HomeMy WebLinkAbout02-15-2023 Agenda (2)HEARING EXAMINER
AGENDA
February 15, 2023
5:30 P.M.
City Council Chambers
25 West Main Street
I.PUBLIC PARTICIPATION
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II.CASE NO:SHL20-0008 – Coal Creek Springs Transmission Main Replacement
Project
APPLICANT: City of Auburn, Public Works Department
Seth Wickstrom, PE, Project Engineer
25 West Main Street
Auburn, WA 98001
PROPERTY OWNER(S): City of Auburn Parks, Arts, and Recreation Department
Thaniel Gouk, Parks Planning & Development Manager
25 West Main Street
Auburn, WA 98001
King County Water and Land Resources Division
River and Floodplain Management Section
Josh Baldi, Director
201 S Jackson Street, Suite 600
Seattle, WA 98104
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Hearing Examiner Agenda
February 15, 2023
5:30 p.m.
2
REQUEST: Request for Shoreline Conditional Use Permit and Shoreline Substantial
Development Permit to construct an approx. 210-foot-long pedestrian
bridge and water transmission main over the White River.
PROJECT LOCATION: The pedestrian bridge and water main construction project site (the Project
Site) is located at river banks of Game Farm Park (3030 R St. SE) and the
Game Farm Wilderness Park (2401 Stuck River Dr.) in Auburn, WA, King
Co. Parcel No. 2921059069, along River Mile 8.5 of the White River. The
off-site mitigation site for the LWM placement will be located at River Mile
9.3, approximately 0.88 miles (4,634 feet) northeast (upstream) of the
bridge construction site.
PARCEL NO(S): King County Assessor Parcel No. 2821059007
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AGENDA BILL APPROVAL FORM
HEARING EXAMINER
Agenda Subject/Title:
Coal Creek Springs Transmission
Main Replacement Project
City File No. SHL20-0008
Shoreline Conditional Use Permit
Shoreline Substantial Dev. Permit
Date:
February 2, 2023
Department:
Community Development
DESCRIPTION:
Request for Shoreline Conditional Use Permit and Shoreline Substantial Development Permit
to construct an approx. 210-foot-long pedestrian bridge and water transmission main over the
White River.
ADMINISTRATIVE RECOMMENDATION:
Hearing Examiner to conduct a public hearing and approve the Shoreline Conditional Use
Permit and Shoreline Substantial Development Permit.
PROJECT SUMMARY:
The applicant seeks to conduct site preparation and install an approximately 210-foot-long
pedestrian bridge and water transmission main over the White River. The 24-inch-diameter
water transmission main will be installed below and attached to the bridge. The purpose of the
24-inch water main will to be convey water from the off-site location of the City of Auburn’s Coal
Creek Springs to the City’s off-site storage reservoirs and water system on the north side of the
White River. In addition to the water transmission main a 12-inch-diameter pipe for potential
future water service and two (2” and 3” respectively) utility conduits for potential future dry
utilities will also be installed under the bridge. The bridge will provide a pedestrian linkage
between two city-owned parks; Game Farm Park and Game Farm Wilderness Park, which are a
single parcel divided by the White River. The bridge will be accessed by approx. 340 lineal feet
of new 10-foot wide paved trails which will connect existing trails within each park. Trees felled
for the project will be salvaged and placed off-site and upstream in a riverbank area as large
woody material (LWM) for future wood recruitment in the White River.
LOCATION:
The pedestrian bridge and water main construction project site (the Project Site) is located at
river banks of Game Farm Park (3030 R St. SE) and the Game Farm Wilderness Park (2401
Stuck River Dr.) in Auburn, WA, King Co. Parcel No. 2921059069, along River Mile 8.5 of the
White River. The off-site mitigation site for the LWM placement will be located at River Mile 9.3,
approximately 0.88 miles (4,634 feet) northeast (upstream) of the bridge construction site, King
Co. Parcel No. 2821059007.
APPLICANT:
City of Auburn, Public Works Department, Seth Wickstrom, PE, Project Engineer, 25 W Main
St., Auburn, WA 98001
EXHIBIT 1
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APPLICANT’S REPRESENTATIVE:
Jacobs Engineering Group, Scott Swarts, Senior Biologist, 1110 112th Ave. NE, Suite 500,
Bellevue, WA 98004
PROPERTY OWNERS:
City of Auburn Parks, Arts, and Recreation Department, Thaniel Gouk, Parks Planning &
Development Manager, 25 W Main St., Auburn, WA 98001 (Game Farm Park and Game Farm
Wilderness Park)
King County Water and Land Resources Division, River and Floodplain Management Section,
Josh Baldi, Director, 201 S Jackson St., Suite 600, Seattle, WA 98104 (LWM mitigation site)
Vicinity Map
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Bridge Construction/Utility Project Site Location
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Large Woody Materials Placement (LWM) (Mitigation Site) Location
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Combined Project Site and LWM Mitigation Site Location
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2021 City of Auburn Aerial Image (Project Site)
The Comprehensive Plan designation, Shoreline environment designation, zoning classification
and current land uses of the site and surrounding properties of the Project Site are:
Comprehensive
Land Use
Designation
Zoning Classification Shoreline
Environment
Designation
Current
Land Use
Project
Site
Institutional Institutional Urban
Conservancy
City Park
North Single Family R-7 Residential N/A Single Family
Residences
East Multiple-Family
Open Space
UNC Unclassified Use District
R-MHC Residential
Manufactured/Mobile Home
Community
N/A Vacant
South Single Family
Open Space
R-7 Residential
Open Space
N/A Vacant
West Single Family
Multiple-Family
R-7 Residential
R-20 Residential
Open Space
N/A Single Family
Residences
Apartment
Complexes
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The Comprehensive Plan designation, Shoreline environment designation, zoning classification
and current land uses of the site and surrounding properties of the LWM mitigation site are:
Comprehensive
Land Use
Designation
Zoning Classification Shoreline
Environment
Designation
Current Land Use
LWM
mitigation
site
Residential
Conservancy
Residential Conservancy Natural Vacant
North Open Space Residential Conservancy N/A Vacant (River)
Mobile/Manufactured
Home Park
East Residential
Conservancy
Open Space
Residential Conservancy N/A Vacant
South Residential
Conservancy
Single Family
Unclassified Use District N/A Vacant (River)
West Open Space
Multiple-Family
UNC Unclassified Use District
R-MHC Residential
Manufactured/Mobile Home
Community
N/A Vacant
Excerpted Comprehensive Plan Land Use Designation Map (Project Site)
Project Site
Single Family
Open Space
Multiple
Family
Institutional
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Excerpted Zoning Classification Map (Project Site)
Excerpted Shoreline Environment Designations (Project Site)
Project Site
R-MHC
UNC
R-7
R-20
Open Space
Project Site
I, Institutional
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Excerpted Shoreline Environment Designations (LWM mitigation site)
SEPA STATUS:
A combined Notice of Application (NOA) and Determination of Non-Significance (DNS) was
issued under City File No. SEP20-0015 on October 21, 2020. The comment period ended
November 5, 2020 the appeal period ended November 19, 2020. Comments received during the
NOA and SEPA public comment period are provided in Exhibit 15. No appeal of the SEPA
decision was received. An SEPA Addendum to the previously issued DNS was issued on to
incorporate the LWM mitigation site. The Addendum was issued on July 13, 2022. A copy of the
Notice of Application (NOA) and Determination of Non-Significance (DNS), issued October 21,
2020 is provided in Exhibit 14. A copy of the SEPA Environmental Checklist, prepared by the
City of Auburn, is included as Exhibit 13. A copy of the SEPA Addendum issued July 13, 2022 is
also provided in Exhibit 14.
FINDINGS OF FACT:
Project Information and Site Characteristics
1. Seth Wickstrom, PE, Applicant, as representative of the City of Auburn Public Works
Department applied on August 18, 2020 for a Shoreline Conditional Use Permit (SCUP)
and Shoreline Substantial Development Permit (SSDP), to install an approx. 210-foot-
long and 12 ft. wide pedestrian bridge (referenced herein as pedestrian bridge) and 24-
inch-diameter water transmission main (referenced herein as water main), collectively
referenced as the “Project”, across the White River at the Project Site located within
Game Farm Park (3030 R St. SE) and the Game Farm Wilderness Park (2401 Stuck
LWM mitigation site
Natural
Urban Conservancy
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River Dr.) in Auburn, WA, King Co. Parcel No. 2921059069, along River Mile 8.5 of the
White River.
2. The main purpose of the Project is to functionally replace an existing water main that
currently exists under the White River. While the existing water main will remain in place,
it will no longer serve as the primary source of water; it will serve as back up to a new
water main. The existing water main is located within a water easement (Recording No.
2095456). The new pedestrian bridge and water main will be located within this existing
water easement. The bridge crossing will provide the added benefit of improved
recreation access between Game Farm Park and the Game Farm Wilderness Park, as
well as additional dry utility conduits and a 12-inch-diameter pipe for potential future
utility expansion to minimize future impacts to the White River.
3. Alternative design proposals to the current project proposal are contained in the
Alternatives Summary Report, Jacobs, dated June 11, 2021, and is provided in Exhibit 9.
This report was prepared in response to concerns raised about the Project by the
Muckleshoot Indian Tribe (MIT), and the Washington Department of Fish and Wildlife
WDFW), and addresses questions raised about alternative design approaches that
have been considered.
4. Per Chapter 16.10 of the Auburn City Code (ACC) the White River is classified as a
Type “S” stream and is identified as “shorelines of the state” under Chapter 90.58 RCW
and the City of Auburn Shoreline Master Program (SMP). The shoreline jurisdiction of
the While River extends 200 feet from the Ordinary High Water Mark (OHWM). The 200
feet of shoreline jurisdiction are categorized into three environment designations for the
White River: “Natural”, “Urban Conservancy”, and “Shoreline Residential”. As outlined in
SMP 4.5, Table 1 “Permitted Uses” the minimum setback from the OHWM is 100 feet in
the “Urban Conservancy” shoreline environment designation and is 200 feet in the
Natural” shoreline environment designation. Since the river is also a regulated critical
area by the City, these setbacks function as a shoreline buffer to provide riparian habitat
and protect water quality. The Project Site will occur within 200 ft. of the White River
shoreline jurisdiction, specifically the “Urban Conservancy” shoreline environment
designation, and within the 100 ft. shoreline buffer. The LWM mitigation site is also
within 200 ft. of the White River shoreline jurisdiction, specifically the “Natural” shoreline
environment designation, and within the 100 ft. shoreline buffer.
5. The bridge is comprised of three components: bridge foundations, bridge superstructure,
and deck. Bridge foundations will consist of a concrete abutment supported on a single
4-foot-diameter concrete drilled shaft on either side of the White River. The concrete
abutments would be about 14 feet by 5 feet and would extend about 11 feet (abutment
1) and 8 feet (abutment 2) above the ground surface. The bridge superstructure will sit
on top of the abutments. The 210-foot-long bridge superstructure would be delivered to
the site in multiple (4 or 5) pieces and be spliced together with high-strength bolts.
Heavy lift cranes would lift the superstructure over the White River and place it on top of
the bridge abutments. Fiber-reinforced polymer deck panels, serving as the pedestrian
path of the bridge, will be installed after the bridge superstructure is in place. The bridge
footings will be placed outside of the OHWM and 100-year base flood elevation on both
sides of the White River. After the bridge is installed, the utility lines will be attached to
the underside of the bridge superstructure via steel hangers. The tie-in to the existing
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water main will be installed through trenching on either side of the river. Trenches will be
set back from the OHWM and 100-year base flood elevation. Utility lines attached to the
bridge would consist of the 24-inch-diameter water transmission main as well as a 12-
inch-diameter future water supply line and two conduits to allow for future utility
installations. No work will occur below the OHWM. No in-water work is proposed.
6. Per the Critical Areas Report and Habitat Impact Assessment, Jacobs, revision dated
May 26, 2022 (Exhibit 7), a total of 33 trees (with a diameter at breast height (DBH) of
six inches and over) that need to be removed to create construction access. The
removed trees will be placed at a nearby off-site, large woody material (LWM) mitigation
site. The LWM will provide for future wood recruitment for fish habitat. The off-site
location was selected due to its easy access and proximity to the Project Site. The LWM
will be transported from the Project Site to the LWM mitigation site via an existing gravel
road (Stuck River Drive and unnamed access road) that is approximately 2,405 feet long
and 18 feet wide. Large woody material at the mitigation site will occupy approx.100
square feet (5 cubic yards) below the OHWM. Above the OHWM and below the 100-
year base flood elevation, the LWM will occupy approx. 540 square feet (35 cubic
yards).
7. New trails will be installed on either side of the new bridge to provide pedestrian access
from existing park trails to the new pedestrian bridge. About 340 linear feet of new 10-
foot-wide, ADA-compliant paved trails would be constructed and is shown on the Civil
Plans, City of Auburn, revision dated January 23, 2023 (Exhibit 6). Most of the trails will
be constructed with 2 inches of hot mix asphalt over 4 inches of crushed surfacing top
course. The new trails will be outside of the 100-year special flood hazard area and
above the OHWM of the White River.
8. Game Farm Park is a City-owned park containing 53-acres of park plus 86.17 acres of
open space, is zoned I, Institutional, and has a land use designation of “Institutional”.
Game Farm Park is one of the largest and most frequently used community parks in
Auburn. The park contains a wide variety of facilities for organized sports, activities,
special community events, and trails. Game Farm Park is bordered by single family
residences and Riverwalk Dr. SE to the north, the White River to the east, Game Farm
Wilderness Park to the south, and R St. SE, single family residences, and apartments to
the west.
9. Game Farm Wilderness Park is a 10-acre City owned park, is zoned I, Institutional, and
has a land use designation of “Institutional”. The park features limited development and
has preserved most of the native woodland along the south side of the White River. The
park is designed for both overnight and daytime visitors and contains a group camping
area is designed to accommodate recreation vehicles, providing each unit with water
and power hook-ups. Game Farm Wilderness Park is bordered by the White River to the
north and east and vacant land to the east and south.
10. Per ACC 18.35.020(D) the I Institutional Zone "is intended to provide an area wherein
educational, governmental, theological, recreational, cultural and other public and quasi-
public uses may be allowed to develop. It is further intended these areas be significant in
scope which will allow a combination of uses which may not be permitted outright within
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other zones. This district is not intended to include those smaller or singular public uses
which are consistent with and permitted in other zones."
11. The Land Use Element states that the “Institutional” Land Use Designation “includes
those areas that are reserved for public or institutional uses. These public uses include
public schools and institutional uses such as large churches and schools. It is also
intended to include those of a significant impact, and not those smaller public uses that
are consistent with and may be included in another designation. For example, public
uses of an industrial character are included in the industrial designation, and small-scale
religious institutions of a residential character are included in the residential designation.”
12. Per Critical Areas Report and Habitat Impact Assessment (Exhibit 7), partial park
closures will occur after May 31 and all park areas will be reopened in the Fall , following
completion of the project (this is dependent on no construction schedule change).
Construction will take approximately four months to complete. Construction work will be
coordinated with the City’s Parks Department to minimize impacts to park operations,
events, and programs. The northeast corner of Game Farm Park will require closure
during construction, including the eastern end of the parking lot, the amphitheater, one
large picnic shelter (during weekday work hours), and adjacent pathways. Construction
access will be along existing park pathways from the end of the parking lot at the
turnaround. All existing game fields and restroom facilities will not be impacted by
construction. Game Farm Wilderness Park, will require closure of a portion of the White
River Trail at the north end, for the duration of construction. Several existing holes on the
disc golf course will require temporary relocation and one will be permanently relocated.
Construction access would be from the existing day-use parking lot. The existing
pathway from the parking lot to the White River Trail will be closed and a pedestrian
detour would be established for access to the existing trail and disc golf course. The
existing overnight camping area will not be impacted by construction, outside of noise
during construction hours.
13. A Cultural Resources Report, Jacobs, dated April 2022 (Exhibit 8) was prepared in
compliance with Section 106 of the Nation Historic Preservation Act (NHPA). Section
106 of the NHPA requires federal agencies to consider the effects of their undertakings
on historic properties. Historic properties may be any district, site, building, structure, or
object that is listed in, or eligible for listing in, the National Register of Historic Place
NRHP). Undertakings are characterized as "any project, activity, or program funded in
whole or in part under the direct or indirect jurisdiction of a federal agency, including
those carried out by, or on behalf of, a federal agency; those carried out with federal
financial assistance; and those requiring a federal permit, license, or approval." Since
the City has secured two federal loans for the Project through the Washington State
Department of Health and from the U.S. Environmental Protection Agency’s Drinking
Water State Revolving Fund, compliance with Section 106 of the NHPA is required.
Geotechnical investigations, encompassing all areas of indirect and direct impacts,
occurred within the proposed “area of potential effects” (APE). The “original” APE
established in 2017), extended west from the center line of the White River to the
Auburn Game Farm Park parking lot and east from the center line of the White River to
the camping parking lot associated with the Game Farm Wilderness Park, and was
approximately 9.5 acres. The original APE was then expanded (known as the APE
expansion area) based on the altered Project design associated with construction of the
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pedestrian bridge over the White River. The APE expansion area included an extension
to the south in Auburn Game Farm Park west of White River and totals approximately 9
acres. The original APE and APE expansion area are shown in Figure 1 of the Cultural
Resources Report. As documented in the Report, no archaeological resources have
been identified within the APE expansion area and there is little potential for
archaeological resources to be encountered during continued activities associated with
this Project. In the event of a discovery an immediate work stoppage in the vicinity of the
find, and the Inadvertent Discovery Plan (IDP), Appendix F of the Cultural Resource
Report, must be followed. The IDP outlines procedures to follow, in accordance with
state and federal laws, if archaeological materials or human remains are discovered.
Critical Areas
14. Per the Critical Areas Report and Habitat Impact Assessment (Exhibit 7), in addition to
occurring within 200 ft. of the White River shoreline and within 100 ft. shoreline buffer,
the Project Site overlaps other regulated critical area per Chapter 16.10 ACC. These
include critical and tertiary wildlife habitat areas, aquifer recharge areas, geologically
hazardous areas, and the special flood hazard area (100-year floodplain) and associated
protected areas (floodway, riparian buffer zone, and channel migration zone). The
Report concluded that there are no wetlands or associated buffers on the Project Site or
the LWM mitigation site.
15. Per the Critical Areas Report and Habitat Impact Assessment (Exhibit 7), as a Type S
stream, the White River is as a migratory corridor for ESA-listed and state-listed
salmonids including Bull Trout (Salvelinus confluentus), Chinook Salmon (Oncorhynchus
tshawytscha), Steelhead Trout (Oncorhynchus mykiss), and Pacific Salmon essential
fish habitat (EFH). Therefore, the Project Site contains critical habitat for the above
referenced state-listed salmonids. The terrestrial areas upland of the White River,
consisting of both park landscapes and riparian forest, within both Game Farm Park and
Game Farm Wilderness Park likely contains tertiary wildlife habitat.
16. Per ACC 15.68.440, an application for development within the Special Flood Hazard
Area must include an assessment of the impact of the project on federal, state or locally
protected species and habitat, water quality and aquatic and riparian habitat.
The assessment must determine if the project would adversely affect:
1. Species that are federal, state or local listed as threatened or endangered.
2. The primary constituent elements for critical habitat when delineated, including but
not limited to water quality, water quantity, flood volumes, flood velocities, spawning
substrate, and/or floodplain refugia for listed salmonids.
3. Essential fish habitat designated by the National Marine Fisheries Service.
4. Fish and wildlife habitat conservation areas.
5. Other protected areas and elements necessary for species conservation.”
17. The Critical Areas Report and Habitat Impact Assessment (Exhibit 7) finds that the ESA-
listed salmonids may be affected because of the following:
The new bridge will be a permanent crossing above salmonid habitat in the
White River.
All three species could be using in-stream portions of the floodplain both during
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construction and long-term during operation.
Temporary vegetation clearing within the floodplain includes an alder and a black
cottonwood tree on the right (northwest) bank and two cottonwoods on the left
southeast) bank.”
However, the ESA-listed salmonids are not likely to be adversely affected because:
There will be no in-water work.
There will be no fill in the floodplain (footings will be wholly outside the
floodplain).
The Project will use BMPs from the TESC plan and SWPPP to minimize and
control sediment and stormwater inputs during construction.
The temporarily cleared vegetation in the regulatory floodplain will be mitigated
through native mitigation plantings, including replacement of removed trees at a
4:1 ratio.
Potential impact of cleared vegetation on LWM recruitment and organic inputs is
discountable due to scale and duration of the effect.”
Further, the Project will have no effect on the critical habitat for ESA-listed salmonids,
and will have no adverse effect on the Pacific Salmon EFH for the reasons provided for
the ESA-listed salmonids.
18. Per ACC 16.10.080(E)(1) critical habitat “are those habitat areas which meet any of the
following criteria:
a. The documented presence of species or habitat listed by federal or state
agencies as “endangered,” “threatened,” or “sensitive”; or
b. The presence of unusual nesting or resting sites such as heron rookeries;
c. Category I wetlands, as defined in these regulations; or
d. Type S streams, as defined in these regulations.”
19. Per ACC 16.10.080(E)(3) “tertiary habitat is habitat which is not classified as critical or
secondary. It is habitat which, while supporting some wildlife and performing other
valuable functions, does not currently possess essential characteristics necessary to
support diverse wildlife communities. Tertiary habitat also includes habitat which has
been created purposefully by human actions to serve other or multiple purposes, such
as open space areas, landscape amenities, and detention facilities.”
20. All proposed pedestrian bridge features will be located above the 100-year base flood
elevation/floodway as indicated on the current FEMA Flood Insurance Rate Map (FIRM)
and associated Flood Insurance Study (FIS). At least four feet of freeboard between the
bottom of the bridge and the 100-year base flood elevation will be provided. The bottom
of the water main will be at least four feet above the 100-year base flood elevation as
well.
21. Per the LWM Mitigation Hydraulic Analysis, Jacobs, dated June 17, 2022 (Exhibit 12),
the White River does not have an official FEMA mapped floodplain or an effective Base
Flood Elevation (BFE) at the LWM mitigation site. The latest Flood Insurance Study
FIS) commissioned by King County for the White River was used for the no-rise
analysis. Large woody material at the mitigation site will occupy 100 square feet (5 cubic
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yards) below the OHWM. Above the OHWM and below the 100-year base flood
elevation, the LWM will occupy approx. 540 square feet (35 cubic yards). This is shown
on the Civil Plans (Exhibit 6). However, LWM placement will not raise the elevation of
the 100-year base flood elevation. Staging for the mitigation site will be placed outside of
the OHWM and 100-year base flood elevation.
22. A Channel Migration Zone (CMZ) has not been defined on the White River. Per ACC
15.68.150(D) when channel migration zone data is not available a permit applicant shall
either:
1. Designate the entire SFHA as the channel migration zone; or
2. Identify the channel migration area in accordance with Regional Guidance for
Hydrologic and Hydraulic Studies in Support of the Model Ordinance for Floodplain
Management under the National Flood Insurance Program and the Endangered Species
Act, FEMA, Region X, 2010.
For the scope of this Project the special flood hazard area is defined as the 100-year
floodway. The proposed bridge piers will be located landward of the 100-year floodway
and therefore will also be located outside of the coincident CMZ.
23. Per the Critical Areas Report and Habitat Impact Assessment (Exhibit 7), the areas
adjacent to the White River are either developed as managed landscaping of park
facilities or dominated by non-native invasive plants. Therefore, the Riparian Buffer Zone
RBZ) at the Project site is limited to the redelineated OHWM and 100-year base flood
elevation. The RBZ is an element of the FEMA floodplain regulations for the purpose of
evaluating effects on endangered species.
24. Per ACC 15.68.100(G) base flood “means the flood having a one percent chance of
being equaled or exceeded in any given year (also referred to as the “100-year flood”).”
25. Per ACC 15.68.100(H) “base flood elevation [BFE] means the elevation to which
floodwater is anticipated to rise during the base flood.”
26. Per ACC 15.68.100(K) channel migration zone (CMZ) “means the area within the lateral
extent of likely stream channel movement due to stream bank destabilization and
erosion, rapid stream incision, aggradation, avulsions, and shifts in location of stream
channels.”
27. Per ACC 15.68.100(Z) floodway “means the channel of a river or other watercourse and
the adjacent land areas that must be reserved in order to discharge the base flood
without cumulatively increasing the water surface elevation more than a designated
height.”
28. Per ACC 15.68.100(SS) riparian buffer zone [RBZ] “means the land located adjacent to
streams, and other bodies of water, where the natural soil, hydrology, and native flora
and fauna perform important ecological functions such as protecting the water body by
filtering out pollutants, preventing erosion and sedimentation, stabilizing stream banks,
and providing natural shade. They are often thin lines of green containing native
grasses, flowers, shrubs and trees that line the banks of streams and other bodies of
water. The riparian buffer zone for the Puget Sound biological opinion applies only to
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areas mapped within the Special Flood Hazard Area, unless the area is undeveloped
with predominately native vegetation that has benefits to endangered species, in which
case the regulations for riparian habitat zones shall apply.”
29. Per ACC 15.68.100(TT) riparian habitat zone “means the water body and adjacent land
areas that are likely to support aquatic and riparian habitat.”
30. Per ACC 15.68.100(UU) special flood hazard area (SFHA) “means the land subject to
inundation by the base flood. Special flood hazard areas are designated on Flood
Insurance Rate Maps with the letters “A” or “V” including AE (floodway), AO, AH, A1-99
and VE. The Special Flood Hazard Area is also referred to as the area of special flood
hazard or SFHA.”
31. The Project Site and the LMW mitigation site are within the within the City’s wellhead
protection regulated critical areas based on 5- or 10-year time of travel and therefore
include Type 1 aquifer recharge areas (reference the Critical Areas Report and Habitat
Impact Assessment (Exhibit 7).
32. Per 16.10.020 aquifer recharge area “means areas with a critical recharging effect on
aquifers used for potable water, including areas where an aquifer that is a source of
drinking water is vulnerable to contamination that would affect the potability of the water,
or is susceptible to reduced recharge.”
33. Per 16.10.080(F) aquifer recharge areas categorized as either Type I or Type II and are
defined below:
1. Type I.
a. Sole source aquifers and wellhead protection areas designated pursuant to the
Federal Safe Drinking Water Act.
b. Areas established for special protection pursuant to a groundwater management
program as described by Chapters 90.44, 90.48 and 90.54 RCW and Chapters
173-100 and 173-200 WAC.
c. Any other area meeting the definition of “areas with a critical recharging effect on
aquifers used for potable water” as described in Chapter 365-190 WAC and the
Auburn comprehensive plan, including groundwater protection areas Nos. 1
through 3 as designated in the “Water Resource Protection Report” prepared for
the city by the Pacific Groundwater Group, December 2000.
2. Type II.
a. Groundwater protection area No. 4 as designated in the “Water Resource
Protection Report” prepared for the city by the Pacific Groundwater Group,
December 2000.
b. Any other area within the city that is not otherwise designated or that is added to
the city via annexation shall be treated as a Type II aquifer recharge area.”
34. The City's GIS mapping system identifies that both sides of the river (within Game Farm
Park and Game Farm Wilderness Park) are erosion-prone regulated critical areas. As
provided in the Geotechnical Engineering Report, Wood, dated October 21, 2020
Exhibit 10) the U.S. Department of Agriculture Natural Resource conservation Service
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NRCS) mapping system, soils of the west river bank of the White River (within Game
Farm Park) consist of “Urban Land”, are described as gravelly sandy loam to gravelly
loam in texture (Ur), and are steeper than 15%. The riverbank erosion risk, however, has
been mitigated by the diversion wall reconstruction, which included concrete armoring at
depth, and armoring the slope surface with large riprap. Per NRCS mapping system,
soils on the east side of the river (within Game Farm Wilderness Park) are mapped as
Mixed Alluvial Land and are described as varying from sand and gravelly sand to silty
clay loam in texture (Ma). The slopes are inclined steeper than 15 percent and vegetated
with conifer trees. The City’s GIS mapping system, does not identify the Project Site to
be within any landslide hazard areas. No buffer or setback from the steep slope areas
will be observed. The bridge abutments will be located on the sloping east and west
riverbank areas. The mitigation measures are proposed to eliminate or reduce the risk
include: temporary erosion and sedimentation control, temporary sloping/shoring, and
restoration of the site (revegetation of disturbed areas and restoration of riprap armoring
of the riverbank).
35. Per the Critical Areas Report and Habitat Impact Assessment (Exhibit 7), King County
iMap website maps the LWM mitigation site as located within an erosion hazard zone.
No ground disturbing work will occur within this area.
36. Per ACC 16.10.020 erosion hazard areas “means ands or areas that, based on a
combination of slope inclination and the characteristics of the underlying soils, are
susceptible to varying degrees of risk of erosion. Erosion hazard areas are classified as
low” (areas sloping less than 15 percent) or “high” (areas sloping 15 percent or more)
on the following Soil Conservation Service (SCS), now known as the Natural Resources
Conservation Service (NRCS), soil types: Alderwood-Kitsap (AkF), Alderwood gravelly
sandy loam (AgD), Kitsap silt loam (KpD), Everett (EvD) and Indianola (InD). Additional
soil groups may be identified through site-specific analysis.”
37. Per ACC 16.10.020 landslide hazard areas mean “areas that, due to a combination of
slope inclination, relative soil permeability, and hydrologic conditions are susceptible to
varying degrees of risk of landsliding. Landslide hazard areas are classified as Classes I
through IV based on the degree of risk as follows:
1. Class I/Low Hazard. Areas with slopes of 15 percent or less.
2. Class II/Moderate Hazard. Areas with slopes of between 15 percent and 40
percent and that are underlain by soils that consist largely of sand, gravel or
glacial till.
3. Class III/High Hazard. Areas with slopes between 15 percent and 40 percent
that are underlain by soils consisting largely of silt and clay.
4. Class IV/Very High Hazard. Areas with slopes steeper than 15 percent with
identifiable zones of emergent water (e.g., springs or groundwater seepage),
areas of identifiable landslide deposits regardless of slope and all areas sloping
more steeply than 40 percent.
The slopes referenced above include only those where the surface drops 10 feet
or more vertically within a horizontal distance of 25 feet.”
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38. As provided in the Critical Areas Report and Habitat Impact Assessment (Exhibit 7),
disturbed riparian forest areas will be restored to conditions better than pre-construction
through the removal of invasive plants and establishment of native vegetation.
Approximately 16,586 square feet of riparian restoration is proposed. To accommodate
the pedestrian trail and bridge, some riparian forest will be permanently impacted (loss).
To compensate loss of the riparian forest, areas of existing degraded riparian forest that
are outside of and adjacent to the construction limits will be enhanced (riparian
enhancement). Approximately 5,000 square feet of riparian enhancement is proposed.
This enhancement provides on-site and in-kind mitigation; the preferred mitigation under
ACC 16.10.120 and Section 4.4.3 of the SMP. The Project will enhance the riparian
forest area equivalent to the amount of area permanently impacted. Native trees
removed by the Project will be replaced at a 4:1 ratio (per WDFW standards) on-site, as
close to the river as appropriate site conditions and available spacing will allow.
Mitigation for the riparian forest disturbance will fulfill the requirement of no net loss of
the ecological functions and ecosystem-wide processes performed by vegetation (per
SMP policy 4.4.2 related to shoreline vegetation conservation). The riparian
enhancement and restoration areas will be monitored biannually for five years to
evaluate the mitigation project and to determine necessary corrective actions to ensure
success. Maintenance of the enhancement/restoration site will be the responsibility of
City of Auburn Public Work Department. Disturbed park landscapes will be restored to
conditions similar to pre-construction with similar vegetation and will be conducted in
coordination with of the City’s Parks Department.
Shoreline Management Program
39. The City of Auburn currently uses its 2020 City of Auburn Shoreline Master Program
SMP) to regulate development and management of the City’s shoreline. Because the
proposal involves the construction of a pedestrian bridge and water main across the
White River within the “Urban Conservancy” shoreline environment designation, a
Shoreline Conditional Use Permit (SCUP) and Shoreline Substantial Development
Permit (SSDP) are required. Per SMP 4.5, Table 1 “Permitted Uses”, primary utilities
such as transmission facilities, of which the water main is considered, are a conditional
use within the “Urban Conservancy” shoreline environment designation. Per SMP 4.5,
Table 1 “Permitted Uses” bridges and paved trails are permitted within the “Urban
Conservancy” shoreline environment designation. A SSDP is required for the bridge
because it is not exempt per WAC 173-27-040.
40. Since the Project Site is within 200 feet of the OHWM along the White River it is within
the “Urban Conservancy” shoreline environment designation and thus, is within the
jurisdiction of the Auburn Shoreline Master Program (SMP 4.2.A). As mentioned
previously, the Project is not exempt and requires a SCUP and SSDP. The language of
this Section provides:
4.2 Applicability.
1. The provisions of this chapter shall apply to all shorelines, shorelands and
associated wetland areas covered by the Shoreline Management Act of
1971 as follows:
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1. All rivers and streams and their associated wetlands downstream
from a point where the mean annual flow is 20 cubic feet per second
or greater.
2. All lakes and their associated wetlands which are 20 surface acres
in size or larger.
3. Shorelands and associated uplands extending 200 feet in all directions
as measured on a horizontal plane from the ordinary high water mark;
floodways and contiguous floodplain areas landward two hundred feet
from such floodways; and all wetlands and river deltas associated with
their streams, lakes, and tidal waters subject to the provisions of Chapter
90.58 RCW.”
41. Per the SMP 4.5, Table 1 “Permitted Uses”, "shoreline habitat and natural systems
enhancement projects" are permitted within the “Natural” shoreline environment
designation. The placement of large woody material (LWM) at the LWM migration site is
considered an “enhancement project” (for fish habitat) and therefore does not require an
SSDP per WAC 173-27-040(o)(i)(C):
A project primarily designed to improve fish and wildlife habitat, remove or
reduce impediments to migration of fish, or enhance the fishery resource
available for use by all of the citizens of the state, provided that any structure,
other than a bridge or culvert or instream habitat enhancement structure
associated with the project, is less than two hundred square feet in floor area and
is located above the ordinary high water mark of the stream.”
42. The applicant provided a Written Statement and Legal Description complying with
requirements (J) and (H) of the City’s SCUP Application – Submittal Checklist and the
SSDP Application – Submittal Checklist. Note that both Submittal Checklists require the
same materials. A copy of the Written Statement and Legal Description is provided as
Exhibit 4. The applicant also provided a Policy Memo which explains how the project is
consistent with the policies and provisions of the SMP. A copy of the Policy Memo is
provided as Exhibit 5.
43. Under the State Shoreline Management Act (SMA), all development occurring within the
shoreline jurisdiction area must be consistent with policies and regulations of the local
SMP, as well as with the policies of the SMA. While some policies, goals, and
development regulations may be referenced as findings within this staff report, additional
policies, goals, and development regulations of the SMP not explicitly referenced may be
found by review of the City’s 2020 SMP document.
44. Because the project requires a SCUP and SSDP the Project must be found consistent
with the criteria established in RCW 90.58.020, "Legislative findings—State policy
enunciated—Use preference", WAC 173-27-140 "Review criteria for all development",
WAC 173-27-150 "Review criteria for substantial development permits", WAC 173-27-
160 "Review criteria for conditional use permits", SMP 6.1.7 "Application – Shoreline
substantial development permit – Review criteria”, and SMP 6.1.8 “Application –
Shoreline conditional use permit – Review criteria”.
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45. The City’s rules and procedures for shoreline permits are contained in the SMP,
specifically Section 6.0. The section provides the following general purpose and intent:
6.1.1 Chapter purpose and intent.
It is the intention of the city council that the provisions of this chapter will
promulgate and adopt a program for the administration and enforcement of a
permit system that shall implement by reference the State Shoreline Management
Act of 1971, Chapter 90.58 RCW; the State Department of Ecology regulations
and guidelines adopted as Chapters 173-26 and 173-27 WAC; the Auburn
shoreline master program attached to the ordinance codified in this chapter,
together with amendments and/or additions thereto, and to provide for the
implementation of the policy and standards as set forth in the aforesaid laws and
regulations which are by reference made a part of this chapter with the force and
effect as though set out in full in this chapter.”
46. Pursuant ACC 6.1.12, the Hearing Examiner shall hold at least one public hearing on the
SCUP and SSDP in accordance with the following:
6.1.12 Application – Hearing – Required.
A. The hearing examiner shall hold at least one public hearing on each
application for a shoreline substantial development permit, shoreline
conditional use permit, or shoreline variance on shorelines within the city. The
public hearing shall be held not less than 30 days following the final
publication of the notice required by ACC 16.08.050.
B. The notice and conduct of the public hearing shall be in accordance with
Chapter 2.46 ACC.”
47. The City’s rules provide the following requirements for public notice:
6.1.6 Application – Notices.
The director shall give notice of the application in accordance with the applicable
provisions of ACC 14.07.040, no less than 30 days prior to permit issuance.
The notices shall include a statement that any person desiring to present his view
to the director with regard to the application may do so in writing to the director,
and any person interested in the hearing examiner's action on an application for
a permit may submit his views or notify the director of his interest within 30 days
of the last date of publication of the notice. Such notification or submission of
views to the director shall entitle said persons to a copy of the action taken on the
application.”
48. The City’s SMP contains the following information regarding the “Urban Conservancy”
shoreline environment designation:
3.3 Urban Conservancy
3.3.1 Purpose:
The purpose of the “Urban Conservancy” environment is to protect and restore
ecological functions of open space, floodplain and other sensitive lands where they exist
in urban and developed settings, while allowing a variety of compatible uses consistent
with the Comprehensive Plan.
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3.3.2 Designation Criteria:
The Urban Conservancy environment designation is appropriate for those areas planned
for development that is compatible with maintaining or restoring of the ecological
functions of the area, and that are not generally suitable for intensive water-dependent
uses.
3.3.3 Management Policies:
The following management policies should apply to all shorelines in the Urban
Conservancy Environment:
1. Primary allowed uses and their associated development standards should
preserve the natural character of the area or promote preservation of open
space, floodplain or sensitive lands where they exist in urban and developed
settings, either directly or over the long term. Uses that result in restoration of
ecological functions should be allowed if the use is otherwise compatible with the
purpose of the environment and the setting.
2. Standards should be established for shoreline stabilization measures, vegetation
conservation, water quality, and shoreline modifications within the "urban
conservancy" designation. These standards should ensure that new development
does not result in a net loss of shoreline ecological functions or further degrade
other shoreline values.
3. Public access and public recreation objectives should be implemented whenever
feasible and significant ecological impacts can be mitigated.
4. Water-oriented uses should be given priority over nonwater-oriented uses. For
shoreline areas with commercial development or adjacent to commercially
navigable waters, water-dependent uses should be given highest priority.
5. Existing mining and related activities may be an appropriate use within the urban
conservancy environment when conducted in a manner consistent with the
environment policies and the provisions of WAC 173-26-241(3)(h) and when
located consistent with mineral resource lands designation criteria pursuant to
RCW 36.70A.170 and WAC 365-190-070. No new mining uses or expansion of
existing mines should be permitted within the shoreline jurisdiction.”
49. The City’s SMP contains the following information regarding the “Natural” shoreline
environment designation:
3.4 Natural.
3.4.1 Purpose:
The purpose of the "Natural" environment is to protect those shoreline areas that are
relatively free of human influence or that include intact or minimally degraded shoreline
functions that would become irreversibly impaired as a result of human development and
activity. These systems require that only very low intensity uses be allowed in order to
maintain ecological functions and ecosystem-wide processes. Consistent with the
policies of the designation, the City of Auburn should include planning for restoration of
degraded shorelines within this environment.
3.4.2 Designation Criteria:
The “Natural” environment designation should be assigned to shoreline areas if any of
the following characteristics apply: (A) The shoreline is ecologically intact (as described
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in WAC 173-26-211(5)(a)(iii)) and therefore currently performing an important,
irreplaceable function or ecosystem-wide process that would be damaged by human
activity; (B) The shoreline is considered to represent ecosystems and geologic types that
are of particular scientific and educational interest; or (C) The shoreline is unable to
support new development or uses without significant adverse impacts to ecological
functions or risk to human safety.
3.4.3 Management Policies:
The following management policies should apply to all shoreline areas classified as
Natural Environments:
1. Any use that would substantially degrade the ecological functions or natural
character of the shoreline area should not be allowed.
2. The following new uses should not be allowed in the "Natural" environment:
a. Commercial uses.
b. Industrial uses.
c. Non-water-oriented recreation.
d. Roads, utility corridors, and parking areas that can be reasonably located
outside of "Natural" designated shorelines.
3. Single-family residential use may be allowed on properties designated as
Natural" if the density and lot configuration can accommodate such use by
maintaining portions of the property in shoreline jurisdiction in a natural condition,
consistent with the purpose of the environment.”
50. The City’s SMP contains the following goals related to Pedestrian Access:
2.2.1 Goals
1. Provide new and enhance existing public access to the shoreline
environment.
2. Create public access to the rivers through the park and trail system that will
not endanger life or property, nor impair the rights of private property owners
on the shorelines.
3. Create public access to the rivers in a manner that will not impair the natural
and ecological systems of the shorelines.”
51. The City’s SMP contains the following goals related to Shoreline Use:
2.5.1 Goals
1. Promote the best possible pattern of land and water uses that will be most
beneficial to the natural and human environments.
2. Designated Shorelines of Statewide Significance are of value to the entire
State and shall be managed consistent with this recognition. In order of
preference the priorities are to:
a. Recognize and protect the Statewide interest over local interest;
b. Preserve the natural character of the shoreline;
c. Result in long term over short term benefit;
d. Protect the resources and ecology of the shoreline; and,
e. Increase public access to publicly owned areas of the shorelines.”
52. The City’s SMP contains the following goals related to Flood Prevention/Critical Areas:
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2.8.1 Goals
1. Continue to participate in a regional approach to flood protection issues,
coordinating with the State of Washington, King County, Pierce County and
other entities interested in reducing flood hazards on both the White and
Green Rivers.
2. Continue to protect wetlands, streams, wildlife habitat, and groundwater and
minimize geologic hazards in the shoreline environment in accordance with
the Critical Areas Ordinance.”
53. The City’s SMP contains the following policies related to Shoreline Vegetation
Conservation:
4.4.2 Shoreline Vegetation Conservation
1. Developments and activities in the City’s shoreline should be planned and
designed to retain native vegetation or replace shoreline vegetation with
native species to achieve no net loss of the ecological functions and
ecosystem-wide processes performed by vegetation.
2. Woody debris should be left in the river corridors to enhance wildlife habitat
and shoreline ecological functions, except where it threatens personal safety
or critical infrastructure, such as bridge pilings. In such cases where debris
poses a threat, it should be dislodged, but should not be removed from the
river.”
54. The City’s SMP contains the following policies related to Critical Areas:
4.4.4 Critical Areas
1. Provide a level of protection to critical areas within the shoreline that is at
least equal to that which is provided by the City’s critical areas regulations
adopted pursuant to the Growth Management Act and the City’s
Comprehensive Plan. If conflicts between the SMP and the critical area
regulations arise, the regulations that are most consistent with the SMA or its
WAC provisions will govern.
2. Allow activities in critical areas that protect and, where possible, restore the
ecological functions and ecosystem-wide processes of the City’s shorelines.
3. Preserve, protect, restore and/or mitigate critical areas within and associated
with the City’s shorelines to achieve no net loss of shoreline ecological
functions.
4. Developments in shoreline areas that are identified as geologically hazardous
areas, or pose a foreseeable risk to people and improvements during the life
of the development, should not be allowed.
55. The City’s SMP contains the following policies related to Public Access:
4.4.5 Public Access (including views)
1. Public access improvements should not result in adverse impacts to the
natural character and quality of the shoreline and associated wetlands or
result in a net loss of shoreline ecological functions. Developments and
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activities within the shoreline should not impair or detract from the public’s
visual or physical access to the water.
2. Protection and enhancement of the public’s physical and visual access to
shorelines should be encouraged.
3. The amount and diversity of public access to shorelines should be increased
consistent with the natural shoreline character, property rights, and public
safety.
4. Publicly owned shorelines should be limited to water-dependent or public
recreation uses, otherwise such shorelines should remain protected,
undeveloped open space.
5. Public access should be designed to provide for public safety. Public access
facilities should provide auxiliary facilities, such as parking and sanitation
facilities, when appropriate, and should be designed to be ADA accessible.”
56. The City’s SMP contains the following policies related to Transportation:
4.7.10 Transportation
1. Plan, locate, design and where appropriate construct, proposed roads, non-
motorized systems and parking facilities where routes will have the least
possible adverse effect on unique or fragile shoreline features, will not result
in a net loss of shoreline ecological functions or adversely impact existing or
planned water-dependent uses. Where other options are available and
feasible, new roads or road expansions should not be built within shoreline
jurisdiction.
2. The number of river crossings should be minimized.
3. Parking facilities in shorelines are not a preferred use and shall be allowed
only as necessary to support an authorized use and then as remote from the
shoreline as possible.
4. Trail and bicycle systems should be encouraged along the White and Green
Rivers wherever possible.
5. Joint use of transportation corridors within the shoreline jurisdiction for roads,
utilities, and non-motorized transportation should be encouraged.
6. New railroad corridors should be prohibited.”
57. The City’s SMP contains the following policies related to Utilities:
4.7.11 Utilities
1. Utility facilities should be designed and located to assure no net loss of
shoreline ecological functions, preserve the natural landscape and vistas,
preserve and protect fish and wildlife habitat, and minimize conflicts with
present and planned land and shoreline uses.
2. Primary utility production and processing facilities, such as power plants,
sewage treatment plants, water reclamation plants, or parts of those facilities
that are nonwater-oriented should not be allowed in shoreline areas.
3. Utilities should utilize existing transportation and utilities sites, rights-of-way
and corridors, whenever possible. Joint use of rights-of-way and corridors
should be encouraged.
4. Transmission facilities for the conveyance of services, such as power lines,
cables, and pipelines, shall be located outside of the shoreline area where
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feasible. Where no other option exists, utilities should be placed underground
or alongside or under bridges.
5. New utilities facilities should be located so as not to require extensive
shoreline protection structures.
6. Where storm water management, conveyance, and discharge facilities are
permitted in the shoreline, they should be limited to the minimum size needed
to accomplish their purpose and should be sited and designed in a manner
that avoids, or mitigates adverse effects to the physical, hydrologic, or
ecological functions.
7. Stormwater conveyance facilities should utilize existing transportation and
utility sites, rights-ofway and corridors, whenever possible. Joint use of right-
of-way and corridors should be encouraged.”
Auburn Comprehensive Plan
58. The following City of Auburn Comprehensive Policies are relevant to the project:
Volume 1, Land Use Element, Institutional Land Use Designation:
Policy LU-92. Appropriate uses include low-intensity recreational uses, passive use open
areas, protected environmental habitat, stormwater detention facilities, and similar low-
intensity uses.”
Volume 8, Utilities Element:
Policy CF-10. Public facilities shall be provided in accord with the guidance of the Capital
Facilities Plan or, as may be appropriate a system plan for each type of facility designed
to serve at an adequate level of service the locations and intensities of uses specified in
this Comprehensive Plan.”
Policy CF-15 Protection of the City’s Coal Creek Springs and West Hill Springs
watersheds, wells, and other water sources shall be a high priority in the designation of
appropriate land uses in the vicinity of these areas and facilities.”
Public Notice, Comments and Procedures
59. A combined Notice of Application (NOA) and Determination of Non-Significance (DNS)
was issued under City File No. SEP20-0015 (Exhibit 14) on October 21, 2020 and
observed at 15-day comment period. The notice was mailed to property owners within
300 feet of the project site, published in the newspaper and posted on site. Four (4)
public comments were received in response to the combined NOA and DNS and are
summarized below. The entirety of the comments and responses are included as Exhibit
15.
a. Mike Kenyon: expressed excitement that a new pedestrian bridge will connect Game
Farm Park to Game Farm Wilderness Park.
City Response: Staff provided details about the project and thanked him for his
comment.
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b. Mike Pruett and Mark Segale: expressed concern (but not necessarily opposition)
that the pedestrian bridge will lead to an expansion of homeless encampments on
nearby southside property owned by Segale.
Staff Response: Staff noted that Community Development is working with our Parks
Department to see which, if any, possible solutions could address his concerns. Staff
also noted that while state regulations allow for utility crossings over the river, a
pedestrian component must be incorporated.
c. Krista Butler: expressed concerned about the safety issues that could be generated
by pedestrians accessing the bridge and would allow passage between Game Farm
Park and Game Farm Wilderness Park. She suggested funds be allocated to assist
the local homeless population.
d. Debbie Caldwell: expressed opposition to the bridge as it would allow for homeless
populations to cross the White River between Game Farm Park and Game Farm
Wilderness Park.
60. An SEPA Addendum to the previously issued DNS was issued on to incorporate the
LWM mitigation site. The Addendum was issued on July 13, 2022.
61. The Notice of Public Hearing (Exhibit 16) was issued on January 10, 2023. As of the
date of writing this staff report, two (2) public comments have been received, and are
summarized below. The entirety of the comments and responses are included as Exhibit
17.
a. Diane Taylor: stated that about four years ago homeless population accessed the
banks of the White River and started a fire. She questioned why the bridge was not
for the pipeline connection only.
Staff Response: Staff stated we are aware of the concerns of the issue of homeless
population possibly accessing the bridge. The pedestrian connection that the bridge
will provide should provide more eyes in the area.
b. Nancy Tibeau: wanted more information about the project, including the proposed
cost, purpose of the project, and estimated start and completion dates.
Staff Response: Staff provided the online posting in which more information could be
obtained, the proposed cost, and the estimated start and completion dates.
62. The contents of the case file for this project (SHL20-0008) are hereby incorporated by
reference and made part of the record of this hearing.
63. The decision on SCUP and SSDP shall be final with the Hearing Examiner and subject
to the Washington State Dept. of Ecology review period as required by the following
code section:
SMP 6.1.18 Grant or denial decision – Notifications.
The director shall notify the following persons in writing of the hearing examiner’s final
approval, disapproval or conditional approval of a substantial development permit,
shoreline conditional use permit, or shoreline variance application within eight days of
its final decision:
A. The applicant;
B. The State Department of Ecology;
C. The State Attorney General;
D. Any person who has submitted to the director written comments on the application;
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E. Any person who has written the director requesting notification.”
64. The Project has been or will be coordinated with the following agencies to ensure the
project is consistent with their plans, programs, and/or regulations:
Washington State Department of Fish and Wildlife granted the Hydraulic Project
Approval (HPA).
King County River and Floodplain Management Section reviewed plans to
ensure project will not adversely affect their levees and revetments.
Washington State Department of Health is administering the Federal Funds and
therefore ensuring the project meets Federal Requirements including the State
Environmental Review Process (SERP) and National Historic Preservation Act
Section 106).
Washington State Department of Ecology has issued a Construction Stormwater
General Permit.
Washington State Recreation and Conservation Office has reviewed Project
scope to ensure it was an allowed use of park land.
Washington State Department of Natural Resources and United State Army Corp
of Engineers confirmed that they do not have jurisdiction in the Project.
65. City of Auburn Community Development Department, Public Works Department and
Parks, Arts, & Recreation Department have reviewed of the Project plans. The following
City permits/approvals have been or will be secured: Shoreline Conditional Use
Permit/Substantial Development Permit (City File No. SHL20-0008), Floodplain
Development Permit (City File No. FDP20-0004), Storm Drainage Permit (City File No.
STM20-000, Grading Permit (City File No. GRA22-0034), and Building Permit (City File
No. BLD22-0087).
CONCLUSIONS:
What follows is the criteria for decision-making provided in bold and italics, followed by an
analysis by staff of the project’s consistency with the criteria.
Shoreline Conditional Use Permit
1. The Shoreline Master Program (SMP) provides the following review criteria for Shoreline
Conditional Use Permits:
6.1.8 Application – Shoreline conditional use permit – Review criteria.
A. Pursuant to WAC 173-27-210, the criteria below shall constitute the minimum
criteria for review and approval of a shoreline conditional use permit. Uses
classified as conditional uses, and not uses prohibited by the regulations of this
SMP, may be authorized; provided, that the applicant can demonstrate all of the
following:
1. That the proposed use will be consistent with the policies of RCW 90.58.020, the
policies of this SMP, the City of Auburn comprehensive plan and other applicable
plans, programs and/or regulations.
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The proposed use is consistent with RCW 90.58.020. The RCW states “Alterations of
the natural condition of the shorelines of the state, in those limited instances when
authorized, shall be given priority for…shoreline recreational uses including but not
limited to parks, marinas, piers, and other improvements facilitating public access to
shorelines of the state...”. The new pedestrian bridge and water main will not impede
with use of the parks.
The Project has demonstrated compliance with the applicable requirements of the City’s
SMP. While the new water main is a conditional use within the “Urban Conservancy”
shoreline environment designation, per SMP 4.7.11(4), utility transmission lines are
permitted where no other options exist. No other options exist as it is not feasible to
build the water main outside of the shoreline area. The existing City connection to the
water source is located south of Game Farm Wilderness Park (the south side of the
river) and the connection to the existing storage, treatment, distribution facilities, and
customers are located north of Game Farm Park (the north side of the river). Therefore
the new water main must cross the river. The water main (and new pedestrian bridge)
will be located in an existing water easement. The pedestrian bridge and paved trails are
permitted uses within the “Urban Conservancy” shoreline environment designation.
As provided in Finding of Fact Nos. 64 and 65, the Project has been or will be
coordinated with all applicable agencies, programs, and regulations.
2. That the proposed use will not interfere with the normal public use or access to
public shorelines.
Once construction is complete, the Project will not interfere with the normal public use or
public access. The bridge crossing will provide the added benefit of improved recreation
access between Game Farm Park and the Game Farm Wilderness Park. Also, as
provided in Finding of Fact No. 7, new trails will be installed on either side of the new
bridge to provide pedestrian access to and from existing park. Approx. 340 linear feet of
new 10-foot-wide, ADA-compliant paved trails would be constructed and is shown on the
Civil Plans (Exhibit 6). Park closures and construction work will be coordinated with the
City’s Parks Department to minimize impacts to park operations, events, and programs.
3. That the proposed use of the site and design of the project will be compatible
with other permitted uses within the area and with uses planned for the area under
the comprehensive plan and shoreline master program.
The Project is compatible with other permitted uses in the area and uses planned for the
area under the Comprehensive Plan and SMP. Other permitted uses for the area include
public parks and levees and revetments along the river. The City Parks Department has
reviewed the project design to ensure they are compatible with any future plans for the
parks. King County River and Floodplain Management Section has also reviewed the
project design to ensure their levees and revetments will not be adversely impacted by
the project now or in the future.
4. That the proposed use will cause no unreasonably adverse effects to the
shoreline, will not result in a net loss of ecological functions, and will not be
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incompatible with the environment designation or zoning classification in which it
is to be located.
The Project will not cause unreasonably adverse effects or result in the net loss of
ecological functions. All disturbed riparian forest areas (with the exception of the areas
needed to accommodate the pedestrian bridge and trails) will be restored to conditions
better than pre-construction through the removal of invasive plants and establishment of
native vegetation. Approximately 16,586 square feet of riparian restoration is proposed
and approximately 5,000 square feet of riparian enhancement is proposed. Mitigation for
the riparian forest disturbance will fulfill the requirement of no net loss of the ecological
functions and ecosystem-wide processes performed by vegetation (per SMP policy 4.4.2
related to shoreline vegetation conservation).
The Project is also compatible with the zoning classification of the area since an existing
waterline is being replaced. The I, Institutional zoning district is intended for areas in
which governmental and recreational uses that are significant in scope to be placed. The
new pedestrian bridge and water main can be considered governmental and recreational
uses that are significant in scope. Also, the new water main and pedestrian bridge will be
located within an existing water easement.
5. That the public interest suffers no substantial detrimental effect.
Public interest will suffer no substantial detrimental effects from the Project. As
described below, the public will actually benefit from the Project.
6. That the proposed use is in the best interest of the public health, safety, morals
or welfare.
The Project is in the best interest of the public health, safety, morals and welfare. The
existing water main under the White River is almost 100-years old and connects the
largest water source in the City of Auburn, Coal Creek Springs, to water storage,
treatment, distribution facilities, and customers. Functionally replacing the water main is
consistent with Auburn's Comprehensive Plan Policy CF-15, as it provides protection of
the City’s Coal Creek Springs water source. The new water main ensures the public will
continue to have a reliable source of water in the future.
7. That consideration of cumulative impacts resultant from the proposed use has
occurred and has demonstrated that no substantial cumulative impacts are
anticipated, consistent with WAC 173-27-160(2).
No substantial cumulative impacts should occur. No other existing utility crossings or
utility easements that cross the White River exist in the vicinity. The closest existing
utility crossing is over a half-mile away and located on an existing street bridge. It is
likely that future replacement of the water main on this bridge will be by reinstallation on
the pedestrian bridge. Further, this Project should also minimize that need for new utility
crossings in the future. Additional dry utility conduits and a 12-inch-diameter pipe will be
installed on the pedestrian bridge for potential future utility expansion to minimize future
impacts to the White River.
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B. The director may attach conditions to the approval of permits as necessary to
assure consistency of the proposal with the above criteria.
Conditions are provided under "Recommended Conditions of Approval" below.
C. The decision of the hearing examiner shall be the final decision of the city. The
Department of Ecology shall be the final authority authorizing a shoreline
conditional use permit consistent with WAC 173-27-200.
Staff finds that the proposal is consistent with the above criteria for a Shoreline Conditional Use
Permit and the criteria outlined in WAC 173-27-160.
Shoreline Substantial Development Permit
2. The Shoreline Master Program (SMP) provides the following review criteria for Shoreline
Substantial Development Permits:
6.1.7 Application – Shoreline substantial development permit – Review criteria.
A. A substantial development permit shall be granted by the director only when the
development proposed is consistent with the following:
1. Goals, objectives, policies and use regulations of the Auburn SMP.
The Project has been reviewed for consistency with the goals, objectives, policies, and
use regulations of the Auburn SMP and is consistent with the following policies and
regulations:
Policy SMP 2.2.1(1) Provide new and enhance existing public access to the shoreline
environment.
The Project will enhance existing public use and access by providing a pedestrian bridge
between Game Farm Park and Game Farm Wilderness Park.
Policy SMP 2.5.1(1) Promote the best possible pattern of land and water uses that will
be most beneficial to the natural and human environments.
The Project will allow for the functional replacement of an existing water main that
currently crossed under the White River. The existing water main will function as backup
to the new water main. The existing water main is located in a water easement. The new
pedestrian bridge and water main will be located within this existing water easement.
Policy SMP 2.8.1(2) Continue to protect wetlands, streams, wildlife habitat, and
groundwater and minimize geologic hazards in the shoreline environment in accordance
with the Critical Areas Ordinance.
The Project Site overlaps with the following regulated critical area per Chapter 16.10
ACC: critical and tertiary wildlife habitat areas, aquifer recharge areas, geologically
hazardous areas, and the special flood hazard area (100-year floodplain) and associated
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protected areas (floodway, RBZ, and CMZ). No wetlands or associated buffers on the
Project Site or the LWM mitigation site.
The Project is not likely to adversely affect the ESA-listed salmonids and will have no
effect on their critical habitat. The Project will have no adverse effect on the Pacific
Salmon EFH for the reasons provided for the ESA-listed salmonids.
All proposed bridge features will be located outside of the OHWM and 100-year base
flood elevation on both sides of the White River and therefore will also be located
outside of the coincident CMZ. At least four feet of freeboard between the bottom of the
bridge and the 100-year base flood elevation will be provided. The bottom of the water
main will be at least four feet above the 100-year base flood elevation. Placement of the
LWM at the mitigation site is not expected to raise the elevation of the 100-year base
flood elevation.
The City’s GIS inventory map system, did not identify the Project Site to be within any
landslide hazard areas. No buffer or setback from the slopes inclined steeper than 15%.
However, the following mitigation measures are proposed to eliminate or reduce the risk:
temporary erosion and sedimentation control, temporary sloping/shoring, and restoration
of the site (revegetation of disturbed areas and restoration of riprap armoring of the
riverbank). No ground disturbing work will occur within the erosion hazard zone of the
LWM mitigation site.
Mitigation for the riparian forest disturbance will fulfill the requirement of no net loss of
the ecological functions and ecosystem-wide processes performed by vegetation.
Policy SMP 4.4.2(1) Developments and activities in the City’s shoreline should be
planned and designed to retain native vegetation or replace shoreline vegetation with
native species to achieve no net loss of the ecological functions and ecosystem-wide
processes performed by vegetation.
All disturbed riparian forest areas (with the exception of the areas needed to
accommodate the pedestrian bridge and trails) will be restored to conditions better than
pre-construction through the removal of invasive plants and establishment of native
vegetation. Approximately 16,586 square feet of riparian restoration is proposed and
approximately 5,000 square feet of riparian enhancement is proposed. Mitigation for the
riparian forest disturbance will fulfill the requirement of no net loss of the ecological
functions and ecosystem-wide processes performed by vegetation.
Policy SMP 4.4.2(2) Woody debris should be left in the river corridors to enhance wildlife
habitat and shoreline ecological functions, except where it threatens personal safety or
critical infrastructure, such as bridge pilings. In such cases where debris poses a threat,
it should be dislodged, but should not be removed from the river.
Thirty-three trees (with a diameter at breast height (DBH) of six inches and over) will be
removed to create construction access. The removed trees will be placed at the LWM
mitigation site and will serve as future wood recruitment for fish habitat. The LWM will
occupy approx. 100 square feet (5 cubic yards) below the OHWM. Above the OHWM
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and below the 100-year base flood elevation, the LWM will occupy 540 square feet (35
cubic yards).
Policy SMP 4.4.4(3) Preserve, protect, restore and/or mitigate critical areas within and
associated with the City’s shorelines to achieve no net loss of shoreline ecological
functions.
The Project will include restoration and maintenance of the native vegetation as
described above.
Policy SMP 4.4.5(1) Public access improvements should not result in adverse impacts to
the natural character and quality of the shoreline and associated wetlands or result in a
net loss of shoreline ecological functions. Developments and activities within the
shoreline should not impair or detract from the public’s visual or physical access to the
water.
As noted in Finding of Fact No. 12, to accommodate construction, partial temporary park
closures of Game Farm Park and Game Farm Wilderness Park will occur after May 31.
All park areas will be reopened in the fall (dependent on no construction schedule
change), following completion of the project. Construction work will be coordinated with
the City’s Parks Department to minimize impacts to park operations, events, and
programs.
Policy SMP 4.7.10(4) Trail and bicycle systems should be encouraged along the White
and Green Rivers wherever possible.
The Project will enhance public use and access by providing a pedestrian bridge
between Game Farm Park and Game Farm Wilderness Park. New trails will be installed
on either side of the new pedestrian bridge to provide access to existing park trails.
About 340 linear feet of new 10-foot-wide, ADA-compliant paved trails will be
constructed. Connection will facilitate new pedestrian circulation loops and patterns.
Policy SMP 4.7.11(4) Transmission facilities for the conveyance of services, such as
power lines, cables, and pipelines, shall be located outside of the shoreline area where
feasible. Where no other option exists, utilities should be placed underground or
alongside or under bridges.
Utility transmission lines are permitted where no other options exist. No other options to
install the new water main exist as it is not feasible to build it outside of the shoreline
area.
Regulation SMP 4.4.2(5) A critical areas study shall be submitted for review for all
proposed development activity within the shoreline jurisdiction. The purpose of the
report is to determine the extent, characteristics and functions of critical areas located
on or potentially affected by proposed activities on site. See ACC 16.10.070 “Critical
Area Review Process and Application Requirements” for required report contents.
A critical areas report and habitat impact assessment has been prepared for this Project
by biologists which analyzes the on-site critical areas, assesses habitat impact, and
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proposed mitigation plan in compliance with the City’s Shoreline Master Program,
Critical Areas code, and Floodplain Development Management code (Chapters 16.08,
16.10, and 15.68 of the Auburn City Code respectively).
Regulation SMP 4.4.3(1) To the extent Washington's State Environmental Policy Act of
1971 (SEPA), Chapter 43.21C RCW, is applicable, the analysis of environmental
impacts from proposed shoreline uses or developments shall be conducted consistent
with the rules implementing SEPA (Chapter 16.06 ACC and WAC 197-11).
A combined Notice of Application (NOA) and Determination of Non-Significance (DNS)
was issued under City File No. SEP20-0015 on October 21, 2020. An SEPA Addendum
to the previously issued DNS was issued on to incorporate the LWM mitigation site. The
Addendum was issued on July 13, 2022. SEPA’s elements of the environment were
considered in reaching the threshold determination.
Regulation SMP 4.4.3(6) When compensatory measures are appropriate pursuant to the
priority of mitigation sequencing above, preferential consideration shall be given to
measures that replace the impacted functions directly and in the immediate vicinity of the
impact. However, alternative compensatory mitigation within the watershed that
addresses limiting factors or identified critical needs for shoreline resource conservation
based on watershed or comprehensive resource management plans applicable to the
area of impact may be authorized. Authorization of compensatory mitigation measures
may require appropriate safeguards, terms or conditions as necessary to ensure no net
loss of ecological functions. ACC 16.10.110, “Mitigation Standards, Criteria And Plan
Requirements,” establishes regulations on location and timing of mitigation. On-site and
in-kind mitigation are preferred.
As provided in Finding of Fact No. 38, mitigation measures will take place directly and in
the immediate vicinity of the impacted area with the exception of the Large Woody
Material placement. Mitigation will be monitored for five years per the Critical Areas
Report and Habitat Impact Assessment (Exhibit 7).
Regulation 4.4.5(8) Shoreline development by any public entities, including the City of
Auburn, port districts, state agencies, and public utility districts, shall include public
access measures as part of each development project, unless such access is shown to
be incompatible due to reasons of safety, security, impact to the shoreline environment
or other provisions listed in WAC 173-26-221(4)(d).
The Project includes public access measures, including a new bridge between Game
Farm Park and Game Farm Wilderness Park. New trails will be installed on either side of
the new pedestrian bridge to provide access to existing park trails.
Regulation SMP 4.4.6(5) Permanent structures placed within the 100-year floodplain
shall be designed and constructed in accordance with the requirements of Chapter 15.68
ACC, “Flood Hazard Areas”.
All proposed bridge features will be located outside of the OHWM and 100-year base
flood elevation on both sides of the White River. At least four feet of freeboard between
the bottom of the bridge and the 100-year base flood elevation will be provided. The
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bottom of the water main will be at least four feet above the 100-year base flood
elevation as well. At the LWM mitigation site, the woody material will occupy approx. 100
square feet (5 cubic yards) below the OHWM. Above the OHWM and below the 100-
year base flood elevation, the LWM will occupy approx. 540 square feet (35 cubic
yards). However, LWM placement will not raise the elevation of the 100-year base flood
elevation.
2. Auburn Comprehensive Plan and Municipal Code.
The Project has been reviewed for consistency with Auburn Comprehensive Plan and
Auburn Municipal Code.
The Project is consistent with Auburn's Comprehensive Plan Policy CF-15, as it provides
protection of the City’s Coal Creek Springs water source (reference Finding of Fact No.
58). The new watermain ensures the public will continue to have a reliable source of
water in the future.
The Project is also compatible with the zoning classification. The I, Institutional zone is
intended for areas in which governmental and recreational uses that are significant in
scope to be placed. The new pedestrian bridge and water main can be considered
governmental and recreational uses that are significant in scope. Also the new water
main and pedestrian bridge will also be located within an existing water easement.
3. The policies, guidelines, and regulations of the SMA (Chapter 90.58 RCW;
Chapters 173-26 and 173-27 WAC).
By meeting the criteria established within the City of Auburn’s SMP, which was most
recently approved by the Washington State Department of Ecology on May 7, 2020, the
project will be consistent with the state SMA.
B. The director may attach conditions to the approval of permits as necessary to
assure consistency of the proposal with the above criteria.
Conditions are provided under "Recommended Conditions of Approval" below.
Staff finds that the proposal is consistent with the above criteria for a Shoreline Substantial
Development Permit and the criteria outlined in WAC 173-27-150.
Consistency with SMA & Local SMP
3. The Shoreline Management rules (WAC 173-27-140) set forth the following two criteria
provided for all developments within the shoreline jurisdiction.
A) No authorization to undertake use or development on shorelines of the state
shall be granted by the local government unless upon review the use or development
is determined to be consistent with the policy and provisions of the Shoreline
Management Act and the master program.”
B) No permit shall be issued for any new or expanded building or structure of more
than thirty-five feet above average grade level on shorelines of the state that will
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obstruct the view of a substantial number of residences on areas adjoining such
shorelines except where a master program does not prohibit the same and then only
when overriding considerations of the public interest will be served.”
As provided in Conclusions 1 and 2, the Project meets the criteria established within the City
of Auburn’s SMP, which was most recently approved by the Washington State Department
of Ecology on May 7, 2020, the project will be consistent with the state SMA.
The Project will not obstruct the view of area residences. The main purpose of the Project is
to functionally replace an existing water main that currently exists under the White River.
The existing water main under the White River is almost 100-years old and connects largest
water source in the City of Auburn, Coal Creek Springs, to water storage, treatment,
distribution facilities, and customers. The new pedestrian bridge and water main will be
located within an existing water easement.
Staff believes that the project is consistent with the criteria established in WAC 173-27-140.
4. The Shoreline Management rules in WAC 173-27-160 set forth the following criteria that
must be met for approval of a Shoreline conditional use permit. The project must be
consistent with:
The purpose of a conditional use permit is to provide a system within the master
program which allows flexibility in the application of use regulations in a manner
consistent with the policies of RCW 90.58.020. In authorizing a conditional use,
special conditions may be attached to the permit by local government or the
department to prevent undesirable effects of the proposed use and/or to assure
consistency of the project with the act and the local master program.
1) Uses which are classified or set forth in the applicable master program as
conditional uses may be authorized provided that the applicant demonstrates all
of the following:
a) That the proposed use is consistent with the policies of RCW 90.58.020 and the
master program;
b) That the proposed use will not interfere with the normal public use of public
shorelines;
c) That the proposed use of the site and design of the project is compatible with
other authorized uses within the area and with uses planned for the area under
the comprehensive plan and shoreline master program;
d) That the proposed use will cause no significant adverse effects to the
shoreline environment in which it is to be located; and
e) That the public interest suffers no substantial detrimental effect.
2) In the granting of all conditional use permits, consideration shall be given to the
cumulative impact of additional requests for like actions in the area. For example,
if conditional use permits were granted for other developments in the area where
similar circumstances exist, the total of the conditional uses shall also remain
consistent with the policies of RCW 90.58.020 and shall not produce substantial
adverse effects to the shoreline environment.
3) Other uses which are not classified or set forth in the applicable master program
may be authorized as conditional uses provided the applicant can demonstrate
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consistency with the requirements of this section and the requirements for
conditional uses contained in the master program.
4) Uses which are specifically prohibited by the master program may not be
authorized pursuant to either subsection (1) or (2) of this section.
As noted previously within the above analysis outlined within Conclusion 1, City of Auburn
staff believe that the project is consistent with the criteria established in WAC 173-27-160.
5. The Shoreline Management rules in WAC 173-27-150 set forth the following criteria that
must be met for approval of a Shoreline Substantial Development Permit. The Project must
be consistent with:
1) A substantial development permit shall be granted only when the development
proposed is consistent with:
a) The policies and procedures of the act;
b) The provisions of this regulation; and
c) The applicable master program adopted or approved for the area. Provided,
that where no master program has been approved for an area, the
development shall be reviewed for consistency with the provisions of chapter
173-26 WAC, and to the extent feasible, any draft or approved master program
which can be reasonably ascertained as representing the policy of the local
government.
2) Local government may attach conditions to the approval of permits as necessary
to assure consistency of the project with the act and the local master program.
As noted previously within the above analysis outlined within Conclusion 2, City of Auburn
staff believe the project is consistent with the criteria established in WAC 173-27-150.
STAFF RECOMMENDATION:
Based on the information contained in this Staff Report, the attached exhibits, Staff
recommends that the Hearing Examiner APPROVE the Shoreline Conditional Use Permit and
Shoreline Substantial Development Permit subject to the five (5) conditions provided below.
RECOMMENDED CONDITIONS OF APPROVAL:
1. The future development of the site associated with the subject Shoreline Conditional Use
Permit and Shoreline Substantial Development Permit shall be completed within two
years from the effective date of the decision from the Department of Ecology, as
specified in WAC 173-27-090.
2. The applicant shall secure all required agency approvals and permits provided in
Finding of Fact No. 64 and 65.
3. The Project shall be developed substantially consistent with the Civil Plans, City of
Auburn, revision dated January 23, 2023 (Exhibit 6).
4. Project mitigation shall be substantially consistent with the Mitigation Plan provided in
the Critical Area Report and Habitat Impact Assessment, Jacobs, revision dated May 26,
2022 (Exhibit 7) and the Civil Plans (Exhibit 6) for the project.
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5. Maintenance of the mitigation sites during the initial 5-year monitoring period will be the
responsibility of the City of Auburn Public Works Department and observe standards of
the city’s critical area regulations, Chapter 16.10 ACC.
Staff reserves the right to supplement the record of the case to respond to matters and
information raised subsequent to the writing of this report.
EXHIBIT LIST:
Exhibit 1 Staff Report
Exhibit 2 Completed City of Auburn Land Use Application Forms, City of Auburn
Exhibit 3 Joint Aquatic Resources Permit Application (JARPA) form, City of Auburn
Exhibit 4 Written Statement and Legal Description, City of Auburn
Exhibit 5 SMP Policy Memo, City of Auburn, revision dated December 27, 2022
Exhibit 6 Civil Plans, City of Auburn, revision dated January 23, 2023
Exhibit 7 Critical Area Report and Habitat Impact Assessment, Jacobs, revision dated May
26, 2022
Exhibit 8 Cultural Resources Report, Jacobs, dated April 2022
Exhibit 9 Alternative Summary Report, Jacobs, dated June 11, 2021
Exhibit 10 Geotechnical Engineering Report, prepared by Wood, dated October 21, 2020
Exhibit 11 Stormwater Site Plan Report, Jacobs, revision dated October 2022
Exhibit 12 LWM Mitigation Hydraulic Analysis, Jacobs, dated June 17, 2022
Exhibit 13 SEPA Environmental Checklist, City of Auburn, revision dated June 2022
Exhibit 14 Notice of Application (NOA), Determination of Non-Significance (DNS), and
Addendum
Exhibit 15 NOA and SEPA DNS Public Comments and Staff Response
Exhibit 16 Notice of Public Hearing (NOH)
Exhibit 17 NOH Comments Received and Staff Response
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A U B U R N
V A L U E S
S E R V I C E
E N V I R O N M E N T
E C O N O M Y
C H A R A C T E R
S U S T A I N A B I L I T Y
W E L L N E S S
C E L E B R A T I O N
PLANNING SERVICES
SHL20 -0008
COAL CREEK SPRINGS TRANSMISSION
MAIN REPLACEMENT PROJECT
ALEXANDRIA D. TEAGUE , AICP
PUBLIC HEARING
FEBRUARY 15, 2023, 5:30 PM
Department of Community Development
Planning ⚫Building ⚫Development Engineering ⚫Permit Center
Community Services ●Code Enforcement ●Economic Development
Applicant: Seth Wickstrom, PE, Applicant, City of Auburn
Public Works Department
Proposal: I nstall an approx. 210 -foot -long and 12 ft.
wide pedestrian bridge and 24 -inch-diameter water
transmission main across the White River
Purpose: F unctionally replace an existing water main
that currently exists under the White River
Project Site Location: riverbanks of Game Farm Park
(3030 R St. SE) and the Game Farm Wilderness Park,
River Mile 8.5
Project Site Property Owner: City of Auburn Parks, Arts,
Parks and Recreation Department
Off-Site Mitigation Location: located at River Mile 9.3,
approximately 0.88 miles (4,634 feet) northeast
(upstream) of the Project Site
Off-Site Mitigation Property Owner: King County Water
and Land Resources Division, River and Floodplain
Management Section
PROJECT BACKGROUND
SEPA STATUS AND PUBLIC NOTICE
A combined Notice of Application (NOA) and
Determination of Non -Significance (DNS)
issued on October 21, 2020.
The comment period ended November 5,
2020.
The appeal period ended November 19, 2020.
19, 2020.
A SEPA Addendum to the previously issued
DNS was issued on to incorporate the LWM
mitigation site.
Addendum was issued on July 13, 2022.
The Notice of Public Hearing was issued on
January 10, 2023.
PUBLIC COMMENTS
Four (4) public comments were received in
response to the combined NOA and DNS.
The comments generally concerned:
▪that the pedestrian bridge will lead to an expansion of
homeless encampments
▪safety issues that could be generated by pedestrians
accessing the bridge
Two (2) public comments have been received
in response to the NOH:
The comments generally concerned:
▪homeless population accessed the banks of the White
River
▪more information about the project, including the
proposed cost, purpose of the project, and estimated
start and completion dates
SEPA STATUS AND PUBLIC NOTICE PROCEDURES
FINDINGS OF FACT
GENERAL
FINDINGS
OF FACT
GENERAL
FINDINGS
OF FACT
GENERAL FINDINGS OF FACT
GENERAL FINDINGS OF FACT
GENERAL
FINDINGS
OF FACT
SHORELINE
FINDINGS
OF FACT
C ritical and tertiary wildlife habitat areas
M igratory corridor for ESA -listed and state -
listed salmonids including Bull Trout,
Chinook Salmon, Steelhead Trout, and
Pacific Salmon essential fish habitat (EFH )
ESA-listed salmonids may be affected but
are not likely to be adversely affected
No effect on the critical habitat for ESA -
listed salmonids
No adverse effect on the Pacific Salmon
EFH for the reasons provided for the ESA -
listed salmonids
CRITICAL AREAS FINDINGS OF FACT
Special Flood Hazard Area
100-year floodplain and associated protected areas
(including the floodway, riparian buffer zone, and
channel migration zone)
Floodway “means the channel of a river or other
watercourse and the adjacent land areas that must be
reserved in order to discharge the base flood without
cumulatively increasing the water surface elevation
more than a designated height.”
C hannel migration zone (CMZ ) “means the area within
the lateral extent of likely stream channel movement
due to stream bank destabilization and erosion, rapid
stream incision, aggradation, avulsions, and shifts in
location of stream channels.”
Riparian buffer zone (RBZ) “means the land located
adjacent to streams, and other bodies of water, where
the natural soil, hydrology, and native flora and fauna
perform important ecological functions such as
protecting the water body by filtering out pollutants,
preventing erosion and sedimentation, stabilizing
stream banks, and providing natural shade.”
CRITICAL AREAS FINDINGS OF FACT
CRITICAL
AREAS
FINDINGS OF
FACT
SHORELINE MANAGEMENT PROGRAM
FINDINGS OF FACT
CRITERIA
1.Consistent with policies of this SMP and the
Comprehensive Plan
2.Will not interfere with the normal public use or
access to public shorelines
3.Compatible with other permitted uses within the
area and with uses planned for the area
4.Will cause no significant adverse effects to the
shoreline environment
5.Public interest suffers no substantial detrimental
effect
6.No substantial cumulative impacts are
anticipated
PROJECT’S CONSISTENCY
1.Utility transmission lines are permitted where
no other options exist
2.Once construction is complete, the Project will
not interfere with the normal public use or
public access
3.Other permitted uses for the area include public
parks and levees and revetments along the
river
4.Disturbed riparian forest areas will be restored
5.New water main ensures the public will
continue to have a reliable source of water in
the future
6.No other existing utility crossings or utility
easements that cross the White River exist in
the vicinity
SHORELINE CONDITIONAL USE PERMIT AND
WAC 173 -27 -160 CONSISTENCY AND CONCLUSIONS
CRITERIA
1.Consistent with the goals, objectives, policies
and use regulations of the Auburn Shoreline
Management Act
2.Consistent with the Auburn Comprehensive
Plan and Municipal Code
3.Consistent with the policies, guidelines, and
regulations of the SMA
PROJECT’S CONSISTENCY
1.Addressed under the previous criteria
2.Compatible with the Institutional zone is
intended for areas in which governmental
and recreational uses that are significant in
scope to be placed
3.Meets criteria the SMP, therefore will be
consistent with the state SMA
SHORELINE SUBSTANTIAL DEVELOPMENT PERMIT AND
WAC 173 -27 -150 CONSISTENCY AND CONCLUSIONS
CRITERIA
1.Consistent with the Shoreline Management Act
and the Shoreline Master Program
2.Cannot obstruct the view of a substantial
number of residences on areas adjoining such
shorelines
PROJECT’S CONSISTENCY
1.Addressed under the previous criteria
2.The Project will not obstruct the view of any
residences
WAC 173 -27 -140
CONSISTENCY AND CONCLUSIONS
Staff recommends that the Hearing Examiner APPROVE the Shoreline Conditional Use Permit and
Shoreline Substantial Development Permit subject to the five (5) conditions:
1.Future development of the site is completed within two years from the effective date of the decision
from Ecology
2.All agency approvals and permits provided in Finding of Fact No. 64 and 65 are secured
3.Project substantially consistent with the Civil Plans (Exhibit 6)
4.Project mitigation substantially consistent with the Mitigation Plan and the Civil Plans (Exhibit 6)
for the project
5.Maintenance of the mitigation sites is the responsibility of the City of Auburn Public Works
Department and observes Critical Areas Ordinance
STAFF RECOMMENDATION AND
RECOMMENDED CONDITIONS OF APPROVAL
1. Staff Report
2. Land Use Application Forms
3. Joint Aquatic Resources Permit
Application
4. Written Statement and Legal
Description
5. SMP Policy Memo
6. Civil Plans
7. Critical Area Report and Habitat Impact
Assessment
8. Cultural Resources Report
9. Alternative Summary Report
10. Geotechnical Engineering Report
11. Stormwater Site Plan Report
12. LWM Mitigation Hydraulic Analysis
13. SEPA Environmental Checklist
14. NOA, SEPA DNS, and Addendum
15. NOA and SEPA DNS Public Comments
and Staff Response
16. NOH
17. NOH Comments Received and Staff
Response
18. Public Hearing Presentation
19. NOH Public Comment 2.15.23 Caldwell
and Staff Response
20. MITFD Comment Letter SHL20 -0008 2 -
14-2023
EXHIBIT LIST
Aquifer recharge areas
Aquifer recharge area “means areas with a
critical recharging effect on aquifers used
for potable water, including areas where an
aquifer that is a source of drinking water is
vulnerable to contamination that would
affect the potability of the water, or is
susceptible to reduced recharge.”
Project Site and the LMW mitigation site are
within the within the City’s Type 1 aquifer
recharge areas.
Geologically hazardous areas
Erosion hazard areas “means ands or areas
that, based on a combination of slope
inclination and the characteristics of the
underlying soils, are susceptible to varying
degrees of risk of erosion. Erosion hazard
areas are classified as “low” (areas sloping
less than 15 percent) or “high” (areas sloping
15 percent or more) on the following Soil
Conservation Service (SCS), now known as
the Natural Resources Conservation Service
(NRCS), soil types: Alderwood -Kitsap (AkF ),
Alderwood gravelly sandy loam (AgD ), Kitsap
silt loam (KpD ), Everett (EvD ) and Indianola
(InD). Additional soil groups may be identified
through site -specific analysis.”
Project Site and the LWM mitigation site are located
within an erosion hazard area.
CRITICAL AREAS FINDINGS OF FACT
Auburn's Comprehensive Plan is the leading policy
document that guides the City's evolution and growth
over a 20 year period. The Comprehensive Plan
identifies the desired type, configuration, and
intensity of land uses throughout the city, as well as
the character and capacity of public facilities and
services like streets and utilities. Its policies
address critical topics such as housing, the
environment, transportation, public safety, and
economic development.
Comprehensive Policies are relevant
to the project:
Policy LU -92. Appropriate uses include low -
intensity recreational uses, passive use open
areas, protected environmental habitat,
stormwater detention facilities, and similar low -
intensity uses.
Policy CF -10. Public facilities shall be provided
in accord with the guidance of the Capital
Facilities Plan or, as may be appropriate a
system plan for each type of facility designed
to serve at an adequate level of service the
locations and intensities of uses specified in
this Comprehensive Plan.”
Policy CF -15. Protection of the City’s Coal
Creek Springs and West Hill Springs
watersheds, wells, and other water sources
shall be a high priority in the designation of
appropriate land uses in the vicinity of these
areas and facilities.”
AUBURN COMPREHENSIVE PLAN FINDINGS
FINDINGS OF FACT
1
Alexandria Teague
From:Alexandria Teague
Sent:Wednesday, February 15, 2023 4:26 PM
To:Debbie Caldwell
Cc:Seth Wickstrom
Subject:RE: Staff contact Alexandria Teague, Planner 2
Thank you for your comment, Ms. Caldwell. I wanted to send an email notify you that it has been received and will be
made part of the public comment record.
Alexandria
If inquiring about a specific site, please include the parcel number or address, or if inquiring about a specific project,
please include the City project number in your email.
Note: Beginning Feb 27th, 2023 I will be out of the office for 3 months.
Planning or Land Use Questions?
Book an online meeting with staff.
Check out our FAQ!
Alexandria D. Teague, AICP, Senior Planner
Department of Community Development
City of Auburn | www.auburnwa.gov
253.931.3003 | ateague@auburnwa.gov
Mailing Address: 25 W Main Street, Auburn, WA 98001
Permit Center Address: 1 E Main Street, Auburn, WA 98002 (Click Here for Map)
Customer Service Survey | https://www.surveymonkey.com/r/XNSL95J
Application Forms | http://www.auburnwa.gov/services/resource_library/forms.htm
Zoning Maps | http://www.auburnwa.gov/services/resource_library/maps.htm
From: Debbie Caldwell <debbiecaldwell@comcast.net>
Sent: Wednesday, February 15, 2023 3:54 PM
To: Planning-1 <Planning@auburnwa.gov>
Subject: Staff contact Alexandria Teague, Planner 2
CAUTION: The following message originated from outside the City of Auburn. Be careful opening links and attachments
Hello Alexandria,
EXHIBIT 19
2
This email is in response to public comments regarding proposed footbridge connecting Garm Farm
Wilderness and Garm Farm Park.
I understand the footbridge would allow and benefit the publics access between the 2 parks.
However, with that brings another level of concerns for those of us living in the surrounding
neighborhoods. Increased litter and filth being tossed from bridge and dumped in the park. There
has been vagrants/drug activity along that secluded road leading to Game Farm Wilderness Park in
the past. If the bridge is open to foot traffic 24/7 there is an increased potential for break-ins and
thefts to occur in our neighborhood.
Game Farm Park is closed at dusk with a locked gate, will the foot bridge also be locked and secured
so that no access either way will be possible during evening hours?
I am skeptical that this isn't just about a foot bridge linking 2 parks. A 24-inch water main installed
under the bridge makes one wonder if there are plans to develop and build yet more houses across
the river? I think the residents in this area should be advised of further developments, as R St SE
can't handle the traffic being dumped on it now.
I hope you take into consideration my potential concerns and work toward a solution which ensures
the health, safety and well being of the citizens in the effected area of construction.
Debbie Caldwell
MUCKLESHOOT INDIAN TRIBE
Fisheries Division
39015 - 172nd Avenue SE Auburn, Washington 98092-9763
Phone: (253) 939-3311 Fax: (253) 931-0752
February 14, 2023
Alexandria Teague
Senior Planner | City of Auburn
Public Works Department | Engineering Services
25 West Main Street | Auburn, WA 98001-4998
planning@auburnwa.gov
RE: Coal Creek Springs Water Main Replacement Project, Shorelines Conditional Use
Permit SHL20-0008
Dear Ms. Teague:
Thank you for providing the Notice of Public Hearing for the above referenced project, which
proposed to install a pedestrian and utility bridge over the White River between the City’s Game
Farm Park and Game Farm Wilderness Park. We have expressed our concerns over this project
to the City on July 19th, 2021 (see attached letter to Mr. Seth Wickstrom), and received the
City’s responses on September 17, 2021 (from Mr. Wickstrom). We have provided follow-up
responses to the City’s response in Appendix A. However, we continue to have outstanding
concerns that this bridge will have adverse impacts to the Tribe’s salmon habitat, fishery, and
restoration objectives. Further, the proposed bridge conflicts with Auburn’s Shorelines
Management Plan as well as the King County Flood Hazard Management Plan. We have
reviewed the materials associated with this project, and offer the following comments in the
interest of Muckleshoot Tribe’s treaty-protected fisheries resources:
The proposed bridge conflicts with goals of the Auburn Shoreline Management Plan
(SMP).
The river needs re-naturalization via a levee setback at the project site. It does not benefit from
further constraint by a new bridge where vast devastation to aquatic habitat has been imposed by
levees, revetments, gravel removal (Figures 1-3), and foremost, diversion of the White River
from the Green River to the Puyallup River. A new bridge at this location will degrade the White
River further, contrary to SMP goals.
The SMP identifies three broad policies of the Shoreline Management Act, the strongest of
which is “Protect shoreline natural resources, including "...the land and its vegetation and
wildlife, and the water of the state and their aquatic life..” [emphasis added].”
EXHIBIT 20
___________________________________________________________________________
MITFD comments on the City of Auburn’s
Coal Creek Springs Water Main Replacement Project,
Shorelines Conditional Use Permit SHL20-0008 P a g e 2 | 12
The SMP’s Flood Protection/Critical Areas Element addresses reducing potential flood hazards
and flood damages in the City of Auburn and the protection of critical areas in Auburn’s
shoreline area. It specifies two goals [emphasis added]:
1. Continue to participate in a regional approach to flood protection issues, coordinating
with the State of Washington, King County, Pierce County and other entities interested in
reducing flood hazards on both the White and Green Rivers.
2. Continue to protect wetlands, streams, wildlife habitat, and groundwater and minimize
geologic hazards in the shoreline environment in accordance with the critical areas
ordinance.
The proposed bridge conflicts with flood management at Lower White River described in the
2013 King County Flood Hazard Management Plan Update (FHMP), a plan that provides a
regional approach to flood-protection issues and reduces flood risk in Auburn. The City has
collaborated with King County in collecting channel data in a 1.25-mile stretch of the Lower
White River, and is apparently aware of flood risks associated with sediment aggradation.
The regional FHMP includes a sediment management program that is applied at Lower White
River along the cities of Auburn and Pacific. Noting widespread and rapid sediment
accumulation has significantly decreased the channel capacity, the FHMP states “Setback of
existing levees has been identified as the preferred approach for flood risk reduction in this river
reach [emphasis added].”
The proposed bridge will compromise the preferred approach for flood risk reduction at Lower
White River because it will establish new constraints for levee setbacks in vicinity of the bridge.
This conflicts with the City’s SMP goal “to participate in a regional approach to flood protection
issues [and coordinate with] other entities interested in reducing flood hazards.”
The proposed bridge also conflicts with the City’s SMP goal “to protect…streams [and] wildlife
habitat.” The proposed bridge will harm the White River by restricting opportunities for habitat
restoration via levee setbacks in vicinity of the bridge. The proposed bridge will also
permanently destroy riparian habitat and harm wildlife supported by that habitat. The destruction
of riparian habitat that protects wildlife at the proposed bridge is ironic because the City’s park
descriptions note the following points, all of which conflict with additions of asphalt, steel,
crushed rock, concrete, cement, and plastic for the proposed bridge:
[At Game Farm Park] The hillside backdrop and proximity to the White River creates a
spectacular natural setting.
[Game Farm Park] is built on wild game refuge property originally owned by the King
County Game Commission. In 1933, ownership was transferred to the Washington State
___________________________________________________________________________
MITFD comments on the City of Auburn’s
Coal Creek Springs Water Main Replacement Project,
Shorelines Conditional Use Permit SHL20-0008 P a g e 3 | 12
Department of Game. It was an experimental facility for [birds]. In 1978, the land
transferred ownership to the State Parks and Recreation Commission. The City of Auburn
signed a long-term use agreement in 1984 which provided that the City cooperate with the
State Parks to develop the 160-acre site as a park. [Presumably not a park with a bridge.]
Game Farm Wilderness Park emphasizes a connection with the natural environment. It
has limited development and has preserved most of the native woodland along the White
River.
[Game Farm Wilderness Park] was also built with the state Department of Parks on land
formerly a game and wildlife area. The property was also part of the Department of Game
land, opposite side of the Stuck River from Game Farm Park.
The White River at this location is severely confined in the leveed reach at the proposed bridge
crossing. Indeed, the levee has incurred damage from floods and is prompting repairs in some
locations.1 This confinement has induced scour to spawning substrate and coarsened the bed, and
simplified habitat. As a result, little to no spawning occurs in this leveed reach. To improve the
habitat conditions, the only meaningful correcting must start with setting back these levees where
possible to remove this confined condition.
The Tribe and King County have been working to restore the flood plain and channel migration
opportunities just upstream at the Trans-Canada site, and we would like to work towards
extending this effort downstream in areas where channel migration is geomorphically possible.
This would include opportunities at Game Farm Wilderness Park, which exhibits a network of
historic side channels and evidence of river occupation.
The bridge option and utility access relies on the continuance of the levee, trail, and currently
confined condition. There remain many challenges to implement the Trans-Canada project, and
certainly, the bridge will not make a levee setback easier to implement. To enable a levee
setback, it will involve working around challenging engineering constraints and require
maintenance of the access trail for the transmission line as well as utility vehicle services. The
piers and surrounding rock within the levee prism will induce a hard-point that controls river
morphology and will dissuade river restoration opportunities if they are a perceived threat to the
piers, trail, access, and integrity of the water line, which will likely be viewed by the City as a
priority over habitat restoration.
For these reasons, a bridge is counter-productive to the Tribe’s habitat restoration objectives, and
will impose further challenges to implement meaningful projects such as a levee setback and
flood plain restoration.
1 King County Stuck River road repair approximately 0.25 miles upstream of the R Street Bridge.
___________________________________________________________________________
MITFD comments on the City of Auburn’s
Coal Creek Springs Water Main Replacement Project,
Shorelines Conditional Use Permit SHL20-0008 P a g e 4 | 12
Muckleshoot Fishery
The Tribe has fishers that rely upon treaty-protected fishing sites in the vicinity of the proposed
bridge and upstream. With increased public access from the Game Farm Park, there will be
increased potential for harassment of Tribal fishers, vandalism to their nets and fishing features,
poaching, theft from nets, and hence will result in more difficulty for fishers to continue their
fishing culture as stated and protected by treaties. Despite the laws protecting tribal access to
their fishing sites, Tribal fishers report that harassment and vandalism is a problem where the
public has access. Increasing public access will subsequently increase the difficulty for Tribal
fishers.
In response to MIT Fishery concerns, the City has previously offered the following:
To minimize the impact this Project may have on Tribal fishing sites due to an increase in public
access to Game Farm Wilderness Park the City plans to take the following measures as part of the
project:
• Extend the security fencing and add additional signage where the White River Trail ends at the
eastern park boundary to discourage the public from using the trail to access private properties east
of the park.
• Try and remove the White River Trail from any map that shows the White River Trail extending
east beyond the park boundary (it’s shown this way on Google Maps for example). The City has
confirmed with King County that they do not maintain a trail on their property east of the park.
• A gate will be installed on the bridge that will be closed at night.
• Non-removable bollards will be installed on both sides of the bridge to ensure it is only used by
pedestrians and not vehicles.
Security fencing, signage, night-time gates, and removal of the trails from maps will
likely be ineffective towards reducing an increase in public access to MIT lands and
fishing sites. If the bridge provides maintenance access in any form, it is likely to be used
by humans to cross, even if unlawfully. There already is a large homeless population in
this vicinity, where additional access opportunity will likely be exploited and increased.
MIT Fisheries staff have observed filleted Chinook carcasses near homeless
encampments here, suggesting poaching or theft from tribal nets. Increasing opportunities
for human access will not help this problem. The only effective above-ground crossing
for the pipeline to limit human access would be to preclude all opportunity for foot
crossing, lawful or not, such as maintenance access.
We maintain that there are water transmission pipe crossing alternatives less impactful to the
SMP, County’s FHMP, and MIT fisheries needs than the proposed bridge alternative. We ask the
Hearing Examiner to consider these impacts and require the City to find a different alternative for
this crossing.
Thank you for this opportunity to provide comments on this extremely important project to the
Tribe. Please feel free to contact me with any questions.
___________________________________________________________________________
MITFD comments on the City of Auburn’s
Coal Creek Springs Water Main Replacement Project,
Shorelines Conditional Use Permit SHL20-0008 P a g e 5 | 12
Sincerely,
Martin J. Fox, Ph.D.
Fisheries Biologist
CC:
WA Department of Ecology
Julian Douglas, WDFW
___________________________________________________________________________
MITFD comments on the City of Auburn’s
Coal Creek Springs Water Main Replacement Project,
Shorelines Conditional Use Permit SHL20-0008 P a g e 6 | 12
Appendix A: MITFD additional follow-up responses to the City’s 9/17/2021 responses
City’s Response to MIT Concerns About the Subjectivity of the Alternatives Summary
Report
The geotechnical borings for a new water-main crossing at White River are confined to the
project site now proposed for a bridge crossing but originally considered for a crossing by
horizontal directional drilling (HDD) circa 2017. Geotechnical borings were not used to evaluate
other locations for a new water-main crossing via HDD rather than a new bridge at the proposed
site.
City’s Responses to Specific MIT Comments on the Jacob’s Alternatives Analysis (1)
The City’s response states “The replacement of the transmission line under the river has been
deferred as long as possible [after most of the transmission main was replaced in the 1960s] due
to the complexity and cost associated with replacing it. It is not a valid supposition that since
replacement of the river crossing was previously deferred that it can continue to be deferred or
that the replacement is not urgent.” MITFD has never contested or “[supposed]” replacement of
the City’s water main below the White River should be deferred, or that its replacement is not is
an urgent interest to the City or others. MITFD has objected to a new water main crossing
affixed to a new bridge over White River, and recommended instead evaluation of alternative
crossing-sites via HDD, or a crossing at “R” Street bridge. The City has not adequately
demonstrated either alternative is invalid, and thus proposes further impacts to a vastly maligned
reach of White River via a new bridge crossing rather than not.
City’s Responses to Specific MIT Comments on the Jacob’s Alternatives Analysis (2)
The City’s response states “As stated in the Alternatives Summary Report, the current R St
bridge would need to be reconstructed to add the new pipe crossing and the timeline to permit,
design, and construct the new bridge could take 10+ years.” But the City’s response also states
the City can “consider short term improvements that may temporarily extend the life of the
existing waterline; however, this line will be required to be replaced within the next 10 to 15
years regardless.” Accordingly, the City should consider adding replacement of the c.1965 ‘R’
Street bridge to its CIP program and request a portion of the $550 B in federal funding authorized
in 2021 for infrastructure improvements over fiscal years 2022-2026, including bridges, so that
the ‘R’ Street bridge can be widened to support re-naturalization of the grossly-constrained river
there and accommodate needs for replacement of a river crossing that transfers water supplied
form Coal Creek Springs. This approach is superior to any that further constrains Lower White
River with a new bridge crossing.
City’s Responses to Specific MIT Comments on the Jacob’s Alternatives Analysis (3)
The City’s response states “even if the timeline to permit, design, and construct the new bridge
was less than 10 years this option would still be deemed infeasible because it would involve
replacing a significant transportation bridge decade(s) before it needed to be replaced for the sole
reason of adding the new pipe.” It is important to note that the primary reason for replacing the
___________________________________________________________________________
MITFD comments on the City of Auburn’s
Coal Creek Springs Water Main Replacement Project,
Shorelines Conditional Use Permit SHL20-0008 P a g e 7 | 12
‘R’ Street bridge is not its c.1965 antiquity (regardless of design life), but chiefly for public
benefit to re-naturalize the river at that reach as needed to reduce flood risks and maintenance
costs for river “facilities” where the river is grossly narrowed by imposition of levees and
revetments emplaced shortly prior to bridge construction.
City’s Responses to Specific MIT Comments on the Jacob’s Alternatives Analysis (4)
The City’s response states “The City has evaluated the pipe lining method and does not feel it
represents a permanent replacement alternative for the 100-year old pipe.” MITFD asserts that
that City has not adequately documented why the pipe-lining method is not a viable solution for
replacing the 100-year-old pipe for which it deferred replacement during 1960s when other
portions of its water main were replaced.
City’s Responses to Specific MIT Comments on the Jacob’s Alternatives Analysis (5)
The City’s response states “The bridge isn’t relevant to MIT’s fish propagation facilities, but
replacement of the transmission main is relevant because the City will not expand the Coal Creek
Springs facilities until and unless the main is replaced. The 1986 settlement agreement states that
during the summer and fall months MIT will reduce its water usage below 3.9 cfs as needed for
domestic water services. This means that as the City grows and the domestic water needs
increase, the summer and fall water available to MIT fisheries would likely be reduced down to
the minimum amount allowed in the agreement Permanent replacement of the river crossing and
subsequent expansion of the Coal Creek Springs facilities (with or without a pedestrian bridge)
may avoid this reduction in water availability to MIT fisheries operations and allow it to be at the
full agreement allocation through the summer and fall months.” It is important to note that
nothing in MITFD comments about the City’s plans for “The replacement of the transmission
line under the river” compromise any word in agreements between MIT and the City.
City’s Responses to Specific MIT Comments on the Jacob’s Alternatives Analysis (6)
The City’s response states “the City would like to clarify that the current bridge design is not
intended to accommodate vehicular access. It is intended to carry the water transmission main.
The pedestrian facilities are an afterthought and perceived added benefit to the communities non-
motorized transportation network and recreational use.” It is ironic to learn the City of Auburn
Capital Project CP1603, Coal Creek Springs Transmission Main Replacement Project, Shoreline
Conditional Use Permit, SHL20-0008 proposes actions that are not afterthoughts, including
pedestrian access, specifically “to provide a pedestrian linkage between City’s Game Farm Park
and Game Farm Wilderness Park, which is divided by the White River.” Nowhere in the
application does the City state it will not use the proposed new bridge for vehicle traffic related
to park excursions, maintenance, or security.
City’s Responses to Specific MIT Comments on the Jacob’s Alternatives Analysis (7)
The City’s response states “The City would be amenable to removing the pedestrian facilities
from the design and providing a utility-only bridge if this would mean it would have MIT’s
support for the bridge. If this were the case, maintenance access would still be required but would
___________________________________________________________________________
MITFD comments on the City of Auburn’s
Coal Creek Springs Water Main Replacement Project,
Shorelines Conditional Use Permit SHL20-0008 P a g e 8 | 12
be secured to keep pedestrians from accessing the bridge.” As noted above, the City’s response
explains the City could exclude pedestrian access at the proposed bridge. But the City of Auburn
Capital Project CP1603, Coal Creek Springs Transmission Main Replacement Project, Shoreline
Conditional Use Permit, SHL20-0008 does not do so, or exclude vehicle access for park
maintenance as required for a “a utility-only bridge.”
City’s Responses to Specific MIT Comments on the Jacob’s Alternatives Analysis (8)
The City’s response states “This section lists the alternative means that were considered when
evaluating the feasibility of the HDD method but ultimately all means were considered to be
infeasible due to the physical presence of boulder and cobbles and the unacceptable risks they
could pose during construction… additional geotechnical work did not evaluate any approach to
reducing HDD drill risks, such as an alternative HDD alignment or a longer HDD length
[emphasis added].” Most importantly, MITFD notes that the City did not investigate additional
geotechnical work to evaluate reduced “HDD drill risks, such as an alternative HDD alignment
or a longer HDD length.” Instead the City proceeded with work to evaluate a water-main
crossing at the proposed site, as long planned, absent borings to evaluate the feasibility of a
water-main crossing via HDD elsewhere. Furthermore, the cumulative percent finer for bed load
material collected by Czuba et al. (2012) at RM 10.5, co-located with USGS gage 12100490
(near ‘R’ Street bridge), as reported by Anderson and Jaeger (2020) (see Figure 4), illustrates that
shallow subsurface materiel at White River channel in the project vicinity is predominantly finer
than cobble size. Therefore, the risk of hitting large boulders with the HDD method is seemingly
unsupported by the finer composition of existing sediment.
References
Anderson, S.W., and Jaeger, K.L., 2020, Supporting Data for Sediment Studies in the White River Watershed,
U.S. Geological Survey data release, https://doi.org/10.5066/P9HT46KB.
Czuba, J.A., Magirl, C.S., Czuba, C.R., Curran, C.A., Johnson, K.H., Olsen, T.D., Kimball, H.K. and Gish,
C.C., 2012. Geomorphic analysis of the river response to sedimentation downstream of Mount
Rainier, Washington. US Department of the Interior, US Geological Survey.
___________________________________________________________________________
MITFD comments on the City of Auburn’s
Coal Creek Springs Water Main Replacement Project,
Shorelines Conditional Use Permit SHL20-0008 P a g e 9 | 12
Figures
Figure 1. Gravel removal operations at White River in vicinity of prosed bridge (Auburn SCUP
SHL20-0008). View is toward right-bank at “Auburn Wall” in Game Farm Park. Photo by Dennis
Moore, MITFD, October 1978 (slide 29-21).
___________________________________________________________________________
MITFD comments on the City of Auburn’s
Coal Creek Springs Water Main Replacement Project,
Shorelines Conditional Use Permit SHL20-0008 P a g e 10 | 12
Figure 2. Gravel removal operations at White River in vicinity of prosed bridge (Auburn SCUP SHL20-
0008). View is upstream toward bluff along right-bank above Game Farm Park, which is out of view
toward left. Photo by Dennis Moore, MITFD, October 1978 (slide 18-07). Note on slide jacket states
"Miles Work at Game Farm Dam."
___________________________________________________________________________
MITFD comments on the City of Auburn’s
Coal Creek Springs Water Main Replacement Project,
Shorelines Conditional Use Permit SHL20-0008 P a g e 11 | 12
Figure 3. Gravel removal operations at White River in vicinity of prosed bridge (Auburn SCUP SHL20-
0008). View is downstream toward proposed bridge site. Game Farm Park is located at upper left.
Note levee along left-bank, and gravel berm along right-bank. Photo by Dennis Moore, MITFD,
October 1978 (slide 29-16).
___________________________________________________________________________
MITFD comments on the City of Auburn’s
Coal Creek Springs Water Main Replacement Project,
Shorelines Conditional Use Permit SHL20-0008 P a g e 12 | 12
Figure 4. The cumulative percent finer for bed load material collected by Czuba et al.
(2012) at RM 10.5, co-located with USGS gage 12100490 (near ‘R’ Street bridge), as
reported by Anderson and Jaeger (2020). These plots illustrate that shallow subsurface
materiel at White River channel in the project vicinity is predominantly finer than cobble
size.