U C 15.6 U C 15.6 277th St/I St S B 17.7 S B 19.5 S B 18.4 277th St/L St U B 10.1 U B 10.2 S A 3.9 49th St/AWN S B 16.6 S B 12.4 S B 17.1 49th St/D St U B 14.4 U B 12.9 U B 14.3 49th St/I St S R C B 29.1 10.5 S R C B 27.4 10.5 S R A A 8.5 10.0 Access/AWN U C 23.5 U A 9.5 U C 23.5 45th St/AWN U C 24.9 S A 8.7 U C 24.9 45th St/I St U B 11.8 U B 14.4 U B 11.9 Control = Intersection control (U = unsignalized; S = signal; R = roundabout) Delay = expressed in seconds of control delay A queuing analysis was performed to analyze stacking, or queuing, between signalized intersections. This analysis forecasts no intersection queuing issues that cannot be mitigated. The TIA evaluated traffic operations if the South Phase site access were signalized at Auburn Way North. Under this condition 45th and 49th Streets NE would also be signalized. Overall study intersection operations with a signal at the South Phase site access were projected to be similar to those under the other Full-Build conditions without the South Phase site access signalized. Vehicle queues are not projected to extend to adjacent intersections, suggesting that the presence of three new signals on Auburn Way North at 49th Street NE, the South Phase site access, and 45th Street NE could operate sufficiently, when warranted by the prevailing traffic volumes. In other words, queues on Auburn Way North would not interfere with traffic operations at the next adjacent signalized intersection. The TIA analyzed the S 277th Street/ I Street NE intersection if the intersection were not improved to a “flying T”. Intersection channelization is as follows: 3 eastbound through lanes, 1 eastbound right-turn lane, 2 westbound left-turn lanes, 2 westbound through lanes, 1 dedicated northbound left-turn lane, 1 dedicated northbound right-turn lane, and 1 shared northbound left-turn-right-turn lane. The westbound through movement would be signal controlled instead of free flowing. This intersection scenario may be warranted NE Auburn/Robertson Properties Special Area Plan EIS Addendum November 2011 49 ESA if the “flying T” proposal is not feasible. Intersection level of service would acceptable if the 227th Street/ I Street NE intersection is a standard intersection. Level of service is similar and comparable to conditions if the intersection were a “Flying T”. Westbound queues increase from “Flying T” conditions, but are not anticipated to spillback to L Street. Northbound queues would increase up to 50% of the segment length on I Street NE between S 277th Street and 49th Street NE. Signal timing may need to be adjusted and storage capacities for the northbound approach will need to be amended if the standard intersection approach is selected verses the “Flying T”. The analysis found that two signals on South 277th Street (at I Street NE and at L Street NE) can generally operate safely and effectively with or without the two-lane 49th Street NE connector that was originally envisioned to connect the Auburn Gateway with Trail Run development. This was true of both the Retail Only and the Office/Retail options at full buildout. The traffic report also examined the impacts of allowing the applicant to construct a signal at the SW access drive at Auburn Way North. The analysis shows with the signal at the SW access, northbound vehicles on Auburn Way North would be delayed by approximately 12 seconds compared to conditions without a signal. Without a signal, the driveway could have safety issues similar to those that currently exist at the intersection of D Street NE and Auburn Way N. Mitigation Traffic related mitigation recommended for the project is substantially the same as that described in the EIS, with some refinements and minor changes based on a more refined development program, project phasing, and traffic forecasts. The City of Auburn has three programmed improvement projects: I Street NE Corridor between 40th Street NE and S 277th Street; S 277th Street between Auburn Way N and Green River; and 49th Street NE between Auburn Way N and M Street NE. All three improvement projects are triggered by the development of Auburn Gateway although other, non-Auburn Gateway traffic will use these facilities to avoid congestion on existing roads. All intersections would operate at or better than the levels forecast in the 2004 EIS. All intersections except for Auburn Way North/ S 277th Street (South Phase Office/ Retail Option only) are forecast operate at or above the City’s adopted LOS Standard (LOS D or better) under each phase or full-build-out development condition. Possible mitigation of this below standard condition can be met by constructing I Street NE as part of the South Phase Office Option, reduce the size or revise the sequence of development phasing of the South Phase Office/Retail Option, or employ a Transportation Management Program (TMP) to reduce trip making. This section outlines the roadway and intersection improvements incorporated into the traffic model(s) used to evaluate the development. Unless otherwise noted below, the following roadway improvements listed below were incorporated in the area-wide alternatives: NE Auburn/Robertson Properties Special Area Plan EIS Addendum 50 November 2011 ESA • Widen S 277th Street from 3 lanes to 5 lanes east of Auburn Way N to L Street NE. At the intersection with I Street NE there is likely the need for a 6 to 7 lane wide section including a dual westbound left turn lane. The majority of widening would occur on the south side of the road. • At S 277th Street/ Auburn Way N: o Eastbound: add one through lane and a right-turn lane o Westbound: add one through lane and a right-turn lane o Northbound: add a northbound to eastbound ‘add lane’ • Extend I Street NE from 45th Street NE to S 277th Street. I Street NE will be a 5 lane cross-section With the possibility of an additional northbound right turn lane (Construct the north sections during North Phase and Full-Build development conditions) • Construct S 277th Street/ I Street NE intersection with a traffic signal (during North Phase and Full-Build development conditions): o Eastbound: 3 through lanes and 1 right-turn lane o Westbound: 2 through lanes and 2 left-turn lanes o Northbound: 1 left-turn lane, one right/left shared turn lane and one exclusive right turn lane • Widen 49th Street NE east of Auburn Way N to I Street NE with a 3-lane minor arterial standard. • Install a new traffic signal at 49th Street NE/ Auburn Way North to include left- turn pockets on 49th Street NE. • Construct a traffic signal at the South Phase access off Auburn Way N. The new signal would include separate right-turn and left-turn approaches from the development site. (During the South Phase development condition or at Full- Build development conditions when conditions warrant). • Close and cul-de-sac the intersection of D Street NE at Auburn Way N • Construct a traffic signal at I Street NE and 49th Street NE when warranted • Construct a traffic signal at 45th Street NE and Auburn Way North when warranted • Construct a traffic signal at I Street NE and 45th Street NE when warranted All road improvements would include curb, gutter, sidewalks, and landscaping except for S 277th Street that would include an all-weather path integrated in the landscape site frontage buffer area. These and other offsite improvements for both of the land use options are summarized in Table 12 below. This table compares all mitigation found in the 2004 EIS with the mitigation required for the current proposals. The mitigation does not change from the 2004 EIS except for the following: NE Auburn/Robertson Properties Special Area Plan EIS Addendum November 2011 51 ESA • D Street between 49th Street and S 277th Street is proposed to be vacated since RPG owns most of the properties on both sides of the street; this corridor can better serve as an internal circulation aisle; and this street will no longer be a through street to the south where a cul-de-sac is proposed to eliminate an existing safety problem. RPG will work with others along the frontage to provide access via a private easement. • I Street NE will be phased so the north portion of the road (49th Street NE to S 277th Street) will only be constructed with the North Phase of site development. With these and other area wide improvements all intersections operate at or better than the levels forecast in the 2004 EIS. All intersections except for Auburn Way North/ S 277th Street (South Phase Office/ Retail Option only) are forecast operate at or above the City’s adopted LOS Standard (LOS D or better) under each phase or full-build-out development condition. Possible mitigation of this below standard condition can be met by constructing I Street as part of the South Phase Office Option, reduce the size or revise the sequence of development phasing of the South Phase Office/Retail Option, or employ a Transportation Demand Management Program (TDMP) to reduce trip making. In the event one or a combination of these options is not determined to be viable, the city has the authority to designate an intersections as categorically exempt from the level of service standard if the intersection has been expanded to the practical maximum that the benefits of increasing capacity are offset by other economic, environmental and/or public safety considerations. Similar to the 2004 FEIS, Table 11 also shows the percentage of development –generated trips at full development for the Retail and Office/Retail Options. However, note that in some cases percentages of project generated trips are not directly applicable to determining proportionate share of a project. In the case of the Site Access Signal, for example, the need for the signal would not exist had it not been for the development’s desire to have a signalized access. The signal serves no purpose on Auburn Way North otherwise and actually impedes regional traffic flow on Auburn Way North The methodology for estimating the development related portion of traffic volume associated with the Retail Only and Office/Retail Options is simply the ratio of the net new development-generated volumes (at full development) divided by the total 2020 volumes with full development. A more detailed description of the derivation and data sources for the ‘Development Trip Portion’ is provided in the TIA, Appendix D. NE Auburn/Robertson Properties Special Area Plan EIS Addendum 52 November 2011 ESA Table 11. Road Mitigation Summary Location 2004 EIS EIS Addendum 2020 Volumes PM Peak Hour Retail Only Option Office/Retail Option No-Build, Full road Network1 Retail Only Option (Office/Retail Option) 2 Development Trip Portion On Site or Adjacent to the Site I Street NE (S 277th to 49th Street NE) – 5 lane minor arterial w/auxiliary right- turn lanes Concurrent with Robertson Development Concurrent with North Phase or Full-build Development Concurrent with North Phase or Full-build Development 687 1,398 (1,670) 51% (59%) I Street NE (49th Street NE to 45th Street NE) – 5 lane minor arterial w/auxiliary right-turn lanes Concurrent with Robertson Development Concurrent with South Phase or Full-build Development Concurrent with South Phase or Full-build Development 599 1,087 (1,290) 45% (54%) 49th Street NE (I Street NE to Auburn Way N) – 3 lane minor arterial Concurrent with Robertson Development Concurrent with Initial Phase of Development Concurrent with Initial Phase of Development 189 562 (682) 66% (72%) S 277th Street (W boundary to E boundary) – 5 lane major arterial w/auxiliary right-turn lanes Concurrent with Robertson Development Concurrent with North Phase or Full-build Development Concurrent with North Phase or Full-build Development 3,324 3,798 (3,960) 12% (16%) S 277th Street (Auburn Way North to D Street) – widen to a 5 lane cross-section None Concurrent with South Phase or Full-build Development Concurrent with South Phase or Full-build Development 3,324 3,798 (3,960) 12% (16%) S 277th Street (D Street to L D Street) – widen to a 4 lane cross-section None Concurrent with South Phase or Full-build Development Concurrent with South Phase or Full-build Development 3,324 3,798 (3,960) 12% (16%) I Street NE at S 277th Street – Signalize w/dual westbound left-turn lane Concurrent with Robertson Development Concurrent with North Phase or Full-build Development Concurrent with North Phase or Full-build Development 3,746 4,672 (4,964) 20% (25%) I Street NE at 49th Street NE – (Roundabout or Signal) Concurrent with Robertson Development (when warrants are met) Roundabout with initial phase or signalization concurrent with Full Development (when warrants are met) Roundabout with initial phase or signalization concurrent with Full Development (when warrants are met) 710 1,403 (1,759) 49% (60%) 49th Street NE at Auburn Way N – Signalize Concurrent with Robertson Development Concurrent with Initial Phase of Development Concurrent with Initial Phase of Development 2,473 2,884 (2,952) 14% (16%) D Street 49th Street NE to S 277th Street – Three lane minor arterial Concurrent with Robertson Development Vacate Street concurrent with site development Vacate Street concurrent with site development 177 302 (292) 41 (39%) D Street 49th Street NE to Auburn Way North – 3 lane minor arterial Nothing Cul-de-sac southerly terminus at Auburn Way North Concurrent with initial phase of Development Cul-de-sac southerly terminus at Auburn Way North Concurrent with initial phase of Development 32 86 (66) 63% (51%) Site Access at Auburn Way N – Signal 3 If warranted When warranted after the 45th Street NE/ Auburn Way North signal is warranted When warranted after the 45th Street NE/ Auburn Way North signal is warranted 2,386 2,836 (2,985) 16% (20%) 1. No-Build Full Network Volumes represent the future without development conditions with the future road network complete (i.e. I Street NE extended between S 277th Street and 45th Street NE) 2. Retail (Office) represents the 2020 Full Build Retail Only and Office/Retail Volumes with a Signal at 45th Street NE/ Auburn Way NE conditions 3. This improvement includes 2020 Full Build Volumes with a signal at the South Phase site access NE Auburn/Robertson Properties Special Area Plan EIS Addendum November 2011 53 ESA Table 11. Road Mitigation Summary (Continued) Location 2004 EIS EIS Addendum 2020 Volumes PM Peak Hour Retail Only Option Office/Retail Option No-Build Full Street Network 1 Retail Only Option (Office/Retail Option) 2 Development Trip Portion Off Site Auburn Way N / S 277th Street (City of Auburn) - Add westbound right-turn lane Include in plans for widening S 277th Street between Auburn Way N and Green River. Concurrent with S 277th Street improvements under the North Phase and Full-Build conditions. Will likely require additional right of way. Concurrent with S 277th Street improvements under the North Phase and Full-Build conditions. Will likely require additional right of way. 5,409 5,988 (6,195) 10% (13%) Auburn Way N / 37th Street NE (City of Auburn) – Add southbound right- turn lane or eastbound right-turn lane Construct improvement. Contribute proportionate share when City includes it on its TIP and acquires right of way Contribute proportionate share when City includes it on its TIP and acquires right of way 3,890 4,111 (4,226) 5% (8%) Harvey Road NE / Eighth Street NE (City of Auburn) – Widen southeast- bound Harvey Road NE to two lanes. Include in City plans for widening Harvey Road NE. Included in City plans for widening Harvey Road NE. Share paid through Traffic Impact Fees. Included in City plans for widening Harvey Road NE. Share paid through Traffic Impact Fees. 5,036 5,137 (5,217) 2% (3%) Central Avenue / S 259th Street (City of Kent) – Add northbound right-turn lane Contribute proportional share. Contribute proportionate share when City includes it on its TIP and acquires right of way Contribute proportionate share when City includes it on its TIP and acquires right of way 4,279 4,442 (4,527) 4% (5%) S 277th Street / 55th Ave S (City of Kent/King County) – Change westbound S 277th Street to a dual left- turn lane and one through lane. Widen 55th Street with dual left turns. Contribute proportional share. Contribute proportionate share when City includes project on its TIP and acquires right of way Contribute proportionate share when City includes project on its TIP and acquires right of way 2,895 2,995 (3,049) 3% (5%) S 272nd Street / Military Road (City of Kent/King County) – Change north- south split signal phasing to conventional signal phasing. Change should be included in King County and City of Kent plans for intersection improvements. Change should be included in King County and City of Kent plans for intersection improvements. Change should be included in King County and City of Kent plans for intersection improvements. 4,028 4,079 (4,111) 1% (2%) SE 304th Street / 112th Avenue SE City of Auburn – Signalize and widen intersection to provide left-turn lanes. Contribute proportional share. Contribute proportionate share when City adds project on its TIP and acquires right of way Contribute proportionate share when City adds project on its TIP and acquires right of way 1559 1,678 (1,721) 7% (9%) 45th Street NE at Auburn Way North – Signalize when warranted Construct when warranted Construct when warranted Construct when warranted 2,475 2,837 (2,924) 13% (15%) 45th Street NE at I Street NE – Signalize when warranted Construct when warranted Construct when warranted Construct when warranted 626 1,188 (1,423) 47% (56%) 1. No-Build Full Network Volumes represent the future without development conditions with the future road network complete (i.e. I Street NE extended between S 277th Street and 45th Street NE) 2. Retail (Office) represents the 2020 Full Build Retail Only and Office/Retail Volumes with a Signal at 45th Street NE/ Auburn Way NE conditions 1. NE Auburn/Robertson Properties Special Area Plan EIS Addendum 54 November 2011 ESA Significant Unavoidable Adverse Impacts The revised road layout and the addition of Auburn Gateway II area would not result in significant unavoidable adverse impacts. Traffic impacts are expected to be equivalent to or less than what was described in the 2004 Draft EIS in most cases, and in no case are the increased impacts considered significant. As described in the 2004 Draft EIS, all of the development alternatives would result in additional traffic at several intersections that would operate at LOS F in the future. The DEIS and this addendum did not identify mitigation for three intersections at which the project would cause an increase in delay: South 277th Street/West Valley Highway, Central Avenue/Willis Street, and 116th Avenue SE/Kent-Kangley Road. These three intersections would operate at LOS F regardless of whether the proposed project is developed. NE Auburn/Robertson Properties Special Area Plan EIS Addendum November 2011 55 ESA Environmental Elements not Analyzed The following briefly discusses the reasons that additional analysis was not performed for other elements of the environment discussed in the EIS. Geology/Soils No change is expected for impacts related to geology and soils due to the development of Auburn Gateway II. There is no topographic break or obvious change in vegetation that would suggest a change in soils between Auburn Gateway I and Auburn Gateway II project areas. Air Quality No change is expected for impacts related to air quality due to the development of Auburn Gateway II. The analysis in the 2004 Draft EIS to determine maximum peak hour carbon monoxide concentrations by examining intersections that would be most affected by the project is still relevant. The development of Auburn Gateway II would not result in an increase in project-related trips because the same amount of retail and office square footage and residential units is proposed for the project as that evaluated in the 2004 EIS. There would be some changes in traffic circulation related to D Street NE and 49th Street NE. The change in traffic circulation is expected to reduce the volume of traffic at South 277th Street and Auburn Way North during the PM peak hour under Alternative 2, an intersection studied in the 2004 EIS for carbon monoxide concentrations. This change is a result of background traffic diverting to internal streets such as 49th Street NE and I Street NE. Under Alternative 2, traffic volumes are expected to be distributed over more intersections, reducing delay at Auburn Way North and South 277th Street and slightly increasing delay at minor intersections like 49th Street NE and Auburn Way North (Transportation Solutions, Inc., 2010). Less delay at the Auburn Way North and South 277th Street would likely result in less carbon monoxide concentrations during PM peak hour than shown in the 2004 EIS under Alternative 2. Noise No change is expected for impacts related to noise due to the development of Auburn Gateway II. Temporary construction noise associated with Auburn Gateway II would be more noticeable to noise-sensitive receivers along D Street NE. Operational noise from project-related traffic is not expected to noticeably change from what was described in the 2004 EIS. This is because development of Auburn Gateway II would not result in an increase in project-related trips since the same amount of retail and office square footage and residential units is proposed for the project as evaluated in the 2004 EIS. There would be some changes in traffic circulation related to D Street NE and 49th Street NE. The change in traffic circulation is not expected to increase impacts to noise sensitive receivers. Of the four noise study focus areas studied in the 2004 EIS, only residences along D Street NE would find project-related traffic to have noticeably increased noise levels. The proposed change in traffic circulation would not increase traffic volume along D Street any further than what was evaluated in the 2004 EIS. NE Auburn/Robertson Properties Special Area Plan EIS Addendum 56 November 2011 ESA Hazardous Materials No change is expected for impacts related to hazardous materials due to the development of Auburn Gateway II. A Phase I Site Assessment was conducted by Landau Associates, Inc. in 2007 to assess and document environmental conditions that may pose a potential liability to a prospective purchaser in the Auburn Gateway II project site area. The assessment revealed no evidence of recognized environmental conditions, as defined by American Society for Testing and Materials, in connection with the subject property. Recognized environmental conditions are defined as the presence or likely presence of any hazardous substances or petroleum products under conditions that indicate an existing release, a past release, or a material threat of a release of any hazardous substances or petroleum products into structures on the subject property or into the ground, groundwater, or surface water of the subject property. (Landau Associates, Inc., 2007). Cultural and Historic Resources No change is expected for impacts related to cultural and historic resources due to the development of Auburn Gateway II. The 2004 Draft EIS evaluated the planning area which includes the Auburn Gateway II site and the Auburn Gateway I site for the potential of discovering cultural and historic resources. The 2004 Draft EIS indicated that within the planning area, there is a high probability of hunter-fisher-gatherer, ethnographic period and historic Indian, and historic period archaeological resources. The probability estimates for the Auburn Gateway project area and the planning area were based on the availability of the Duwamish River – Green River floodplain for hunter- fisher-gatherer use, soils data that indicate old channels and low terrace deposits, prehistoric and historic period land use in similar environmental settings, and documented ethnographic and historic period land use in these two areas. Land Use No change is expected for impacts related to land uses due to the development of Auburn Gateway II if the same comprehensive plan and C4, Mixed Use Commercial zoning designations apply. Auburn Gateway II would be developed with retail, office and/or residential units, parking lots, and stormwater facilities similar to Auburn Gateway I. The same amount of retail, office, and/or residential development that was evaluated in the 2004 Draft EIS would be constructed but the development would be spread out into a larger geographic area. The private residences and commercial facility located south of the Auburn Gateway II project site would be affected by the change from a low-intensity setting with relatively quiet surroundings to commercial, office and/or residential activities, but the nature of the impact would be similar to those evaluated in the 2004 EIS. NE Auburn/Robertson Properties Special Area Plan EIS Addendum November 2011 57 ESA Recreation No change is expected for impacts related to recreation due to the development of Auburn Gateway II. The development of Auburn Gateway II would not affect the development of a Class I Trail along the south side of South 277th Street or the internal trail connections proposed as part of Auburn Gateway I and identified in the proposed Auburn Gateway Design Guidelines. The recreational demand as a result of retail, office, and/or residential development would be the same as what was evaluated in the 2004 Draft EIS since the project proposes the same amount of development evaluated in the 2004 EIS. Aesthetics No change is expected for impacts related to aesthetics due to the development of Auburn Gateway II if the applicant’s same architectural and site design standards apply. Auburn Gateway II would be developed in the same manner as Auburn Gateway I with retail, office, residential or mixed-use structures, surface parking lots, and stormwater facilities. The 2004 Final EIS estimated that 650,000 cubic yards of fill may be necessary to implement the Preferred Alternative. Based on the current site plan and addition of the Auburn Gateway II property, RPG is currently proposing to fill approximately 600,000 to 750,000 cubic yards for the Auburn Gateway I and II sites. Additional fill may raise the project even higher than the grades described in the 2004 EIS making the bulk and scale of the development more apparent. However, the Auburn Gateway Design Guidelines proposed in the 2004 Draft EIS together with the landscaping and other measures required by the Auburn City Code, include measures to mitigate the aesthetic impacts of the project that would be effective in addressing this additional impact. Utilities and Public Services No change is expected for impacts related to utilities, except storm drainage systems, and public services due to the development of Auburn Gateway II. The same amount of retail, office and/or residential development that was evaluated in the 2004 Draft EIS would be constructed but the development would be spread out into a larger geographic area. Therefore, the estimate for domestic water consumption and wastewater production associated with development in the 2004 Draft EIS is still accurate. . In order to ensure orderly and efficient extensions of public utilities consistent with the proposed phasing and city regulations, a master plan is to be provided prior to construction authorizations. The fiscal impact analysis associated with fire, emergency medical, and police service is also still applicable. NE Auburn/Robertson Properties Special Area Plan EIS Addendum 58 November 2011 ESA REFERENCES Almack, J.A. and S.H. Fitkin. 1998. Grizzly Bear and Gray Wolf Investigations in Washington State 1994-1995: Final Progress Report. Washington State Department of Fish and Wildlife. Olympia, Washington. City of Auburn. 2008. 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Olympia, Washington. May 1991. Wessels, Ralph. 2003. Personal communications (telephone conversations with Erich Hester, Herrera Environmental Consultants, Inc., Seattle, Washington, regarding timing and other parameters of a wetland mitigation project in the floodplain of the Green River.) Third Runway Project Manager. Port of Seattle. April 1 and 8, 2003.