HomeMy WebLinkAbout06-18-2024 AgendaPlanning Commission Meeting
J une 18, 2024 - 6:30 P M
City Hall Council Chambers
A GE NDA
I .P UB L I C PART I C IPAT IO N
A .P ublic P articipation I nformation
The City of A uburn P lanning Commission Meeting scheduled for Tuesday, J une 18,
2024, at 6:30 p.m., will be held in person and virtually. To attend the meeting virtually,
click one of the links below, or call in at one of the phone numbers below:
J oin Z oom Meeting
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Meeting I D: 799 910 2307
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I I .C AL L T O O RD E R
A .RO L L C AL L/E S TAB L I S HM E NT O F Q UO RUM
B .P L E D G E O F AL L E G I ANC E
I I I .P UB L I C C O M M E NT
Comment from the audience on any proposal for action by the Commission. I f the comment
is related to an action subsequently listed here as a public hearing, the comment should be
provided at the time of the public hearing.
I V.AP P RO VAL O F M INUT E S
A .May 21, 2024 Draft Minutes from the S pecial Planning Commission Meeting
V.I NT RO D UC T I O N
A .P resentation Overview (S teiner)
B rief overview of upcoming Element Presentations and Public Hearing schedule.
Page 1 of 373
V I .P UB L I C HE ARI NG S
A .S tormwater P lan Element (Carlaw)
S taff presentation on the proposed changes to the Comprehensive S tormwater P lan.
V I I .O T HE R B US I NE S S
A .Capital Facilities E lement (Steiner)
S taff P resentation of the proposed changes to the Capital F acilities Element.
B .Comprehensive Plan D E IS (S teiner)
S taff to provide update on Comprehensive P lan D E I S, public meetings, and E I S
schedule.
V I I I .C O M M UNIT Y D E V E L O P M E NT RE P O RT
I X.AD J O URNM E NT
The City of Auburn Planning Commission is a seven member advisory body that provides
recommendations to the Auburn City Council on the preparation of and amendments to land
use plans and related codes such as zoning. Planning Commissioners are appointed by the
Mayor and confirmed by the City Council.
Actions taken by the Planning Commission, other than approvals or amendments to the
Planning Commission Rules of Procedure, are not final decisions; they are in the form of
recommendations to the city council which must ultimately make the final decision.
Page 2 of 373
AGENDA BILL APPROVAL FORM
Agenda Subject:
May 21, 2024 Draft Minutes from the Special Planning
Commission Meeting
Date:
June 10, 2024
Department:
Community Development
Attachments:
May 21, 2024 Draft Minutes
Budget Impact:
Current Budget: $0
Proposed Revision: $0
Revised Budget: $0
Administrativ e Recommendation:
Background for Motion:
Background Summary:
Rev iewed by Council Committees:
Councilmember:Staff:Teague
Meeting Date:June 18, 2024 Item Number:
Page 3 of 373
Planning Commission Meeting
May 21, 2024 - 6:00 P M
Special Meeting - City Hall Council
Chambers
MINUT E S
I .P UB L I C PART I C IPAT IO N
A .P ublic P articipation I nformation
T he City of Auburn Planning Commission M eeting was held in
person and virtually.
I I .C AL L T O O RD E R
Chair J udi Roland called the meeting to order at 6:00 p.m. in the
Council Chambers of Auburn City Hall, 25 West M ain Street.
A .RO L L C AL L/E S TAB L I S HM E NT O F Q UO RUM
Commissioners present: Chair J udi Roland, Vice Chair P hillip
S tephens, J ulie Berry, Kent S prague, William Stewart, Aaron
Vanderpol, and Lynn Walters.
S taff members present: Acting Planning Services M anager
Alexandrea Teague, Acting City Attorney Doug Ruth, Director of
P ublic Works Ingrid Gaub, Utilities E ngineering M anager Ryan
Vondrak, S torm Drainage Utility Engineer T im Carlaw, Sewer Utility
E ngineer Robert E lwell, Planner Gabriel Clark, and Deputy City
Clerk Rebecca Wood-P ollock
B .P L E D G E O F AL L E G I ANC E
Chair Roland led those in attendance in the Pledge of Allegiance.
I I I .P UB L I C C O M M E NT
T here was no public comment.
I V.AP P RO VAL O F M INUT E S
A .A pril 30, 2024 Draft Minutes from the S pecial Planning Commission Meeting
Vice Chair Stephens moved and Commissioner S tewart seconded
to approve the April 30, 2024 P lanning Commission M eeting
M inutes.
M O T I O N C ARRI E D UNANI M O US LY. 7-0
Page 1 of 3Page 4 of 373
V.O T HE R B US I NE S S
A .P resentation Overview (Teague)
S taff will provide a brief overview of upcoming Element Presentations and Public
Hearing schedule.
M anager Teague provided the Commission with an update on the
future Comprehensive Plan E lement presentations and addressed
updates to the Public Hearing schedule.
B .S ewer P lan Element (E lwell)
S taff presentation of the proposed changes to the S ewer P lan Element.
Chair Roland opened the P ublic Hearing at 6:06 p.m.
S ewer Utility Engineer Elwell shared a presentation with the
Commission on the Utilities E lement and Sewer Plan Overview and
Update, including progress with the P lan's development, an
introduction on the Sanitary S ewer Utility process, an overview of
the 2024 Sanitary S ewer Comprehensive Plan, and the next steps in
the process.
T he Commission discussed future expansion to accommodate for
population growth, the new King County Waste T reatment Center,
regulations on sewage treatment, Roegner P ark sewer capacity
improvements, inflow and infiltration analysis, rainfall predictions
for 2024, pipe capacity, pipe lining and rehabilitation, the 2013
M uckleshoot Tribe Utility Services Agreement, the Capital F unding
P lan, and sewer monitoring systems.
Vice Chair Stephens moved and Commissioner Vanderpol
seconded to continue the P ublic Hearing to the next P lanning
Commission meeting on J une 4, 2024.
M O T I O N C ARRI E D UNANI M O US LY. 7-0
V I .AD J O URNM E NT
T here being no further business to come before the Planning
Commission, the meeting was adjourned at 6:45 p.m.
AP P RO V E D this 18th day of J une, 2024.
________________________ _________________________
J UD I RO L AND, C HAIR Rebecca Wood-Pollock,
Deputy City Clerk
The City of Auburn Planning Commission is a seven member advisory body that provides
Page 2 of 3Page 5 of 373
recommendations to the Auburn City Council on the preparation of and amendments to land
use plans and related codes such as zoning. Planning Commissioners are appointed by the
Mayor and confirmed by the City Council.
Actions taken by the Planning Commission, other than approvals or amendments to the
Planning Commission Rules of Procedure, are not final decisions; they are in the form of
recommendations to the city council which must ultimately make the final decision.
Page 3 of 3Page 6 of 373
AGENDA BILL APPROVAL FORM
Agenda Subject:
Presentation Overview (Steiner)
Date:
June 11, 2024
Department:
Community Development
Attachments:
2024 Comp Plan Memorandum
Budget Impact:
Current Budget: $0
Proposed Revision: $0
Revised Budget: $0
Administrativ e Recommendation:
Background for Motion:
Background Summary:
See attached Memorandum.
Rev iewed by Council Committees:
Councilmember:Staff:Steiner
Meeting Date:June 18, 2024 Item Number:
Page 7 of 373
Memorandum
To: Judi Roland, Chair, Planning Commission
Planning Commission Members
From: Josh Steiner, Senior Long-Range Planner, Comm. Dev. Dept.
Tim Carlaw, Storm Drainage Utility Engineer, Public Works
Date: June 18, 2024
Re: Special Meeting: 2024 Comprehensive Plan - Planning Commission
Each city and county in Washington state is required to conduct a periodic update of its
comprehensive plan and development regulations per RCW 36.70A.130 (The Growth
Management Act or GMA). In general, the purpose is to ensure consistency with the Puget
Sound Regional Council Vision 2050, the Countywide Planning Policies (for Auburn this means
both Pierce and King County), any changes in state laws over the intervening time, and to
respond to changing conditions within the local community.
Tonight, a public hearing on the Stormwater Comprehensive Plan and a public meeting on the
Capital Facilities Element will be conducted. This meeting is open to the public and has been
advertised appropriately as a regular meeting. The table below illustrates current, past, and
upcoming Planning Commission meetings for the Comprehensive Plan update, as well as
subject.
Subject Public
Meeting
Public
Hearing
Deliberation and
Action
Land Use N/A
Housing N/A
Historic Preservation N/A
Economic Development N/A
Climate N/A
Parks and Open Space N/A
Sewer Plan September 17
Transportation July 16 July 16
PROS Plan TBD TBD
Stormwater Plan June 18 If Needed
Capital Facilities June 18 July 2 October 23
Water System Plan July 2 July 16 October 23
Utilities Element July 2 July 16 October 23
Page 8 of 373
Planning Commission Comp Plan
Action (Community
Development/Parks)
July 16
For reference, the current adopted Comprehensive Plan Elements can be found here.
Feel free to contact Josh Steiner, Senior Planner, at jsteiner@auburnwa.gov or 253-804-5064
with any questions.
Included Attachments:
Attachment A – Stormwater Planning Commission Presentation
Attachment B – V3 Draft Auburn Comp Storm Drainage Plan
Attachment C – Capital Facilities Element Planning Commission Presentation
Attachment D – V1 Draft 2024 Capital Facilities Element
Note: V1 = Currently adopted Plan showing staff edits
V2 = Clean version of V1 with staff edits incorporated
V3 = Clean version of V2 with edits incorporated, showing edits in response to public
comments, Planning Commission comments, and/or agency comments. May include
maps or other figures that have been amended by staff since V2 in response to
comments.
If V1 is not available, please see currently adopted Element via link above.
Page 9 of 373
AGENDA BILL APPROVAL FORM
Agenda Subject:
Stormwater Plan Element (Carlaw)
Date:
June 11, 2024
Department:
Community Development
Attachments:
Attachment A - Stormwater Presentation
Attachment B - V3 Draft Auburn Comp Storm
Drainage Plan
Budget Impact:
Current Budget: $0
Proposed Revision: $0
Revised Budget: $0
Administrativ e Recommendation:
Background for Motion:
Background Summary:
See Attachments
Rev iewed by Council Committees:
Councilmember:Staff:Carlaw
Meeting Date:June 18, 2024 Item Number:PH.1
Page 10 of 373
AUBURN
VALUES
SERVICE
ENVIRONMENT
ECONOMY
CHARACTER
SUSTAINABILITY
WELLNESS
CELEBRATION
ENGINEERING SERVICES
2024 COMPREHENSIVE
STORM DRAINAGE PLAN
PUBLIC HEARING OVERVIEW
TIM CARLAW, STORM DRAINAGE UTILITY
ENGINEER
PLANNING COMMISSION MEETING
JUNE 18, 2024
Public Works Department
Engineering Services Airport Services Maintenance & Operations Services
Page 11 of 373
SERVICE ENVIRONMENT ECONOMY CHARACTER SUSTAINABILITY WELLNESS CELEBRATION
2024 Comprehensive Storm Drainage Plan
overview and update was presented to the
Planning Commission May 4, 2024.
Storm Utility goals and policies were
previously discussed with City Council May
2023.
Plan now includes the appendices; no
changes to the individual chapters have been
made.
2
2024 STORM DRAINAGE COMPREHENSIVE PLAN
Page 12 of 373
SERVICE ENVIRONMENT ECONOMY CHARACTER SUSTAINABILITY WELLNESS CELEBRATION
Appendices include:
A) The draft 2024-2029 NPDES Permit
B) Technical Memo on Hydrology and
Hydraulic analysis
C) Evaluation of Asset Management system
D) Regulatory -Driven Improvements
Assessment
E) Drainage Ditch Maintenance Program
F) SEPA Compliance Documentation
3
2024 STORM DRAINAGE COMPREHENSIVE PLAN
Page 13 of 373
SERVICE ENVIRONMENT ECONOMY CHARACTER SUSTAINABILITY WELLNESS CELEBRATION
Any Questions?
2024 STORM DRAINAGE COMPREHENSIVE PLAN
4Page 14 of 373
SERVICE ENVIRONMENT ECONOMY CHARACTER SUSTAINABILITY WELLNESS CELEBRATION
~Previously Presented Slides~
5Page 15 of 373
AUBURN
VALUES
SERVICE
ENVIRONMENT
ECONOMY
CHARACTER
SUSTAINABILITY
WELLNESS
CELEBRATION
ENGINEERING SERVICES
2024 COMPREHENSIVE
STORM DRAINAGE PLAN
OVERVIEW AND UPDATE
TIM CARLAW, STORM DRAINAGE UTILITY
ENGINEER
PLANNING COMMISSION MEETING
JUNE 4, 2024
Public Works Department
Engineering Services Airport Services Maintenance & Operations Services
Page 16 of 373
SERVICE ENVIRONMENT ECONOMY CHARACTER SUSTAINABILITY WELLNESS CELEBRATION
2024 COMPREHENSIVE STORM PLAN IS PART OF THE
CITY COMPREHENSIVE PLAN
Auburn Comprehensive Plan Elements
Core Plan (Community Development)
Land Use Element (Community Development)
Housing Element (Community Development)
Historic Preservation (Community Development)
Climate Change – NEW (Community Development)
Economic Development (Community Development)
Capital Facilities Element (Public Works)
Transportation Element (Public Works)
Utilities Element (Public Works)
Parks and Recreation (Parks)
Citywide effort involving all departments coordinating together to create a
cohesive, consistent, and forward-thinking Plan covering range of subject areas
7Page 17 of 373
SERVICE ENVIRONMENT ECONOMY CHARACTER SUSTAINABILITY WELLNESS CELEBRATION
Spring 2023 –
Council review
of goals and
policies
•Identify potential
future Issues
•Gather potential
project information
•Update asset
management inventory
Fall 2023 –
Select projects
for
implementation
•National Pollutant
Discharge Elimination
System (NPDES)
requirements
•SMAP
implementation
•Plan for future
projects
Spring 2024 -
Planning
Commission
review
•NPDES permit
issue
•Public input
•SEPA review
Fall 2024 –
City Council
review and
adoption
8
PLAN DEVELOPMENT PROGRESS/MILESTONES
Page 18 of 373
SERVICE ENVIRONMENT ECONOMY CHARACTER SUSTAINABILITY WELLNESS CELEBRATION
Storm Drainage Utility Service
Area = City Limits
240 miles pipe
40 miles of ditches
10,275 catch basins
3,025 manholes
167 stormwater ponds
7 pump stations
STORM DRAINAGE UTILITY INTRODUCTION
SERVICE ENVIRONMENT ECONOMY CHARACTER SUSTAINABILITY WELLNESS CELEBRATION 9Page 19 of 373
SERVICE ENVIRONMENT ECONOMY CHARACTER SUSTAINABILITY WELLNESS CELEBRATION
Chapter 1 - Introduction
Purpose and objectives
Approach and document
organization
Chapter 2 - Background
Utility organization and
funding
Regulatory standards
National Pollutant Discharge
Elimination System (NPDES) Phase II
Municipal Stormwater Permit
Storm Water Management Manual for
Western Washington (SWMMWW)
10
2024 STORM DRAINAGE COMPREHENSIVE PLAN
Page 20 of 373
SERVICE ENVIRONMENT ECONOMY CHARACTER SUSTAINABILITY WELLNESS CELEBRATION
2024 STORM DRAINAGE COMPREHENSIVE PLAN
June 26,
2023
•Broad statements indicating
a general aim or purpose to
be achieved.Goals
•Topic-specific statement
providing guidelines for
current and future decision-
making.
•Indicates a clear commitment
of the local legislative body.
Policies
11
Chapter 3 – System Goals
and Policies
System planning
Operations and
maintenance
Fiscal responsibility
Environment and regional
coordination
Storm Drainage Policies -
City Council Review &
Discussion
Page 21 of 373
SERVICE ENVIRONMENT ECONOMY CHARACTER SUSTAINABILITY WELLNESS CELEBRATION
Chapter 4 – Description of
Existing System
Natural drainage features of
the area
Geology
Geography
Groundwater
Land use and development
Inventory of assets
12
2024 STORM DRAINAGE COMPREHENSIVE PLAN
Page 22 of 373
SERVICE ENVIRONMENT ECONOMY CHARACTER SUSTAINABILITY WELLNESS CELEBRATION
Chapter 4 – Description of
Existing System
Climate change analysis
Risk mitigation
Cost-Benefit of system
resilience
Ecology SWMMWW revisions
Regional studies and models
13
2024 STORM DRAINAGE COMPREHENSIVE PLAN
Hegewisch, K.C., Abatzoglou, J.T., Chegwidden,O., and Nijssen, B. 2023. Climate Mapper web tool.
Climate Toolbox.
Page 23 of 373
SERVICE ENVIRONMENT ECONOMY CHARACTER SUSTAINABILITY WELLNESS CELEBRATION
Chapter 5 - Storm Drainage
Utility Analysis
Hydraulic evaluation of
known problem areas
Asset management review
Regulatory driven
improvements
14
2024 STORM DRAINAGE COMPREHENSIVE PLAN
Page 24 of 373
SERVICE ENVIRONMENT ECONOMY CHARACTER SUSTAINABILITY WELLNESS CELEBRATION
Chapter 6 - Operations and
Maintenance
Routine operations
Non-Routine and emergency
operations
Record keeping
Staffing requirements
15
2024 STORM DRAINAGE COMPREHENSIVE PLAN
Page 25 of 373
SERVICE ENVIRONMENT ECONOMY CHARACTER SUSTAINABILITY WELLNESS CELEBRATION
Chapter 7 - Capital Projects
6 Year CIP
Vegetation Sorting Facility
287th St SE WQ Road Retrofit
2026 Local St Preservation
R St SE (22nd St to 33rd St)
Storm Pipeline Extension Program
Street Utility Improvements
Frame & Grate Replacement
Storm Drainage R&R Program
284th St SE (West) WQ Road Retrofit
West Main St Pump Station Upgrade
M St NE Widening
16
2024 STORM DRAINAGE COMPREHENSIVE PLAN
Page 26 of 373
SERVICE ENVIRONMENT ECONOMY CHARACTER SUSTAINABILITY WELLNESS CELEBRATION
Chapter 8 – Implementation
6 -year CIP
Programmatic measures for
NPDES compliance
Future staffing options
Asset management
expansion
Additional recommendations
Climate change considerations
Ditch maintenance program
17
2024 STORM DRAINAGE COMPREHENSIVE PLAN
Page 27 of 373
SERVICE ENVIRONMENT ECONOMY CHARACTER SUSTAINABILITY WELLNESS CELEBRATION
Chapter 9 - Finance
6 -year review
Planned expenses funding plan
10-year forecast
Maintaining reserves
Projected rates
18
2024 STORM DRAINAGE COMPREHENSIVE PLAN
Page 28 of 373
SERVICE ENVIRONMENT ECONOMY CHARACTER SUSTAINABILITY WELLNESS CELEBRATION
NEXT STEPS
SERVICE ENVIRONMENT ECONOMY CHARACTER SUSTAINABILITY WELLNESS CELEBRATION
December
2024
•Resolution for
Adoption
August
2024
•Draft Plan
Discussion with
Council
June-
August
2024
•SEPA and Agency
Reviews
June
2024
•Planning Commission
Meeting - Tonight
•Public Hearing and
Deliberation – June 18
19Page 29 of 373
SERVICE ENVIRONMENT ECONOMY CHARACTER SUSTAINABILITY WELLNESS CELEBRATION
Any Questions?
2024 STORM DRAINAGE COMPREHENSIVE PLAN
20Page 30 of 373
Draft
Comprehensive Storm
Drainage Plan Update
Prepared for
June 2024
Page 31 of 373
Draft Comprehensive Storm
Drainage Plan Update
Prepared for
City of Auburn
25 W Main Street
Auburn, WA 98001
Prepared by
Parametrix
719 2nd Avenue, Suite 200
Seattle, WA 98104
T. 206.394.3700 F. 1.855.542.6353
www.parametrix.com
June 2024 │ 553-1931-052
Page 32 of 373
Citation
Parametrix. 2024. Draft Comprehensive Storm
Drainage Plan Update.
Prepared for City of Auburn by Parametrix,
Seattle, Washington.
June 2024.
Page 33 of 373
Draft Comprehensive Storm Drainage Plan Update
City of Auburn
June 2024 │ 553-1931-052 i
Contents
1. Introduction .................................................................................................................................. 1-1
1.1 Purpose and Objectives........................................................................................................... 1-1
1.2 Approach and Document Organization .................................................................................. 1-2
2. Background .................................................................................................................................. 2-1
2.1 Storm Drainage Utility.............................................................................................................. 2-1
2.1.1 Organizational Structure ........................................................................................... 2-1
2.1.2 Funding Mechanisms ............................................................................................... 2-2
2.2 Development Code and Design Standards Updates ............................................................. 2-4
2.3 Regulatory and Policy Considerations .................................................................................... 2-4
2.3.1 Growth Management Act .......................................................................................... 2-3
2.3.2 Phase II Municipal Stormwater Permit .................................................................... 2-3
2.3.3 Governmental Accounting Standards Board ........................................................... 2-3
3. System Goals and Policies ........................................................................................................... 3-1
3.1 City Comprehensive Plan Consistency ................................................................................... 3-1
3.2 Storm Drainage Comprehensive Plan Policy Goals ............................................................... 3-1
3.2.1 System Planning........................................................................................................ 3-1
3.2.2 Operations and Maintenance ................................................................................... 3-2
3.2.3 Fiscal Responsibility.................................................................................................. 3-3
3.2.4 Environment and Regional Coordination ................................................................. 3-3
4. Drainage System .......................................................................................................................... 4-1
4.1 Natural Drainage ..................................................................................................................... 4-1
4.1.1 Receiving Waters ...................................................................................................... 4-3
4.1.2 Drainage Areas .......................................................................................................... 4-4
4.1.3 Geology and Groundwater ........................................................................................ 4-6
4.1.4 Soils and Runoff Potential ........................................................................................ 4-8
4.1.5 Land Use and Development ..................................................................................... 4-8
4.1.6 Flood Hazard Mapping ............................................................................................ 4-11
4.1.7 Recent Climate and Precipitation Trends .............................................................. 4-11
4.1.8 Anticipated Changes in Climate ............................................................................. 4-12
4.2 Stormwater Drainage Infrastructure .................................................................................... 4-15
4.3 Critical Facilities ..................................................................................................................... 4-18
4.4 Water Quality .......................................................................................................................... 4-20
Page 34 of 373
Draft Comprehensive Storm Drainage Plan Update
City of Auburn
Contents (continued)
June 2024 │ 553-1931-052 ii
4.4.1 Existing Conditions .................................................................................................. 4-20
4.4.2 Regulatory Compliance ........................................................................................... 4-20
4.5 Existing Drainage Problems .................................................................................................. 4-21
5. Evaluation of the Storm Drainage Utility ...................................................................................... 5-1
5.1 Hydraulic Evaluation ................................................................................................................ 5-1
5.1.1 Updating Existing Models ......................................................................................... 5-2
5.1.2 Creating New Models ................................................................................................ 5-2
5.1.3 Updating Precipitation Record and Flow Frequency ............................................... 5-3
5.2 Asset Management Review ..................................................................................................... 5-3
5.2.1 Best Practices ........................................................................................................... 5-3
5.2.2 Evaluation .................................................................................................................. 5-4
5.2.3 Recommendations .................................................................................................... 5-7
5.3 Regulatory-Driven Improvements Investigation ..................................................................... 5-8
5.3.1 New Permit Requirements and Recommendations ............................................... 5-8
5.4 Climate Change Analysis ......................................................................................................... 5-9
5.4.1 Discussion of Proposed Approaches ....................................................................... 5-9
5.4.2 Recommendations .................................................................................................. 5-11
6. Maintenance and Operations ...................................................................................................... 6-1
6.1 Utility Responsibility and Authority ......................................................................................... 6-1
6.1.1 Organizational Structure ........................................................................................... 6-1
6.1.2 Staffing Level ............................................................................................................. 6-1
6.1.3 Level of Service ......................................................................................................... 6-2
6.1.4 Training and Education ............................................................................................. 6-2
6.2 Routine Operations Provided by the Storm Drainage Utility ................................................. 6-3
6.2.1 Catch Basin and Manhole Inspection, Cleaning, and Repair ................................. 6-3
6.2.2 Stormwater Pipeline Cleaning .................................................................................. 6-3
6.2.3 Stormwater Outfall Inspection, Cleaning, and Maintenance ................................. 6-4
6.2.4 Drainage Ditch Maintenance and Restoration ........................................................ 6-4
6.2.5 Stormwater Facility Inspection, Maintenance, and Restoration ............................ 6-4
6.2.6 Culvert Inspection and Cleaning .............................................................................. 6-5
6.2.7 General Facility Maintenance and Other Field Tasks ............................................. 6-5
6.2.8 Storm Drainage Utility Overhead .............................................................................. 6-5
Page 35 of 373
Draft Comprehensive Storm Drainage Plan Update
City of Auburn
Contents (continued)
June 2024 │ 553-1931-052 iii
6.3 Routine Operations Provided to the Storm Drainage Utility .................................................. 6-6
6.3.1 Vegetation Maintenance .......................................................................................... 6-6
6.3.2 Stormwater Pump Station Maintenance ................................................................. 6-6
6.3.3 Manufactured Treatment Device Maintenance ...................................................... 6-6
6.4 Non-Routine and Emergency Operations ............................................................................... 6-7
6.4.1 Customer Service Requests ..................................................................................... 6-7
6.4.2 Emergency Response Program ................................................................................ 6-7
6.4.3 Source Control Inspection Program ......................................................................... 6-8
6.5 Data Collection and Record-Keeping ..................................................................................... 6-8
6.6 M&O Staffing Requirements ................................................................................................. 6-10
6.6.1 Existing Staffing Requirements .............................................................................. 6-10
6.6.2 Future Staffing Requirements and Equipment Needs ......................................... 6-13
6.7 Potential Improvement Opportunities and Capital Needs .................................................. 6-16
7. Capital Improvements .................................................................................................................. 7-1
7.1 Project Prioritization ................................................................................................................ 7-3
7.2 Proposed Capital Improvement Projects ................................................................................ 7-3
7.3 Programmatic Drainage Projects .......................................................................................... 7-29
8. Implementation Plan .................................................................................................................... 8-1
8.1 6-Year and 20-Year Capital Improvement Program .............................................................. 8-1
8.2 Programmatic Measures for NPDES Compliance .................................................................. 8-5
8.3 Future Staffing and Equipment Needs ................................................................................... 8-7
8.3.1 Engineering Services ................................................................................................ 8-7
8.3.2 Maintenance and Operation Services ..................................................................... 8-7
8.4 Continue Implementation of Best Practices for Asset Management ................................... 8-7
8.5 Recommendations for Additional Activities ........................................................................... 8-8
8.5.1 Climate Change ......................................................................................................... 8-8
8.5.2 Ditch Maintenance Program .................................................................................... 8-9
8.5.3 Ongoing System Updates and Capital Facilities Plan Projects ............................... 8-9
8.6 Implementation Plan ............................................................................................................. 8-10
9. Financial Plan ............................................................................................................................... 9-1
9.1 Introduction .............................................................................................................................. 9-1
9.2 Past Financial Performance .................................................................................................... 9-1
Page 36 of 373
Draft Comprehensive Storm Drainage Plan Update
City of Auburn
Contents (continued)
June 2024 │ 553-1931-052 iv
9.2.1 Comparative Financial Statements.......................................................................... 9-1
9.3 Financial Plan ........................................................................................................................... 9-5
9.4 Available Funding Assistance and Financing Resources ...................................................... 9-8
9.4.1 City Resources ........................................................................................................... 9-8
9.4.2 Outside Resources .................................................................................................... 9-8
9.4.3 Capital Financing Strategy ........................................................................................ 9-9
9.5 Financial Forecast ................................................................................................................. 9-10
9.5.1 Current Financial Structure .................................................................................... 9-11
9.5.2 Financial Forecast ................................................................................................... 9-12
9.6 Current and Projected Rates ................................................................................................. 9-15
9.6.1 Current Rates .......................................................................................................... 9-15
9.6.2 Projected Rates ....................................................................................................... 9-16
9.6.3 Affordability.............................................................................................................. 9-16
9.7 Conclusion .............................................................................................................................. 9-17
10. Limitations ................................................................................................................................. 10-1
11. References ................................................................................................................................. 11-1
FIGURES
Figure 2-1. Public Works Department Staff Organizational Chart ........................................................ 2-1
Figure 4-1. Natural Drainage Features of the City of Auburn ................................................................ 4-2
Figure 4-2. Drainage Subareas for the City of Auburn Storm Drainage Utility ..................................... 4-5
Figure 4-3. Surface Geology in the Vicinity of the City of Auburn .......................................................... 4-7
Figure 4-4. Land Use Designations for the City of Auburn .................................................................. 4-10
Figure 4-5. Projected Change in Average Precipitation for Seattle, Washington. .............................. 4-13
Figure 4-6. Projected Changes in 1-Hour Precipitation Statistics for the 2080s vs. 1970–1999 ... 4-14
Figure 4-7. Drainage Infrastructure for the City of Auburn Storm Drainage Utility ............................ 4-17
Figure 4-8. City and Storm Drainage Critical Facilities for the City of Auburn .................................... 4-19
Figure 4-9. Drainage Problem Locations for the Storm Drainage Utility ............................................ 4-23
Figure 5-1. Pipe Installation Date Relative to Total Linear Feet of Pipe ............................................... 5-4
Figure 5-2. Pipe Material Relative to Total Linear Feet of Pipe ............................................................ 5-5
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Figure 6-1. City Drainage Ditch Inventory ............................................................................................. 6-14
Figure 7-1. Capital Improvement Project Locations .............................................................................. 7-2
Figure 8-1. Annual Costs for 6-Year Capital Improvement Plan............................................................ 8-3
Figure 8-2. NPDES Compliance Schedule .............................................................................................. 8-6
Figure 8-3. Implementation Plan Activities Timeline ........................................................................... 8-11
TABLES
Table 2-1. 2024 and 2025 Utility Rates for Storm Drainage Service .................................................. 2-3
Table 2-2. Federal, State, and City Regulations, Guidance, and Programs Relevant to the
Auburn Storm Drainage Utility .......................................................................................................... 2-4
Table 4-1. Federal Emergency Management Agency Flood Insurance Rate Maps
Applicable to Auburn ....................................................................................................................... 4-11
Table 4-2. Precipitation Frequency Data for Auburn, Washington, from NOAA Atlas 2 ..................... 4-12
Table 4-3. Stormwater Drainage Infrastructure Summary .................................................................. 4-16
Table 4-4. Critical City Facilities ............................................................................................................ 4-18
Table 4-5. Critical Stormwater Facilities ............................................................................................... 4-18
Table 4-6. Existing Drainage Problems ................................................................................................. 4-21
Table 5-1. Recommended Actions Regarding New Permit Requirements ........................................... 5-9
Table 6-1. Storm Drainage Utility M&O Personnel ................................................................................. 6-2
Table 6-2. Existing Storm Drainage System Maintenance and Staffing Requirements .................... 6-10
Table 6-3. Existing Vegetation Maintenance and Staffing Requirements .......................................... 6-12
Table 6-4. Future Storm Drainage System Maintenance and Staffing Requirements ...................... 6-16
Table 7-1. Summary Programmatic Drainage Projects ....................................................................... 7-30
Table 8-1. Annual Cost Summary for 6-Year Capital Improvement Plan .............................................. 8-2
Table 8-2. Capital Improvement Cost Summary for 2031–2044......................................................... 8-4
Table 8-3. Ongoing System Updates ....................................................................................................... 8-9
Table 8-4. Capital Facilities Plan Project Schedule 2024–2026 ....................................................... 8-10
Table 9-1. Summary of Historical Fund Resources and Uses Arising from Cash Transactions .......... 9-2
Table 9-2. Summary of Historical Comparative Statements of Net Position ....................................... 9-4
Table 9-3. 10-Year and 20-Year Capital Improvement Plans ............................................................... 9-6
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Table 9-4. 10-Year Capital Improvement Plan (Escalated $) ................................................................ 9-7
Table 9-5. 10-Year and 20-Year Capital Financing Strategy ............................................................... 9-10
Table 9-7. Ending Cash Balance Summary .......................................................................................... 9-15
Table 9-8. Existing Schedule of Rates .................................................................................................. 9-15
Table 9-9. Proposed Storm Drainage Rates ......................................................................................... 9-16
Table 9-10. Community Affordability Test ............................................................................................ 9-16
APPENDICES
A DRAFT Western Washington Phase II NPDES MS4 Permit
B Hydrologic and Hydraulic Modeling Analysis
C Asset Management Evaluation
D Regulatory-Driven Improvements Assessment
E Ditch Maintenance and Operations Program - Development and Recommended Actions
F SEPA Compliance Documentation
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Acronyms and Abbreviations
ACC Auburn City Code
BMP best management practice
CCTV closed-circuit television
CDR critical drainage review
CEMP City Emergency Management Plan
CFP capital facilities plan
CIP capital improvement project
CMMS computerized maintenance management system
COA Supplement City of Auburn Supplement
CWA Clean Water Act
DEM digital elevation model
Ecology Washington State Department of Ecology
Engineering City of Auburn Department of Engineering Services
EPA Environmental Protection Agency
ESA Endangered Species Act
ESU equivalent service unit
FEMA Federal Emergency Management Agency
FIRM Flood Insurance Rate Map
FIS Flood Insurance Study
FTE full-time equivalent
GASB Governmental Accounting Standards Board
GIS geographic information system
GMA Growth Management Act
G.O. general obligation
H&H hydrologic and hydraulic
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Acronyms and Abbreviations (continued)
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HPA Hydraulic Project Approval
IDDE illicit discharge detection and elimination
KCFCD King County Flood Control District
KCSWDM King County Surface Water Design Manual
LID low impact development
LOMR Letters of Map Revision
LOS level of service
MEP maximum extent practicable
M&O maintenance and operations
MS4 municipal separate storm sewer system
NASSCO National Association of Sewer Service Companies
NFIP National Flood Insurance Program
NOAA National Oceanic and Atmospheric Administration
NPDES National Pollutant Discharge Elimination System
NRCS Natural Resources Conservation Service
NSF non-single family
OCI Overall condition index
OCR overall condition rating
PACP Pipeline Assessment and Certification Program
PCB polychlorinated biphenyl
PFAS per- and polyfluoroalkyl substance
Plan Comprehensive Storm Drainage Plan
RCP Representation Concentration Pathway
RCW Revised Code of Washington
ROW right-of-way
R&R repair and replacement
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Acronyms and Abbreviations (continued)
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RSI required supplementary information
SCIP Source Control Inspection Program
SEPA State Environmental Policy Act
SDC system development charge
SFHA Special Flood Hazard Areas
SMAP Stormwater Management Action Plan
SR State Route
SRP soluble reactive phosphorus
SWMP Stormwater Management Program
SWMMWW Surface Water Management Manual for Western Washington
TAPE Technology Assessment Protocol – Ecology
TMDL total maximum daily load
UIC underground injection control
ULID utility local improvement district
USACE U.S. Army Corps of Engineers
VRFA Valley Regional Fire Authority
WAC Washington Administrative Code
WSDOT Washington State Department of Transportation
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1. Introduction
This Comprehensive Storm Drainage Plan (Plan) for the City of Auburn, Washington, updates the
previous plan that was completed in December 2015. The 2015 Plan is being updated for several
reasons:
The Washington State Growth Management Act (GMA) requires planning documents to be
reassessed and updated periodically.
Current and future regulatory and permitting requirements, such as those associated with
the National Pollutant Discharge Elimination System (NPDES), need to be addressed. Since
adoption of the 2015 Plan, the NPDES permit was updated and reissued in 2019 and will be
updated again in August 2024.
New compliance elements, such as the Stormwater Management Action Plan (SMAP) and the
Source Control Inspection Program (SCIP) require new activities and regulatory
responsibilities.
Continued growth and system expansion via development, in addition to the 2024 annexed
development area from the City of Kent, requires new and revised evaluations of the storm
drainage system maintenance responsibilities and expanded service area.
The storm drainage system inventory has been updated and is needed to manage utility
assets and to update the analyses used for condition assessments and replacement
planning.
The capital improvements identified in the 2015 Plan needed reevaluation to account for
completed projects, new compliance elements, changes in system conditions, new problem
areas identified, and new development, as well as to incorporate new financial information.
In addition, expectations and changes to the stormwater program mission are evolving, which may
include increasing coordination with land use and watershed planning, identifying proactive actions
to update and retrofit the system, improving the maintenance programs and record-keeping,
providing area-wide or basin stormwater control systems, and considering long-term retrofitting.
This Plan contains time frames that are the intended framework for future funding decisions and
within which future actions and decisions are intended to occur. However, these time frames are
estimates and, depending on factors involved in the processing of applications and project work and
the availability of funding, the timing may change from the included time frames. The framework
does not represent actual commitments by the City of Auburn, which may depend on funding
resources available.
1.1 Purpose and Objectives
The purpose of this Plan is to guide the City’s Storm Drainage Utility with respect to future activities
and improvements. The Plan’s objectives are to:
Evaluate environmental, social, and regulatory drivers to update the system goals for capital
facility infrastructure development, operation, maintenance, and other key elements of utility
management.
Perform hydraulic modeling analysis to evaluate system capacity, focusing on known
problems and areas where data are available for model development and calibration.
Incorporate those updates into the hydraulic models used for analyzing the system.
Develop capital improvements that meet system needs and effectively manage risks.
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Document maintenance and operations (M&O) activities and develop recommendations for
improving the M&O program.
Review and document the condition of existing stormwater system assets and develop a
prioritization system for inspecting critical system elements.
List and describe Capital Improvement Projects (CIPs) to prioritize 6- and 20-year
funding frameworks.
Provide future-looking suggestions based on potential changing climate factors.
Incorporate information and activities from current and anticipated NPDES
compliance planning.
Identify additional staffing needed based on NPDES requirements and future maintenance
and operation activities.
Coordinate the capital and operations plans to meet the anticipated revenue stream.
Develop programmatic recommendations to address utility needs.
1.2 Approach and Document Organization
This Plan is organized to focus on the actions the utility will take to implement the Plan. In most
cases, supporting documentation and background information is included in appendices rather than
chapters of the Plan. The Plan is organized into the following chapters:
Chapter 1 Introduction: Describes the reasons for developing an updated Plan and states
the purpose and objectives of the Plan.
Chapter 2 Background: Provides background information regarding the Storm Drainage
Utility and regulatory drivers for developing system goals.
Chapter 3 System Goals and Policies: Specifies the system goals used to develop capital
improvements and future M&O activities.
Chapter 4 Drainage System: Describes the existing conditions of the City’s drainage system.
Chapter 5 Evolution of the Storm Drainage Utility: Describes methodologies used to
evaluate existing problems and develop CIPs.
Chapter 6 Maintenance and Operations: Documents existing Storm Drainage Utility M&O
activities.
Chapter 7 Capital Improvements: Describes recommended capital improvement projects,
including cost estimates and conceptual figures.
Chapter 8 Implementation Plan: Prioritizes CIPs and lays out a future work plan.
Chapter 9 Finance: Identifies the total cost of providing stormwater drainage services and
provides a program for the utility to remain viable during execution of the CIP.
Chapter 10 Limitations: Sets the limits of legal applications of this document.
Chapter 11 References: Lists documents referenced throughout the Plan.
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2. Background
This chapter provides a brief description of the Storm Drainage Utility, organizational structure, and
funding mechanisms, as well as an overview of the federal, state, and local regulations that can
affect stormwater management in the City.
2.1 Storm Drainage Utility
2.1.1 Organizational Structure
The City’s Storm Drainage Utility is organized under the larger umbrella of the Public Works
Department (see Figure 2-1). The Public Works Department covers several areas of responsibility
related to stormwater management:
Utility Program.
Transportation Program.
M&O Program.
Project Engineering.
GIS (Asset Management).
Under these programs, the Public Works Department is responsible for the planning, design,
construction, operations, and maintenance of the City’s storm drainage. Management and
construction of storm drainage CIPs is provided by Engineering Services, while maintenance of storm
drainage facilities is provided by dedicated stormwater and vegetation divisions within M&O.
Figure 2-1. Public Works Department Staff Organizational Chart
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2.1.2 Funding Mechanisms
The following section provides adapted text from Auburn City Code (ACC) Title 13: Water, Sewers and
Public Utilities, Chapter 13.48, Storm Drainage Utility, §13.48.060, Authority to establish rates. Per
the ACC, the City has established rate classifications, service charges, and various fees and charges
to pay for the following costs:
The development, adoption, and implementation of a Comprehensive Storm Drainage Plan.
The debt service and related financing expenses of the design and construction of storm
drainage and water quality facilities required for the management of stormwater and surface
waters that benefit the service area.
The operation, repair, maintenance, improvement, replacement, and reconstruction of storm
drainage facilities that benefit the present service area (e.g., CIPs to increase system
capacity in accordance with level of service [LOS] goals).
The purchase of a fee or lesser interest, including easements, in land that may be necessary
for the storm drainage system in the service area, including, but not limited to, land
necessary for the installation and construction of storm drainage facilities and all other
facilities that are reasonably required for proper and adequate management of stormwater
for the benefit of the service area.
The costs of monitoring, inspection, enforcement, and administration of the utility, including,
but not limited to, water quality surveillance, private system maintenance inspection,
construction inspection, and other activities that are reasonably required for the proper and
adequate implementation of the City’s stormwater and surface water policies and
regulations.
Preparing and implementing requirements for the City’s municipal separated storm sewer
system (MS4) permit.
2.1.2.1 Rates
The currently established rates for the storm drainage service are provided in Table 2-1 below, which
lists rates for 2024 and 2025. Base rates are the monthly charge for service from the Storm
Drainage Utility to recover costs incurred by the utility, such as administrative, billing, and collection.
Equivalent service units (ESU) are used as a means for estimating the development or impervious
surfaces 1 estimated to contribute an amount of runoff to the City’s storm drainage system, which is
approximately equal to that which is created by the average single-family residential parcel. Open,
uncovered, retention/detention facilities shall not be considered as impervious surfaces for the
purpose of ESU calculations. One ESU is equal to 2,600 square feet of impervious surface area or
any portion thereof. Table 2-1 provides the current monthly charges, base rates, and ESU monthly
rates for classifications used by the utility.
1 An impervious surface is a hard surface area that prevents the entry of water into the soil mantle (see ACC
Chapter 13.41). Common impervious surfaces include, but are not limited to rooftops, walkways, patios,
concrete, or asphalt paving.
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Table 2-1. 2024 and 2025 Utility Rates for Storm Drainage Service
Effective as of January 1, 2024 Effective as of January 1, 2025
Single-family parcel types Monthly charge, $ Monthly charge, $
Single-family residential parcels a 18.09 19.31
Two-family residential parcels b 19.25 19.31
Non-single-family (NSF) parcels ESU rate per month, $ ESU rate per month, $
NSF c 18.09 19.31
NSF with detention d 15.57 16.62
NSF with retention e 13.04 13.92
NSF with water quality treatment f 16.64 17.76
NSF with detention and water quality
treatment
4.12 15.07
NSF with retention and water quality
treatment
11.59 12.37
a. Any parcel of land having on it a single detached dwelling unit that is designed for occupancy by one family or a similar group of people.
b. A building designed exclusively for occupancy by two families living independently of each other and containing two dwelling units.
c. Any parcel of developed land other than single-family or two-family (duplex) residential.
d. Detention is the temporary storage of stormwater and surface water runoff, with provisions for the controlled offsite surface release of
the stored water.
e. Retention means the storage of stormwater and surface water runoff, with no provisions for off-site surface release of the stored water
other than by evaporation and infiltration.
f. Water quality treatment means an engineered and approved facility to remove contaminants in the existing flow regime of stormwater
generated from a developed parcel pursuant to applicable design standards in place at the time of approval.
Storm Drainage Utility rates are billed monthly. Storm drainage charges start from the day a water
meter servicing the property is installed by the City. In cases where the property does not receive
water service from the City, storm drainage charges start from the day that the storm drainage
permit is finalized by the City. Payments received for utility bills are applied to expenses in the
following order of priority: late charges, additional fees, stormwater, garbage, sewer, and water.
Payment for stormwater drainage service charges is due and payable to the Finance Department
office 15 days after the billing date that appears on the bill. Utility charges are constituted as a lien
and thus can be applied to a lien upon the property from which such charges are due, superior to all
other liens and encumbrances whatsoever, except for general taxes and local special assessments.
2.1.2.2 Connection Fees
Connection fees are comprised of a connection permit fee and a system development charge (SDC).
Connection permit fees are applied to cover the planning, review, inspection, record drawings, and
processing of permit information for new connections to the public storm drainage system. Other
permit fees are assessed for inspection and permit processing for various repair, retrofit, and
demolition activities.
A utility SDC is a charge imposed on new customers, or existing customers revising use of their
property, in recognition of the previous investment of the City and its customers in the utility systems.
The purpose of an SDC is to recover a fair share of the costs of providing existing utility system
infrastructure to serve new customers or revised uses of existing customers and provide for future
improvements to serve new customers. As with Storm Drainage Utility rates, SDCs are based on the
relative amount of impervious surface added to the system. In 2024, SDCs were estimated to be
$1,759 per ESU.
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2.2 Development Code and Design Standards Updates
In compliance with the previous NPDES MS4 permit, the City has conducted updates to its
development regulations and design standards and adopted a stormwater manual as required by the
permit. Specifically, the City adopted the Washington State Department of Ecology (Ecology)
2019 Surface Water Management Manual for Western Washington (SWMMWW), with a City of
Auburn Supplement (COA Supplement). The COA Supplement has received minor updates as
needed—generally annually—to include new technologies and regulations. Ecology has recently
adopted an update to the 2024 SWMMWW. The City has formally updated the standards to the
revised manual as a condition of the NPDES MS4 permit.
In August 2024, Ecology issued an updated NPDES MS4 permit to comply with requirements of the
federal Clean Water Act (CWA) when the current permit expires. The new permit would be effective
through July 31, 2029.
Development regulations related to stormwater and drainage design standards will also be reviewed
for potential revision consistent with current policies and LOS goals.
See the following section for an overview of the City’s Stormwater Management Program (SWMP)
and Chapter 8 for specific steps needed to maintain compliance with updated NPDES MS4
permit requirements.
2.3 Regulatory and Policy Considerations
Numerous federal, state, and local regulations govern stormwater management in the City. Other
plans and programs provide additional guidance. Applicable regulations and policy guidance are
summarized in Table 2-2.
Table 2-2. Federal, State, and City Regulations, Guidance, and Programs Relevant to the
Auburn Storm Drainage Utility
Title
Regulation, Guidance, or
Program Application to the City
Federal
Clean Water Act (CWA): §402 NPDES Regulation
The National Pollutant Discharge
Elimination System (NPDES) permit
includes several requirements that affect
stormwater management in the City. See
Section 2.3.2 below.
CWA: §303(d) Impaired Waters and
Total Maximum Daily Load
(TMDL) Program
Regulation
In addition to existing TMDLs, new TMDLs
could lead to more stringent stormwater
quality controls in future NPDES permits.
CWA: §404 Permit Program Regulation
Some stormwater Capital Improvement
Projects (CIPs) can affect wetlands or other
“waters of the U.S.” §404 permitting and
mitigation can increase CIP costs and
schedules.
Endangered Species Act (ESA) Regulation
Stormwater CIPs that involve federal
permitting or funding could require
consultation with federal agencies under §7
of the ESA. ESA consultation could increase
project timelines and costs.
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Table 2-2. Federal, State, and City Regulations, Guidance, and Programs Relevant to the Auburn
Storm Drainage Utility (continued)
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Title
Regulation, Guidance, or
Program Application to the City
National Flood Insurance Program Program
The Plan could affect the City’s rating under
the Community Rating System, which
affects flood insurance rates.
Governmental Accounting Standards
Board (GASB) Statement 34 Program
Requires accurate inventory of City’s
stormwater infrastructure. See Section
2.3.3 below.
State
State Environmental Policy Act (SEPA)
(Washington Administrative Code
[WAC] 197-11)
Regulation
Each CIP would require SEPA review prior to
implementation unless that project is
categorically exempt.
Water quality standards
(WAC 173-201A) Regulation
The NPDES MS4 permit does not authorize
discharges that would violate State water
quality standards. The State may establish
TMDLs for water bodies that violate the
standards. As noted above, the TMDLs can
become NPDES permit requirements.
§401 water quality certification Regulation
Individual projects that require §404 or
other federal permits would also require a
§401 certification from Ecology. A §401
certification could include site-specific
mitigation measures, which could affect CIP
design and cost estimates.
Puget Sound Water Quality
Management Plan Guidance
Plan recommendations should be
consistent with the Puget Sound Water
Quality Management Plan.
Puget Sound Partnership Guidance
In 2007, the Washington State Legislature
created a State agency for the purpose of
developing and overseeing the
implementation of a 2014/2015 “Action
Agenda” to clean up, restore, and protect
Puget Sound by 2020. The partnership’s
“Action Agenda” identified three priorities,
one of which is to prevent pollution from
urban stormwater runoff.
Growth Management Act (GMA) and
City Comprehensive Plan Regulation This Plan is required by the GMA. GMA is
discussed in Section 2.3.1 below.
State Hydraulic Code (Revised Code
of Washington 77.55, WAC 220-660) Regulation
CIPs that involve work in waters of the State
would require a Hydraulic Project Approval
(HPA) permit. HPA permitting and mitigation
measures could affect CIP costs.
Archaeological and cultural
coordination Regulation
If any CIPs are planned for areas with
known or suspected archaeological sites,
the City will need to coordinate with the
Department of Archaeology and Historic
Preservation, local Indian tribes, and King
County Historic Preservation.
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Table 2-2. Federal, State, and City Regulations, Guidance, and Programs Relevant to the Auburn
Storm Drainage Utility (continued)
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Title
Regulation, Guidance, or
Program Application to the City
City
Environmental review (Auburn City
Code [ACC] Title 16.06) Regulation
Each CIP would be subject to environmental
review prior to permitting and construction
as prescribed in ACC 16.06. This chapter of
the ACC was adopted under the authority
of SEPA.
Critical areas ordinance
(ACC Title 16.10) Regulation
The Plan should avoid CIPs in critical areas
(e.g., wetlands, groundwater protection
zones, or wildlife habitat). If a CIP must be
sited in a critical area, the cost estimate
should include costs for mitigation and
permitting as prescribed in ACC 16.10.
Development regulations
(ACC Title 18) Regulation
The City’s development regulations must be
consistent with NPDES MS4 permit
requirements.
Shoreline Master Program
(ACC Title 16.08) Regulation
Future projects should be located and
designed to be consistent with the City
shoreline regulations (ACC 16.08). Projects
within designated shorelines could require
permits and mitigation, which could affect
project costs and schedules.
Most of the regulations listed in Table 2-2 primarily affect the implementation of specific measures
recommended in the Plan. For example, CIPs that could affect wetlands would need to comply with
City critical areas regulations and possibly federal CWA Section 404 regulations. However, three of
the regulations listed in Table 2-2—the GMA, Ecology’s Phase II NPDES Stormwater permit, and
federal Governmental Accounting Standards Board (GASB) Statement 34—directly affect the LOS for
this Plan.
These regulations are discussed in greater detail in Sections 2.3.1 through 2.3.3 below.
2.3.1 Growth Management Act
The Washington State Legislature enacted the GMA in 1990 in response to rapid population growth
and concerns with suburban sprawl, environmental protection, quality of life, and related issues. The
GMA is codified primarily in Revised Code of Washington (RCW) Chapter 36.70A.
The GMA provides a framework for regional coordination, and counties planning under the GMA are
required to adopt countywide planning policies to guide plan adoption within the county and to
establish urban growth areas. Local comprehensive plans must include the following elements: land
use, housing, capital facilities, utilities, transportation, economic development, parks and recreation,
and, for counties, a rural element. This Plan serves as a component of the utilities element for
City-owned storm drainage assets.
2.3.2 Phase II Municipal Stormwater Permit
The NPDES MS4 permit program is a requirement of the federal CWA, which is intended to protect
and restore waters for “fishable, swimmable” uses. The federal Environmental Protection Agency
(EPA) has delegated permit authority to state environmental agencies, and these agencies can set
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permit conditions in accordance with and in addition to the minimum federal requirements. In
Washington, Ecology is the NPDES-delegated permit authority.
Phase I of the stormwater NPDES regulation applies to cities and counties that operate MS4s and
had populations of 100,000 people or more according to the 1990 census. Phase II of the
stormwater NPDES regulation applies to municipalities that operate MS4s and have populations of
fewer than 100,000 people according to the 1990 census. Auburn is a Phase II permittee.
Ecology issued the current Western Washington Phase II Municipal Stormwater permit (the NPDES
MS4 permit) in July 2024, with an effective date of August 2024. The NPDES MS4 permit term will
last until July 2029.
The NPDES MS4 permit requires the City to submit a SWMP Plan by March 31 of each year, in which
the City identifies activities to be completed in compliance with the permit requirements. The permit
also requires submittal of an annual report that looks back on SWMP activities for the prior year. The
NPDES MS4 permit and associated requirements are described in detail in the City’s current SWMP
Plan, which is available on the City’s website.
The NPDES MS4 permit allows municipalities to discharge stormwater runoff from their municipal
drainage systems into the state’s water bodies (e.g., streams, rivers, lakes, and wetlands) as long as
municipalities implement programs to protect water quality by reducing the discharge of
“nonpoint source” pollutants to the “maximum extent practicable” (MEP) through application of
permit-specified “best management practices” (BMPs). The stormwater management activities
specified in the NPDES MS4 permit are collectively referred to as the SWMP and grouped under the
following program components:
SWMP administration.
Public education and outreach.
Public involvement and participation.
Illicit discharge detection and elimination (IDDE).
Control of runoff from new development, redevelopment, and construction sites.
Municipal operations and maintenance.
Monitoring and assessment.
The NPDES MS4 permit also requires compliance with established total maximum daily loads
(TMDLs).2 The current NPDES MS4 permit requires the City to monitor discharges to the White River,
in association with the Puyallup River watershed fecal coliform TMDL. Additional actions required by
the City to ensure compliance with TMDLs are listed in Appendix 2 of the NPDES MS4 permit
(Appendix A of this Plan). Ecology has identified several other water bodies in the vicinity of Auburn
that do not appear to meet the water quality standards, and additional TMDL requirements are
possible in future permits.
2 A total maximum daily load (TMDL) is a calculated maximum pollutant loading a water body can receive while
still meeting water quality standards. Once a TMDL is established, the State determines how much each
source must reduce its discharges of the pollutant in order to bring the water body back into compliance with
the water quality standards. The federal CWA requires that TMDLs be established for all water bodies that do
not meet water quality standards, and that TMDL requirements be included in the NPDES permits for
dischargers into the affected water bodies.
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2.3.3 Governmental Accounting Standards Board
Financial reporting by public utilities must adhere to requirements set by the GASB, the agency
responsible for developing standards of state and local governmental accounting and financial
reporting. Most prominent is GASB Statement 34, “Basic Financial Statements—and Management’s
Discussion and Analysis—for State and Local Governments,” which was issued in June 1999. The
main objective of Statement 34’s requirements is to have financial reports that are more
comprehensive and are easier to understand by the public. Statement 34 consists of several
components, which can be seen in full in paragraphs 3 to 166 of the GASB publications. In summary,
Statement 34 requires that the basic financial statements and required supplementary information
(RSI) for general purpose governments should consist of the following:
Management’s discussion and analysis. In sum, this requirement states that prior to the
basic financial statements, a discussion providing an analytical overview of the government’s
financial activities is necessary.
Basic financial statements, which should include:
→ Government-wide financial statements that include information on net assets (e.g., storm
drainage infrastructure) and a statement of activities.
→ Fund financial statements that focus on information about the government’s major
governmental and enterprise funds (e.g., the City’s Storm Drainage Utility), including its
blended component units.
→ Notes to the financial statements that will enable users to understand the basic financial
statements.
Required supplementary information. Budgetary comparison schedules should be presented
as RSI along with other types of data, as required by previous GASB pronouncements.
Consequently, the City needs an accurate inventory of its stormwater infrastructure in order to
comply with the GASB 34 requirements.
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3. System Goals and Policies
This chapter describes a set of overarching goals for the City’s Storm Drainage Utility and policies for
complying with these goals.
3.1 City Comprehensive Plan Consistency
The City Comprehensive Plan is the City’s growth management plan and contains policies for
protecting critical areas and natural resource lands, designating urban growth areas, preparing
comprehensive utility plans, and implementing them through capital investments and development
regulations. Therefore, the City Comprehensive Plan provides a framework of policies for
development, expansion, and maintenance of the Storm Drainage Utility reflected in this Storm
Drainage Comprehensive Plan.
3.2 Storm Drainage Comprehensive Plan Policy Goals
The City’s Storm Drainage Utility policies are grouped within goal statements that are headlined
under the following categories:
System Planning.
Operations and Maintenance.
Fiscal Responsibility.
Environment and Regional Coordination.
Taken together with the City Comprehensive Plan and ACC these goals define how the Storm
Drainage Utility shall be operated and maintained. Several policies have been developed within each
goal, many of which are also based on the Washington Department of Ecology SWMMWW and the
City’s Phase II NPDES MS4 permit.
3.2.1 System Planning
Goal 1: Employ recognized best business practices resulting in creating a sustainable, efficient, and
cost-effective operation of the Storm Drainage Utility.
POLICY 1.1 Incorporate the Comprehensive Storm Drainage Plan as an Element of the City's
Comprehensive Plan.
POLICY 1.2 The City shall seek to manage stormwater runoff within the public Right Of Way (ROW):
to provide access to and functionality of critical services.
to preserve mobility on major transportation routes (i.e., arterial roads) and
residential roads.
to protect real property structures (e.g., residences and businesses).
POLICY 1.3 The City shall seek to provide pump redundancy and backup power generators or dual
power feeds at City-owned and -operated drainage pump stations.
POLICY 1.4 The City shall routinely assess the performance of pumped systems with a focus on
capacity and vulnerability. This review aims to ensure that these systems operate
efficiently, meet their intended capacity, and remain resilient against potential risks.
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POLICY 1.5 The City shall require the separation of sanitary and storm sewer facilities wherever
combined sewers may be discovered.
POLICY 1.6 Establish, maintain, and update an asset database to be used in prioritizing asset
maintenance and repair and replacement activities. The database will include asset age
and material information and will be validated and updated through inspections, records
review, and other available information.
POLICY 1.7 Review complaints/citizen reports and claims made against the City and create a list of
operational and capital improvements to be implemented by the Plan.
POLICY 1.8 The City shall use the outcomes of future rainfall intensity data updates for informing the
design of its stormwater systems. Specifically, the same design storms—such as the
25-year event for pipe capacity and the 100-year event for storage facilities—shall be
employed using projected rainfall statistics. The City shall draw upon relevant studies,
including those mentioned in the King County Surface Water Design Manual (KCSWDM)
or other ongoing regional research once the results become available (King County
DNR 2021).
3.2.2 Operations and Maintenance
Goal 2: Maintain existing infrastructure and ensure facilities are reliable and operational now and
into the future.
POLICY 2.1 The City shall maintain or seek access to all City-owned facilities for necessary
maintenance and operation. [ACC 13.48.440B]
POLICY 2.2 The City’s Storm Drainage Utility shall be responsible for implementation, maintenance,
and operation of the City’s public storm drainage system. Storm systems serving
City-owned properties managed by other departments and/or divisions of the City that are
not part of the public storm drainage serving the public ROW (e.g., Parks, Arts &
Recreation; Administration – Facilities; Public Works – Airport) shall be responsible for
their own maintenance and upkeep.
POLICY 2.3 Drainage facilities constructed to serve private property shall be owned and maintained
by the property owner. Drainage facilities constructed to serve public ROW shall be owned
and maintained by the City.
POLICY 2.4 The City shall seek to maintain storm drainage infrastructure to ensure proper function of
drainage facilities by performing scheduled maintenance in accordance with the NPDES
permit. [ACC 13.48.180]
POLICY 2.5 The City shall seek to seasonally maintain storm drain inlets, conveyance, and outfalls to
preserve design conveyance capacity.
POLICY 2.6 Employee safety will be a primary consideration in the design, construction, operation,
and maintenance of storm drainage infrastructure.
POLICY 2.7 Investigate all customer service calls within 24 hours and record results in the
computerized maintenance management system (CMMS.)
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3.2.3 Fiscal Responsibility
Goal 3: Responsibly manage funds, employ best business practices, and operate the utility in a
cost-effective manner.
POLICY 3.1 Appropriate rates and system development charges shall be assessed and periodically
updated to fund the ongoing maintenance, operation, and capital expenditures of the
utility. [ACC 13.48.060]
POLICY 3.2 Manage the Storm Drainage Utility funds and resources in a professional manner in
compliance with applicable laws, regulations, and City financial policies, which requires
ongoing monitoring of revenues and expenses in order to make prudent business
decisions, and report to City officials, as needed, regarding the status of utility operations.
POLICY 3.3 The City shall require that developers evaluate off-site storm drainage systems, consider
improvements needed to serve new development, and construct identified improvements
prior to or simultaneously with such development.
POLICY 3.4 The City shall continue to prioritize asset management as a business practice and use it
to plan for preventative maintenance, predict system depreciation and replacement
costs, prioritize inspections for condition status to inform system risk, and prepare to
minimize the occurrence and impact of system failures.
POLICY 3.5 The City will monitor capital project implementation by tracking schedule, budget
accuracy, and overall efficiency.
POLICY 3.6 Consider replacing or upgrading storm facilities to current standards in the ROW
whenever a street is to be substantially reconstructed or other significant utility work is to
be completed, especially when storm improvements are specifically identified in the Plan.
In addition, consider street and other utility improvement needs when replacing or
upgrading storm facilities.
POLICY 3.7 Pursue opportunities to secure grants and other revenue partnerships to fund storm
drainage program needs.
POLICY 3.8 The utility will not accept nonstandard, powered, or private facilities for ownership,
operation, or maintenance by the utility.
3.2.4 Environment and Regional Coordination
Goal 4: Work to protect the natural environment within the City and contribute to the preservation of
natural resources throughout the region.
POLICY 4.1 The Storm Drainage Utility shall work with other jurisdictions and agencies to address
regional water quality issues.
POLICY 4.2 The City shall comply with all federal, state, and local regulations pertaining to
stormwater management, facility maintenance, and pollution control.
POLICY 4.3 The City shall promote policies that preserve existing native vegetation and natural
drainage courses while maintaining their conveyance capacity.
POLICY 4.4 Environmental issues, such as water quality and fish habitat protection, shall be
considered in all new development applications and new storm drainage improvements.
This policy includes consideration of new and emerging concerns, such as the chemical
6PPD-quinone in street runoff and the effects of climate change on stream temperatures.
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POLICY 4.5 The City shall seek to minimize impacts to natural river systems by encouraging
pretreatment of surface flows from new development and reintroduction into
groundwater, where feasible.
POLICY 4.6 The City shall seek opportunities, where feasible, to reintroduce treated urban runoff
back into the groundwater system as new development and redevelopment occurs in
order to minimize urbanization impacts to the hydrology of natural river systems.
POLICY 4.7 The City shall evaluate the feasibility of improving the water quality of its existing
discharges into river systems.
POLICY 4.8 The City shall seek to comply with all federal, state, and local regulations to reduce runoff
volumes and pollutant loads associated with new development and redevelopment.
POLICY 4.9 The City shall seek to prevent erosion and landslides related to construction, operation,
and maintenance of the publicly owned drainage system.
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4. Drainage System
Chapter 4 develops a future work plan to collect and organize information describing the current
conditions of the storm drainage system, which provides the basis for investigations (Chapter 5)
designed to evaluate the Storm Drainage Utility performance relative to the system goals. This
chapter provides an overview of the City’s drainage system, including both natural (Section 4.1) and
constructed (Section 4.2) drainage elements. It also summarizes key factors related to the storm
drainage system, namely critical facilities (Section 4.3) and water quality (Section 4.4), and existing
issues facing the Storm Drainage Utility (Section 4.5).
Figures presented in this chapter consist of several maps of the Storm Drainage Utility service,
drainage and surrounding areas.
4.1 Natural Drainage
The City of Auburn encompasses approximately 30 square miles; the central portion of the City lies
along the bottom of a valley, while the outer edges of the City extend into the surrounding hills (see
Figure 4-1). In general, stormwater runoff from the City flows to one of three major receiving waters:
the Green River, the White River, and Mill Creek. Other notable water features in the Auburn area
include the following:
Big Soos Creek, which drains southeast into the Green River.
Soosette Creek (also known as Little Soos Creek), which drains south into Big Soos Creek.
Mullen Slough, which drains along the northwest side of Mill Creek toward the Green River.
Bowman Creek, which drains north into the White River.
Olson Creek, which drains west into the Green River.
Lake Tapps, which is located just south of the City.
White Lake, which is located southeast of R Street SE and State Route (SR) 18.
Coal Creek Springs, which drains north to the White River.
The City contains nearly 30 miles of rivers and streams and more than 1,000 acres of floodplain
area associated with these water features. There are over 1,500 acres of wetlands, including
forested/shrub and freshwater emergent wetlands.
The following section provides additional information on each of the three major receiving waters.
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16TH ST NW
R ST SE112TH AVE SECOMPREHENSIVE STORM DRAINAGE PLAN
May 2024
LEGEND
Watercourse
Water Body
Wetland
City Boundary
Roadways
H:\PW\STORM\Planning\Storm Comprehensive Plans\2024\figures\Old figure project file.aprxFigure 4-1
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4.1.1 Receiving Waters
4.1.1.1 Green River
The Green River flows over 93 miles, beginning on the west slope of the Cascade mountains and
ending in the Duwamish Waterway, meandering through the northeast portion of Auburn along the
east valley wall. Throughout the last century, the Green River was altered for the purpose of flood
control, including the construction of levees and bank revetments and the diversion of the White
River in the early 1900s. In 1962, the Howard A. Hanson Dam was built on the Green River to control
flooding in the valley.
From 1960 to 2007, the City of Auburn participated in Green River flood management activities as
part of the Green River Flood Control District. In 2007, the Green River Flood Control District was
phased out because flood control and management efforts for the Green River are now included in
the King County Flood Control District (KCFCD), which was established in 2007. These efforts are
reflected in the 2006 King County Flood Hazard Management Plan. The KCFCD goals and objectives
include maintaining and repairing levees and revetments and acquiring at-risk floodplain properties.
Auburn elected officials and staff serve on advisory committees for the KCFCD.
4.1.1.2 White River
The White River originates on the slopes of Mount Rainier and flows generally northward and
westward into the Puget Sound lowlands. Near Auburn, the White River flows north and then west
through the southern portions of the City before it curves southward toward the Puyallup River. The
White River is a very dynamic, sediment-laden river, which has led to changing channel morphology.
Prior to 1900, the White River flowed into the Green-Duwamish River; however, floodwaters from the
White River drained to both the Green-Duwamish River and the Puyallup River. A flood in 1906
caused the White River to shift and flow into the old Stuck River channel, which leads to the Puyallup
River. In 1907, a diversion wall was constructed in Game Farm Park to permanently direct the White
River flow into the Puyallup River (USACE 2009a).
The shifting of floodwaters from the White River caused inter-jurisdictional conflicts between King
and Pierce Counties. After attempts by the two counties to control flooding along the White River met
with limited success, the U.S. Army Corps of Engineers (USACE) was engaged for help. In 1948, the
USACE finished construction of the Mud Mountain Dam to control floods on the White River.
At the time Mud Mountain Dam was finished, White River channel capacity in Auburn was estimated
to be 20,000 cubic feet per second. Since then, vegetation encroachment and sediment
accumulation have reduced channel capacity (USACE 2009a). Reduced channel capacity causes
higher river levels during large storm events, which can impact the City’s gravity drainage outfalls
along the White River.
4.1.1.3 Mill Creek
Mill Creek flows out of the hills on the west side of the valley near SR 18 and then turns northward
along the western portion of the City, running adjacent to SR 167. It crosses under SR 167 several
times as it flows through the valley floor. Approximately 1 mile north of the City boundary, Mill Creek
discharges into the Green River.
Historically, Mill Creek served as vital habitat for migrating salmon and provided ideal conditions for
rearing and storm refuge. However, increasing development has altered the natural flow pattern of
Mill Creek, including the installation of diversions and culverts, channel straightening, degradation of
water quality, and aggradation from increased stormwater inflows with high sediment loads. In many
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areas the stream is straight and shallow and exhibits a lack of quality riparian habitat for
Endangered Species Act (ESA)-listed species such as Chinook salmon and bull trout (USACE 2009b).
Aggradation along Mill Creek has also contributed to flooding and drainage problems in the City. The
City’s drainage outfalls to Mill Creek can become submerged, thereby reducing the hydraulic capacity
of the system.
4.1.2 Drainage Areas
The City’s drainage can be described by dividing the City into six general subareas and their
discharge location (Figure 4-2):
Lea Hill lies northeast of the Green River. Most of the Lea Hill area drains west into the Green
River. However, the eastern edge drains south and east out of the City into Soosette Creek
and Big Soos Creek.
West Hill lies west of Mill Creek. The West Hill area drains into several small tributaries to Mill
Creek. The northern portion of West Hill drains to the northeast into steep ravines that
discharge to Mullen Slough and other wetland areas on the valley floor.
The southern portion of the City drains to the White River. The area west of Bowman Creek
consists largely of single family residential developments, which drain to the White River to
the west and north and Bowman Creek to the east, with a small portion draining south
toward Lake Tapps. The area east of Bowman Creek consists of rural residential
development. This area drains to Bowman Creek on the southwest and the White River on
the northeast side.
The southeast portion of the City lies along a narrow plateau between the Green and White
Rivers. Runoff from this area drains to the Green River along the north side and the White
River along the south side.
The north central portion of the City lies along the valley floor and is located north of
27th Street SE. This is part of the central and most developed area of the City. The
topography in this area is so flat that roadways and storm drainage infrastructure largely
determine the receiving water to which runoff is diverted. Runoff from this area is generally
split between Mill Creek and the Green River.
The south central portion of the City also lies along the valley floor and is located south of
27th Street SE. This area is also part of the most developed area of the City. The topography
in this area is so flat that roadways and storm drainage infrastructure largely determine the
receiving water to which runoff is directed. This area features extensive infiltration into
groundwater, but otherwise drains toward the White River.
The above-described areas can be divided into smaller drainage subbasins. The City maintains a
mapping of the storm drainage basins and subbasins, with a total of 59 drainage subbasins. Each
subbasin is identified by a series of one, two, or three letters (Figure 4-2).
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COMPREHENSIVE STORM DRAINAGE PLAN
LEGEND
Watercourse
Water Body
Wetland
Drainage Subarea
Subbasins
City Boundary
Roadways
Major receiving water
Green River
Mill Creek
Mullen Slough
Soosette and Big Soos Creeks
White River
Outfalls
GREEN RIVER
MILL CREEK
WHITE RIVER
WETLAND
STREAM
H:\PW\STORM\Planning\Storm Comprehensive Plans\2024\figures\Old figure project file.aprxFigure 4-2
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4.1.3 Geology and Groundwater
Topography and geology in the Auburn region has been influenced largely by millions of years of
advancing and retreating glaciers, most recently with the Vashon glaciation occurring approximately
12,000 to 18,000 years ago (Booth 1991). Following the retreat of the glacier, interglacial
processes, such as landslides, mudflows, erosion, and alluvial deposition, have continued to shape
the region. In general, the upland hills around the City’s periphery comprise glacial and interglacial
deposits, while the valley is filled with more recent deposits overlying glacial and older
interglacial deposits.
Major geologic units of the White and Green River valley include undifferentiated glacial and
interglacial deposits, Vashon recessional deltaic deposits, undifferentiated alluvium, Osceola
mudflow, and White River alluvium. The undifferentiated glacial and interglacial deposits form the
lowest layer in the valley consist of materials deposited during the glacial periods. As the glacier
retreated, meltwater flowed into a water-filled embayment then occupying the present White and
Green River valley area. This meltwater deposited sand and gravel known as the Vashon recessional
deltaic deposits. After the end of the glacial period, the Green River deposited undifferentiated
alluvium in the valley because of erosion of upland glacial deposits. Approximately 5,700 years ago,
a massive volcanic mudflow from Mount Rainier, known as the Osceola mudflow, flowed down into
the valley (Troost and Booth 2008). White River alluvium is the geologic unit nearest the surface and
consists of alluvial deposits from the White and Green Rivers.
Bedrock is found approximately 1,280 feet beneath the valley floor. Surficial geologic mapping of the
Auburn region is shown in Figure 4-3.
In general, groundwater flow systems in the Auburn area are characterized by upland recharge
flowing toward the valley. The two major aquifers in the White and Green River valley are the modern
alluvium aquifer and a deep deltaic valley aquifer; the latter is used for Auburn’s water supply. The
modern alluvium aquifer is the shallowest aquifer in the Auburn-Kent Valley, often lying 10 to 15 feet
below the ground surface. Groundwater in the deep deltaic valley generally flows in a pattern parallel
to the direction of the Green River in the north and the White River in the south.
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37TH ST NW
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S 316TH ST
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41ST ST SETERRACE DR NWSUMNER-
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132ND
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May 2024
LEGEND
Watercourse
Water Body
Wetland
City Boundary
Roadways
Surficial Geology
Qa
Qc
Qf
Qga
Qgd
Qgl
Qgo
Qgp
Qgp(s)
Qgp(st)
Qgpc
Qgt
Qls
Qp
Qvl(o)H:\PW\STORM\Planning\Storm Comprehensive Plans\2024\figures\Old figure project file.aprx0 4,000 8,000
Feet
Figure 4-3
Surface Geology in
the Vicinity of the
City of Auburn
Geologic Unit Lithology
Qa Alluvium
Qc Continental sedimentary deposits or rocks
Qf Artificial fill, including modified land
Qga Advance continental glacial outwash, Fraser-age
Qgd Continental glacial drift, Fraser-age
Qgl Glaciolacustrine deposits, Fraser-age
Qgo Continental glacial outwash, Fraser-age
Qgp Continental glacial drift, pre-Fraser
Qgp(s)Continental glacial drift, pre-Frasier, Salmon Springs Drift
Qgp(st)Continental glacial drift, pre-Fraser, Stuck Drift
Qgpc Continental glacial drift, pre-Fraser, and nonglacial deposits
Qgt Continental glacial till, Fraser-age
Qls Mass-wasting deposits, mostly landslides
Qp Peat deposits
Qvl(o)Lahars
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4.1.4 Soils and Runoff Potential
Surface soils are classified by the Natural Resources Conservation Service (NRCS) into four
hydrologic soil groups based on the soil’s runoff potential: A, B, C, and D. Group A soils generally
have the lowest runoff potential while Group D soils have the highest. Hydrologic soil groups are
defined by NRCS (1986) as follows:
Group A is sand, loamy sand, or sandy loam types of soils. It has low runoff potential and high
infiltration rates, even when thoroughly wetted. It consists chiefly of deep, well- to excessively
drained sands or gravels and has a high rate of water transmission.
Group B is silt loam or loam. It has a moderate infiltration rate when thoroughly wetted and
consists chiefly of moderately deep to deep, moderately well- to well-drained soils with
moderately fine to moderately coarse textures.
Group C is sandy clay loam. It has low infiltration rates when thoroughly wetted and consists
chiefly of soils with a layer that impedes downward movement of water and soils with
moderately fine to fine structure.
Group D is clay loam, silty clay loam, sandy clay, silty clay, or clay. It has very low infiltration
rates when thoroughly wetted and consists chiefly of clay soils with a high swelling potential,
soils with a permanent high water table, soils with a claypan or clay layer at or near the
surface, and shallow soils over nearly impervious material.
Areas in the valley floor is mostly Group D soils, which typically have very low infiltration rates and
high runoff potential. The West Hill, Lea Hill, and Lakeland Hills areas are predominantly Group C
soils, which have low infiltration rates and moderate to high runoff potential. The Southeast area,
Bowman Creek area, and valley area located generally between SR 18 and the White River have
Group A soils, which are characterized by high infiltration rates and low runoff potential. See the
NRCS maps (http://www.nrcs.usda.gov/) for mapped soils within the City.
4.1.5 Land Use and Development
Land use and the intensity of development have considerable effects on the quality and quantity of
stormwater runoff flowing into the drainage system and ultimately discharging to receiving waters. As
the population of the City increases, new areas of the City are developed or existing areas are
redeveloped at a higher density. These changes can result in increased stormwater runoff and
greater water quality impacts to water bodies. However, development regulations and drainage
design standards imposed by the City are intended to mitigate these impacts. The following sections
describe expected growth and how development regulations and design standards are being
updated to reduce impacts to stormwater runoff.
4.1.5.1 Recent Growth
Auburn’s population has steadily increased since the 1950s. Auburn’s population increased by an
average of 8% per year from 1960 to 1980, then slowed to approximately 1.7% per year from 1980
to 1994. Auburn’s population growth rate began to increase in 1998 and continued as the City
annexed new areas, known locally as the Lea Hill, West Hill, and Lakeland Hills areas. The larger Lea
Hill area annexations began in 2000 and continued to 2024. The West Hill area was annexed in
2007, while the Lakeland Hills area annexations occurred between 1998 and 2005. As of 2010, the
population of Auburn increased to 70,180 and increased to 86,340 by 2020. The Washington State
Office of Financial Management indicates that Auburn’s population in 2023 was approximately
88,820 (approximately 78,760 in King County and 10,060 in Pierce County).
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4.1.5.2 Future Growth
The City’s goals, objectives, and policies for growth and development are described in detail in the
2025 Comprehensive Plan. These goals, objectives, and policies are applied to different areas of the
City through land use designations (see Figure 4-4). The City also has developed special land use
plans for certain areas of the City where specific land use goals have been identified. An important
example is the City’s downtown area; one of the goals described in the Comprehensive Plan is to
encourage development and redevelopment in the downtown area to serve as an urban center for
the community.
4.1.5.3 Development Regulations and Drainage Design Standards
The City implements state and federal stormwater regulations through the stormwater code, the COA
Supplement, and related stormwater management programs and policies. City stormwater
regulations contain specific requirements for managing stormwater quality and quantity in areas
subject to new development and redevelopment. For example, the SWMMWW provides guidance for
implementing low impact development (LID) measures that are designed both to improve water
quality and to control peak flows and durations of runoff. The City reviews and updates its local
development regulations and design standards as necessary to meet the NPDES MS4 permit
requirements. The COA Supplement was last updated in 2022.
City stormwater regulations and development standards are intended to avoid substantial increases
in stormwater discharges to the existing drainage system through the implementation of on-site
stormwater controls. This would keep stormwater conveyance demands at or near existing levels.
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Land Use Designations
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LEGEND
Watercourse
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NAME
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¯1:48,000
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4.1.6 Flood Hazard Mapping
The City of Auburn is a participant in the National Flood Insurance Program (NFIP) administered
through the Federal Emergency Management Agency (FEMA) to enable property owners to purchase
insurance protection from the government against losses from flooding. Participation in the NFIP is
based on an agreement between the City and the federal government, stating that if the City adopts
and enforces a floodplain management ordinance to reduce future flood risks to new construction in
areas designated as Special Flood Hazard Areas (SFHA), the federal government will make flood
insurance available within the community as a financial protection against flood losses. The SFHAs
and other risk premium zones applicable to each participating community are depicted on Flood
Insurance Rate Maps (FIRMs).
FEMA established flood hazard zones from a Flood Insurance Study (FIS) for King County conducted
in 2013, which examined flooding along several major rivers. Although the primary purpose of the
FIS was to establish flood insurance rates, the flood mapping resulting from these studies is also
used for floodplain management and flood hazard mitigation planning. Updates to the flood hazard
zones are continually being made at local levels (King County and Pierce County) and represented in
Preliminary FIRMs or Letters of Map Revision (LOMR). Preliminary FIRMs for all of King County were
reissued on August 19, 2020. The most recent flood hazard mapping for Pierce County is presented
in its Rivers Flood Hazard Management Plan adopted in 2023 and also in LOMR files located on the
FEMA Map Service Center Web page (Pierce County 2023). Table 4-1 lists the FIRMs developed for
areas within the City of Auburn.
Table 4-1. Federal Emergency Management Agency Flood Insurance Rate Maps Applicable to Auburn
53033CIND1B 53033CIND2B 53033C1232G 53033C1235G
53033C1242G 53033C1251G 53033C1252G 53033C1253G
53033C1254G 53033C1257G 53033C1259G 53033C1261G
53033C1262G 53033C1263G 53033C1264G 53033C1266G
53033C1267G 53033C1268G 53033C1269G 53033C1476F
53033C1477F
4.1.7 Recent Climate and Precipitation Trends
Auburn’s climate is typical of that in the Puget Sound lowlands of Western Washington, where the
summers are cool and comparatively dry, while the winters are mild, wet, and cloudy (WRCC 2014).
Mean annual precipitation in the Puget Sound lowlands varies from 32 inches (north Seattle) to
approximately 47 inches (near Centralia, Washington).
The precipitation gauge at Auburn City Hall has been recording data since 1995. The mean annual
precipitation recorded at that gauge (with missing data filled in from the nearby King County
Lakeland Hills gauge) from 2015 to 2022 was approximately 39 inches. This is very similar to the
mean annual precipitation recorded at the two nearest long-term gauges:
Seattle-Tacoma Airport, which is part of the National Oceanic and Atmospheric
Administration (NOAA) Cooperative Network (Station 457473), has a mean annual
precipitation of approximately 38 inches based on 74 years of recorded data (WRCC 2014b).
The Seattle-Tacoma Airport gauge is located approximately 8 miles northwest of Auburn.
Kent, Washington (NOAA Co-op Station 454169) has a mean annual precipitation of
approximately 39 inches based on 57 years of recorded data (WRCC 2014c). The Kent gauge
is located approximately 7 miles north of Auburn.
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Precipitation-frequency data for Washington are compiled in Volume 9 of NOAA Atlas 2 (Miller et
al. 1973); precipitation-frequency estimates for Auburn, Washington, are listed in Table 4-2.
Table 4-2. Precipitation Frequency Data for Auburn, Washington, from NOAA Atlas 2
Frequency, duration Precipitation (inches)
2-year, 6-hour 0.95
2-year, 24-hour 1.75
100-year, 6-hour 1.90
100-year, 24-hour 3.80
4.1.8 Anticipated Changes in Climate
Changing climate will continue to be a key factor in the performance, operation, maintenance, and
design of the City’s stormwater system. According to the publication, Climate Change Impacts and
Adaptation in Washington State, the state is projected to experience decreases in snowpack,
increases in stream temperatures, changes in stream base flow, increased frequency of high rainfall
intensity and magnitude, and changes in peak stormwater runoff, streamflow, and flooding
frequency (Snover et al. 2013). This section provides an assessment and strategy for the City to
address future changes and effects to the storm sewer and flood management systems while
considering the range of uncertain climate projections.
The available information on future climate conditions will help guide decisions and investments,
avert impending impacts on stormwater programs from climate change, and enhance the
effectiveness and resilience of stormwater systems in the face of environmental uncertainties.
Assessing future climate impact magnitude, risk, and uncertainty are critical to making appropriate
decisions about physical attributes (size, location, elevation, capacity) and performance (service
levels, acceptable impacts, failure scenarios) for stormwater programs.
The following future climate conditions are potentially impactful to the City’s stormwater programs:
Precipitation: Projected changes in precipitation show evidence for increased frequency of
intense, large, or persistent rains in the future, mostly in the winter storm season. These
increases could exceed the existing level of performance in the City’s stormwater system.
System performance and flooding: Increased frequency of larger or more intense storms
could lead to increased stormwater runoff and thus more frequent flooding of existing storm
drainage systems in the City. Pumped or other operated systems are typically more
vulnerable to changing storms.
River and stream flooding: Increased frequency of larger and longer duration storms could
lead to increased local stream and river flooding, increased stages over known or mapped
floodplains, and different flood control operations on the White and Green River dams.
Groundwater: More frequent storms of higher magnitude have the potential for increased
infiltration and thus rising groundwater table. This should be a consideration in infiltration
facility design, subsurface excavations, and installation of stormwater structures such
as vaults.
High temperature: Average and extreme high temperatures in Auburn are expected to be
higher in the future, causing effects like higher summer surface water temperatures that can
be harmful to aquatic life and fisheries.
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4.1.8.1 Uncertainty and Risk Management
Addressing uncertainty in climate projections is an important aspect of climate research. Since
future outcomes in climate conditions heavily rely on human activities and the Earth's climate
system is extraordinarily complex, global climate models have an amount of uncertainty. All future
climactic conditions are projections, not predictions. Ongoing research aims to reduce uncertainties
by improving climate models, refining data collection methods, and enhancing our understanding of
the Earth's climate system and its interactions with human activities.
When possible, this section uses locally refined, dynamic data to inform potential future climate
scenarios. Because uncertainty is inherent in projections of climate change, the likelihood of a range
of possibilities are presented.
Stormwater management is a risk-based practice, which means that standards are typically based
on the likelihood or probability that an event will occur, and the level of protection needed is related
to that possibility. Consequently, the approaches to applying recommendations in part consider the
coincident events (e.g., sea level rise ranges plus event probability) with expected performance. No
“reasonable” or applicable stormwater standards can apply to all possible events or outcomes, and
extremes can exceed system capacity. An important consideration that is a core practice when
establishing storm system criteria is to consider the consequences of failure, because all systems
(unless designed for the probable maximum flood) can fail in any year.
4.1.8.2 Precipitation Projections
According to climate models, the region’s average precipitation is expected to undergo minimal
changes (Hegewisch et al. 2023). Figure 4-5 illustrates the projected alterations in average
precipitation for two climate scenarios: Representation Concentration Pathway (RCP) 4.5 (low end)
and RCP 8.5 (high end). When examining individual seasons, we observe a slight increase in total
precipitation during the winter, an almost negligible loss of precipitation in the summer, a slight
increase in precipitation in the fall, and a slight decrease in precipitation in the spring.
Modified from Hegewisch et al. 2023.
Figure 4-5. Projected Change in Average Precipitation for Seattle, Washington.
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Although the City is not predicted to see a significant increase in overall precipitation, climate models
predict an increase in the intensity of precipitation, specifically during the winter months. Heavy rain
events in the Pacific Northwest are often caused by atmospheric rivers, where long, narrow regions
of concentrated moisture are carried from lower latitudes (Morgan et al. 2021). Intensification of
atmospheric rivers is projected to cause an increase in extreme winter precipitation frequency.
Figure 4-6 outlines the anticipated percentage change in extreme heavy rain events in SeaTac,
Washington. The figure shows predicted changes in short duration storms (1 hour) across different
return frequencies (ranging from 2 to 100 years) during the entire water year, as well as individual
seasons (winter, spring, summer, and fall) for the 2080s (spanning from 2070 to 2099) relative to
1970 to 1999. Key details are summarized below:
Projection scope: The total projection includes all precipitation occurring in a season or
water year.
Return frequencies: The 2- to 100-year return frequency projections represent the high- and
low-end extremes, estimated based on only the largest value in each year.
Measurement: All 2080 projections are expressed as the percent change in 1-hour
precipitation depth relative to the climate normal period from 1970 to 1999, following the
convention established by NOAA.
Climate scenarios: The results are based on two greenhouse gas scenarios: RCP 8.5 (high
end) and RCP 4.5 (low end).
Data presentation: The data is organized by water year, season, total annual precipitation,
and extremity.
Modified from Mauger et al. 2019
Figure 4-6. Projected Changes in 1-Hour Precipitation Statistics for the 2080s vs. 1970–1999
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4.1.8.3 Implications
The increase in precipitation intensity will have several key implications or risks to the stormwater
system. More frequent and intense winter storms are likely to exceed the capacity of the stormwater
system more often than current conditions.
Impact
Stormwater structures are sized to meet system LOS objectives, considering the anticipated
frequency of storm events. Historical rainfall data are collected and characterized by intensity (e.g.,
inches of rain per minute or hour) or magnitude over a certain time period (e.g., X-inches in 24
hours). The design storms are usually described in the likelihood of exceeding a certain depth. For
instance, a 4% chance of occurrence may also be described by the “average” frequency of
occurrence for that duration, such as a 25-year, 24-hour event (for a 4% exceedance event).
Future rainfall patterns are predicted to deviate from historic norms. Note that storms are not
“increasing in size” (larger storms are possible any time without climate change), but rather the
frequency of larger events is greater. For example, if a 3-inch, 24-hour storm has occurred every
25 years in the recent past, climate change can cause a 3-inch storm to occur more frequently in the
future. The new 25-year, 24-hour storm could be 3.5 inches of rain or more at the same potential
frequency. Storm intensity (the rate of rainfall depth per unit of time) follows the same pattern—the
same extreme rates are more frequent.
For example, when a storm system is designed to convey water away from a roadway for a 25-year,
24-hour event, we assume that the system may fail, on average, once every 25 years. We accept this
failure level because the impact may be modest and the cost of providing additional protection is
high. However, with more frequent events of the same size, flooding could happen every 10 to
15 years, which may not be tolerable for safety, system disruption, or property damage.
Consequently, returning to the same LOS would require a new drainage system to provide the same
frequency of performance. However, floods could still occur that exceed that LOS. If a higher LOS is
desired, careful consideration of a new, future design storm becomes necessary.
4.2 Stormwater Drainage Infrastructure
As part of the implementation of the City’s NPDES MS4 permit, the City embarked on a substantial
effort to update its inventory of drainage system infrastructure owned or operated by the Storm
Drainage Utility. The citywide inventory is completed, but continued maintenance and new features
will be ongoing. An up-to-date system inventory will assist the City in the following objectives:
Help to meet regulatory requirements.
Provide input for hydraulic models to analyze system conveyance capacity.
Serve as a basis for an asset criticality database used to prioritize repair and replacement
(R&R) activities.
Support the City’s M&O activities through the CMMS.
Table 4-3 provides a summary of stormwater infrastructure inventory.
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Table 4-3. Stormwater Drainage Infrastructure Summary
Infrastructure element Quantity a Unit
Pipes, all sizes 1,310,937 Linear feet
Pipes, all sizes (excluding force mains) 15,259 Count
6–10 in. diameter 3,361 Count
215,900 Linear feet
12–15 in. diameter 8,822 Count
698,000 Linear feet
16–18 in. diameter 1,480 Count
165,600 Linear feet
21–24 in. diameter 858 Count
106,500 Linear feet
27–36 in. diameter 548 Count
85,200 Linear feet
42–48 in. diameter 173 Count
37,200 Linear feet
54–72 in. diameter 17 Count
2,300 Linear feet
Force mains 35 Count
4,400 Linear feet
Open channels 222,000 b Linear feet
Culverts 1,164 Count
Manholes 3,172 Count
Catch basins 10,800 Count
Control structures 223 Count
Outfalls (to water courses, ditches, etc.) 124 Count
Detention ponds 156 Count
Infiltration ponds 14 Count
Vaults 8 Count
Pump stations 7 Count
a. Quantities are based on current inventory and have not yet been finalized.
b. Length has been approximated based on available data.
Most storm drainage infrastructure is in the City’s core between Mill Creek and the Green River,
where development densities are highest. Figure 4-7 shows an overview of the City’s stormwater
drainage infrastructure.
Page 72 of 373
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4.3 Critical Facilities
Policies and system goals for managing the City’s critical facilities and critical stormwater assets are
described in Chapter 3, Section 3.2. Two groups of system goals and policies in particular focus on
criticality. The first applies to critical facilities, stating that the City will manage stormwater runoff
within the public ROW in the vicinity of critical facilities to allow access and ensure function of these
facilities at all times (Policy 1.2). Ten critical facilities have been identified and included in Table 4-4.
The second group of policies relates to the management of the City’s critical stormwater assets
(Policies 1.4, 1.6, 2.4, 2.5, and 3.4). The City will modify its inspection and maintenance practices to
prioritize active management of facilities with the highest combined risk and likelihood of failure
(i.e., a criticality based maintenance program). Factors that impact likelihood of failure include the
age of the asset, inspection or repair history of the asset, and condition of the asset. The
consequences of a system failure impacting a hospital or school are considered more serious than
one affecting a residence or unoccupied property and are thus assigned as critical assets. The City
has identified 10 City facilities (Table 4-4) and seven stormwater pump stations (Table 4-5) as critical
assets. The list of critical stormwater assets may expand as the City refines its criticality database by
adding information (e.g., inspection and repair logs, asset age; see Policy 1.6). The locations of these
critical facilities are shown in Figure 4-8.
Table 4-4. Critical City Facilities
Facility Address
City Hall 25 W Main Street
City Hall Annex 1 E Main Street
Justice Center 340 E Main Street
Maintenance and Operation Facility 1305 C Street SW
Regional Hospital 201 N Division Street
Valley Regional Fire Authority (VRFA) Station 31 1101 D Street NE
VRFA Station 32 1951 R Street SE
VRFA Station 33 500 182nd Avenue E
VRFA Station 34 31290 124th Avenue SE
VRFA Station 35 2905 C Street SW
Table 4-5. Critical Stormwater Facilities
Storm drainage facility Year constructed Address
A Street Pump Station 1973 404 A Street SE
Auburn Way S Pump Station 1994 405 Auburn Way S
Brannan Park Pump Station 2001 1302 30th Street NE
Emerald Park Pump Station 1999 499 42nd Street NE
M Street Pump Station 2014 410 M Street SE
West Main Street Pump Station 2008 1410 W Main Street
White River Pump Station 2012 4640 A Street SE
Page 74 of 373
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31ST ST E
42ND ST NW
119TH AVE ESE 286TH ST
65TH AVE SSE 276TH PL
S
2
9
7
T
H
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L
SE 295TH PL
27TH ST SE
128TH AVE ES 344TH ST
SE 364TH ST
SE 290TH ST
SE 280TH ST
V ST SEV CT SES 285TH ST
SE 294TH ST
146TH AVE SESE 293RD ST
126TH AVE SEZ ST SESUMNER-TAPPS HWY ESE 307TH PL 140TH AVE SE108TH AVE SE73RD ST SE
SE 295TH ST
S 319TH ST
S 366TH ST
26TH ST NE
SE 297TH ST
66TH ST SE
SE 296TH ST
SE 285TH ST117TH AVE SES 302ND PL
2ND AVE SE
7TH ST117TH AVE E51ST PL SHEATHER AVE SE112TH PL SESE 292ND ST
114TH AVE SE123RD AVE EFIR ST SES 342ND ST
28TH PL SE184TH AVE E8TH ST E
16TH ST E
SE 284TH ST
SE 292ND ST
SE 296TH ST
SR 167D ST SESR 18R ST NWM ST NWSE 282ND ST
24TH ST E TBDS 277T
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S
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16TH ST ER ST NW51ST AVE STBD17TH ST SE
SE 282ND ST
M ST NETBDC S
T
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W
TBD
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32ND ST E D ST SESR 167SR 167SR 167112TH AVE SESR 167SR 167O ST NETBDSE 288TH ST
55TH AVE S18TH ST E
SE 272ND ST
SR 167SR 167TBDTBD
SE 272ND ST
TBDOPC9
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OPC8
OPC5OPC2
OPC4
OPC10
OPC11
OPS1OPS2
OPS3
OPS4
OPS5
OPS6
COMPREHENSIVE STORM DRAINAGE PLAN
May 2024H:\PW\STORM\Planning\Storm Comprehensive Plans\2024\figures\Old figure project file.aprx0 4,000 8,000
Feet
Figure 4-8
City and Storm Drainage
Critical Facilities for
the City of Auburn
LEGEND
Storm Critical Facility
City Critical Facility
Roadway
Watercourse
Water Body
Wetland
City Boundary
(
(
(
((OPC1 OPC3
OPC5
OPC2
A ST SEC ST SWE MAIN STC ST NWSR 18
4TH ST NE
E ST NE4TH ST SE I ST SED ST SEAUBURN WAY S2ND ST NE
F ST SEH ST SEE ST SEG ST SED ST NWA ST SWA ST NE7TH ST SE
W MAIN ST
8TH ST SEB ST NE1ST ST NE
3RD ST NE
A ST NWH ST NED ST SW3RD ST NW
S DIVISION ST6TH ST SE
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6TH ST NE
5TH ST SW
SR 18
6TH ST SE
8TH ST SE D ST SE7TH ST SE
SR 18OPS1OPS2
SEE INSET
INSET
¯1:48,000
C1
S1
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4.4 Water Quality
This section describes the existing water quality and regulatory conditions that affect surface water
quality in Auburn and describes processes that are required to maintain compliance with the City’s
NPDES MS4 permit.
4.4.1 Existing Conditions
According to water resource inventories by Ecology, the main water bodies within the City’s
administrative boundaries include the Green River, Mill Creek, White Lake, White River, Bowman
Creek, and Soosette Creek. Municipal storm sewers that discharge runoff to surface waters are not
authorized to violate state water quality standards.
Appendix 2 of the NPDES MS4 permit (Appendix A of this Plan) describes water bodies that are
impaired and have additional requirements based on established TMDLs. A fecal coliform TMDL for
the Puyallup River watershed is included in the current NPDES MS4 permit. As part of the TMDL,
Ecology has designated the basin as a high-priority basin for IDDE screenings. Details of the required
activities are included in Appendix 2 to the NPDES MS4 permit.
The Green River has a TMDL for temperature that was approved by EPA in 2011. The TMDL report
indicated a cumulative waste load allocation was developed for all the municipal stormwater
permittees. However, the TMDL did not contain any additional TMDL-related actions for stormwater
permittees (Ecology 2011).
Other TMDLs under development include the lower White River pH TMDL and the Soos Creek
subbasin multiparameter (temperature, dissolved oxygen, bacteria, and fine sediment) TMDL,
described in the following paragraphs.
The lower White River pH TMDL was approved by EPA on January 13, 2023, and additional
stormwater actions are listed in the public comment draft of the 2024–2029 NPDES MS4 permit.
These include outfall and tributary conveyance mapping, monthly IDDE screening for flow in the
critical period of May 1 to October 31, soluble reactive phosphorus (SRP) testing of flow from outfalls
in the watershed during the critical period under certain sampling conditions (preceding
precipitation, stormwater flow, and river flow), and source control tracing for any flow with SRP
values that exceed the specified limits. Phosphorus treatment BMPs for new development and
redevelopment will be required in the watershed no later than June 30, 2027.
The Soos Creek TMDL is not expected to be complete in time for the 2024–2029 Municipal
Stormwater Permit. The temperature, dissolved oxygen, and bacteria TMDL is expected to be
finalized in 2026. The fine sediment portion has become a separate TMDL and development of the
draft implementation plan began in 2023. The impairments in this TMDL have been identified as fine
sediment, high peak flows during storm events, and issues related to habitat degradation.
Other waterbodies listed as impaired on the Ecology water quality map include Mill Creek for bacteria
(fecal coliform and e. coli), dissolved oxygen, pH, and benthic macro invertebrates; Bowman Creek
for dissolved oxygen, temperature, and fecal coliform; and Olson Creek for benthic
macroinvertebrates. These impairments will be addressed through future TMDLs.
4.4.2 Regulatory Compliance
The City has a well-developed MS4 M&O program that employs and provides training on numerous
processes and procedures to minimize water quality impacts from municipal operations. The City
also actively implements stormwater management BMPs in its municipal activities. BMPs include
activities, prohibitions of practices, maintenance procedures, and structural and/or managerial
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practices that prevent or reduce the release of pollutants and other adverse impacts to waters of
Washington State.
The current NPDES MS4 permit includes provisions for monitoring and assessment of water quality.
Permittees have the option of paying annual fees to participate in statewide monitoring programs or
developing individual monitoring programs to meet the requirement. The City notified Ecology in
2013 that it intends to participate in the statewide monitoring programs and has continued
contributing the required funds every year since.
The City is in full compliance with its NPDES MS4 permit, with programs, codes, processes, and
procedures that meet all of the requirements currently in effect. The City’s SWMP Plan contains a
summary of the NPDES MS4 permit requirements and descriptions of the City’s current and planned
activities for permit compliance.
The City will continue to make sundry changes to comply with updated requirements of the NPDES
MS4 permit that phase in during the permit term. The City is conducting a process to identify and
implement needed updates to codes, standards, and programs by the relevant due dates.
A schedule of relevant due dates to comply with updated NPDES MS4 permit requirements is
provided in Chapter 8, Figure 8-2.
4.5 Existing Drainage Problems
Members of the City staff working within the Storm Drainage Utility are experienced and familiar with
the condition of the drainage system. Existing drainage problems have been observed by the staff
and are known to cause frequent flooding of roadways. The most apparent problems were identified
for analysis (see Hydraulic Evaluation, Section 5.1). Existing drainage problems are described in
Table 4-6 and locations are mapped in Figure 4-9. Problems were evaluated for potential inclusion in
the capital improvement plan. CIPs developed to address these problems are described in
Chapter 7.
Table 4-6. Existing Drainage Problems
No. Priority Location Description
Approximate
frequency or last
noted occurrence
1 1 West Main
Street dead end
near SR 167
The dead-end portion of Old West Main Street near State
Route (SR) 167 has a history of observed flooding. The
City installed a temporary pump station to dewater the
gravity pipe flowing on the south side of Old West Main
Street in an effort to protect local businesses from
flooding. Since its installation in 2008, the pump station
has eliminated flooding at the observed location. The
pump station, however, does not meet the City’s level of
service guidelines regarding pump redundancy and may
be insufficient to convey the 25-year flow rate.
The City’s gravity pipe on the north side of Old West Main
Street experiences flooding at one catch basin
approximately once per year. High water persists even in
summer months.
The pump station and gravity pipe discharge to a
Washington State Department of Transportation ditch
along the east side of SR 167.
Catch basin flooding
once per year and
system surcharging
2 2 Auburn Way
South
Auburn Way South/SR 18 Underpass – minor roadway
flooding causes disruptions to traffic during periods of
intense rainfall.
Every few years
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Table 4-6. Existing Drainage Problems (continued)
June 2024 │ 553-1931-052 4-22
No. Priority Location Description
Approximate
frequency or last
noted occurrence
3 3 I St NE The area between 33rd Street NE and 35th Street NE on
the east side of I Street NE has reoccurring flooding when
the river level is high.
Every few years
4 2 Auburn Way
South and
A Street Pump
Stations
Two existing stormwater pumping stations are reliant on
portable emergency power, increasing workflow and
reducing system reliability at time of need.
5 3 Storm Pipeline
Extension
There are areas within the City not served by the public
storm system, such as paved alleys and residential
streets where roadwork is not anticipated.
Page 78 of 373
287th St SE WQ
M St NE Widening
284th St SE (west) WQ
R St SE (22nd to 33rd)
West Main St Pump Station
2026 Local St Preservation
Vegetation Sorting Facility A ST SESR 18-WEST I ST NEB ST NWC ST SWSR 167-SOUTHSR 167-NORTHM ST SEAUBURN WAY NR ST SESR 18-
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N
W
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LAKE TAPPS PKWY SE
SE 304TH ST 132ND AVE SE51ST AVE SKE
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W
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S
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29TH ST SE
SE 312TH ST
8TH ST NE
37TH ST NW
LAKELAND HILLS WAY SEORAVETZ RD SESE 320TH STD ST NWA ST NERON CROCKETT DR NWS 277TH ST
37TH ST NE
S 316TH ST
D ST NE112TH AVE SEEAST VALLEY HWY E108TH AVE SEBOUNDARY BLVD SWTERRACE DR NW6TH ST SE
132ND
W
A
Y
S
E
16TH ST NW
SE 304TH ST
R ST SE112TH AVE SEKing County, WA State Parks GIS, Esri, TomTom, Garmin, SafeGraph, GeoTechnologies, Inc, METI/
NASA, USGS, Bureau of Land Management, EPA, NPS, USDA, USFWS
COMPREHENSIVE STORM DRAINAGE PLAN
May 2024
LEGEND
Watercourse
Water Body
City Boundary
Roadway
CIP Projects
H:\PW\STORM\Planning\Storm Comprehensive Plans\2024\figures\Old figure project file.aprx0 4,000 8,000
Feet
Figure 4-9
Drainage Problem Locations for
the Storm Drainage Utility¯1:42,000
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5. Evaluation of the Storm Drainage Utility
This chapter presents analyses conducted to evaluate the Storm Drainage Utility and identify gaps
between existing service levels and the system goals described in Section 3.2. The following types of
evaluations were completed to identify Storm Drainage Utility future activities to address the range of
system goals:
Existing system deficiency and future service area expansion: Identified existing system
deficiencies and future service areas in Chapter 4 and considered them in developing the
capital improvement plan (Chapter 7). Did not evaluate improvements to address existing
deficiencies and future expansion relative to policy and system goals as a part of this Plan.
Hydraulic: Gathered system data, updated or developed computer models, assessed
hydraulic performance, and developed CIPs with respect to associated system design
criteria.
Asset management: Reviewed existing asset system for data gaps, analyzed the adequacy of
the condition assessment data being collected, established criteria for preparing criticality
and risk analyses, developed the prioritization system to inspect critical system elements,
developed the system requirements specification for integrating pipe criticality into the City’s
CMMS, estimated the funds needed for future asset repair and replacement, and included
those estimates in the resource planning assessment (Chapter 6).
Regulatory-driven improvements: Determined differences between the 2024–2029 permit
and the previous NPDES MS4 permit and evaluated how the differences could affect City
regulations, infrastructure, and activities; estimated the time and costs for NPDES MS4
permit compliance.
Climate change analysis: Conducted a climate change analysis by reviewing the projected
alterations in climate outlined in Chapter 4 and offered recommendations for effective
mitigation measures.
Maintenance and operations: Assessed process performance, equipment, and personnel
with respect to service levels for M&O (covered in Chapter 6).
These evaluations were conducted to develop capital improvements for the 6- and 20-year horizons,
as well as to identify future M&O needs. The following sections summarize the hydraulic, asset
management, regulatory-driven improvements, and climate change evaluations. The existing system
deficiency and future service area expansion are described in Chapter 4, and the M&O evaluations
are described in Chapter 6.
5.1 Hydraulic Evaluation
As described in Chapter 4, the City of Auburn owns and operates a large system of stormwater
drainage infrastructure to collect and convey stormwater runoff to nearby receiving waters.
Hydraulic modeling efforts for the 2024 Plan focused on updating models covering locations of
proposed capital projects. The model updates were based on recent geographic information system
(GIS) data, design drawings, and record drawings.
The City reviewed the remaining CIPs listed in the 2015 Plan and the recent proposed stormwater
CIPs. Six projects are located within existing subbasins represented by hydrologic and hydraulic
(H&H) subbasin models. Two of the projects were evaluated with associated H&H subbasins models
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and were included in this Plan’s CIP program. Appendix B provides a detailed description of the
H&H model updates and CIP evaluation results.
The following sections describe the steps used to update existing models or develop new models.
5.1.1 Updating Existing Models
The hydraulic components of existing models were updated with recent GIS data. The following
model data were verified against the GIS data:
Pipe size.
Pipe invert elevations.
Pipe material (for estimating pipe roughness).
Node rim elevation.
System connectivity.
Where the GIS data did not accurately describe the existing system, technical reports, record
drawings, or construction drawings were used to update the model. Where data were available,
models were given more detail with respect to pump and storage facility information.
For model hydrology, subcatchment delineations within problem areas were reviewed and revised
based on recent GIS data, topographic data, and 2024 aerial photography. For subbasins with
significant changes in basin delineation, total impervious area was updated with the City’s
impervious area coverage. No existing models were calibrated or uncalibrated. If new and significant
large infiltration facilities were constructed since the 2015 Plan, the percent impervious area was
reduced based on an assumed contributing area by visual inspection of aerial photography.
5.1.2 Creating New Models
The following is a general description of steps followed to develop new Personal Computer
Stormwater Management Models (PCSWMM)3.
1. Infrastructure data from existing GIS databases were used to build drainage networks in problem
areas. Drainage network models consist of catch basins, manholes, pipes, junctions, ditches,
control structures, vaults, storage ponds, pump stations, and outfalls. GIS data were validated
and augmented as necessary based on record drawings and City-conducted field investigations.
2. The drainage network was developed to a level of detail that is sufficient for analyzing
conveyance on a subbasin-wide or problem-specific scale. In general, pipes 1 foot in diameter or
greater were included. Smaller-diameter pipes and pipes that were part of private systems were
generally not included in the model unless they provided an important link within the system.
3. Subbasin areas were divided into smaller drainage area delineations called subcatchments,
which in the model are linked into the drainage network at specific nodes. Hydrologic
parameters, such as area, slope, and percent impervious area, are developed for each
subcatchment. Subcatchment slope was estimated as the average slope based on a digital
elevation model (DEM). Total impervious area was estimated with the City’s impervious area
coverage.
3 PCSWMM is a GIS-based hydraulic and hydrologic modeling platform developed by Computational Hydraulics
International (CHI). The software fully supports the EPA SWMM5 hydrology and hydraulics engine, thus
providing comparable computation between EPA SWMM and PCSWMM models. Information about PCSWMM
software can be found at http://www.chiwater.com/Software/PCSWMM/index.asp.
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For the purposes of this plan, there was no requirement to develop new models. Rather, the existing
H&H models from the 2015 Plan underwent refinement and updates. Further information on these
specific modifications is available in Appendix B.
5.1.3 Updating Precipitation Record and Flow Frequency
Auburn’s H&H models use historical meteorological data to estimate stormwater flows and storage
within the City’s storm drainage system. The data consist of monthly evaporation and 15-minute
precipitation volumes. As part of the Plan, the 15-minute precipitation record was extended to
September 30, 2022, creating an approximate 74-year precipitation record.
Long-term simulations were performed using the extended precipitation record to determine the 2%
and 4% exceedance storms (one in 50-year and one in 25-year flows, respectively) for the updated
models. These storms were used as design storms to size capital improvements, which meet the
water treatment standards and LOS (see Chapter 7 for a description of proposed capital
improvements).
5.2 Asset Management Review
All utilities manage their assets in one way or another through maintenance practices, CIPs, and
repair and replacement (R&R) activities. However, the ability to make an informed decision regarding
where and how to direct limited resources is dependent on the quality of the utility’s asset
management. A comprehensive asset management framework includes building a thorough asset
inventory, using that inventory to prioritize and document maintenance and inspection tasks, and
tracking annual management expenses. An asset management framework developed in this way will
demonstrate both the extent of the existing system, as well as aid in forecasting its useful life and
the future costs of maintenance, reparation, and replacement.
Stormwater system assets fall into this framework but also exhibit unique characteristics regarding
their service levels, failure risk and consequences, and asset response approaches. For example, the
consequence of failure for a stormwater pipe is less significant than it would be for a water pipe, and
this distinction is reflected in the asset management approach. The asset management plan for the
City’s stormwater system accounts for these considerations along with the current inventory and
condition information while adopting a responsible approach to resource management of the assets.
5.2.1 Best Practices
The best practices for asset management involve methodically basing choices on an understanding
of asset condition and performance, risks, and costs in the long term. Asset management best
practices include the following:
Establishing and maintaining a sustainable LOS that balances the performance goals of the
utility, regulatory requirements, and consumer demand.
Preparing and regularly updating an inventory and map of the system.
Understanding the risk associated with managing a given asset (i.e., defining the asset’s
likelihood and consequence of failure).
Implementing a prioritization process for work based on condition assessments and taking a
life cycle approach to asset management planning.
Establishing funding levels and rates to provide reliable, cost-effective service, and support
ongoing infrastructure rehabilitation or replacement projects.
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These best practices were followed in evaluating the management of the City’s assets, as described
below. System goals for the City’s Storm Drainage Utility were established in Chapter 3 of this Plan.
5.2.2 Evaluation
For the Plan, the preliminary focus of the asset management evaluation was on the City’s stormwater
collection pipe network, the results of which may be used to inform the management plan for the
other categories of assets within the City’s Storm Drainage Utility system. The City uses Cartegraph
as its CMMS to store and map its asset inventory, so all evaluations were performed on data
exported from this source.
Data Gaps Analysis & Condition Assessment
The first step in the evaluation involved assessing the comprehensiveness of the asset inventory. To
do so, a data gaps analysis and condition assessment was necessary to understand the
completeness of the asset inventory and the availability of feature data for developing criticality and
risk analyses. The results of these analyses demonstrated a pipe inventory that was incomplete.
Several pipes were missing attribute data—namely installation date and material—critical for
estimating risk of failure in the next step in the evaluation. See Figure 5-1 and Figure 5-2 for the
availability of pipe attribute data relative to the total length of pipe in the system for reference.
Figure 5-1. Pipe Installation Date Relative to Total Linear Feet of Pipe
Unknown
10%1940-1949
1%
1960-1969
8%
1970-1979
8%
1980-1989
13%
1990-1999
20%
2000-2009
23%
2010-2019
14%
2020-2029
3%
Unknown
1940-1949
1960-1969
1970-1979
1980-1989
1990-1999
2000-2009
2010-2019
2020-2029
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Figure 5-2. Pipe Material Relative to Total Linear Feet of Pipe
For the purposes of the risk evaluation, professional estimates were made to serve as placeholders
for missing attribute data. A preliminary GIS-based assessment was performed to provide an
estimate installation date based on adjacent infrastructure, parcel build-out years, and historical
imagery as needed. Estimated inputs were added to a copy of the installation date attribute to
ensure estimates could be distinguished from the original dataset. Further detail regarding the steps
taken in the data gaps analysis and condition assessment is provided in Appendix C. There were
critical data gaps in other stormwater asset inventories, namely culverts. Thus it could be beneficial
to do a similar GIS-based assessment for other asset types to have a comprehensive starting point
for prioritization of work. It is recommended that critical data gaps be addressed as part of the asset
management program, as summarized in the following paragraphs.
Risk Determination
The next step in the evaluation involves determining the risk associated with managing each of the
City’s storm drainage assets. The exported pipe data from the City’s Cartegraph database was used
to build a risk assessment spreadsheet. The spreadsheet evaluates specified criteria to generate a
score for likelihood of failure and criticality of failure for each asset. Within the spreadsheet,
likelihood of failure is largely dependent on critical attributes specific to the feature, while criticality
of failure is dependent on location-based factors.
For the City’s pipe network, the attributes used to develop the likelihood of failure score include
installation data and material. The installation date provides the age of the pipe, while the
installation material is used to estimate the expected useful life. Combining these characteristics
provides an estimate for the pipe’s remaining useful life, which is the basis for the likelihood of
failure score. In general, if a pipe had a negative remaining useful life, it had a high likelihood of
failure (the highest score being 5), whereas if it had a positive remaining useful life, it had a low
likelihood of failure (the lowest score possible is 1).
The criticality of failure score was developed by evaluating a pipe’s proximity to critical facilities,
high-priority roadways, and high-trafficked roadways. If a pipe is in close proximity to one of the
aforementioned factors, this results in a higher criticality of failure score (the highest score being 5).
Conversely, a pipe not in close proximity to any evaluated factors results in a low criticality of failure
score (the lowest score being 1).
Other
2%
CMP
7%
CONCRETE
26%
CPEP
10%
DUCTILE IRON
6%
PVC
39%
RCP
8%
Unknown
2%
Other
CMP
CONCRETE
CPEP
DUCTILE IRON
PVC
RCP
Unknown
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While the spreadsheet was developed solely for the City’s pipe system, a similar process may be
followed for the other asset types within the stormwater inventory. See Appendix C for the critical
attributes recommended to use in determining the risk for the other types of stormwater assets.
Work Prioritization
The resulting failure scores allow for the City to rank different assets both on likelihood and criticality
of failure. It is recommended to use this ranking strategy to develop an inspection program where
inspections of different types of assets are prioritized based on their rank. The asset inspection
program will serve to fill data gaps, update the likelihood of failure score based on field verification,
and identify asset features requiring repair or replacement. After inspection data are input for an
asset feature, the results of the inspection will supersede the use of estimated remaining useful life
and installation date (where applicable) in calculating a likelihood of failure score. Using this system
to prioritize maintenance allows resources to be used more efficiently and fills in data gaps resulting
in a more robust asset inventory.
For the City’s pipe system, the recommended program would prioritize inspection based on likelihood
of failure and then criticality of failure. In this way, pipes with likelihood of failure scores greater than
or equal to 4 (or a negative useful life estimate) will be inspected first. The next tier of inspections
should address pipes with likelihood of failure scores equal to 3 and pipes with unknown installation
dates. After pipes are inspected, they should be assigned a condition score, which will supersede the
installation date and useful life expectancy in determining the likelihood of failure. The likelihood of
failure for a pipe will increase over time, and this prioritization method will take this into account
while integrating field inspection data. Since storm catch basins and storm manholes are related to
pipes, it is recommended to inspect these at the same time as adjacent pipes.
The same inspection prioritization method is recommended for culverts as the failure consequences
are similar. For storm pumps, it is recommended to closely evaluate their condition as their useful
life nears the end (e.g., 5 or fewer years) and upgrade or replace them before probable failure.
Stormwater control facilities should be routinely inspected and prioritized for inspection when critical
feature data are unavailable. As mentioned previously, critical feature data for each asset type are
listed in Appendix C. More detail regarding the inspection frequency and schedule for each type of
stormwater asset is included in Chapter 6.
Life Cycle Estimation
A life cycle analysis was performed for pipes to demonstrate the expected depreciation rate of each
asset and provide background for the recommended maintenance frequency of the entire system. To
do so, the remaining useful life estimate for the City’s pipe database was analyzed over time. This
analysis was used to identify any spikes in development (and accordingly when spikes in R&R would
be expected) and estimate the total linear feet of pipe “lost” (or whose projected remaining useful
life becomes negative) per year. This rate of pipe loss may be used as a point of comparison for
basing the resource planning recommendations in Chapter 6. A similar life cycle analysis could be
beneficial for culverts.
As features are updated with field-verified data (during inspection or maintenance), the results of
this life cycle analysis are expected to change. For this reason, the pipe depreciation analysis may be
reconducted to evaluate the effect on the projected rate of pipe loss. The results of the pipe
depreciation analysis can be found in Appendix C.
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Cost Projection
A brief review of costs were included in the asset management evaluation for consideration in
setting the R&R budget and resource planning goals in Chapter 6. Two options were contemplated in
setting the R&R budget: investigating the prior use or need and evaluating the results of the life cycle
estimation. The City’s R&R spending in previous years was compiled to investigate the prior use. To
evaluate the results of the life cycle estimation, the cost of replacing pipes based on the rate of
depreciation was projected. The useful life of the system was also varied to observe the change in
budgetary needs.
A comprehensive cost estimate was prepared for both pipe replacement and the replacement of
catch basins and manholes within the City. Notably, the cost estimate for pipe replacement serves as
a generic assessment for the City of Auburn rather than being tied to any specific project or
geographical area. The primary calculations for cost estimation assume the replacement of
5,000 linear feet of pipe along with the associated conveyance structures, such as manholes and
catch basins. To simplify these calculations, certain generalizations were made—including the
assumption that all pipes are of uniform size, material, and depth—based on GIS averages for
the City.
Furthermore, various scenarios were explored to assess how the cost of pipe replacement might vary
based on location (downtown versus rural) and quantity (5,000 versus 10,000 linear feet). The
resulting cost opinion is intentionally conservative, approximately $1,500 per linear foot, to account
for the wide range of generalizations and assumptions inherent in the process. Notably, the analysis
indicated that pipe replacement in rural areas is expected to be less costly than in the City center.
Additionally, replacing a larger quantity of pipe is only marginally more cost-effective.
For detailed estimates and further information regarding the cost projection, please refer to
Appendix C.
As a prudent practice, it is recommended to diligently track the costs associated with installation,
repair, and replacement of asset features on an annual basis. This data serve as valuable reference
information for future asset replacement budget planning. As additional data are collected, cost
opinions can be updated to enhance accuracy.
5.2.3 Recommendations
Evaluations completed for this Plan consisted of developing a system requirements specification for
implementing risk assessment using the data in the City’s asset management system, Cartegraph.
The spreadsheet’s scoring methods may be integrated into Cartegraph so that, as the pipe inventory
is updated, likelihood of failure and criticality of failure scores can be used to inform future R&R
priorities. Currently, the spreadsheet only includes collection system piping scores. However, there is
an opportunity to expand the scoring methods to include other asset features, as described in
Appendix C.
The following are recommended to implement the asset management strategy:
Train staff in asset inventory needs, capability, data collection, data quality objectives, and
maintenance of system.
Implement the likelihood of failure and criticality of failure scoring methods into Cartegraph.
Implement the prioritized inspection and asset information update process to fill data gaps in
the asset data and provide observation-based condition assessments.
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Develop a process for reviewing the asset inventory and a routine for updating when changes
and inspections occur.
Expand scoring methods to include asset types other than collection system piping and
implement them similarly into Cartegraph and inspection prioritization techniques.
Consider reconducting pipe depreciation analysis every 5 years to evaluate the effect of
implementing the prioritization practice.
Assess the inspection process in 5 years to assess the efficiency of the program and identify
areas for improvement.
5.3 Regulatory-Driven Improvements Investigation
The federal Clean Water Act requires municipalities to help maintain fishable/swimmable waters
through the NPDES MS4 permit program (see Section 2.3.2 and Appendix A), which requires
municipalities to reduce the discharge of pollutants from their stormwater systems to the MEP by
implementing municipal stormwater management programs. The City has an established municipal
SWMP that complies with all NPDES MS4 permit requirements currently in effect. Updates to the
City’s codes, programs, and standards are being developed to comply with the requirements of the
updated 2024 NPDES MS4 permit.
The City’s SWMP plan identifies activities that will be implemented by the City to comply with NDPES
MS4 permit requirements. The SWMP plan is updated annually to reflect new requirements that phase
in during each year, including one-time and new ongoing activities. An updated SWMP is submitted to
Ecology in March of each year. The City’s current SWMP plan is accessible on the City website.
To plan for upcoming requirements of the new NPDES MS4 permit, the City formed a project team
consisting of staff from the City Public Works department and Parametrix.
The project team reviewed Auburn’s citywide stormwater management programs, codes, standards,
processes, and documentation protocols in order to identify potential actions to comply with the
NPDES MS4 permit conditions over the 5-year permit period. From these sources, the project team
created a document cataloging responsible City departments/entities, reference documents, and
potential requirements for each updated section of the permit. Interviews were then conducted with
appropriate staff (e.g., stormwater M&O staff) to discuss the potential implications of permit changes
for existing City codes, programs, and standards. The information on existing City practices and
programs was then compared to the updated permit requirements to identify potential compliance
needs. Some policy issues and potential compliance strategies were also identified. A technical
memorandum summarizing the current and anticipated NPDES requirements and infrastructure
changes was developed and is included in Appendix D. Recommended future activities are
summarized below and included in the implementation plan in Chapter 8.
5.3.1 New Permit Requirements and Recommendations
Table 5-1 summarizes the recommended actions to address regulatory driven stormwater program
responsibilities.
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Table 5-1. Recommended Actions Regarding New Permit Requirements
Permit Section New Requirement Recommended Action(s)
S2.B Develop a management plan for per- and
polyfluoroalkyl substances (PFAS).
Coordinate with firefighting agencies/departments
to implement specific protocols regarding PFAS
discharges into stormwater.
S5.C.1.c.iii Adopt and implement tree canopy goals and
policies to support stormwater management
and water quality improvement in receiving
waters.
Prepare an assessment of existing conditions.
Draft a list of potential policies.
Select and adopt policies.
S5.C.1.d.i Complete a stormwater management action
plan (SMAP) for at least one new high-priority
catchment area or additional actions for the
existing SMAP.
Identify a preferred catchment area for inclusion or
enhancement.
Prepare a new SMAP or update the existing SMAP.
S5.C.1.d.i.(a) Consider implementing projects that address
transportation-related runoff, such as projects
that address tire wear runoff.
Review the road system plan.
Review high-priority roadways.
Determine candidate sites for retrofitting using
SMAPs, capital improvement projects, or other
relevant plans.
Select projects and include in capital improvement
plan.
S5.C.2.a.i.(b) Provide public education regarding source
control best management practices (BMPs) for
building materials to reduce pollution to
stormwater, including stormwater pollution
from materials containing polychlorinated
biphenyls (PCBs).
Provide public education regarding source control
BMPs for building materials.
S5.C.4.b.ii Develop a map of discharge points that have
stormwater treatment and flow control
BMPs/facilities.
Develop a methodology to map tributary basins to
outfalls.
Identify facilities to be mapped.
Use a geographic information system (GIS) to
prepare a map of catchment areas.
S5.C.4.b.iii Map permittee-owned or operated properties
with tree canopy.
Begin mapping of permittee-owned or operated
properties with tree canopy based on available,
existing data.
S5.C.7.b Fully fund, start construction, or completely
implement project(s) that meet the City’s
assigned equivalent acreage of 8.9 acres.
Prioritize projects developed in the SMAP that
together meet the City’s assigned 8.9 acres.
S5.C.9.e Develop and implement a municipal street
sweeping program to target high-priority areas.
Review and revise the existing sweeping program as
needed.
5.4 Climate Change Analysis
Section 4.1.8 reviewed the projected climate changes specific to the City. This section focuses on
potential strategies to mitigate these changes and provides recommendations for effective
implementation. By comprehending expected shifts in the environment, the City can proactively
adapt its practices and policies to safeguard the community.
5.4.1 Discussion of Proposed Approaches
Although the City is not predicted to see a significant increase in overall precipitation, climate models
predict an increase in the frequency of intense precipitation, specifically during the winter months
(see Figure 4-5). Increased winter storm intensity frequency is most likely to push the stormwater
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system past the accepted LOS over time up to the projected time frame of the reported climate
models.
Storm intensity (rate of rainfall for a unit of time, usually in inches per minute) tends to affect storm
drainage systems differently than prolonged, atmospheric river systems. Storm sewers and local
conveyance systems are generally designed for the peak runoff intensity (within a short or long
event), whereas larger conveyance systems, streams and floodplains, and stormwater control
facilities are designed using hydrographs for longer duration events. This would suggest, based on
the predictions regarding total rainfall versus intense rainfall, that storm sewers, conveyance
systems, and culverts will be more vulnerable to capacity exceedance and subsequent flooding.
One approach to addressing this potential service deficiency is to design with future projected storm
patterns or to apply a larger design storm. This would address the greater flood frequency risk.
However, it would not “prevent” flooding. This would increase the costs of all projects for both public
and private development and would also impact the cost of housing impacting the affordability of
future housing developments. Stormwater conveyance systems are designed to manage a specific
LOS, usually the peak runoff rate from a 25-year, 24-hour storm. Performance is typically evaluated
by hydraulic metrics, such as minimum freeboard in a channel, headwater depth on a culvert, or
surcharging in a storm sewer that keeps water in the system and away from property. While a
stormwater system may not be performing according to design, the impacts may not be flooding or
property damage. In addition, storms larger than the design storm can and will occur, with adverse
consequences.
It has generally been deemed to not meet cost-benefit metrics to build systems to address every
likely storm outcome. An event exceeding the design capacity of a system could occur at any time;
the “average” number of times it occurs is likely to increase with increased storm intensity frequency
due to climate change. Another approach would be to address the consequences of the projected
change on a site-by-site basis rather than a blanket change in service levels for future rainfall.
Stormwater flow control facilities are designed to manage changes to the landscape and resultant
runoff to existing or predeveloped levels. The analyses use a historical rainfall record and projections
of that record over an extended time period, all based on past rainfall patterns. The stormwater
control standards require runoff changes to be matched to land conditions prior to development or
existing conditions, typically a forested condition. One approach to new stormwater standards to
address flow control under a changed climate with more frequent intense rains is to use projected
rainfall patterns that are modified to add climate change projections. In addition, flow control
evaluations are comparative, which means they evaluate the hydrologic changes due to
development. This is different than considering the changes in hydrology from the site today with a
site under future climate conditions (in addition to restoring existing hydrology to predevelopment
conditions). The comparative change (future climate to compare existing and future site
development) may not be significant.
River and stream flooding could increase in frequency due to climate change. According to the
stream flow projections shown in the publication, Effect of Climate Change on Flooding in King
County Rivers, winter flow volumes are expected to rise due to an increase in the proportion of
precipitation falling as rain over the course of the 21st century (Lee et al. 2018). This increase is
anticipated despite the modest long-term projections for average annual rainfall shown in Figure 4-5.
Smaller, local stream systems (e.g., Olson Creek, Mill Creek, Bowman Creek) are expected to have
more frequent flooding (i.e., flow overflowing its confined banks), and extreme events are more likely
to occur (i.e., the current 1% probability flood would have a higher percentage chance of occurring in
the future). Storm drainage infrastructure that interfaces with these natural drainages should be
reevaluated to consider negative consequences and resiliency (the ability to safely withstand critical
service disruption).
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5.4.2 Recommendations
Stormwater design guidelines will need to consider the possible changes in storms that are informed
by future climate scenarios. The strategy aligns with the guidance for stormwater design and sizing
recommended and approved by the Water and Land Resources Division of the King County
Department of Natural Resources (King County DNR 2021). For example, the guidance provides
direction for the design of new pipe systems with sufficient capacity to convey and contain (at
minimum) the future predicted 25-year peak flow. Pipe system structures may overtop during runoff
events that exceed the 25-year design capacity. However, this is permissible as long as the overflow
resulting from a larger event (e.g., a 100-year runoff event) does not lead to severe flooding or
erosion issues. Additional design guidelines for new flow control standards, conveyance standards,
culverts, ditches, and canals are also included.
The recommended approach to mitigate effects due to climate change is described as follows.
Drainage System Performance. Because of likely changes in the frequency of intense rainfall, the
following recommendations should be considered in the design of conveyance systems:
Review and revise the hydraulic performance metrics related to freeboard, headwater depth,
and surcharging. Evaluate the financial implications associated with enforcing strict hydraulic
performance standards.
Prepare a critical drainage review (CDR) process (as identified as a work order in Section 8)
to evaluate the consequences of storm events exceeding the design parameters. Establish
clear policies regarding safety, property protection, service continuity, and mitigation of
nuisance flooding to make systems more resilient to infrequent but probable flooding.
Ensure that the level of protection aligns with the associated costs and risk factors.
Prioritize effective hydraulic performance and resilience measures for critical facilities during
severe storm events that go beyond the intended design limits.
River and Stream Flooding. River and stream flooding frequency is expected to increase. The
vulnerability of existing infrastructure in or near streams or floodplains has not been assessed in
this Plan.
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6. Maintenance and Operations
An evaluation of existing Storm Drainage Utility M&O activities was conducted in support of this Plan.
This chapter documents existing Storm Drainage Utility M&O activities with the primary purpose of
establishing a baseline understanding of the proactive and responsive maintenance procedures
performed by City Storm Drainage Utility M&O staff. This baseline understanding is used herein to
evaluate utility staffing, data collection and computerized record-keeping needs, and other utility
needs necessary to continue to meet system goals.
The information provided in this chapter is a summary of information collected during City Storm
Drainage Utility staff interviews, review of computerized records, and existing utility forms/checklists.
6.1 Utility Responsibility and Authority
This section provides an overview of the Storm Drainage Utility organization and basic information
related to utility staffing, training, and education.
6.1.1 Organizational Structure
The City Storm Drainage Utility is operated as a utility enterprise under the direction of the director of
public works. The Public Works Department is responsible for planning, design, construction,
operation, maintenance, quality control, and management of the storm drainage system. The City
has a mayor-council form of government; therefore, the director of public works reports to the mayor,
with input from council through council study sessions and meetings. The mayor provides oversight
for the implementation of policies, planning, and management for the Storm Drainage Utility. The
City Council provides direction on policy and budget considerations.
The Engineering Services Department is the lead group for comprehensive storm drainage system
planning, development of a CIP, and the design, construction, and inspection of projects related to
the storm drainage system.
M&O Services is the lead group responsible for the day-to-day maintenance and operation of the
storm drainage system. The storm drainage/sanitary sewer manager reports to the M&O Services
general manager and oversees 11 total storm drainage employees (1 field supervisor and
10 maintenance workers, as shown in Table 6-1). The Vegetation Maintenance Division is
responsible for mowing, tree trimming, and weed control of City ROW and storm facilities.
The overall Public Works Department organizational structure is shown in Figure 2-1.
6.1.2 Staffing Level
The Storm Drainage Utility currently includes 10 full-time M&O field staff, plus a field supervisor and
a manager, who perform administrative duties. This chapter does not include an evaluation of utility
management, which includes regulatory compliance, planning, and coordination with other City
departments. Position titles and the primary functions of the M&O staff working within the Storm
Drainage Utility are shown in Table 6-1.
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Table 6-1. Storm Drainage Utility M&O Personnel
Position Primary function(s)
Storm drainage/sanitary sewer manager Management of sanitary sewer and storm drainage M&O staff
Storm field supervisor Supervision of field staff
Maintenance worker Ten full-time staff dedicated to field inspection and maintenance
M&O = Maintenance and Operations
In addition to the M&O field staff identified in Table 6-1, secondary staff support the following Storm
Drainage Utility functions:
Management and administration: A full-time manager performs administrative duties for
both the Sanitary Sewer and Storm Divisions. Management and administrative tasks include
general oversight of the Sanitary Sewer and Storm Drainage Utility M&O staff, regulatory
compliance, planning, and coordination with other City departments. Field work is supervised
by a full-time field supervisor.
Vegetation maintenance: The Vegetation Maintenance Division consists of 10 full-time staff,
a field supervisor, and a manager. These staff primarily support the Storm Drainage Utility
M&O field staff (approximately 60% of total staff effort) with pond vegetative control, weed
control and herbicide spraying, ROW and ditch mowing, tree trimming and removal, and leaf
removal.
Contracted services: The Storm Drainage Utility uses other City departments or external
contractors for some services, as discussed in Section 6.3.
M&O activities routinely performed by Storm Drainage Utility staff are discussed in Section 6.2. The
staffing plan presented in Section 6.6 considers M&O activities performed by Storm Drainage Utility
and Vegetation Maintenance staff.
6.1.3 Level of Service
The Storm Drainage Utility operates in accordance with the system goals and policies outlined in
Chapter 3 and internally adopted objectives integral to meeting those goals. These objectives are
generally based on the current staffing level and tasks deemed most critical to the City and its
residents. However, the existing staffing requirements discussed in Section 6.6 herein include
near-term goals that may not be met by existing staff.
6.1.4 Training and Education
The City recognizes the value of having a knowledgeable and well-trained staff operating the storm
drainage system and encourages employees to obtain the highest level of training available. At this
time, the State of Washington does not require certification for stormwater maintenance operators, but
the City would support any effort to establish certification for these positions. Seminars, conferences,
and college coursework have become tools to advance knowledge for maintenance staff.
Many M&O staff are specialized in specific job functions, which can promote expertise through
specialization but also has the potential to limit the ability of the utility to absorb absences due to
vacation, sickness, retirement, resignation, and termination. To mitigate this limitation, the City has
broadened the scope of the Storm Drainage Utility’s education system by conducting
cross-training programs.
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6.2 Routine Operations Provided by the Storm Drainage Utility
This section discusses routine operations provided by the Storm Drainage Utility M&O staff shown in
Table 6-1. Each subsection provides a brief description of the M&O activity, City goals with respect to
proactive maintenance, and the estimated Storm Drainage Utility staff effort to achieve the proactive
maintenance goal.
6.2.1 Catch Basin and Manhole Inspection, Cleaning, and Repair
The storm drainage system includes approximately 10,800 catch basins and 3,172 manholes. Catch
basin and manhole maintenance includes initial inspection and potential follow-up cleaning and/or
repair. Inspection is performed by a two-person crew using utility mapping to locate the targeted
facilities. M&O staff use condition categories from the CMMS asset management system to identify
which facilities require further cleaning or repair. The condition categories consider items such as
observation of trash, debris, sediment, or vegetation blocking or within the catch basin/manhole;
structural damage; evidence of contamination or pollution; and the integrity of catch basin grates,
manhole covers, and ladders. Follow-up cleaning and maintenance work orders are generated based
upon the results of initial inspection and typically include a two-person crew. Based upon recent
maintenance history, approximately one in five catch basin and manhole inspections leads to further
cleaning. The City assumes that a total of 5% of catch basins and manholes per year require an
additional visit post inspection for some level of maintenance or repair. Catch basins and manholes
requiring only minor maintenance tasks that can be performed during inspection are not included in
this total.
Catch basin inspection is required as part of the City’s NPDES MS4 permit, per the most recent
permit, 2024–2029 issuance. The City is required to inspect and maintain all catch basin facilities
every 2 years, with each 2-year cycle ending on December 31. To achieve this permit requirement,
the City goal is to inspect 40 catch basins per day. Manhole inspection frequency is not mandated by
the permit, but the City’s goal is to complete inspection of all City manholes on a 4-year rotating
schedule.
The City will use the CMMS software (see Section 6.5) to record and track results of catch basin
inspection, cleaning, and maintenance efforts. In the future, if catch basin inspection records
demonstrate that catch basins generally comply with maintenance standards and do not require
inspection every 2 years, the City may be able to justify and suggest a less frequent inspection
schedule for compliance with the Permit.
6.2.2 Stormwater Pipeline Cleaning
The storm drainage system includes approximately 250 miles of collection system piping. The City
currently cleans its stormwater pipelines on an as-needed basis. Cleaning of the storm drainage
system is performed using a City-owned Vactor/jet truck. Cleaning is typically performed from
structure to structure (e.g., catch basin or manhole) by a two-person crew.
Jetting of stormwater pipelines is the principal means of removing debris or obstructions from the
storm drainage system. A hose with a special end fitting is inserted into a pipe and high-pressure
water (up to 2,500 pounds per square inch) is sent through the hose. The high-pressure water exits
the small hole at the tip of the nozzle, breaking down and/or scouring obstructions. Debris is then
removed via suction by the Vactor truck equipment at each manhole.
The City expects to clean 4% of its stormwater pipeline system per year. On average, a two-person
crew can clean approximately 1,500 feet of pipe per day and inspect approximately 500 feet of pipe
per day.
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6.2.3 Stormwater Outfall Inspection, Cleaning, and Maintenance
The storm drainage system includes 124 outfalls or discharges from localized collection systems to the
Green River, White River, or Mill Creek. Outfall maintenance includes initial inspection and potential
follow-up corrective actions. Outfall inspections are performed to identify the following: excessive
vegetative growth that could obstruct flow, outfall erosion protection, structural damage to the
conveyance system itself, and abnormal discharge that might be indicative of contamination (as
demonstrated by a color, sheen, or odor). Cleaning and minor maintenance tasks are performed during
inspection. Necessary follow-up repairs or more intensive maintenance work orders are generated
based upon the results of the initial inspection. The City goal is to inspect, clean, and perform minor
maintenance tasks at each outfall twice per year. The City assumes that 5% of outfall inspections per
year require an additional visit post-inspection for some level of maintenance/repair. For a two-person
crew, it is anticipated that inspection, cleaning, and minor maintenance requires 2 hours per outfall,
while follow-up maintenance or repairs requires 0.5 hour per outfall.
6.2.4 Drainage Ditch Maintenance and Restoration
The storm drainage system includes approximately 42 miles of drainage ditches (as shown in Figure 6-1).
Drainage ditch maintenance is required to preserve the original line and grade, hydraulic capacity, and
purpose of the ditch. Routine maintenance activities include regrading and removal of sediment;
nuisance vegetation; and isolated obstructions, such as trash, trees, and accumulated debris. Because
vegetation is important for erosion control, the City strives to minimize the removal of beneficial
vegetation.
Up to six M&O staff are required for a single ditch maintenance crew to operate the City-owned excavator,
control traffic (as necessary), and manually regrade or remove obstructions. On average, these crews can
complete 200 feet of ditch maintenance per hour. This rate does not include mobilization and
demobilization, equipment repair and other downtime, waste disposal, and administrative tasks, such as
training and record keeping. Currently the ditch inventory is maintained on an as-needed basis, however
the City has a target to maintain all ditches within the system on a 5-year cycle.
6.2.5 Stormwater Facility Inspection, Maintenance, and
Restoration
Inspection of the approximate 300 City stormwater facilities is performed by a one-person crew using
an inspection checklist to identify conditions that require correction. Facilities include stormwater
ponds, swales, vaults, tanks, UIC, LID, and manufactured treatment devices. The checklist includes
items such as observation of trash, debris, sediment, and animal or insect infestation that could impact
function or future maintenance; structural damage or erosion; evidence of contamination or pollution;
and the integrity and/or function of emergency overflow spillways (as applicable). The City goal is to
inspect each facility once per year. On average, inspection activities require 0.75 hours for a one-person
crew per location. This rate does not include mobilization and demobilization, equipment repair and
other downtime, waste disposal, and administrative tasks, such as training and record keeping.
Maintenance and restoration of each facility type varies. The City has a goal of maintaining permeable
pavement twice per year. On average, a four-person crew can maintain 0.3 miles of permeable
pavement per hour. The maintenance of vaults, tanks, and underground injection control (UIC) wells are
all accounted for under general facility maintenance in Section 6.2.9, Manufactured treatment devices
are maintained by an outside contractor and included in Section 6.3.3.
Maintenance of ponds and swales (of which there are approximately 184) are performed as necessary,
with the expectation of maintaining or restoring 20% of the system each year. A six-person stormwater
pond crew is required for pond maintenance, while swales require a four-person crew. For the purposes
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of the full-time equivalent (FTE) calculation, the expected maintenance of ponds and swales have been
combined (as there are only two swales within the system). Follow-up maintenance and restoration is
scheduled during the summer months. The City assigns a six-person stormwater pond/swale crew
approximately 21 days per year (3 days per week for 3 out of 4 months in the summer).
After significant storms, it is recommended that some stormwater facilities be inspected to verify
proper function and identify damage, if any. It is recommended that the City develop a list of facilities
that should be inspected following these larger storm events.
6.2.6 Culvert Inspection and Cleaning
Culvert maintenance includes inspection and cleaning of the approximately 1,164 culverts within the
storm drainage system. Culverts are typically inspected by a two-person crew, with corrective actions
and cleaning performed during the inspection when possible. On average, inspection and cleaning
activities require 1 hour per culvert for a two-person crew. Culvert inspection focuses on the
assessment of free flow within the culvert and identifying any structural defects. Any debris that
cannot be removed during the initial inspection or any noted structural concerns result in a work
order for corrective action. The City goal is to inspect (and clean as necessary) each culvert once
per year.
6.2.7 General Facility Maintenance and Other Field Tasks
Storm Drainage Utility M&O staff perform a number of field tasks that do not readily fall into the
categories previously listed and often support other City departments. Examples of these additional
storm drainage tasks include the following:
General facility maintenance: Maintenance may include detention vault and tank cleaning
and sediment removal, weir cleaning, filter inspection and cleaning, and maintenance of
oil/water separators and UIC.
Engineering support: Storm Drainage Utility M&O staff often provide facility inspection
services for engineering projects and support Engineering through visual observation in the
field. M&O staff also make small repairs such as replacing catch basins or failed culverts or
minor drainage pipe replacement. See Section 6.7 for recommendations related to
documenting M&O repair projects.
Identifying the FTE for each task identified above was not considered as a part of this Plan. Instead,
the FTE for the above tasks have been combined into one group summarizing the general inspection
and field tasks performed by the Storm Drainage Utility staff. The City may choose to identify the
expected FTE for each task at a later date, if desired. FTE assumptions are summarized in
Section 6.6.
6.2.8 Storm Drainage Utility Overhead
The Storm Drainage Utility is responsible for ensuring routine operations are carried out as described
above. To do so, several tasks not readily assigned to any one of the routine operation categories
must be performed. Examples of these tasks are listed below:
Training: Staff must be trained in routine field operations as well as the general order of
processes required before and after field operations
Record keeping and map maintenance: The utility ensures the results of routine operations
are recorded and updated with condition assessments and mapped appropriately. The utility
also notes any other field observations that may require further investigation. Additional
details regarding this topic are given in Section 6.5.
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Equipment repair: Staff must address equipment malfunctions and necessary repairs,
as needed.
Preparation: Time is needed to prepare for routine operations
These tasks are expected for each routine operation previously described, but they have not been
allocated to the specific tasks. For the purposes of resource planning, overhead is expected to
account for 10% of the available staffing time.
6.3 Routine Operations Provided to the Storm Drainage Utility
This section discusses routine operations performed by other City staff or by contracted services in
support of the Storm Drainage Utility. Each subsection provides a brief description of the M&O
activity. FTE efforts for these activities are funded by the Storm Drainage Utility. Because Vegetation
Maintenance staff primarily support the Storm Drainage Utility (approximately 60% of total staff
effort), these staff are included in the existing staffing requirements discussed in Section 6.6.
6.3.1 Vegetation Maintenance
Vegetation maintenance is performed by Vegetation Maintenance Division full-time and seasonal
staff that support City Storm Drainage Utility M&O staff. Vegetation maintenance includes mowing,
herbicide application, seeding and replanting, and removal of nuisance vegetation or vegetation that
impairs the function of storm drainage facilities. In the fall, vegetation maintenance also includes
removal of leaves that can accumulate and block flow to catch basins (performed as needed).
Full-time Storm Drainage Utility staff may also perform limited vegetation maintenance as part of the
routine operations discussed in Section 6.2.
6.3.2 Stormwater Pump Station Maintenance
Maintenance of the seven pump stations within the City storm drainage system is performed by
Sanitary Sewer Utility staff because they have pump specialists who perform all pump station
maintenance. Sanitary ewer Utility staff perform scheduled weekly and monthly maintenance
inspections, as described in the City of Auburn Sewer Comprehensive Plan Update and
summarized below.
Pump station maintenance activities include both weekly and monthly inspections and include
checking lubrication, seals, valves, and general cleanliness of pump stations, as well as cleaning out
sumps and trash racks.
6.3.3 Manufactured Treatment Device Maintenance
As described in Section 6.2.5, manufactured treatment devices are inspected by city staff annually
to identify conditions that require additional, unscheduled maintenance. Such conditions could
include excess sediment accumulation, damaged piping, or vault and access cover damage.
Manufactured treatment devices are serviced by City staff, as noted in the inspections. Some
proprietary media or filter units are maintained by a private contractor, as needed.
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6.4 Non-Routine and Emergency Operations
The intent of the routine inspection and maintenance activities discussed in Sections 6.2 and 6.3 is
to minimize, through proactive management of the stormwater facilities, the potential for conditions
that could lead to emergencies. This section discusses unscheduled activities performed by Storm
Drainage Utility M&O staff and describes a response plan for emergency conditions.
6.4.1 Customer Service Requests
Customer service requests, typically related to a local drainage complaint, trigger creation of a work
order to inspect the affected area or stormwater facility and identify potential solutions. In some
cases, relatively simple solutions, such as removal of blockages, can alleviate the issue. However,
other cases require coordination with Engineering or other City departments. On average, City Storm
Drainage Utility staff respond to approximately five customer service/complaint-related work orders
per week. The effort required to resolve these complaints varies considerably.
Good recordkeeping helps in complaint resolution by ensuring that all relevant data are gathered
and by serving as a reminder to resolve the complaint and notify the complainant. When a complaint
is received, the following information is recorded to the extent possible:
Name and contact information of the person making the complaint.
Brief description of the nature of the complaint.
Time and date the complaint was received.
Storm Drainage Utility staff assigned to respond.
Following initial response, the complaint record gets updated to include the results of inspections
and any corrective actions taken. If the complaint cannot be resolved internally within the Storm
Drainage Utility, the complaint record will be forwarded to Engineering for further investigation.
Notification of any system investigation and/or action is provided to the customer making the
complaint.
6.4.2 Emergency Response Program
The Storm Drainage Utility, in conjunction with the other utility divisions, has prepared an Emergency
Binder as a guide on how to handle emergency situations. While the guide is by no means all-
inclusive for every type of disaster, it is a valuable tool for dealing with many of the emergency
situations that municipalities face. Copies of the Emergency Binder are available at the M&O
Building, and at City Hall Annex with the Director.
The primary objectives of the Utilities response is ensuring public safety, restoring essential services
as quickly as possible, and providing assistance to other areas as required. There is also a master
response program for the entire City, as documented in the City’s Comprehensive Emergency
Management Plan (CEMP). The material in the CEMP provides guidance for mitigation,
preparedness, responsibilities, recovery operations, training, and community education activities.
Copies of the CEMP are located in each City department, the M&O Building, and the VRFA.
The utility has implemented a standby program whereby one on-call employee is designated to be
the first to receive after-hours emergency calls. Most storm drainage system problems that occur
outside of normal working hours are reported through the City’s 911 emergency response system or
a non- emergency response number. An emergency callout list is provided to the emergency operator
in order to contact utility staff in case of an emergency. The primary responder to those after-hours
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calls is the on-call employee. Storm Drainage Utility M&O staff have been trained to respond to
system emergencies. The contacted staff assesses the situation, contacts additional staff as
necessary, and then responds in accordance with established emergency response procedures.
6.4.3 Source Control Inspection Program
Per the NPDES MS4 permit, the City must implement a program to prevent pollutant-laden runoff
from existing development to its MS4. A source control inventory of publicly and privately owned
institutional, commercial, and industrial sites with the potential to contribute pollutants to the MS4
was developed in 2022 and must be updated once every 5 years. The City is required to annually
inspect 20% of the sites listed in its source control inventory to assess compliance with source
control requirements, evaluate the effectiveness of existing BMPs (and provide recommendations),
and ensure required BMPs and actions are enacted through enforcement (as needed).
The City has hired a full-time employee to handle the SCIP. As the program is only in its second year,
the required time and resources are still being evaluated. It is recommended that the City document
these aspects and evaluate after 5 years. This will allow the City to develop a more accurate
estimate of the required FTE for implementation of the SCIP.
6.5 Data Collection and Record-Keeping
Data collection and record-keeping functions for the Storm Drainage Utility are performed using a
CMMS system called Cartegraph, a web-based commercial software package provided by Cartegraph
Inc. Cartegraph integrates GIS data with utility M&O records, providing managers with overview
information about system and operational performance and field crews with information related to
the condition and failure history of specific stormwater facilities. The City currently uses Cartegraph
to plan field staff activities (work orders), record results of both routine and non-routine
maintenance, and compare actual maintenance efforts to City goals. The City recently upgraded its
Cartegraph system and plans to transition toward the use of Cartegraph as an asset management
tool, through which the City would optimize staffing and capital resource planning.
In recent years, the City has made considerable progress in adding asset information to Cartegraph,
specifically GIS data, physical information related to size and material, and installation dates. However,
to fully utilize the asset management function of Cartegraph, additional information related to risk,
asset criticality, and condition is also necessary. To assist the City’s transition to an asset management
program, as described in Chapter 5, the attributes listed below should be used within Cartegraph to
define each of the City stormwater assets (catch basin, pipe segment, stormwater pond, etc.).
Asset-specific attributes. The following asset-specific attributes are related to the asset and remain
relatively unchanged over time.
Asset ID: The unique asset number that is used by all business systems to identify an asset.
Location: Where the asset is located (GIS).
Installation date: The date the asset was installed.
In-service date: The date the asset was placed into service.
Material: The material making up the composition of the asset’s structure.
Asset class: A group of assets that share the same characteristics (e.g., ponds, pipe segments).
Asset class is used to estimate replacement costs and useful life of groups of assets.
Nameplate information and asset specifications: Important information that is used to
uniquely describe an asset, such as the manufacturer name, type of asset, serial number,
size, material, etc. This information is used for asset identification, replacement, and repair.
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Operation-specific attributes: The following attributes are related to routine operations (inspection
and repair or replacement) for each asset and must be updated afterwards accordingly.
Replacement cost: The cost to replace the asset.
Replacement year: The year the replacement cost data were calculated.
Inspection date: The date the asset was inspected.
Overall condition rating (OCR): The condition rating of the asset assigned as a result of the
inspection.
Overall condition index (OCI): A numeric score describing the condition of the asset, assigned
as a result of the inspection (related to OCR).
Post-processing attributes. The attributes listed below are generated using asset-specific and
operation-specific attributes data for each asset. These attributes are not manually entered. They are
calculated to determine the risk associated with each asset and prioritize future work accordingly (as
previously described in Chapter 5, and detailed in Appendix C).
Useful life: The average life expectancy of the asset (life expectancy estimates for the
different asset types can be found in Appendix C).
Remaining useful life: The age of the asset (installation year – current year) subtracted from
its useful life.
Asset criticality: A value assigned to each asset that indicates how essential it is to maintain
a defined LOS. Typically it is defined as a combined score based on the consequence of
failure and the likelihood of failure.
→ Criticality of failure: A score assigned to an asset on the scale of 1 to 5 that
communicates the social and economic cost if the asset fails, where a score of 1 would
represent an asset not expected to have extreme consequences after failure, and a score
of 5 would represent an asset that may have detrimental consequences after failure.
This score will not be entered manually into Cartegraph; it is determined largely based on
location-based factors and will be assigned using a GIS-based spatial analysis.
→ Likelihood of failure (condition): A score assigned to an asset on a scale of 1 to 5 that
communicates the estimated time until the asset fails, where a score of 1 would
represent an asset in excellent condition, and a score of 5 would represent an asset on
the brink of failure. This score will not be entered manually into Cartegraph. It is initially
calculated based on critical attributes (as defined in Appendix C), but after the inspection
date becomes available, the results of the inspection (OCI and OCR) will supersede the
estimated rank based on critical attributes in assigning a likelihood of failure score.
M&O attributes. The following M&O attributes are captured as part of the operations, maintenance,
and repair history associated with each asset:
Asset ID: The unique asset number that is used by all business systems to identify an asset.
Work orders should be associated with one or more assets.
Issue, cause, action: These codes are used to classify historical M&O activities associated
with corrective actions or unplanned maintenance.
→ Issue: What is the problem observed in the field?
→ Cause: What is the underlying cause of the problem?
→ Action: What was done to address the cause?
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Target hours and actual hours: Recording the estimated hours and actual hours to complete
a work order can help in determining efficiency, planning workloads, and assessing
repair costs.
Target start and stop dates and actual dates: Recording the estimated and actual start and
stop dates for a work order can help in determining efficiency, planning workloads, and
assessing repair costs.
Work order costs: Work order costs include labor, parts, materials, and equipment and
should be accurately recorded for each work order.
Work order type: Work order types are used to group and compare different types of work
activities. Typical work order types are as follows:
→ Capital improvement: Work associated with a CIP.
→ Corrective maintenance: Work associated with an unplanned repair.
→ Preventive maintenance: Work associated with a planned preventive maintenance
activity (or inspection).
→ Predictive maintenance: Work associated with predictive measures (usually for critical
assets).
Warranty information: Helps to determine assets that are under warranty and the warranty
maintenance requirements.
6.6 M&O Staffing Requirements
This section outlines existing and future staffing requirements for M&O staff.
6.6.1 Existing Staffing Requirements
Existing staffing requirements for M&O activities discussed in this chapter were compiled and
evaluated to determine the M&O staffing level needed to efficiently operate, maintain, repair the
storm drainage system and collect and report the information necessary to properly operate system.
Table 6-2 and Table 6-3 evaluate Storm Drainage Utility and Vegetation Maintenance Division staff,
respectively. Each table evaluates the estimated time to conduct storm drainage system M&O tasks
in the manner currently performed. Calculated days for each M&O activity are for a single person
performed over an 8-hour “day.” Therefore, an activity that is performed quarterly and that requires
4 hours and two M&O staff to complete would result in an annual requirement of 4 days.
Table 6-2. Existing Storm Drainage System Maintenance and Staffing Requirements
Work activity FTE days required annually Assumptions/City goal
Catch basin and manhole inspection, cleaning, and repair
Catch basin inspection 270 Inspect once every 2 years, total of
10,800 catch basins. Perform
40 inspections per day with
2-person crew.
Manhole inspection 79 Inspect once every 4 years, total of
3,172 manholes. Perform
20 inspections per day with
2-person crew.
Catch basin cleaning 68 1 cleaning is required for every
10 inspections.
2-person crew, 0.25 hour each.
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Work activity FTE days required annually Assumptions/City goal
Manhole cleaning 32 1 cleaning is required for every
10 inspections.
2-person crew, 0.4 hour each.
Catch basin/manhole repair 155 310 repairs (approximately 5% of all
inspected) per year.
2-person crew, 0.5 hours each.
Stormwater pipeline cleaning
Pipeline cleaning 67 City expects 50,688 ft per year (entire
system in 25 years).
2-person crew can clean 1,500 ft of
pipe per day.
Stormwater outfall inspection, cleaning, and maintenance
Inspection/Cleaning 124 City goal is 2 times per year (124 total
outfalls).
2-person crew, 2 hours each.
Maintenance 2 City expects 10% of annual outfall
inspections to require an additional
maintenance visit.
2-person crew, 0.5 hours each.
Maintenance and restoration of drainage ditches, stormwater ponds/swales, and permeable pavement
Drainage ditch maintenance and
restoration
166 City’s goal is once every 5 years.
6-person crew, 200 ft per hour.
Stormwater pond and swale
maintenance and restoration
28 6-person crew expected to
maintain/restore 20% of the ponds
and swales within the system
per year.
Permeable pavement maintenance
and restoration
9 City’s goal is 2 times per year
(approximately 89,000 square feet).
4-person crew, 0.3 miles per hour.
Stormwater facility inspection
Stormwater facility inspection 28 City goal is once per year for each
facility (approximately 300 total).
Includes ponds, swales, vaults, tanks,
UIC, LID, and manufactured treatment
devices”
1-person crew, 0.75 hours each.
Culvert inspection and cleaning
Culvert inspection and cleaning 291 City goal of once per year for each of
1,164 culverts.
2-person crew, 1 hour each.
Other stormwater M&O activities
General facility maintenance and
other field tasks
26 1 day per week.
2-person crew, 2 hours each.
Customer service
requests/complaints
65 5 requests per week.a
2-person crew, 1 hour each.
Utility overhead for routine operations
FTE total for Routine Operations 1410
Overhead 141 Assumed 10% of FTE total.
Data entry 130 20 hours per week total (8 people at
0.5 hours per day).
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Work activity FTE days required annually Assumptions/City goal
SCIP
Implementation of SCIP 260 FTE reflects the full-time employee
who will be implementing the SCIP.
1 person, 52 weeks per year,
40 hours per week.
Subtotal 1,941
Total 2,135 Assumes 10% unquantified work
Total number of working days
available per FTE
221 365 minus weekends (104), holidays
(12), vacation (15), sick (12) and
training (1).
Number of FTEs required 9.7 2,135 days required divided by
221 days per FTE year.
Current funded FTEs 10.0 10 full-time staff dedicated to field
inspection and maintenance.
Note: FTE = full-time equivalent. FTE days are defined as 8 hours.
a. Many customer service requests are related to maintenance needs for privately owned drainage systems.
Table 6-3. Existing Vegetation Maintenance and Staffing Requirements
Work activity FTE days required annually Assumptions/City goal
Pond/Vegetation Management
Mowing 683 6-person crew, 40 hours per week for
7 months
Weeding/Spraying 152 4-person crew, 20 hours per week for
7 months
Weed Control/Herbicide Spraying
Weed Control/Herbicide Spraying 59 2-person crew, 3 days per week for
6 months
ROW and Ditch Mowing
Staff 1 137 40 hours per week for 9 months
Staff 2 49 2 days per week for 8 months
Tree Trimming and Removal
Tree Trimming and Removal 173 4-person crew, 40 hours per week for
4 months
Leaf Removal
Leaf Removal 390 2-person crew, 40 hours per week for
12 months
Total 1,641
Total number of working days
available per FTE
221 365 minus weekends (104), holidays
(12), vacation (15), sick (12), and
training (1).
Number of FTEs required 7.4 1,641 days required divided by 221
days per FTE year
Current funded FTEs 7.6
6.6 FTE
3 seasonal staff
Note: FTE = full-time equivalent. FTE days are defined as 8 hours.
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Table 6-2 shows that the Storm Drainage Utility meets the base level of staffing required with respect
to meeting current City proactive goals for M&O activities. Additional staffing needs required to
implement future regulatory requirements and recommended management activities are discussed
in Section 6.6.2. Table 6-3 shows that there is adequate staffing to meet current vegetation
maintenance needs of the Storm Drainage Utility.
6.6.2 Future Staffing Requirements and Equipment Needs
The M&O activities discussed in Section 6.2 and summarized in Table 6-2 are current efforts and do
not include additional activities that will be required as part of the revised NPDES MS4 permit. In
order to implement newly recommended asset management tasks with respect to drainage ditches
and pipe inspection (see Table 6-4), additional staffing may be required. Future staffing
requirements are summarized in the sections below.
6.6.2.1 Drainage Ditch Maintenance Program
The City’s ditch maintenance program was reviewed by Parametrix on behalf of this Plan to
determine if additional controls and resources are required to meet needs and address potential
liabilities. As a result of the review, it is recommended that the City categorize ditches according to
the anticipated M&O needs (roadside ditch, facility-related, and collection [other]) and incorporate
inspection as a new aspect in the ditch maintenance program. Figure 6-1 shows the extent of the
City’s ditch inventory and the recommended categorization according to M&O needs.
Roadside ditches are expected to require constant maintenance. Additional or enhanced actions are
not anticipated at this time but could be an outcome of an enhanced maintenance program that
could be proposed or required under the NPDES MS4 permit. The collection ditches will require
additional routine maintenance, such as annual mowing and sediment removal. Facility-related
ditches are recommended to be maintained and inspected with the facilities they are related to. This
will require adjusting the City’s goal of maintenance frequency.
Inspection will involve field verifying the condition, updating the asset inventory with findings, and
generating a work order (as needed). Work orders will ensure the appropriate staff are aware of the
issue (M&O, vegetation, office staff, etc.). Features in need of action are prioritized, and that work is
scheduled appropriately. The following items will require consideration in incorporating the proposed
ditch maintenance program.
How does inspection turn into a work order?
How often should ditches be inspected?
What are the thresholds for action?
Because the inspection process is new, it is expected to take time to understand the staff and time
needed as well as to set an achievable goal for inspection of the entire system. To begin to
understand the expectation of M&O staff, starting estimates were developed for consideration. For
the purposes of this Plan, inspection is anticipated to require a one-person crew to inspect 500 feet
of ditch per hour, and it is recommended to inspect all ditches within the program annually. Further,
the frequency and resources needed for this program should be evaluated every 5 years.
Page 103 of 373
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Sources: City of Auburn, King County, Pierce
County, WA Ecology, WA DNR, USGS, ESRI
Disclaimer: This product is for informational
purposes and may not have been prepared for, or
be suitable for legal, engineering, or surveying
purposes.
City Drainage Ditch Inventory
Maintenance & Operations (M&O) Categorization
Stormwater Drainage Utility
Comprehensive Storm Drainage Plan
0 ½1¼
Miles
Auburn City Limits
Watercourse
M&O Category
Roadside Conveyance (34
mi)
Facility-Related (~1 mi)
Collection (Other) (8 mi)
N/A* (27 mi)\\parametrix.com\PMX\PSO\Projects\Clients\1931-CityOfAuburn\553-1931-052 StormDrainagePlnUpdate\99Svcs\GIS\MapDocs\Auburn_DrainagePlan_Figures.aprxN/A includes all other ditch features that the City has
mapped, but are either not owned by the City
(privately owned or owned by another jurisdiction), or
not maintained by the storm drainage utility (i.e.,
features mapped at the airport or watercourses). For
this reason, they have not been sorted into one of the
other three M&O categories, and not included in the
City’s Ditch M&O program.
Figure 6-1
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For the near-term future ditch program, additional analysis and resource streams have been
identified. The proposed ditch inspection program and recordkeeping will be initiated. New protocols
for finding, adding, mapping, and classifying ditches in the system are needed and should primarily
focus on collector and facility ditches. Newly added ditches will require ownership and responsibility
research and subsequent easements or purchase. The ditch inspections may reveal system failures
that require minor capitol repairs or replacement. The projects should be added as a programmatic
CIP. In addition, an assessment to consider ditch improvements for water quality improvement will
be prepared, focused on roadside ditches.
The findings and recommendations of the drainage ditch maintenance program have been
discussed in further detail in Appendix E.
Taking this into consideration, the City will need to increase the expectation of overall Storm
Drainage Utility staffing in order to dedicate more staff to drainage ditch maintenance and
restoration (see Table 6-4). It is recommended that the City consider adjusting from the current
levels to a regulated biannual basis for maintaining the its ditch inventory. In addition, it would be
recommended to inspect the ditch inventory annually to prioritize ditches for maintenance. In order
to meet this goal, approximately 363 FTE days (with a six-person crew), or 1.6 FTE per year would be
needed (see Table 6-4).
6.6.2.2 Stormwater Pipe Inspection
As explained in Chapter 5.2, the City has a goal to implement an inspection prioritization program for
its stormwater pipe system. The program will prioritize inspection for pipes with the highest likelihood
of failure scores, which are generally those that are older, have little to no critical attribute data on
record, or have no recorded history inspection. As part of the inspection process, feature attributes
will be added/updated to the CMMS system, resulting in a robust pipe inventory and a more efficient
use of resources. In the beginning of the program, there will be a greater number of pipes with high
likelihood of failure scores (approximately 52,000 feet of pipe) since there is a large amount of
missing feature data, and approximately 15,000 feet of the City’s pipe system per year is expected
to have surpassed its expected useful life (see Appendix C).
They City will slowly expand its pipe inspection program as time and finances allow, beginning with
periodic use of the Sanitary Sewer Utility’s closed-circuit television (CCTV) equipment on an
as-needed basis. Since the CCTV equipment will be used as-needed, it is not anticipated to require
additional FTE days at this time and has not been included in Table 6-4. Dedicated equipment for
the storm utility will be investigated and worked into future budget cycles.
“Lamping” inspections, where the camera is inserted into the manhole or catch basin but not
advanced through the pipe system, are typically performed as a first step of the CCTV process.
Although the visual range is limited, lamping can identify structures and piping that are in very good
condition. In these cases, no additional CCTV inspection would be necessary. Lamping can be
utilized in many areas to get a baseline and can be done with current equipment. It is not a full
substitute for CCTV inspections but will help get the program going before additional equipment can
be purchased.
6.6.2.3 Other M&O Activities
The NPDES MS4 permit requires the City to implement a municipal street sweeping program to
target high-priority areas (see Section 5.3). The City will need to review the existing street sweeping
program and ensure the permit requirements are addressed or revised, as necessary. The new
requirements are not anticipated to require additional FTE days for sweeping crews.
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Table 6-4. Future Storm Drainage System Maintenance and Staffing Requirements
Work activity FTE days required annually Assumptions/City goal
Drainage ditch maintenance program
Drainage ditch inspection 55 1-person crew, 500 ft per hour.
Inspection of the entire system
(~220,000 ft) annually.
Roadside ditch maintenance and
restoration
327 6-person crew, 200 ft per hour.
Expect to maintain the entire category
(79% of drainage ditch inventory)
every 2 years.
Collector-ditch maintenance and
restoration
79 6-person crew, 200 ft per hour.
Expect to maintain the entire category
(20% of drainage ditch inventory)
every 2 years.
Facility-related ditch maintenance
and restoration
20 6-person crew, 200 ft per hour.
Expect to maintain (1% of drainage
ditch inventory) at the same time as
maintenance occurs for the related
facility (annually).
Total 530 Assumes 10% unquantified work
Additional FTE required for ditch
maintenance and restoration
363 Subtracting the existing staffing goal
(166 FTE days) to understand the
additional need.
Total number of working days
available per FTE
221 365 minus weekends (104), holidays
(12), vacation (15), sick (12), and
training (1).
Number of FTEs required 1.6 363 days required divided by 221
days per FTE year.
Note: FTE = full-time equivalent
6.6.2.4 Equipment Considerations
The Storm Drainage Utility utilizes the Sanitary Sewer Utility’s reallocated CCTV inspection equipment
and truck. New equipment would allow for increased efficiency and inspection frequency. It is
recommended that the City consider the benefit of acquiring a CCTV for the Storm Drainage Utility
after the pipe inspection program has been in effect for 5 years.
6.7 Potential Improvement Opportunities and Capital Needs
The Storm Drainage Utility has a positive track record for M&O, as evidenced by the limited need for
non-routine maintenance and few customer service complaints about the City’s drainage system.
Routine facility cleaning, regular inspections, experienced staff, and a well-planned storm drainage
system contribute to that success. Additionally, significant increases to the drainage ditch
maintenance and pipeline inspection program could be addressed by the City by adding to the
current Storm Drainage Utility M&O staff. An additional 1.6 FTEs are required to achieve proactive
City M&O goals (Table 6-4).
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Based upon discussions with City staff and analysis of M&O activities discussed in this chapter, the
following improvement opportunities are available to the Storm Drainage Utility. These opportunities
are based on improving existing services, regulatory compliance, and improving work productivity:
Continue to integrate asset management with existing utility management software
(Cartegraph and GIS).
→ Continue to add GIS attributes to known Storm Drainage Utility assets.
→ Perform and document condition assessments. Use defined criteria (such as
leaks/cracks observed, cleanliness, and other specific measures), and provide staff
training to ensure assessment consistency.
→ Use results of condition assessments to move toward risk-based maintenance to best
utilize staff resources. For example, consistently high assessment scores would result in
a lower risk or need for maintenance, allowing M&O staff to be diverted to more essential
activities.
→ Over time, demonstrate (through maintenance records) that a subset of City catch basins
do not require inspection, cleaning, and maintenance every 2 years per the NPDES
MS4 permit.
Reevaluate the inspection frequency and expected effort for the pipe inspection and ditch
maintenance programs to adjust as needed.
Consider obtaining a CCTV inspection equipment for pipe inspection the following utility
equipment to improve M&O efficiency.
Consider aligning catch basin cleaning with stormwater pipeline cleaning and CCTV to ensure
efficient use of available resources.
All M&O repair projects should be constructed to established City engineering standards. It is
recommended that the City develop a more formal procedure for tracking M&O repair
projects to ensure that as-built and GIS records are updated when repairs are completed.
Develop a list of facilities that should be inspected following major design storms and inspect
accordingly to verify proper function and identify damage, if any.
Document the time and resources required on behalf of the SCIP program. Evaluate the
resource need of the program after 5 years. This will allow the City to develop a more
accurate estimate of the required FTE for implementation of the SCIP.
Continue to develop the ditch maintenance program as broken down in the steps below.
→ Ditch mapping and classification: Develop protocols for finding, adding, mapping, and
classifying ditches within the system. Focus primarily on collector and facility ditches.
Accurate mapping and classification will help prioritize maintenance efforts.
→ Adding new ditches: Consider the steps required when adding new ditches to the system.
Elements to address include determining ownership, responsibility, and any necessary
easements or land purchases. Having a clear plan in place ensures smooth integration of
new ditches.
→ System failures and CIP: Use the results of regular ditch inspections to identify system
failures. System failures may include erosion, blockages, or other issues that require
capital repair or replacement. Add a program to the CIP to address ditches with these
system failures.
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→ Water quality improvements: Implement a program that focuses on retrofitting ditches
with water quality enhancements. Specifically target roadside ditches, which play a
crucial role in managing runoff and pollutant removal.
Coordinate with the Street division to review and revise the City’s street sweeping plan, as
needed.
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7. Capital Improvements
This chapter describes the recommended capital improvement plan for the City of Auburn Storm
Drainage Utility. Of the 12 CIPs described in this chapter, 4 are included in the 6-year plan
(2025–2030) and 8 are included in the 20-year plan (2031–2044). The 6-year plan includes the
highest priority CIPs that address existing drainage problems, address an ongoing waste disposal
issue, and ensure compliance with NPDES MS4 permit deadlines. The 20-year plan addresses longer-
term capital goals (see Chapter 8). This Plan contains timeframes that are the intended framework for
future funding decisions and within which future actions and decisions are intended to occur. However,
these time frames are estimates and, depending on factors involved in the processing of applications
and project work and the availability of funding, the timing may change. The framework, which may
depend on available funding resources, does not represent actual commitments by the City of Auburn.
In general, CIPs are modifications to stormwater drainage infrastructure designed to improve the
condition and function of the drainage system so that it can meet the LOS goals established for the
City’s Storm Drainage Utility (see Chapter 3). CIPs may also be developed to ensure the utility is able
to carry out routine operations and ensure compliance with permit requirements.
The CIPs presented in this chapter were identified and developed through focused investigations and
by working collaboratively with City staff. This focused and collaborative approach was based on the
practical consideration that the quantity and delivery of CIPs the City can implement is limited by
existing revenue streams and staff availability. The intent is to produce an economical capital
improvement plan that addresses the most salient issues in the near term, while still planning for the
long-term ability of the Storm Drainage Utility to meet LOS goals. The following steps were used to
develop the CIPs.
A list of potential projects was developed for further investigation. The list was developed by working
closely with City staff to identify the delayed projects from the 2015 Plan that were still necessary or
beneficial to the Utility, locate and characterize existing problems based on direct staff observations,
recognize potential opportunities for enhancement, and address needs of the utility. Projects that
were generated on behalf of the SMAP for Olsen Creek were also included in this list. Such
observations are a valuable supplement to modeling analyses and, in this case, were used in
conjunction with modeling activities to assist with model development.
For the potential projects that required H&H analyses, modeling was completed using PCSWMM, a
software package that uses GIS technology to import and export data, allowing a seamless transition
between the system inventories and modeling input files. Models used the historical event that most
closely produced a once per 25-year flow rate (the specific event varied by basin). Results from
historical events were used to assess the extent and severity of the drainage problem. Results from
the design event were used to understand the feasibility of the potential project in mitigating the
drainage problem.
Potential projects were developed and discussed with members of the City staff to identify the most
viable alternative/solution. Potential projects were then evaluated based on their potential benefit
and feasibility, and a final list was developed. Once the projects were defined, the project team
developed concept-level cost estimates.
An overview of project locations is shown in Figure 7-1. Section 7.1 describes a tiered method for
establishing project priorities. Section 7.2 presents detailed descriptions of CIPs. Section 7.3
describes programmatic drainage projects.
Page 109 of 373
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Date: 5/9/2024
Sources: City of Auburn, King County, Pierce
County, WA Ecology, WA DNR, USGS, ESRI
Disclaimer: This product is for informational
purposes and may not have been prepared for, or
be suitable for legal, engineering, or surveying
purposes.
Figure 7-1
Capital Improvement Project (CIP) Locations
Stormwater Drainage Utility
Comprehensive Storm Drainage Plan
0 ½1¼
Miles
Auburn City Limits
Watercourse
CIP Location\\parametrix.com\PMX\PSO\Projects\Clients\1931-CityOfAuburn\553-1931-052 StormDrainagePlnUpdate\99Svcs\GIS\MapDocs\Auburn_DrainagePlan_Figures.aprxSee Inset
Page 110 of 373
Draft Comprehensive Storm Drainage Plan Update
City of Auburn
June 2024 │ 553-1931-052 7-3
7.1 Project Prioritization
Storm Drainage Utility staff prioritized CIPs by grouping them into one of three tiers. Projects in the
top tier, or highest priority, are classified as tier 1. Projects with medium priority are classified as
tier 2. And projects with lowest priority relative to the other projects are considered tier 3.
The following items were considered when prioritizing the CIPs:
The magnitude of the LOS gap that would be addressed by a CIP. For example, a project that
rectifies an annual flooding problem would rank higher than a project in a different area that
eliminates less frequent flooding.
The reduction in risk and reduction in consequences associated with a CIP. For example, the
consequence of flooding that occurs near critical facilities (e.g., hospital or fire station) or
along major arterial streets may be larger than flooding along residential streets. A CIP that
addresses a larger consequence would rank higher.
The opportunity for coordination with ongoing City of Auburn street improvements or other
utility or transportation projects. Coordinated projects that reduce the overall cost of a CIP
would rank higher.
The capital funding capacity of the Storm Drainage Utility. The overall list of project priorities
attempts to balance the need for action with the funding and implementation capacity of the
Storm Drainage Utility.
The action deadlines necessary for compliance with the NPDES MS4 permit.
Other considerations with the potential to improve water quality, reductions in maintenance,
and increased reliability of the system.
Priorities for each project are included in each project description in the following sections. Project
priority and budgetary constraints were considered together in developing the year-by-year schedules
for project implementation in the 6- and 20-year capital improvement plans (see Chapter 8).
7.2 Proposed Capital Improvement Projects
CIPs described in this section were developed as part of this Plan and are described in sufficient
detail to allow the City to proceed with budgeting and design. Project descriptions are organized into
summaries containing the following information:
Project number: CIP numbers generally assigned to align with the number given in the SMAP
(as applicable) for consistency.
Project name: A short, descriptive name assigned to each project.
Project type: A brief description of the specific type of project being undertaken, used to
categorize and identify the purpose or focus of the project.
Location: A simple description of the project location, such as the cross streets.
Existing and proposed use: A summary of the existing and proposed site conditions.
Drainage basin: The receiving water drainage basin where the project is situated.
Tributary drainage area: Area (in acres) that drains to the project (as applicable).
Total cost: The estimated cost of the project, based on the attached opinion (estimate) of
probable cost.
Page 111 of 373
Draft Comprehensive Storm Drainage Plan Update
City of Auburn
June 2024 │ 553-1931-052 7-4
Project description: A description of the proposed project, including major project elements
and sizes.
Site opportunities: The anticipated opportunities and benefits of the project.
Site challenges: The anticipated challenges in undertaking the project.
Opinion (estimate) of probable cost: A list of estimated costs, including construction costs,
engineering and administrative costs, taxes, and contingency costs. The estimate was
developed based on the conceptual design, preliminary quantity take-offs, and estimated
unit costs. Estimated unit costs were based on bids from the WSDOT Unit Bid Tab, vendor
quotes, and escalated project costs from recent projects with similar components.
Vicinity map: A figure showing the location of the project relative to the City of Auburn.
Proposed conditions figures: Figures showing the conceptual design and location of
project elements.
CIP summaries and cost opinions are presented on the following pages.
Page 112 of 373
May 2024 │ 553-1931-052 7-5 CIP 1 – SE 287th Street Stormwater Device 6-Year Capital Improvement Plan (Priority 1) RETROFIT TYPE Road retrofit
Manufactured treatment device LOCATION At the end of SE 287th Street
EXISTING USE ROW PROPOSED USE ROW with enhanced runoff
treatment
DRAINAGE BASIN Olson Creek
TRIBUTARY DRAINAGE AREA 7.3 acres total
2.0 acres impervious TOTAL COST (2024 DOLLARS) $427,000 Project Description
This project is proposing to replace the existing Type 1 catch basin with a stormwater treatment technology reviewed and certified by the
Washington state Technology Assessment Protocol – Ecology (TAPE) program to provide 7.3 acres with enhanced water quality treatment.
This project would provide treatment for approximately 700 linear feet of roadway. The catch basin replacement will likely be low complexity
since there is existing infrastructure in place and traffic control needs will be low. Final size, placement, and configuration of the project
components may be adjusted as the design progresses.
Site Opportunities
Project Name CIP 1 - SE 287th Street Stormwater Device
At the end of SE 287th Street (Near 10624 SE 287th Street, Auburn, WA 98092)ITEM SPECNO. SECTION DESCRIPTION QTY UNIT UNIT PRICE TOTAL COST1
MOBILIZATION (10%)10%$14,4422CONTRACTOR PROVIDED SURVEY (3%)3%$4,3323TESC (5%)5%$7,2214DEWATERING (2%)2%$2,888$28,8835SAWCUTTING56LF$31$1,7156PAVEMENT REMOVAL/RESTORATION11SY$220$2,3477ENHANCED MEDIA FILTER SYSTEM 6X82EA$60,000 $120,0008CONNECTION TO DRAINAGE STRUCTURE 4EA$3,415$13,6619STRUCTURE EXCAVATION CLASS A INCL. HAUL 44CY$41$1,82410SHORING OR EXTRA EXCAVATION CLASS B1LS$1,000$1,00011STRUCTURE EX AND SHORING LABOR (50% OF EACH)50$1,41212CRUSHED SURFACING BASE COURSE3TN$54$17613RECORD DRAWINGS1LS$2,280$2,280$144,416$173,29950%$86,6495%$8,66525%$43,3255%$8,66525%$43,32510%$17,330$382,000TOTAL PROJECT COST
Opinion (Estimate) of Probable Cost
SITE PREP AND TESC
% of lines 5-13% of lines 5-13
% of lines 5-13Location
% of lines 5-13Lines 1 - 4 Subtotal% of lines 9-10
City Project Mgmt. Admin.
Construction Management
Management ReserveLines 5 - 13 SubtotalSubtotal Line-Item Costs
MATERIALS
Design Contigency
Permitting
Design
May 2024 | 553-1931-0527-6Page 114 of 373
May 2024 │ 553-1931-052 7-7 CIP 2 – SE 284th Street & 109th Avenue SE Bioswale
Additions20-Year Capital Improvement Plan (Priority 3) RETROFIT TYPE Road retrofit
New bioswales LOCATION SE 284th Street and 109th
Avenue SE
EXISTING USE ROW (vegetated and gravel
driveway)
PROPOSED USE ROW with basic runoff treatment
DRAINAGE BASIN Olson Creek
TRIBUTARY DRAINAGE AREA 20.6 acres total
3.0 acres impervious TOTAL COST (2024 DOLLARS) $143,000 Project Description
This project will retrofit a section of SE 284th Street by adding two bioswale ditch enhancements. The bioswales will provide basic water
quality treatment to 20.6 acres, including approximately 2,300 linear feet of roadway. Final size, placement, and configuration of the project
components may be adjusted as the design progresses.
Site Opportunities
Project Name CIP 2 - SE 284th Street & 109th Avenue Bioswale AdditionsSE 284th Street and 109th Avenue SEITEM SPECNO. SECTION DESCRIPTION QTY UNIT UNIT PRICE TOTAL COST1
MOBILIZATION (10%)10%$5,3902CONTRACTOR PROVIDED SURVEY (3%)3%$1,6173TESC (5%)5%$2,6954DEWATERING (2%)2%$1,078$10,7815CLEARING AND GRUBBING0.1ACRE$10,000$1,0456CHANNEL EXCAVATION INCL. HAUL169 CY$40$6,7247TOPSOIL TYPE A253SY$66$16,5998COMPOST BLANKET42SY$8$3379SEEDING, FERTILIZING, AND MULCHING506SY$58$29,200$53,904$64,68550%$32,3435%$3,23425%$16,1715%$3,23425%$16,17110%$6,469$143,000LocationMATERIALSLines 5 - 9 SubtotalSITE PREP AND TESC
Opinion (Estimate) of Probable Cost
Subtotal Line-Item CostsT
OTAL PROJECT COSTLines 1 - 4 Subtotal% of lines 5-9
% of lines 5-9
% of lines 5-9
% of lines 5-9
Construction Management
Management Reserve
Design Contigency
Permitting
Design
City Project Mgmt. Admin.
May 2024 | 553-1931-0527-8Page 116 of 373
May 2024 │ 553-1931-052 7-9 CIP 3 – SE 284th Street West Bioswale Additions6-Year Capital Improvement Plan (Priority 1) RETROFIT TYPE Road retrofit
New bioswales LOCATION Along SE 284th Street
EXISTING USE ROW PROPOSED USE ROW with basic runoff treatment
DRAINAGE BASIN Olson Creek
TRIBUTARY DRAINAGE AREA 2.2 acres total
1.1 acres impervious TOTAL COST (2024 DOLLARS) $52,000 Project Description
This project will retrofit a section of SE 284th Street by adding two bioswale ditch enhancements to the side of the road. The bioswales will
provide basic water quality treatment to 3.3 acres, including approximately 700 linear feet of roadway. Final size, placement, and
configuration of the project components may be adjusted as the design progresses.
Site Opportunities
Project Name CIP 3 - SE 284th Street West Bioswale Additions
Along SE 284th Street (Near 11429 SE 284th Street, Auburn, WA 98082)ITEM SPECNO. SECTION DESCRIPTION QTY UNIT UNIT PRICE TOTAL COST1
MOBILIZATION (10%)10%$1,7192CONTRACTOR PROVIDED SURVEY (3%)3%$5163TESC (5%)5%$8604DEWATERING (2%)2%$3445PROJECT TEMPORARY TRAFFIC CONTROL (15%)15%$2,579$6,0176CLEARING AND GRUBBING0.04ACRE$10,000$4197CHANNEL EXCAVATION INCL. HAUL68 CY$40$2,6988TOPSOIL TYPE A34SY$66$2,2219COMPOST BLANKET17SY$8$13510SEEDING, FERTILIZING, AND MULCHING203SY$58$11,718$17,192$23,20950%$11,6045%$1,16025%$5,8025%$1,16025%$5,80210%$2,321$52,000TOTAL PROJECT COST
Opinion (Estimate) of Probable CostLocationS
ITE PREP AND TESC
Construction Management
Management Reserve
MATERIALS
Design Contigency
Permitting
DesignLines 1 - 5 Subtotal% of lines 6-10
% of lines 6-10
% of lines 6-10
City Project Mgmt. Admin.
% of lines 6-10
% of lines 6-10Lines 6 - 10 SubtotalSubtotal Line-Item Costs
May 2024 | 553-1931-0527-10Page 118 of 373
May 2024 │ 553-1931-052 7-11 CIP 4 – SE 284th Street East Bioswale Additions20-Year Capital Improvement Plan (Priority 3) RETROFIT TYPE Road retrofit
New bioswale LOCATION Along SE 284th Street
EXISTING USE Roadside ditch
PROPOSED USE Roadside bioswale
DRAINAGE BASIN Olson Creek
TRIBUTARY DRAINAGE AREA 1.8 acres total
0.8 acres impervious TOTAL COST (2024 DOLLARS) $28,000 Project Description
This project will retrofit a section of SE 284th Street by adding a bioswale ditch enhancement to the side of the road. This bioswale will
provide basic water quality treatment to 2.6 acres, including approximately 1,600 linear feet of roadway. Final size, placement, and
configuration of the project components may be adjusted as the design progresses.
Site Opportunities
Project Name CIP 4 - SE 284th Street East Bioswale Additions
Along SE 284th Street (Near 11619 SE 284th Street, Auburn, WA 98082)ITEM SPECNO. SECTION DESCRIPTION QTY UNIT UNIT PRICE TOTAL COST1
MOBILIZATION (10%)10%$9322CONTRACTOR PROVIDED SURVEY (3%)3%$2803TESC (5%)5%$4664DEWATERING (2%)2%$1865PROJECT TEMPORARY TRAFFIC CONTROL (15%)15%$1,398$3,2626CLEARING AND GRUBBING0.02ACRE$10,000$2277CHANNEL EXCAVATION INCL. HAUL37 CY$40$1,4638TOPSOIL TYPE A18SY$66$1,2049COMPOST BLANKET9SY$8$7310SEEDING, FERTILIZING, AND MULCHING110SY$58$6,353$9,321$12,58350%$6,2925%$62925%$3,1465%$62925%$3,14610%$1,258$28,000Opinion (Estimate) of Probable Cost
SITE PREP AND TESCLines 1 - 5 SubtotalMATERIALS
Design Contigency
% of lines 6-10
% of lines 6-10
% of lines 6-10
% of lines 6-10Location% of lines 6-10
TOTAL PROJECT COSTLines 6 - 10 SubtotalSubtotal Line-Item Costs
Permitting
Design
City Project Mgmt. Admin.
Construction Management
Management Reserve
May 2024 | 553-1931-0527-12Page 120 of 373
May 2024 │ 553-1931-052 7-13 r CIP 5 – 124th Avenue SE near 293rd Street
Stormwater Treatment Device 20 Capital Improvement Plan (Priority 2) RETROFIT TYPE Road retrofit
Manufactured treatment device LOCATION 124th Avenue SE near
293rd Street
EXISTING USE Untreated ROW
PROPOSED USE ROW with enhanced runoff
treatment
DRAINAGE BASIN Olson Creek
TRIBUTARY DRAINAGE AREA 14.1 acres total
2.4 acres impervious TOTAL COST (2024 DOLLARS) $581,000 Project Description
This project will retrofit a section of 124th Avenue SE by replacing existing Type 1 catch basins with TAPE-approved manufactured treatment
devices. The manufactured treatment devices will provide enhanced water quality treatment to 14.1 acres, including approximately 800
linear feet of roadway. Final size, placement, and configuration of the project components may be adjusted as the design progresses.
Site Opportunities
Project Name CIP 5 - 124th Avenue SE near 293rd Street Stormwater Treatment DeviceAlong 124th Avenue SE near 293rd StreetITEM SPECNO. SECTION DESCRIPTION QTY UNIT UNIT PRICE TOTAL COST1
MOBILIZATION (10%)10%$19,5622CONTRACTOR PROVIDED SURVEY (3%)3%$5,8683TESC (5%)5%$9,7814DEWATERING (2%)2%$3,9125PROJECT TEMPORARY TRAFFIC CONTROL (15%)15%$29,342$68,4666UTILITY RELOCATION (SMALL)1LS$15,000$15,0007PAVEMENT REMOVAL/RESTORATION52SY$220$11,4898REMOVE CEMENT CONCRETE CURB AND GUTTER20LF$14$2749ENHANCED MEDIA FILTER SYSTEM 6X102EA$68,000 $136,00010CONNECTION TO DRAINAGE STRUCTURE 4EA$3,415$13,66111STRUCTURE EXCAVATION CLASS A INCL. HAUL 52CY$41.04$2,12812SHORING OR EXTRA EXCAVATION CLASS B1LS$1,000$1,00013STRUCTURE EX AND SHORING LABOR (50% OF EACH)50$1,56414CRUSHED SURFACING BASE COURSE4TN$54$22015SCHEDULE A STORM SEWER PIPE 12 IN. DIAM. 100LF$120$12,00016RECORD DRAWINGS1LS$2,280$2,280$195,616$264,08250%$132,0415%$13,20425%$66,0205%$13,20425%$66,02010%$26,408$581,000Lines 1 - 5 SubtotalLines 6 - 16 SubtotalOpinion (Estimate) of Probable CostLocationS
ubtotal Line-Item Costs
TOTAL PROJECT COST
SITE PREP AND TESC
% of lines 6-16
% of lines 6-16
% of lines 6-16
% of lines 6-16
City Project Mgmt. Admin.
Construction Management
Management Reserve
MATERIALS
Design Contigency
Permitting
Design
% of lines 11-12
% of lines 6-16
May 2024 | 553-1931-0527-14Page 122 of 373
May 2024 │ 553-1931-052 7-15 CIP 6 – Vintage Hills Swale Retrofit20-Year Capital Improvement Plan (Priority 1) RETROFIT TYPE Existing facility retrofit
Swale soil amendment LOCATION Along 124th Avenue SE
EXISTING USE Bioswale
PROPOSED USE Bioretention swale with e nhanced
treatment
DRAINAGE BASIN Olson Creek
TRIBUTARY DRAINAGE AREA 5.0 acres total
1.1 acres impervious TOTAL COST (2024 DOLLARS) $264,000 Project Description
This project is proposing to amend the soil in the existing Vintage Hills swale. The soil will be replaced from conventional soil to bioretention
soil to provide enhanced treatment for 5.0 acres. Rock check dams may be required throughout the length of the swale to ensure infiltration
occurs to provide treatment. Final size, placement, and configuration of the project components may be adjusted as the design progresses. Site Opportunities
Project Name CIP 6 - Vintage Hills Swale Retrofit
Along 124th Avenue SE (Near 29501 125th Avenue SE, Auburn, WA 98082)ITEM SPECNO. SECTION DESCRIPTION QTY UNIT UNIT PRICE TOTAL COST1
MOBILIZATION (10%)10%$10,4582CONTRACTOR PROVIDED SURVEY (3%)3%$3,1373TESC (5%)5%$5,2294DEWATERING (2%)2%$2,0925PROJECT TEMPORARY TRAFFIC CONTROL (15%)15%$15,687$20,9156CHANNEL EXCAVATION INCL. HAUL151 CY$40 $6,0127EROSION CONTROL BLANKET75SY$9 $687818" BIORETENTION SOIL750SF$120 $90,0009COMPOST BLANKET75SY$8 $60310QUARRY SPALLS6TN$70 $42411TRASH RACK1EA$500 $50012SEEDING, FERTILIZING, AND MULCHING75SY$58 $4,35113RECORD DRAWINGS1LS$2,000 $2,000$104,577$125,49250%$62,7465%$6,27515%$18,8245%$6,27525%$31,37310%$12,549$264,000Design Contigency
Permitting
DesignLines 1 - 5 Subtotal% of lines 6-13
% of lines 6-13
% of lines 6-13
% of lines 6-13
MATERIALS
Opinion (Estimate) of Probable CostLines 6 - 13 SubtotalSubtotal Line-Item Costs
TOTAL PROJECT COSTLocationSITE PREP AND TESC
City Project Mgmt. Admin.
Construction Management
Management Reserve
% of lines 6-13
May 2024 | 553-1931-0527-16Page 124 of 373
May 2024 │ 553-1931-052 7-17 CIP 7 – 124th Avenue SE near 307th Place Stormwater
Treatment Device20-Year Capital Improvement Plan (Priority 2) RETROFIT TYPE Road retrofit
Manufactured treatment device LOCATION 124th Avenue SE near
307th Place
EXISTING USE Untreated ROW
PROPOSED USE ROW with enhanced runoff
treatment
DRAINAGE BASIN Olson Creek
TRIBUTARY DRAINAGE AREA 5.9 acres total
1.4 acres impervious TOTAL COST (2024 DOLLARS) $531,000 Project Description
This project will retrofit a section of 124th Avenue SE by replacing existing Type 1 catch basins with TAPE-approved manufactured treatment
devices. The manufactured treatment devices will provide enhanced water quality treatment to 5.9 acres, including approximately 1,200
linear feet of roadway. Final size, placement, and configuration of the project components may be adjusted as the design progresses.
Site Opportunities
Project Name CIP 7 - 124th Avenue SE near 307th Place Stormwater Treatment Device124th Avenue near 302nd PlaceITEM SPECNO. SECTION DESCRIPTION QTY UNIT UNIT PRICE TOTAL COST1
MOBILIZATION (10%)10%$17,8472CONTRACTOR PROVIDED SURVEY (3%)3%$5,3543TESC (5%)5%$8,9244DEWATERING (2%)2%$3,5695PROJECT TEMPORARY TRAFFIC CONTROL (15%)15%$26,771$62,4666UTILITY RELOCATION (SMALL)1LS$15,000 $15,0007PAVEMENT REMOVAL/RESTORATION50SY$220 $10,9028REMOVE CEMENT CONCRETE CURB AND GUTTER16LF$14$2199ENHANCED MEDIA FILTER SYSTEM 6X82EA$60,000 $120,00010CONNECTION TO DRAINAGE STRUCTURE 4EA$3,415 $13,66111STRUCTURE EXCAVATION CLASS A INCL. HAUL 44CY$41.04 $1,82412SHORING OR EXTRA EXCAVATION CLASS B1LS$1,000 $1,00013STRUCTURE EX AND SHORING LABOR (50% OF EACH)50$1,41214CRUSHED SURFACING BASE COURSE3TN$54$17615SCHEDULE A STORM SEWER PIPE 12 IN. DIAM. 100LF$120 $12,00016RECORD DRAWINGS1LS$2,280 $2,280$178,475$240,94150%$120,4705%$12,04725%$60,2355%$12,04725%$60,23510%$24,094$531,000TOTAL PROJECT COSTLines 1 - 5 SubtotalCity Project Mgmt. Admin.
Construction Management
Management Reserve
MATERIALS
Design Contigency
Permitting
Design
% of lines 11-12Lines 6 - 16 SubtotalSubtotal Project Cost
Opinion (Estimate) of Probable Cost
SITE PREP AND TESC
% of lines 6-16% of lines 6-16
% of lines 6-16Location% of lines 6-16
% of lines 6-16
May 2024 | 553-1931-0527-18Page 126 of 373
May 2024 │ 553-1931-052 7-19 CIP 8 – 124th Avenue SE near 302nd Place Stormwater Treatment Device20-Year Capital Improvement Plan (Priority 2) RETROFIT TYPE Road retrofit
Manufactured treatment device LOCATION 124th Avenue SE near
302nd Place
EXISTING USE Untreated ROW
PROPOSED USE ROW with enhanced runoff
treatment
DRAINAGE BASIN Olson Creek
TRIBUTARY DRAINAGE AREA 2.9 acres total
1.3 acres impervious TOTAL COST (2024 DOLLARS) $531,000 Project Description
This project will retrofit a section of 124th Avenue SE by replacing existing Type 1 catch basins with a TAPE-approved manufactured
treatment devices. The manufactured treatment devices will provide enhanced water quality treatment to 2.9 acres, including approximately 1,600 linear feet of roadway. Final size, placement, and configuration of the project components may be adjusted as the
design progresses.
Site Opportunities
Project Name CIP 8 - 124th Avenue SE near 302nd Place Stormwater Treatment Device124th Avenue near 307th PlaceITEM SPECNO. SECTION DESCRIPTION QTY UNIT UNIT PRICE TOTAL COST1
MOBILIZATION (10%)10%$17,8472CONTRACTOR PROVIDED SURVEY (3%)3%$5,3543TESC (5%)5%$8,9244DEWATERING (2%)2%$3,5695PROJECT TEMPORARY TRAFFIC CONTROL (15%)15%$26,771$62,4666UTILITY RELOCATION (SMALL)1LS$15,000 $15,0007PAVEMENT REMOVAL/RESTORATION50SY$220 $10,9028REMOVE CEMENT CONCRETE CURB AND GUTTER16LF$14 $2199ENHANCED MEDIA FILTER SYSTEM 6X82EA$60,000 $120,00010CONNECTION TO DRAINAGE STRUCTURE 4EA$3,415 $13,66111STRUCTURE EXCAVATION CLASS A INCL. HAUL 44CY$41.04 $1,82412SHORING OR EXTRA EXCAVATION CLASS B1LS$1,000 $1,00013STRUCTURE EX AND SHORING LABOR (50% OF EACH)50$1,41214CRUSHED SURFACING BASE COURSE3TN$54 $17615SCHEDULE A STORM SEWER PIPE 12 IN. DIAM. 100LF$120 $12,00016RECORD DRAWINGS1LS$2,280 $2,280$178,475$240,94150%$120,4705%$12,04725%$60,2355%$12,04725%$60,23510%$24,094$531,000TOTAL PROJECT COST
% of lines 6-16
City Project Mgmt. Admin.
Construction Management
Management Reserve
MATERIALS
Design Contigency
Permitting
Design
% of lines 11-12
% of lines 6-16Lines 1 - 5 SubtotalLines 6 - 16 SubtotalSubtotal Line-Item Costs
Opinion (Estimate) of Probable Cost
SITE PREP AND TESC
% of lines 6-16% of lines 6-16
% of lines 6-16Location
May 2024 | 553-1931-0527-20Page 128 of 373
May 2024 │ 553-1931-052 7-21 CIP 9 – 30th Street NE Area Flooding, Phase 220-Year Capital Improvement Plan (Priority 3) RETROFIT TYPE Road retrofit
Upgraded conveyance system LOCATION East of I Street NE between 32nd
Street NE and 35th Street NE
EXISTING USE Conveyance system
PROPOSED USE New conveyance system and
upgraded pipe
DRAINAGE BASIN Mill Creek and Green River
TRIBUTARY DRAINAGE AREA Unknown TOTAL COST (2024 DOLLARS) $1,186,000 NOTES Cost, design, figures, and
description completed by Brown &
Caldwell in 2015. Cost and
description updated by Parametrix
per City comments Project Description
The north-central area of Auburn has a history of surface flooding with street flooding occurring once every few years. The residential
development east of I Street NE between 32nd Street NE and 35th Street NE discharges flows into a City-owned infiltration area. The
infiltration area commonly experiences prolonged periods of standing water due to high groundwater from extended high flows in the Green
River, which is adjacent to the infiltration area. The drainage system on I Street NE currently lacks infrastructure to collect and convey
stormwater away from the infiltration area, as well as residential roadways and parking area. Ponding occurs within the parking areas of the
developments and presents a nuisance and potential hazard to local residents.
This project is Phase 2 of a three-phased capital improvement project (Relieve 30th Street NE Area Flooding) from the 2015 Comprehensive
Stormwater Drainage Plan. The goal of the 2015 CIP was to increase the capacity of the 30th Street NE system to reduce flooding along
30th Street NE and to provide capacity to connect other flooding drainage systems (C Street NE and I Street NE). The implementation of this
CIP is occurring in phases, as funding, staff availability, and priorities allow. The first phase (30th Street NE Area Flooding, Phase 1) was
scheduled for construction in 2015/2016. The next phase, referred to as CIP 9 in this Plan, is scheduled for the 2031–2044 timeframe.
This project would address the flooding adjacent to I Street NE. This project would locate a storm drain line to capture stormwater from the
two residential developments currently discharging stormwater to the City’s infiltration area. In addition, this project would construct a new
storm drain within I Street NE southward to connect into the 42-inch-diameter storm drain (constructed as part of the 30th Street NE Area
Flooding project, Phase I, from the 2015 Plan) near the intersection of I Street NE and 30th Street NE. The 42-inch-diameter line will have
sufficient available capacity to convey the I Street NE flows.
Site Opportunities
Project Name CIP 9 - 30th Street NE Area Flooding, Phase 2
30th Street NE and I Street NEITEM SPECNO. SECTION DESCRIPTION QTY UNIT UNIT PRICE TOTAL COST1
CONTRACTOR OVERHEAD, PROFIT, AND MOBILIZATION18%$115,380$115,38022015 PROJECT (4A) 1,850 LF OF 15-IN DRAINAGE PIPE 1LS$641,000 $641,000$641,000$756,38020%$151,2769%$79,874$987,53020%$197,506$1,186,000Opinion (Estimate) of Probable Cost
MATERIALSLocationSITE PREP AND TESC
% of lines 2-2Lines 1 - 1 SubtotalSubtotal Line-Item Costs
Subtotal Construction Costs
TOTAL PROJECT COSTLines 2 - 2 SubtotalConstruction ContingencySales Tax (all above costs)Permitting, design, management,
and administration
May 2024 | 553-1931-0527-22Page 130 of 373
May 2024 │ 553-1931-052 7-23 CIP 10 – Vegetative Waste Sorting Facility6-Year Capital Improvement Plan (Priority 3) RETROFIT TYPE New waste sorting facility LOCATION GSA site
EXISTING USE Shared open space
PROPOSED USE Waste sorting facility for
plant/organic material pulled from
conveyance and treatment
systems and facilities
DRAINAGE BASIN White River
TRIBUTARY DRAINAGE AREA N/A TOTAL COST (2024 DOLLARS) $200,000 NOTES Cost, design, figures, and
description completed by Brown &
Caldwell. Cost and description
updated by Parametrix per City
comments. Project Description
The Storm Drainage Utility is responsible for the M&O of the storm drainage system. Pond and drainage ditch maintenance and
rehabilitation involves removal of plant material and sediments, which are considered non-hazardous and are suitable for recycling. During
fall and winter, debris from storm cleanups also yield materials suitable for recycling. The Storm Drainage Utility currently uses the City-
owned Jacobson Tree Farm property for storing and drying of these materials prior to hauling off-site for recycling. The property is owned by
the Parks Department and is scheduled to be repurposed, precluding its use for ongoing M&O activities.
This project addresses the need for a new site to sort, dry, and store materials removed from drainage ditches, swales, and ponds during
maintenance and restoration activities necessary to maintain the storm drainage system. The project property is being sourced from
existing land owned by the City. The cost to develop the property and purchase equipment are represented in the project cost.
Site Opportunities
Project Name CIP 10 - Vegetative Waste Sorting Facility
GSA Site
ITEM SPEC
NO. SECTION DESCRIPTION QTY UNIT UNIT PRICE TOTAL COST1
MOBILIZATION (10%)10%$10,0002
CONTRACTOR PROVIDED SURVEY (5%)5%$5,0003
TESC (5%)5%$5,0004
PROJECT TEMPORARY TRAFFIC CONTROL (5%)5%$5,000
$25,0005
2015 PROJECT (10) DEVELOP PROPERTY AND PURCHASE
EQUIPMENT1 LS $100,000 $100,000
$100,000
$125,000
20%$25,000
5%$6,250
10%$12,500
5%$6,250
10%$12,500
10%$12,500
$200,000
% of lines 5-5
Opinion (Estimate) of Probable Cost
Location
SITE PREP AND TESC
Construction Management
Management Reserve
Subtotal Line-Item Costs
TOTAL PROJECT COST
Lines 5 - 5 Subtotal
Construction Cost Contigency
Permitting
Design
City Project Mgmt. Admin.
% of lines 5-5
% of lines 5-5
% of lines 5-5
Lines 1 - 4 Subtotal
MATERIALS
May 2024 | 553-1931-052 7-24Page 132 of 373
May 2024 │ 553-1931-052 7-25 CIP 11 – Christa Ministries Facility Retrofit20-Year Capital Improvement Plan (Priority 3) RETROFIT TYPE Existing facility retrofit
New water quality pond LOCATION Christa Ministries property
EXISTING USE Bioswale
PROPOSED USE Enhanced water quality
treatment pond
DRAINAGE BASIN Green River
TRIBUTARY DRAINAGE AREA 377 acres total
242 acres impervious TOTAL COST (2024 DOLLARS) $2,906,000 Project Description
This project proposes retrofitting an existing stormwater swale to an enhanced water qualtiy treatment pond. The pond would be sized
based on current enhanced treatment standards for 366 acres of contributing area before discharging into the Green River. Final size,
placement, and configuration of the project components may be adjusted as the design progresses.
Site Opportunities
Project Name CIP11 - Christa Ministries Facility Retrofit
Christa Ministries Property (Southeast in 35th St NE & I St NE intersection)ITEM SPECNO. SECTION DESCRIPTION QTY UNIT UNIT PRICE TOTAL COST1
MOBILIZATION (10%)10%$107,0102CONTRACTOR PROVIDED SURVEY (6%)6%$64,2063TESC (5%)5%$53,5054PROJECT TEMPORARY TRAFFIC CONTROL (3%)3%$32,103$256,8255CLEARING AND GRUBBING4 ACRE$45,471 $175,7036CHANNEL EXCAVATION INCL. HAUL7,065CY$39 $275,5357COMMON BORROW INCL. HAUL1,445CY$30 $43,3508EMBANKMENT COMPACTION1,445CY$9 $13,0059SCHEDULE A STORM SEWER PIPE 30 IN. DIAM. 1,190LF$311 $370,09010CATCH BASIN TYPE 2 60 IN. DIAM. 3EACH$9,978 $29,93411CONNECTION TO DRAINAGE STRUCTURE 2EACH$3,535$7,07012QUARRY SPALLS18TON$68$1,22413GRAVEL MAINTENANCE ROAD3,028SY$32 $96,88214CATCH BASIN TYPE 2 72 IN. DIAM. 1EACH$11,877 $11,87715SEEDING, FERTILIZING, AND MULCHING (BY ACRE)4ACRE$10,205 $39,43316RECORD DRAWINGS1LS$6,000.00$6,000$1,070,103$1,326,92730%$398,0789%$119,42340%$530,77110%$132,69320%$265,38510%$132,693$2,906,000TOTAL PROJECT COST
Subtotal Line-Item Costs
City Project Mgmt. Admin.
Construction Management
Management ReserveLines 5 - 16 SubtotalConstruction Cost Contingency
Permitting
Design (Including Contingency)
MATERIALSLocationSITE PREP AND TESC
% of lines 1-4
% of lines 1-4
% of lines 1-4
% of lines 1-4Lines 1 - 4 SubtotalOpinion (Estimate) of Probable Cost
May 2024 | 553-1931-0527-26Page 134 of 373
May 2024 │ 553-1931-052 7-27 CIP 12 – West Main Street Pump Station Upgrade6-Year Capital Improvement Plan (Priority 1) RETROFIT TYPE Existing facility retrofit
Pump station upgrade LOCATION South of West Main Street, east of
the SR 167 overpass
EXISTING USE Pump station
PROPOSED USE Upgraded pump station
DRAINAGE BASIN Mill Creek
TRIBUTARY DRAINAGE AREA N/A TOTAL COST (2024 DOLLARS) $3,929,000 NOTES Cost, design, figures, and
description completed by Brown &
Caldwell. Cost and description
updated by Parametrix per City
comments. Site Opportunities
This project consists of building a new pump station sized to convey the peak 25-year flow rate with multiple pumps to meet the pump
redundancy LOS. The new pump station would convey all flows from the gravity pipe on the north and south sides of Old West Main Street.
The pump station and its associated area pipes will be reassessed for overall function and purpose. A new design for the pump station will
be created that will allow for adequate pumping capacity and a new discharge location that will alleviate backflow flooding from Mill Creek
and its drainage ditches.
Site Opportunities
Project Name CIP 12 -West Main Street Pump Station Upgrade
South of West Main Street east of the SR 167 overpass ITEM SPECNO. SECTION DESCRIPTION QTY UNIT UNIT PRICE TOTAL COST1
WETLAND PERMITTING AND MITIGATION20%$302,0002CONTRACTOR OVERHEAD, PROFIT, AND MOBILIZATION18%$271,800$573,80032015 PROJECT (1) STORMWATER PUMP STATION WITH
SCADA/TELEMETRY1LS$999,000 $999,00042015 PROJECT (1) GRAVITY PIPING: 150 FT OF 12-INCH-
DIAMETER PIPE AND 113 FT OF 24-INCH-DIAMETER PIPE1LS$114,000 $114,00052015 PROJECT (1) FORCE MAIN: 200 FT OF 30-INCH-
DIAMETER FORCE MAIN, ABANDON CULVERT, RIPRAP
ROCK SPLASH PAD AT CULVERT OUTFALL1LS$343,000 $343,00062015 PROJECT (1) ANCILLARY IMPROVEMENTS:
DECOMMISION EXISTING STATION, INSTALL BACKFLOW
PREVENTER ON WSDOT CULVERT1LS$54,000 $54,000$1,510,000$2,083,80030%$625,1409%$238,387$2,947,32733.3%$981,460$3,929,000Opinion (Estimate) of Probable CostLocationS
ITE PREP AND TESC
Subtotal Line-Item Costs
TOTAL PROJECT COST
Subtotal Construction CostsLines 3 - 6 SubtotalConstruction ContingencySales Tax (all above costs)Permitting, Design, Management,
Administration, Contingency
% of construction subtotalLines 1 - 2 SubtotalMATERIALS
% of construction subtotal
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7.3 Programmatic Drainage Projects
To ensure an adequate level of utility funding in the future, the City must consider longer-range
programmatic efforts to maintain and/or improve storm drainage service. Table 7-1 lists
programmatic projects that should be included in the Storm Drainage Utility budget. These projects
are not linked to any specific problem or location, but are included for budgetary purposes. By
itemizing these activities, the Storm Drainage Utility can track actual costs to compare with budgeted
costs and specifically track how these expenditures address the LOS goals listed in Chapter 3. The
items listed in the table below are distributed between the 6- and 20-year CIPs in Chapter 8.
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Table 7-1. Summary Programmatic Drainage Projects
Project
Number
Program Name Description Priority Total Project Cost
(2024 dollars)
13 Street Utility Improvements The Storm Drainage Utility will seek
opportunities to incorporate drainage
improvements into transportation and
pavement projects on City roads. A
significant portion of storm drainage
costs related to projects make
improvements to the street network
are incurred by the City's
Transportation Program.
2 $5,200,000
14 Frame & Grate Replacement As manholes and catch basins age
and their condition deteriorates,
frame and grates can become loose
and/or misoriented or, due to age, are
no longer meeting standards. This
annual project will replace
approximately 50 storm manhole and
catch basin frame and grates to
maintain access to the storm system
and decrease the likelihood of the
manholes becoming road hazards. In
some years, this replacement will be a
stand-alone project, and in some
years, many of these replacements
will be in conjunction with other City
projects.
2 $1,700,000
15 Storm Drainage Infrastructure
Repair & Replacement
Program
This program addresses the need to
repair or replace storm drainage
infrastructure, such as individual
pipes, pump station repair and
maintenance, and pond
improvements. The long-term
priorities for R&R should be developed
by adhering to the City's system goals
regarding the maintenance of a
criticality database and the prioritized
assessment of critical infrastructure.
1 $14,400,000
16 Storm Pipeline Extension
Program
Program to extend stormwater
infrastructure into areas lacking
infrastructure or where known
stormwater issues occur.
3 $7,450,000
Note: All costs are in 2024 dollars.
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8. Implementation Plan
This chapter presents the implementation plan, which brings together information from the
preceding chapters of this 2024 Comprehensive Storm Drainage Plan to form a work plan of future
activities for the Storm Drainage Utility. The information in this chapter serves as a road map to the
Storm Drainage Utility staff. This road map outlines the critical elements of plan implementation
(e.g., capital improvement plan implementation, NPDES MS4 permit compliance, future staffing,
asset management, drainage ditch maintenance program, climate change, etc.) and links them into
a schedule of utility activities.
The implementation plan is divided into five main sections:
Section 8.1 presents the capital improvement plan for both 6-year and 20-year time frames.
Section 8.2 contains a summary of activities for NPDES MS4 permit compliance.
Section 8.3 presents recommendations for future staffing and M&O activities.
Section 8.4 summarizes the recommendations for continuing the implementation of best
practices for asset management.
Section 8.5 lists recommendations for additional activities that help the Storm Drainage
Utility achieve the system goals.
The foldout chart (Figure 8-3) at the conclusion of this chapter shows the proposed implementation
timeline. Appendix F provides the SEPA determination for the implementation plan.
8.1 6-Year and 20-Year Capital Improvement Program
The 6-year CIP contains near-term capital improvement projects focused on mitigating critical
existing drainage problems that have been observed and are well understood by the City’s staff,
addressing an ongoing waste disposal issue and ensuring compliance with NPDES MS4 permit
requirements. These projects are described in detail in Chapter 7. In addition to site-specific
projects, the 6-year CIP contains ongoing programmatic efforts, such as the Storm Drainage Utility’s
participation in the Street Utility Improvement program, which is a program designed to complete
storm repairs and replacements in conjunction with transportation projects. Table 8-1 lists the short-
term capital improvement projects and programs described in Chapter 7 and lays out annual
expenditures for the 6-year capital improvement time frame. Project timing is based on project
priorities weighed with likely budgetary constraints such that costs are distributed somewhat evenly
from year to year (see Table 8-1 and Figure 8-1).
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Table 8-1. Annual Cost Summary for 6-Year Capital Improvement Plan
Project
Number Project Name Priority
Repair/
Replacement
Upgrade/
Expansion 2025 2026 2027 2028 2029 2030 6-Year Cost
1 SE 287th Street
Stormwater Device 1 0% 100% $139,000 $243,000 $0 $0 $0 $0 $382,000
3 SE 284th Street West
Bioswale Additions 1 0% 100% $0 $0 $20,000 $32,000 $0 $0 $52,000
10 Vegetative Waste
Sorting Facility 3 90% 10% $200,000 $0 $0 $0 $0 $0 $200,000
12 West Main Street
Pump Station Upgrade 1 25% 75% $0 $0 $0 $0 $907,000 $3,022,000 $3,929,000
13 Street Utility
Improvements 2 100% 0% $260,000 $260,000 $260,000 $260,000 $260,000 $260,000 $1,560,000
14 Frame & Grate
Replacement 2 100% 0% $85,000 $85,000 $85,000 $85,000 $85,000 $85,000 $510,000
15
Storm Drainage
Infrastructure Repair &
Replacement Program
1 100% 0% $720,000 $720,000 $720,000 $720,000 $720,000 $720,000 $4,320,000
16 Storm Pipeline
Extension Program 3 0% 100% $190,000 $555,000 $190,000 $555,000 $190,000 $555,000 $2,235,000
Total 6-year CIP cost for priority 1 projects/programs: $859,000 $963,000 $740,000 $752,000 $1,627,000 $3,742,000 $8,683,000
Total 6-year CIP cost for priority 2 projects/programs: $345,000 $345,000 $345,000 $345,000 $345,000 $345,000 $2,070,000
Total 6-year CIP cost for priority 3 projects/programs: $390,000 $555,000 $190,000 $555,000 $190,000 $555,000 $2,435,000
Total 6-year cost: $1,594,000 $1,863,000 $1,275,000 $1,652,000 $2,162,000 $4,642,000 $13,188,000
Note: All costs are in 2024 dollars.
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Note: All costs are in 2024 dollars.
Figure 8-1. Annual Costs for 6-Year Capital Improvement Plan
After high-priority drainage problems are addressed, the City will be able to focus on the remaining
projects described in Chapter 7. In addition, the City will continue to emphasize the management of
existing storm drainage assets to ensure that LOS goals are continuously met. Table 8-2 summarizes
the program expenditures and forecasts total capital improvement costs for the years 2031 to 2044.
In addition to the identified projects and programs, the Storm Drainage Utility will be involved in
several ongoing system updates and capital facilities plan (CFP) projects that will require the utility’s
time and expenditures. Additional detail regarding these items are provided in Section 8.5.
$0
$500,000
$1,000,000
$1,500,000
$2,000,000
$2,500,000
$3,000,000
$3,500,000
$4,000,000
$4,500,000
$5,000,000
2025 2026 2027 2028 2029 2030Annual Cost for 6-Year Capital Year
Priority 1 Priority 2 Priority 3
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Table 8-2. Capital Improvement Cost Summary for 2031–2044
Project
Number Project Name Priority 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044
Cost for
2031–2044
2 SE 284th Street & 109th
Avenue Bioswale Additions 3 $55,000 $88,000 $143,000
4 SE 284th Street East Bioswale
Additions 3 $11,000 $17,000 $28,000
5
124th Avenue SE near 293rd
Street Stormwater Treatment
Device
2 $225,000 $356,000 $581,000
6 Vintage Hills Swale Retrofit 1 $95,000 $169,000 $264,000
7
124th Avenue SE near 307th
Place Stormwater Treatment
Device
2 $205,000 $326,000 $531,000
8
124th Avenue SE near 302nd
Place Stormwater Treatment
Device
2 $205,000 $326,000 $531,000
9 30th Street NE Area Flooding,
Phase 2 3 $198,000 $988,000 $1,186,000
11 Christa Ministries Facility
Retrofit 1 $774,000 $2,132,000 $2,906,000
13 Street Utility Improvements 2 $260,000 $260,000 $260,000 $260,000 $260,000 $260,000 $260,000 $260,000 $260,000 $260,000 $260,000 $260,000 $260,000 $260,000 $3,640,000
14 Frame & Grate Replacement 2 $85,000 $85,000 $85,000 $85,000 $85,000 $85,000 $85,000 $85,000 $85,000 $85,000 $85,000 $85,000 $85,000 $85,000 $1,190,000
15
Storm Drainage Infrastructure
Repair & Replacement
Program
1 $720,000 $720,000 $720,000 $720,000 $720,000 $720,000 $720,000 $720,000 $720,000 $720,000 $720,000 $720,000 $720,000 $720,000 $10,080,000
16 Storm Pipeline Extension
Program 3 $190,000 $555,000 $190,000 $555,000 $190,000 $555,000 $190,000 $555,000 $190,000 $555,000 $190,000 $555,000 $190,000 $555,000 $5,215,000
Total 2031–2044 cost for priority 1 projects/programs: $815,000 $889,000 $1,494,000 $2,852,000 $720,000 $720,000 $720,000 $720,000 $720,000 $720,000 $720,000 $720,000 $720,000 $720,000 $13,250,000
Total 2031–2044 cost for priority 2 projects/programs: $345,000 $345,000 $345,000 $345,000 $550,000 $671,000 $550,000 $671,000 $570,000 $701,000 $345,000 $345,000 $345,000 $345,000 $6,473,000
Total 2031–2044 cost for priority 3 projects/programs: $190,000 $555,000 $190,000 $555,000 $190,000 $555,000 $190,000 $555,000 $190,000 $555,000 $388,000 $1,543,000 $256,000 $660,000 $6,572,000
Total 2031–2044 cost for projects/programs: $1,350,000 $1,789,000 $2,029,000 $3,752,000 $1,460,000 $1,946,000 $1,460,000 $1,946,000 $1,480,000 $1,976,000 $1,453,000 $2,608,000 $1,321,000 $1,725,000 $26,295,000
Note: All costs are in 2024 dollars.
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8.2 Programmatic Measures for NPDES Compliance
The City of Auburn is covered by the Western Washington Phase II Municipal Stormwater permit. The
permit regulates stormwater discharges from the City’s MS4 (see Section 2.3.2). The current version
of the NPDES MS4 permit was issued in August 2024 and will remain in effect through July 2029,
when a new version is due to be issued. A regulatory-driven improvements investigation was
performed on behalf of this Plan and was discussed in Chapter 5.3. The recommended actions on
behalf of this investigation have been summarized below.
Update local development regulations and drainage standards in accordance with updated
NPDES MS4 permit requirements.
Review and revise municipal code to reflect IDDE changes, specifically concerning routine
washdowns of structures likely to have PCB-containing materials.
Carry out permit-required activities related to TMDLs (identified in Chapter 4.4.1).
Develop and implement protocols with firefighting agencies regarding PFAS discharges
into stormwater.
Develop and implement tree canopy goals to support stormwater management and improve
receiving water quality.
Prepare an SMAP for a new high-priority catchment area or enhance the existing one for
Olson Creek.
Ensure the existing street sweeping plan covers the permit requirements.
Reflect on the ongoing public outreach campaign and consider adding new actions or
developing a new campaign.
Map piped MS4 outfalls with flow control or stormwater treatment upstream to determine
the amount of treated/untreated area within the MS4.
Continue implementing the SCIP.
These actions have been further detailed and organized on a timeline in Figure 8-3. Additionally, the
compliance-specific schedule for key requirements under the current NPDES MS4 permit is shown in
Figure 8-2.
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Figure 8-2. NPDES Compliance Schedule
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8.3 Future Staffing and Equipment Needs
During this planning effort, current Engineering and M&O staffing were considered in light of future
activities that will need to be performed to maintain compliance with the NPDES MS4 permit. M&O
staffing and equipment were also reviewed, taking into account existing maintenance goals and
future, additional M&O responsibilities. The following sections summarize the additional staffing,
staffing responsibilities, and equipment needs for the Storm Drainage Utility.
8.3.1 Engineering Services
As part of this Plan, the City evaluated engineering staffing responsibilities required to address the
revised NPDES MS4 permit and other storm drainage system deficiencies. The recommended
actions in Figure 8-3 are expected to be managed by engineering staff.
8.3.2 Maintenance and Operation Services
The evaluation of M&O staffing for managing, operating, and maintaining the storm drainage system
in Chapter 6 revealed that the Storm Drainage Utility is adequately staffed to meet current proactive
City goals. However, additional staff and equipment may be necessary to fulfill NPDES MS4 permit
requirements and anticipated future work (as outlined in Section 6.6.2). Although no immediate
staffing additions are planned, ongoing monitoring of staffing levels will assess the need.
Support from M&O staff will be needed in the following actions (identified in Chapter 6 and
summarized below):
Asset management recommendations (Section 8.4):
→ Prioritizing work using risk-based scoring methods.
→ Documenting condition assessments and work orders in Cartegraph.
Street Sweeping Plan (NPDES MS4 permit):
→ Coordinating with the Street Division (as needed) to implement the required street
sweeping plan.
Ditch Maintenance Program (Section 8.5):
→ Carrying out the recommended needs from the ditch maintenance program.
Additionally, based on discussions with City staff and analysis of M&O activities, the Storm Drainage
Utility will consider obtaining CCTV inspection equipment for pipe inspection within five years.
8.4 Continue Implementation of Best Practices for Asset
Management
As an integral part of this comprehensive plan, the City conducted a thorough review of its existing
asset inventory and management practices, as discussed in Chapter 5.2. The recommended actions
have been summarized below.
System inventory:
→ Continuously update the inventory with additional data collected during maintenance
activities (e.g., condition assessment and frequency of maintenance).
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→ Train staff on asset inventory needs, capability, data collection, data quality objectives,
and maintenance processes.
→ Develop a process for reviewing and updating the asset inventory when changes and
inspections occur (see Section 5.2.3).
→ Implement the prioritized inspection and asset information update process to address
data gaps and provide observation-based condition assessments.
Risk-based scoring in Cartegraph:
→ Integrate scoring methods into Cartegraph.
→ Populate critical feature attributes (used in risk calculations).
→ Add scoring fields to calculate likelihood of failure and criticality of failure scores for each
pipe in Cartegraph.
Risk-based scoring improvements:
→ Expand scoring methods to include asset types beyond collection system piping.
→ Implement these improvements into Cartegraph and inspection prioritization techniques
(see Appendix C for recommended attributes for other stormwater assets).
Maintenance and R&R prioritization:
→ Prioritize maintenance activities for assets with the highest risk.
→ Assess the inspection process every 5 years to evaluate efficiency and identify areas
for improvement.
→ Consider reconducting pipe depreciation analysis periodically to assess the impact of
prioritization practices.
8.5 Recommendations for Additional Activities
The following sections summarize recommendations for additional activities discussed during this
Plan for the Storm Drainage Utility. Section 8.5 is divided into the following three sub-sections:
Section 8.5.1 summarizes recommendations discussed in Section 5.4.2.
Section 8.5.2 summarizes recommendations discussed in Section 6.6.2.1.
Section 8.5.3 presents the ongoing system updates carried out by the Storm Drainage Utility
and the CFP projects that will require coordination from the Utility.
8.5.1 Climate Change
As discussed in Chapter 5.4, climate change will need to be considered in developing and
implementing stormwater design guidelines for future scenarios. The actions recommended on
behalf of climate change are summarized below.
Review and revise the hydraulic performance metrics related to freeboard, headwater depth,
and surcharging. Evaluate the financial implications associated with enforcing strict hydraulic
performance standards.
Prepare a CDR process to evaluate the consequences of storm events exceeding the design
parameters. Establish clear policies regarding safety, property protection, service continuity,
and mitigation of nuisance flooding to make systems more resilient to infrequent but
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probable flooding. Ensure that the level of protection aligns with the associated costs and
risk factors.
Prioritize effective hydraulic performance and resilience measures for critical facilities during
severe storm events that go beyond the intended design limits.
8.5.2 Ditch Maintenance Program
A drainage ditch maintenance program was developed as a part of this Plan. See Chapter 6.6.2.1 for
more details. The previously discussed recommendations have been summarized below.
Develop protocols for finding, adding, mapping, and classifying ditches within the system.
Consider the steps required when adding new ditches to the system.
Use the results of regular ditch inspections to identify system failures.
Implement a program that focuses on retrofitting ditches with water quality enhancements.
8.5.3 Ongoing System Updates and Capital Facilities Plan
Projects
The City will be involved in several ongoing system updates throughout the period of 2031–2044.
These updates and their projected costs and timelines have been listed in Table 8-3 below.
Table 8-3. Ongoing System Updates
Name Description
2031–2044
Cost
Pump Station Level of Service
Review
Program to review all pump stations for level of service. Specifically
focus on A Street SE and Auburn Way S as an existing drainage
issue has been identified there (see Section 4.5).
$400,000
Pump Station Update Program to update the pump stations according to the results of
the level of service review. $2,000,000
Underground Injection Wells
Retrofit Program
Retrofit program to map underground injection wells in the City with
water quality treatment. $975,000
Total 2031–2044 cost: $3,375,000
Note: All costs are in 2024 dollars.
In addition, there are several CFP projects that will require coordination from the Storm Drainage
Utility from 2024–2026. These projects are listed in Table 8-4 below.
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Table 8-4. Capital Facilities Plan Project Schedule 2024–2026
Name 2024 Cost 2025 Cost 2026 Cost Cost for 2024–2026
R Street SE Widening - 22nd Street SE to
33rd Street SE $303,850 $938,897 $1,242,747
Regional Growth Center Improvements $100,000 $100,000
R Street SE Preservation $320,000 $320,000
12th Street SE Water Main Improvements $16,000 $16,000
Arterial Preservation $215,000 $215,000
Jornada Park Access Improvements $100,000 $100,000
C Street SW Preservation (W Main to GSA signal) $50,000 $50,000
M Street NE Widening $824,000 $824,000
Total project cost for 2024–2026: $801,000 $1,127,850 $938,897 $2,867,747
Note: Costs shown in this table have been escalated as described in Section 9.
8.6 Implementation Plan
The recommended actions within this Plan have been organized in a timeline, as depicted in
Figure 8-3. This timeline serves as a guide for implementing the actions in a structured manner.
Page 148 of 373
Implementation Plan Activities Timeline 2024
Chapter Action Q1-Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4
CIP
7 1. SE 287th Street Stormwater Device x z z z z z z y
7 2. SE 284th Street & 109th Avenue Bioswale Additions x
7 3. SE 284th Street West Bioswale Additions x z z z z z z y
7 4. SE 284th Street East Bioswale Additions x
7 5. 124th Avenue SE near 293rd Street Stormwater Treatment Device
7 6. Vintage Hills Swale Retrofit x
7 7. 124th Avenue SE near 307th Place Stormwater Treatment Device x
7 8. 124th Avenue SE near 302nd Place Stormwater Treatment Device x
7 9. 30th Street NE Area Flooding, Phase 2 x
7 10. Vegetative Waste Sorting Facility x z z y
7 11. Christa Ministries Facility Retrofit x
7 12. West Main Street Pump Station Upgrade x z z z z z z y
7 13. Street Utility Improvements w u u u u u u u u u u u u u u u u u u u u u u u u u
7 14. Frame & Grate Replacement w u u u u u u u u u u u u u u u u u u u u u u u u u
7 15. Storm Drainage Infrastructure Repair & Replacement Program w u u u u u u u u u u u u u u u u u u u u u u u u u
7 16. Storm Pipeline Extension Program w u u u u u u u u u u u u u u u u u u u u u u u u u
System Goals and Policies
2 Review and update inventory of existing capital facilities.w
2 Forecast capital facility needs for planning period. Consider reducing LOS or increasing revenue as needed.w
2 Identify the proposed locations and capacity of expanded/new facilities.w
2 Update the 6-year plan biennially.w v v v
3 Routinely assess performance of pumped systems.w x z z y
3 Consider using future rainfall intensity data for designing stormwater systems.y
4 Address the existing drainage problems through capital or otherwise.w x u u u u u u u u u u u u u u u u u u u u u u u u
NPDES MS4 permit Compliance
2 Review development regulations from new permit to ensure consistency with policies and LOS goals.x z y
2 Adopt the revised manual as required by NPDES MS4 permit.x z y
Review and revise municipal code to reflect IDDE changes.x z y
2 Submit a SWMP plan to Ecology every year.v v v v v v
2 Submit an annual report to Ecology by March 31 every year.v v v v v v
2 Track the costs of implementing SWMP and TMDL requirements and provide in annual report by March 2027.v v v v
2 By March 31, 2027, describe how stormwater management strategies and receiving water health are informing long-range
comprehensive planning in the annual report.v v v v
2 Monitor discharges to the White River in association with the Puyallup River Watershed Fecal Coliform TMDL.w u u u u u u u u u u u u u u u u u u u u u u u u u
2 Routinely update and review asset inventory for accuracy.w u u u u u u u u u u u u u u u u u u u u u u u u u
4 Update development regulations and design standards in accordance with NPDES MS4 permit requirements.x z y
4 Map all known piped MS4 outfalls to the Lower White River.x z z z z z y
4 Screen all known piped MS4 outfalls to the Lower White River for illicit discharges.x z z z z z y
2025 2026 2027 2028 2029 2030 2031-
2044
Legend
Completed
Recommended Start
Midway Point (Anticipated Duration)
Deadline
Repeated Action
Ongoing Action
Figure 8-3.
Implementation Plan Activities Timeline
(1 of 3)Page 149 of 373
Implementation Plan Activities Timeline 2024
Chapter Action Q1-Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4
2025 2026 2027 2028 2029 2030 2031-
2044
4 Require phosphorus treatment BMPs for all new and redevelopment projects in the Lower White River implementation area.x z z y
4 Continue ongoing inspection programs and reinspect facilities found to have bacteria source potential.w u u u u u u u u u u u u u u u u u y
4 Enact public education and outreach activities to increase awareness of bacterial pollution problems.w x z z y
4 Maintain pet waste collection stations at Permittee-owned or -operated lands, as needed.w x u u u u u u u u u u u u y
4 Review expected activities for Soos Creek TMDL when it becomes available and implement activities as necessary.x u u u u u u u u u u u u u u u y
4 Develop process to identify and implement needed updates to codes, standards, and programs by relevant due dates.x z y
5 Coordinate with firefighting agencies/departments to implement specific protocols regarding PFAS discharges into
stormwater.x z z z z y
5 Prepare an assessment of existing conditions.x z z z z z z y
5 Draft a list of potential policies.x z z y
5 Select and adopt policies.y
5 Identify a preferred catchment area for inclusion or enhancement.x y
5 Prepare a new SMAP or update the existing SMAP.x z z z z y
5 Review the road system plan.x z z y
5 Review high-priority roadways.x z z y
5 Determine candidate sites for retrofitting using SMAPs, capital improvement projects, or other relevant plans.x z z y
5 Select projects and include in capital improvement plan.x z z y
5 Document the effectiveness of the behavior change campaign required under the 2019 NPDES MS4 permit.x z y
5 Develop a public education campaign. Consider source control BMPs for building materials as the focus.x z z z z y
5 Submit results of public education campaign and recommended strategies for improvement.x z y
5 Document public involvement opportunities to overburdened communities.v v v v v
5 Identify facilities to be mapped.x z z z y
5 Develop a methodology for mapping outfalls.x z z z z z z y
5 Use a geographic information system (GIS) to prepare a map of catchment areas.x z z z z z z y
5 Begin mapping of permittee-owned or operated properties with tree canopy based on available data.x z z y
5 Prioritize projects developed in the SMAP that together meet the City’s assigned 8.9 acres.y
5 Review and revise the existing sweeping program.x z z z z z y
5 Enact the modified sweeping program.x u u u u u u u u u u u u u u
5 Review, revise, and make effective LID codes x z z z z y
6 Evaluate the resource need of the SCIP program and update accordingly.w x z z y
6 Coordinate with the Street utility to review and revise the City’s street sweeping plan, as needed.x z z z z z y
Asset Management
5 Implement asset management program.w
5 Train staff on asset inventory needs, data collection and quality objectives, and system maintenance.x z y
5 Implement the likelihood of failure and criticality of failure scoring methods into Cartegraph.x z z y
5 Establish and conduct the practice for prioritization of inspection and other work based on scoring methods.x z z y
5 Develop and conduct process for reviewing the asset inventory and a routine for updating when changes and inspections
occur.x z z y
Legend
Completed
Recommended Start
Midway Point (Anticipated Duration)
Deadline
Repeated Action
Ongoing Action
Figure 8-3.
Implementation Plan Activities Timeline
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Implementation Plan Activities Timeline 2024
Chapter Action Q1-Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4
2025 2026 2027 2028 2029 2030 2031-
2044
5 Expand scoring methods to include asset types other than collection system piping and implement similarly into
Cartegraph and inspection prioritization techniques.x z z y
5 Reconduct pipe depreciation analysis every 5 years to evaluate the effect of the prioritization practice.x z z y
6 Consider obtaining CCTV inspection equipment for future pipe inspection.x
6 Develop a methodology for adding GIS attributes to existing asset inventory.w x z y
6 Develop methodology to document condition assessments and provide staff training to implement.x z z y
6 Use results of condition assessments to move toward risk-based maintenance.x z z y
6 Demonstrate (through maintenance records) that a subset of City catch basins do not require inspection, cleaning, and
maintenance every 2 years per the NPDES MS4 permit.x z z z z y
6 Reevaluate the inspection frequency and expected effort for the pipe inspection and ditch maintenance programs to adjust
as needed.x z z z z y
6 Investigate the process for coordinating pipe cleaning and CCTV.x z z y
6 Develop a more formal procedure for tracking M&O repair projects to ensure that as-built and GIS records are updated
when repairs are completed.x z z z y
6 Develop a list of facilities that should be inspected following major design storms and inspect accordingly to verify proper
function and identify damage, if any.x z z y
6 Develop protocols for finding, adding, mapping, and classifying ditches within the system.w x z z y
6 Determine how to address the elements required when adding new ditches to the system. w x z z y
6 Use the results of regular ditch inspections to identify system failures. Add a program to the CIP to address ditches with
these system failures.x z z y
6 Implement a program that focuses on retrofitting ditches with water quality enhancements. w x z z z z y
Climate Change
5 Update hydraulic performance metrics.x z z z z y
5 Prepare a critical drainage review (CDR).x z z z z y
5 Develop hydraulic performance measures for critical facilities.x z z z z y
5 Assess vulnerability of critical access roads.x z z y
5 Protect riparian tree canopy.x z z y
Additional Activities
8 Pump Station LOS Review
8 Pump Station Update v
8 Underground Injection Wells Retrofit Program x
8 R Street SE Widening - 22nd Street SE to 33rd Street SE x z z z z z z y
8 Regional Growth Center Improvements
8 R Street SE Preservation
8 12th Street SE Water Main Improvements
8 Arterial Preservation
8 Jornada Park Access Improvements
8 C Street SW Preservation (W Main to GSA signal)
8 2026 Local Street Preservation x z z z z z z y
8 M Street NE Widening x z z y
Legend
Completed
Recommended Start
Midway Point (Anticipated Duration)
Deadline
Repeated Action
Ongoing Action
Figure 8-3.
Implementation Plan Activities Timeline
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9. Financial Plan
9.1 Introduction
This chapter was prepared by FCS Group to provide a financial program that allows the City of
Auburn Storm Drainage Utility to remain financially viable during the planning period. This financial
viability analysis considers the historical financial condition, current and identified future financial
goals and policy obligations, M&O needs, and the financial impacts of the capital projects identified
in this Comprehensive Storm Drainage Plan. Furthermore, this chapter provides a review of the
Storm Drainage Utility’s current rate structure with respect to rate adequacy and customer
affordability.
9.2 Past Financial Performance
This section includes a historical summary of financial performance as reported by the City, including
fund resources and uses arising from cash transactions.
9.2.1 Comparative Financial Statements
The City legally owns and operates the Auburn Storm Drainage Utility. Table 9-1 shows a summary of
storm drainage fund resources and uses arising from cash transactions for the previous six years
(2017 through 2022). The 2023 financial statements were not available at the time this chapter was
developed. Table 9-2 shows a summary of assets and liabilities, with the difference between the two
reported as “net position.” Increases and decreases in net position are useful indicators of the
financial position of the City’s utility. Noteworthy findings and trends for the historical performance
and condition of the City’s Storm Drainage Utility are then discussed.
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Table 9-1. Summary of Historical Fund Resources and Uses Arising from Cash Transactions
9.2.1.1 Findings and Trends
The City’s storm drainage charges for services increased from $9.8 million in 2017 to $11.0
million in 2022. The average annual increase was approximately 2.4% per year, with a total
increase of 12.4% from 2017 to 2022. Operating expenditures increased by $1.2million
across the 6 years with an average annual increase of 2.5%. While operating expenditures
increased across the 6 years, they fell in 2019 and 2020 before increasing by 8.9% in 2021.
With growth in total operating revenues slightly below growth in operating expenses,
operating income has remained positive in all years.
The M&O coverage ratio (total operating revenues divided by total operating expenses) was
113% in 2017. With relatively balanced revenues and expenses, this metric has maintained
its stability, ending 2022 at 112.0%. A ratio of 100% or greater shows that operating revenue
will successfully cover operating expenses, and the utility has remained above this ratio for
the past 6 years.
Net operating income as a percentage of operating revenue was 11.5% in 2017, decreasing
to 8.6% in 2018, before recovering back to 10.7% by 2022. Similar to the M&O coverage
ratio, these trends show how successfully operating revenue actually covered operating
expenses, with higher positive numbers being the best and negative numbers showing a
need for improvement. In addition, these trends demonstrate the ability of the utility to invest
in capital, whether through direct cash transfers or the issuance and servicing of debt.
2017 2018 2019 2020 2021 2022
OPERATING REVENUES
Charges for Service 9,778,102$ 9,809,840$ 10,110,490$ 10,301,049$ 10,591,890$ 10,985,794$
Other Operating Revenue - - - - - -
Total Operating Revenues 9,778,102$ 9,809,840$ 10,110,490$ 10,301,049$ 10,591,890$ 10,985,794$
OPERATING EXPENSES
Operations and Maintenance 3,379,046$ 3,568,600$ 3,509,728$ 3,360,404$ 4,150,264$ 4,135,306$
Administration 3,372,935 3,326,599 3,230,505 3,144,182 3,109,673 3,835,875
Depreciation and Amortization 1,885,931 2,067,030 2,092,443 2,120,788 2,133,233 1,837,459
Other Operating Expenses 13,085 - - - - -
Total Operating Expenses 8,650,997$ 8,962,229$ 8,832,676$ 8,625,374$ 9,393,170$ 9,808,640$
Operating Income (Loss)1,127,105$ 847,611$ 1,277,814$ 1,675,675$ 1,198,720$ 1,177,154$
NONOPERATING REVENUES (EXPENSES)
Interest Revenue 151,733$ 327,884$ 518,073$ 162,516$ (34,640)$ 300,426$
Other Non-Operating Revenue 78,397 165,136 81,307 125,963 102,214 132,440
Gain (Loss) on Sale of Capital Assets - - - - - -
Interest Expense (328,972) (310,816) (293,420) (129,471) (152,526) (133,330)
Other Non-Operating Expense - (101,328) - (26,022) - (428,759)
Total Non-Operating Revenues (Expenses)(98,842)$ 80,876$ 305,960$ 132,986$ (84,952)$ (129,223)$
Income (Loss) before Contributions and Transfers 1,028,263$ 928,487$ 1,583,774$ 1,808,661$ 1,113,768$ 1,047,931$
Capital Contributions 2,313,033$ 995,853$ 1,021,824$ 1,546,772$ 5,364,962$ 1,408,167$
Transfers In 300,000 125,000 - - - -
Transfers Out (672,122) (332,589) (138,357) (137,399) (155,972) (133,555)
Change in Net Position 2,969,174$ 1,716,751$ 2,467,241$ 3,218,034$ 6,322,758$ 2,322,543$
Net Position, January 1 64,010,652$ 66,979,826$ 68,696,577$ 71,163,818$ 74,381,852$ 80,704,610$
Net Position, December 31 66,979,826$ 68,696,577$ 71,163,818$ 74,381,852$ 80,704,610$ 83,027,153$
O&M Coverage Ratio 113.0% 109.5% 114.5% 119.4% 112.8% 112.0%
Net Operating Income as a % of Operating Revenue 11.5% 8.6% 12.6% 16.3% 11.3% 10.7%
Debt Service Coverage Ratio 3.75 3.63 4.21 5.59 4.92 4.46
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The debt service coverage ratio measures the amount of cash flow available to meet
principal and interest payments. Typically, revenue bond debt service coverage requires a
minimum factor of 1.25 during the life of the loans. This ratio is calculated by dividing cash
or net operating income (operating revenues minus operating expenses) by annual revenue
bond debt service. The debt service coverage ratio for all outstanding revenue bond debt
ended 2017 at 3.8, decreasing to 3.6 in 2018, before increasing to 4.5 by 2022. The fact
that this ratio has sustained levels higher than the minimum target of 1.25 indicates a stable
capacity for new debt and will likely result in favorable terms when entering the bond market.
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Table 9-2. Summary of Historical Comparative Statements of Net Position
2017 2018 2019 2020 2021 2022
CURRENT ASSETS
Cash and Cash Equivalents 14,545,114$ 10,644,121$ 12,738,639$ 17,124,762$ 16,904,318$ 16,689,485$
Investments - 4,781,224 4,389,043 2,729,581 4,951,200 4,566,850
Restricted Cash:
Bond Payments 804,480 803,251 800,093 679,184 657,541 658,088
Customer Deposits 3,422 3,422 3,422 3,422 3,422 3,422
Other (Reserve for Bonds and Rate Stabilization)1,195,817 1,203,670 1,211,285 1,081,961 1,082,389 1,088,818
Customer Accounts 1,066,124 1,105,972 1,631,660 1,712,774 1,611,351 1,796,825
Other Receivables - 14,757 14,757 - 7,104 7,104
Due From Other Governmental Units 70,124 103,343 - 72,123 109,161 122,276
Inventories 7,390 4,795 9,099 8,745 9,597 10,414
Total Current Assets 17,692,471$ 18,664,555$ 20,797,998$ 23,412,552$ 25,336,083$ 24,943,282$
NONCURRENT ASSETS
Long-Term Contracts, Leases and Notes -$ -$ -$ -$ -$ -$
Net Pension Asset - - - - 2,040,168 751,962
Capital Assets Not Being Depreciated:
Land 5,937,014 5,937,014 5,937,014 5,937,014 5,937,014 5,937,014
Intangible - Water Rights - - - - - -
Construction In Progress 459,310 153,082 648,531 342,126 980,569 1,135,843
Capital Assets:
Buildings and Equipment 290,575 290,575 290,575 282,111 282,111 282,111
Improvements Other Than Buildings 79,177,949 81,449,103 82,903,631 84,749,193 89,739,833 93,201,563
Right of Use (Leases)- - - - -
Less Accumulated Depreciation (26,325,396) (28,392,426) (30,484,869) (32,587,697) (34,720,930) (36,558,389)
Total Noncurrent Assets Net of Accumulated Depreciation 59,539,452$ 59,437,348$ 59,294,882$ 58,722,747$ 64,258,765$ 64,750,104$
TOTAL ASSETS 77,231,923$ 78,101,903$ 80,092,880$ 82,135,299$ 89,594,848$ 89,693,386$
DEFFERED OUTFLOWS OF RESOURCES
Deferred Outflow from Bond Refunding -$ -$ -$ 29,232$ 29,232$ 29,232$
Deferred Outflow related to Pensions 292,611 254,676 274,851 309,222 286,842 820,313
Total Deferred Outflows of Resources 292,611 254,676 274,851 338,454 316,074 849,545$
CURRENT LIABILITIES
Current Payables 391,180$ 308,381$ 578,689$ 305,576$ 626,924$ 496,608$
Claims Payable - - - - - -
Loans Payable - Current - - - - - -
Employee Leave Benefits - Current 173,857 156,429 154,609 156,429 199,603 246,831
Leases Payable - Current - - - - - -
Revenue Bonds Payable - Current 425,578 437,948 452,418 411,430 426,973 446,716
Payable From Restricted Assets:
Accrued Interest 377,766 365,303 347,675 267,753 249,914 229,124
Deposits 3,422 3,422 3,422 3,422 3,422 3,422
Other Liabilities Payable 469
Total Current Liabilities 1,372,272$ 1,271,483$ 1,536,813$ 1,144,610$ 1,506,836$ 1,422,701$
NONCURRENT LIABILITIES
Employee Leave Benefits 52,506$ 56,590$ 41,091$ 56,590$ 86,394$ 94,689$
Loans Payable - - - - - -
Leases Payable - - - - - -
Revenue Bonds Payable 7,495,862 7,030,496 6,550,661 6,069,633 5,564,619 5,039,861
Net Pension Liability 1,339,843 805,573 527,198 509,014 (122,090) 128,697
Total Non Current Liabilities 8,888,211$ 7,892,659$ 7,118,950$ 6,635,237$ 5,528,923$ 5,263,247$
TOTAL LIABILITIES 10,260,483$ 9,164,142$ 8,655,763$ 7,779,847$ 7,035,759$ 6,685,948$
DEFERRED INFLOWS OF RESOURCES
Deferred Inflow Related to Leases -$ -$ -$ -$ -$ -$
Deferred Inflow Related to Pensions 284,225 495,860 548,150 312,054 2,170,553 829,830
Total Deferred Inflows of Resources 284,225$ 495,860$ 548,150$ 312,054$ 2,170,553$ 829,830$
NET POSITION
Net Investment in Capital Assets 52,422,492$ 52,772,155$ 53,091,896$ 52,920,868$ 56,884,546$ 58,512,575$
Restricted For:
Debt Service 398,648 411,110 426,793 375,725 393,992 1,078,288
Rate Stabilization 419,403 427,257 436,817 438,483 438,483 438,483
Pension Asset - - - - 751,962
Unrestricted 13,739,283 15,086,055 17,208,312 20,646,776 22,987,589 22,245,845
TOTAL NET POSITION 66,979,826$ 68,696,577$ 71,163,818$ 74,381,852$ 80,704,610$ 83,027,153$
Current Ratio 12.9 14.7 13.5 20.5 16.8 17.5
Debt to Net Position Ratio 0.12 0.11 0.10 0.09 0.08 0.07
Debt to Noncurrent Capital Assets Ratio 0.14 0.13 0.12 0.11 0.10 0.09
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9.2.1.2 Findings and Trends
The current ratio is calculated by dividing unrestricted current assets by current liabilities and
measures an entity’s ability to pay short-term obligations. This ratio ranges from a low of
12.9 in 2017, reaching a high of 20.5 in 2020, before ending at 17.5 in 2022. Anything
above 2.0 for this liquidity ratio is good.
The debt-to-net-position ratio compares total debt to total net position, which is the
difference between current assets and liabilities. This ratio begins at 0.12 or 12% debt in
2017 and decreases to 0.07 or 7% by 2022. These results indicate the utility has ample
borrowing capacity to address future capital improvement needs. For utilities, a ratio of 40%
to 60% helps to moderate rate impacts by spreading costs over a longer period. Based on
these results, the City may consider utilizing debt service for future capital investments,
especially if it benefits system expansion.
The debt-to-noncurrent-capital-asset ratio compares total debt to noncurrent capital assets,
which are also known as property, plant, and equipment. This ratio begins at 0.14 or 14%
debt to 86% noncurrent assets in 2017. Noncurrent capital assets increase by $5.2 million
throughout the 6-year history, while debt decreases $2.5 million, and the ratio decreases to
0.09 or 9% by 2022. Similar to the debt-to-net position ratio, these results indicate the utility
has ample borrowing capacity and may consider utilizing debt service for future capital
investments, especially if it benefits system expansion. A ratio of 40% debt to 60% equity or
below is a general industry target.
9.3 Financial Plan
The Storm Drainage Utility is responsible for generating sufficient revenue to meet all of its costs.
The primary source of funding is derived from ongoing monthly service charges, with additional
revenue coming from late fees, storm applications and investment interest. The City controls the
level of user charges and, with City Council approval, can adjust user charges as needed to meet
financial objectives.
The financial plan can only confirm financial feasibility if it considers the total system costs of
providing storm drainage services, both operating and capital. To meet these objectives, the
following elements have been completed.
1. Capital Funding Plan. Identifies the total capital improvement plan obligations of the planning
period. The plan defines a strategy for funding the capital improvement plan, including an
analysis of available resources from rate revenues, existing reserves, system development
charges, debt financing, and any special resources that may be readily available (e.g., grants,
developer contributions). The capital funding plan impacts the financial plan through the use
of debt financing (resulting in annual debt service) and the assumed rate revenue made
available for capital funding.
2. Financial Forecast. Identifies future annual non-capital costs associated with the operation,
maintenance, and administration of the storm drainage system. Included in the financial
plan is a reserve analysis that forecasts cash flow and fund balance activity, along with
testing for satisfaction of actual or recommended minimum fund balance policies. The
financial plan ultimately evaluates the sufficiency of utility revenues in meeting all
obligations, including cash uses such as operating expenses, debt service, capital outlays,
and reserve contributions, as well as any coverage requirements associated with long-term
debt. The plan also identifies the future adjustments required to fully fund all utility
obligations in the planning period.
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9.3.1.1 Capital Funding Plan
To properly evaluate future capital funding needs, capital costs were escalated by 3% annually to the
year of planned spending. The capital improvement plan developed for this Plan identifies $26.5
million in escalated project costs over the 10-year planning horizon from 2024 to 2033. The 20-year
period through 2043 includes $61.7 million in total escalated project costs.
A summary of the 10-year and 20-year capital improvement plans are shown in Table 9-3. As shown,
each year has varied capital cost obligations depending on construction schedules and infrastructure
planning needs.
Table 9-3. 10-Year and 20-Year Capital Improvement Plans
Table 9-4 provides more detail for the 10-year capital improvement plan.
2024 2,531,000$ 2,531,000$
2025 3,498,220 3,603,167
2026 6,257,780 6,638,879
2027 1,282,000 1,400,876
2028 1,659,000 1,867,219
2029 1,255,000 1,454,889
2030 1,620,000 1,934,365
2031 1,352,000 1,662,789
2032 2,065,000 2,615,880
2033 2,104,000 2,745,243
10-Year Total 23,624,000$ 26,454,307$
2034 - 2043 23,073,000 35,209,528
20-Year Total 46,697,000$ 61,663,835$
Year Unescalated $Escalated $
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Table 9-4. 10-Year Capital Improvement Plan (Escalated $)
Project 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033
Vegetative Waste Sorting Facility $206,000
SE 287th Street Stormwater Device 158,332 289,923
2026 Local Street Preservation 157,075 485,362
R Street SE Widening - 22nd Street SE to 33rd Street SE 303,850 938,897
Storm Pipeline Extension Program 195,700 588,800 207,618 624,657 220,262 662,699 233,676 703,057 247,907
Street Utility Improvements 260,000 267,800 275,834 284,109 292,632 301,411 310,454 319,767 329,360 339,241
Frame & Grate Replacement 85,000 87,550 90,177 92,882 95,668 98,538 101,494 104,539 107,675 110,906
Storm Drainage Infrastructure Repair & Replacement Program 720,000 741,600 763,848 786,763 810,366 834,677 859,718 885,509 912,074 939,437
SE 284th Street West Bioswale Additions 29,504 43,895
West Main Street Pump Station Upgrade 265,000 661,260 3,206,040
Pump Station Level of Service Review 253,354
Vintage Hills Swale Retrofit 119,298 215,351
Storm Comprehensive Plan Update 400,000
Underground Injection Wells Retrofit Program 95,008 97,858
Christa Ministries Facility Retrofit 1,009,894
Regional Growth Center Improvements 100,000
R Street SE Preservation 320,000
12th Street SE Water Main Improvements 16,000
Arterial Preservation 215,000
Jornada Park Access Improvements 100,000
C Street SW Preservation (W Main to GSA signal) 50,000
M Street NE Widening 824,000
Total $2,531,000 $3,603,167 $6,638,879 $1,400,876 $1,867,219 $1,454,889 $1,934,365 $1,662,789 $2,615,880 $2,745,243
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9.4 Available Funding Assistance and Financing Resources
Feasible long-term capital funding strategies must be defined to ensure that adequate resources are
available to fund the capital improvement plan identified in this Plan. In addition to the City’s
resources, such as accumulated cash reserves, capital revenues, and rate revenues designated for
capital purposes, capital needs can be met from outside sources, such as grants, low-interest loans,
and bond financing. The following is a summary of the City’s internal and external resources.
9.4.1 City Resources
Resources appropriate for funding capital needs include accumulated cash in the capital fund, rate
revenues designated for capital spending purposes, developer contributions, and capital-related
charges such as system development charges. The first two resources will be discussed in the Fiscal
Policies section of the Financial Forecast. Capital-related charges are discussed below.
9.4.1.1 System Development Charges
A connection charge, such as the City’s SDC, refers to a one-time charge imposed on new customers
as a condition of connecting to the storm drainage system. The purpose of the SDC is two-fold: (1) to
promote equity between new and existing customers and (2) to provide a source of revenue to fund
capital projects necessary for meeting growth. This revenue can only be used to fund utility capital
projects or to pay debt service incurred to finance those projects. In the absence of a connection
charge, growth-related capital costs would be borne in large part by existing customers. In 2024, the
City charged all new customers an SDC of $1,759 per ESU, which is defined as 2,600 square feet of
impervious surface area.
9.4.1.2 Local Facilities Charge
A utility local improvement district (ULID) is another mechanism for funding infrastructure that
assesses benefited properties based on the special benefit received by the construction of specific
facilities. Most often used for local facilities, some ULIDs also recover related general facilities costs.
Substantial legal and procedural requirements can make this a relatively expensive process, and
there are mechanisms by which a ULID can be rejected.
9.4.2 Outside Resources
This section outlines various grant, loan, and bond opportunities available to the City through federal
and state agencies to fund the capital improvement plan identified in the Plan.
9.4.2.1 Grants and Low-Cost Loans
Historically, federal and state grant programs were available to local utilities for capital funding
assistance. However, these assistance programs have been mostly eliminated, substantially reduced
in scope and amount, or replaced by loan programs. Remaining grant programs are generally lightly
funded and heavily subscribed. Nonetheless, the benefit of low-interest loans makes the effort of
applying worthwhile.
The State of Washington’s Department of Commerce maintains a document currently entitled
“Funding Programs for Drinking Water and Wastewater Projects; Updated 3-5-2024,” which contains
details on government programs, eligibility requirements, and contact information, should the City
wish to inquire about program offerings and eligibility requirements.
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9.4.2.2 Bond Financing
General Obligation Bonds – General obligation (G.O.) bonds are bonds secured by the full faith and
credit of the issuing agency, committing all available tax and revenue resources to debt repayment.
With this high level of commitment, G.O. bonds have relatively low interest rates and few financial
restrictions. However, the authority to issue G.O. bonds is restricted in terms of the amount and use
of the funds, as defined by the Washington constitution and statute. Specifically, the amount of debt
that can be issued is linked to assessed valuation.
RCW 39.36.020 states:
(2)(a)(ii) Counties, cities, and towns are limited to an indebtedness amount not
exceeding one and one-half percent of the value of the taxable property in such
counties, cities, or towns without the assent of three-fifths of the voters therein
voting at an election held for that purpose.
(b) In cases requiring such assent counties, cities, towns, and public hospital districts
are limited to a total indebtedness of two and one-half percent of the value of the
taxable property therein.
While bonding capacity can limit the availability of G.O. bonds for utility purposes, these can
sometimes play a valuable role in project financing. A utility rate savings may be realized through two
avenues: the lower interest rate and related bond costs and the extension of repayment obligation to
all tax-paying properties (not just developed properties) through the authorization of an ad valorem
property tax levy.
Revenue Bonds – Revenue bonds are commonly used to fund utility capital improvements. The debt
is secured by the revenues of the issuing utility. With this limited commitment, revenue bonds
typically bear higher interest rates than G.O. bonds and require security conditions related to the
maintenance of dedicated reserves (a bond reserve) and financial performance (added bond debt
service coverage). The City agrees to satisfy these requirements by resolution as a condition of
bond sale.
Revenue bonds can be issued in Washington without a public vote. There is no bonding limit, except
perhaps the practical limit of the utility’s ability to generate sufficient revenue to repay the debt and
provide coverage. In some cases, poor credit might make issuing revenue bonds problematic.
9.4.3 Capital Financing Strategy
An ideal capital financing strategy would include the use of grants and low-cost loans when debt
issuance is required. However, these resources are very limited and competitive in nature and do not
provide a reliable source of funding for planning purposes. It is recommended that the City pursue
these funding avenues but assume revenue bond financing to meet the needs that can’t be met by
available cash resources. The capital financing strategy developed to fund the capital improvement
plan identified in this Plan assumes the following funding resources:
Accumulated cash reserves.
Transfers of excess cash (over minimum balance targets) from the operating fund.
System development charge revenues.
King County Opportunity Fund grant revenues.
Interest earned on capital fund balances.
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The majority, 83%, of projects are funded through cash resources. The remaining 17% are funded
through a combination of system development charges and grants. No new debt is anticipated in the
next 10-year or 20-year planning periods. Table 9-5 presents the 10-year and 20-year capital
financing strategy.
Table 9-5. 10-Year and 20-Year Capital Financing Strategy
9.5 Financial Forecast
The financial forecast, or revenue requirement analysis, forecasts the amount of annual revenue
that needs to be generated by storm drainage service rates. The analysis incorporates operating
revenues, M&O expenses, debt service payments, rate-funded capital needs, and any other
identified revenues or expenses related to operations. The objective of the financial forecast is to
evaluate the sufficiency of the current level of rates. In addition to annual operating costs, the
revenue needs also include debt covenant requirements and specific fiscal policies and financial
goals of the City.
For this analysis, two revenue sufficiency tests have been developed to reflect the financial goals
and constraints of the City—cash needs must be met, and debt coverage requirements must be
realized. In order to operate successfully with respect to these goals, both tests of revenue
sufficiency must be met.
Cash Test – The cash flow test identifies all known cash requirements for the City in each year of the
planning period. Typically, these include M&O expenses, debt service payments, rate-funded system
reinvestment funding or directly funded capital outlays, and any additions to specified reserve
balances. The total annual cash needs of the City are then compared to projected cash revenues
using the current rate structure. Any projected revenue shortfalls are identified, and the rate
increases necessary to make up the shortfalls are established.
2024 2,531,000$ 375,000$ -$ 2,156,000$ 2,531,000$
2025 3,603,167 362,335 - 3,240,832 3,603,167
2026 6,638,879 374,698 500,000 5,764,181 6,638,879
2027 1,400,876 387,482 - 1,013,394 1,400,876
2028 1,867,219 400,703 - 1,466,516 1,867,219
2029 1,454,889 414,375 - 1,040,514 1,454,889
2030 1,934,365 428,514 - 1,505,851 1,934,365
2031 1,662,789 443,135 - 1,219,655 1,662,789
2032 2,615,880 458,255 - 2,157,626 2,615,880
2033 2,745,243 473,890 - 2,271,353 2,745,243
Subtotal 26,454,307$ 4,118,387$ 500,000$ 21,835,920$ 26,454,307$
2034 - 2043 35,209,528 5,725,752 - 29,483,776 35,209,528
Total 61,663,835$ 9,844,139$ 500,000$ 51,319,696$ 61,663,835$
Year
Capital
Expenditures
Escalated
System
Development
Charge Revenue
Cash / Reserve
Funding
Total Financial
ResourcesGrant Funding
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Coverage Test – The coverage test is based on a commitment made by the City when issuing
revenue bonds and some other forms of long-term debt. For the purposes of this analysis, revenue
bond debt is assumed for any needed debt issuance. As a security condition of issuance, the City
would be required per covenant to agree that the revenue bond debt would have a higher priority for
payment (a senior lien) compared to most other expenditures; the only outlays with a higher lien are
M&O expenses. Debt service coverage is expressed as a multiplier of the annual revenue bond debt
service payment. For example, a 1.00 coverage factor would imply that no additional cushion is
required. A 1.25 coverage factor means revenue must be sufficient to pay M&O expenses, annual
revenue bond debt service payments, and an additional 25% of annual revenue bond debt service
payments. The excess cash flow derived from the added coverage, if any, can be used for any
purpose, including funding capital projects. Targeting a higher coverage factor can help the City
achieve a better credit rating and provide lower interest rates for future debt issues.
In determining the annual revenue requirement, both the cash and coverage sufficiency tests must be
met, and the test with the greatest deficiency drives the level of needed rate increase in any given year.
9.5.1 Current Financial Structure
The City maintains a fund structure and implements financial policies that target management of a
financially viable and fiscally responsible storm drainage system.
9.5.1.1 Fiscal Policies
A summary of the key financial policies employed by the City, as well as those recommended and
incorporated in the financial program, are discussed below.
Operating Fund – Operating reserves are designed to provide a liquidity cushion to ensure that
adequate cash working capital will be maintained to deal with significant cash balance fluctuations,
such as seasonal fluctuations in billings and receipts, unanticipated cash expenses, or lower than
expected revenue collections. Like other types of reserves, operating reserves also serve another
purpose: they help smooth rate increases over time. Target funding levels for an operating reserve
are generally expressed as a certain number of days of M&O expenses, with the minimum
requirement varying with the expected revenue volatility. Industry practice for utility operating
reserves ranges from 30 days (8%) to 120 days (33%) of M&O expenses, with the lower end more
appropriate for utilities with stable revenue streams and the higher end more appropriate for utilities
with significant seasonal or consumption-based fluctuations.
This financial plan targets a minimum balance in the Storm Drainage Utility operating fund equal to
60 days of M&O expenses.
Capital Fund – A utility capital contingency reserve is an amount of cash set aside in case of an
emergency should a piece of equipment or a portion of the utility’s infrastructure fail unexpectedly.
The reserve could also be used for other unanticipated capital needs, including capital project cost
overruns. Industry practices range from maintaining a balance equal to 1% to 2% of fixed assets, an
amount equal to a 5-year rolling average of capital improvement plan costs, or an amount
determined sufficient to fund equipment failure (other than catastrophic failure). The final target
level should balance industry standards with the risk level of the City.
This financial plan targets a minimum balance in the Storm Drainage Utility capital fund equal to 1%
of fixed assets.
Rate Stabilization Fund - A rate stabilization reserve is a restricted fund balance intended to be
available to offset specific variations in revenues or expenses. For rate modeling, planned deposits
into the fund would appear as an expense, and use of the reserve would rarely appear in rate
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planning (only when analyzing adverse conditions). The reserve is established with specific rules and
restrictions regarding contributions, withdrawals, and replenishment. These rules are generally
constructed to minimize or mitigate rate impacts.
The City currently maintains a rate stabilization reserve for the Storm Drainage Utility but does not
have a formal rate stabilization reserve policy. For modeling purposes, the study does not assume
additional reserves are funded. Rather, the City will maintain the reserve at its current level.
System Reinvestment – System reinvestment funding promotes system integrity through ongoing
repair and replacement of system infrastructure. Ideally, a detailed asset management plan would
guide the level of rate funded system reinvestment. However, in absence of this level of effort,
annual depreciation expense is commonly used as a measure of the decline in asset value
associated with routine use of the system. Particularly for utilities that do not already have an explicit
system reinvestment policy in place, implementing a funding level based on full depreciation
expense could significantly impact rates. An alternative benchmark is annual depreciation expense
net of debt principal payments on outstanding debt. This approach recognizes that customers are
still paying for certain assets through the debt component of their rate and intends to avoid
simultaneously charging customers for an asset and its future replacement. The specific benchmark
used to set system reinvestment funding targets is a matter of policy that must balance various
objectives, including managing rate impacts, keeping long-term costs down, and promoting
“generational equity” (i.e., not excessively burdening current customers with paying for facilities that
will serve a larger group of customers in the future).
The City is currently phasing in system reinvestment funding and is forecast to reach 67% of annual
depreciation levels by 2033. With this phase-in strategy in place, the City is forecast to fund an
average of $1.1 million in capital costs annually through rate revenues within the 10-year
forecast period.
Debt Management – It is prudent to consider policies related to debt management as part of a
broader utility financial policy structure. Debt management policies should be evaluated and
formalized, including the level of acceptable outstanding debt, debt repayment, bond coverage, and
total debt coverage targets. The City has two outstanding storm drainage revenue bonds, one of
which will be fully repaid in 2030, with the second fully repaid by 2032. This forecast meets or
exceeds the required revenue bond debt service coverage of 1.25.
9.5.2 Financial Forecast
The financial forecast is primarily based upon the City’s budget through 2024 and takes into
consideration other key factors and assumptions needed to develop a complete portrait of the City’s
annual Storm Drainage Utility financial obligations. The following is a list of the key revenue and
expense factors and assumptions used to develop the financial forecast.
Growth – Rate revenue is escalated utilizing a 0.4% growth rate developed based on actual
historical trends within the City.
Revenue – The City has two general revenue sources: (1) storm drainage service charges
(rate revenue) and (2) miscellaneous (non-rate) revenue. In the event of a forecasted annual
shortfall, rate revenue can be increased to meet the annual revenue requirement. For the
purpose of this financial forecast, rate revenues are forecasted to increase with customer
growth. Non-rate revenues are held constant throughout the forecast period, with the
exception of interest earnings, which are calculated based on projected balances, assumed
investment rates, and senior rebates, which increase with customer growth assumptions.
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System Development Charge Revenue – The existing system development charges are
applied to the projected new connections to forecast revenue. Connection charges are
forecasted to generate an average of $412,000 annually from 2024 through 2033. This
equates to an average of 204 new ESUs per year. Connection charge revenue is directed
towards annual capital needs.
Expenses – M&O expense projections are based on the City’s budget through 2024 with
general cost inflation increases of 3%, labor cost inflation of 5% for 2025 and 2026,
decreasing to 3% thereafter and benefit cost inflation increases of 12.5% for 2025 and
2026, decreasing to 5.5% per year thereafter. Budget figures were used for taxes through
2024. Future taxes are calculated based on forecasted revenues and prevailing tax rates.
Facilities GO Bond - In order to construct a new facility for M&O for the City, the Storm
Drainage Utility will fund part of a G.O. bond totaling approximately $38 million. Beginning in
2025, the Storm Drainage Utility’s proportionate share of the bond is forecasted at
$333,000 annually for the remainder of the 20-year forecast.
Existing Debt – The Storm Drainage Utility has two outstanding revenue bond debt issues.
The 2020 refunding bond has annual payments of $314,000 that end after 2030, with the
2013 revenue bond carrying payments of $343,000 annually, ending after 2032. The total
annual existing debt service obligations begin 2024 at $659,000 and are completely repaid
by 2033.
Future Debt – No new debt is anticipated in the 10-year and 20-year forecast periods.
Transfers to Capital – Operating fund balance above the minimum requirement is assumed
to be available to fund capital projects and projected to be transferred to the capital fund
each year, if needed. In total, the utility is forecast to fund $13 million in capital projects from
excess operating fund cash within the 10-year forecast period.
Although the financial plan is completed through 2043, the rate strategy focuses on the shorter-term
planning period of 2024 through 2033. It is recommended that the City revisit the proposed rates
every 2 to 3 years to ensure that the rate projections developed remain adequate. Any significant
changes should be incorporated into the financial plan and future rates should be adjusted as needed.
Table 9-6 summarizes the annual revenue requirements based on the forecast of revenues,
expenditures, fund balances, and fiscal policies.
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Table 9-6. 10-Year Financial Forecast
Revenue Requirement 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033
Revenues
Rate Revenues Under Existing Rates 12,458,782$ 12,508,618$ 12,558,652$ 12,608,887$ 12,659,322$ 12,709,959$ 12,760,799$ 12,811,843$ 12,863,090$ 12,914,542$
Non-Rate Revenues 262,900 291,876 206,130 181,367 181,869 182,399 182,953 183,531 184,135 184,766
Total Revenues 12,721,682$ 12,800,494$ 12,764,782$ 12,790,254$ 12,841,191$ 12,892,359$ 12,943,752$ 12,995,373$ 13,047,225$ 13,099,308$
Expenses
Cash Operating Expenses 10,828,608$ 11,812,282$ 12,353,297$ 12,714,570$ 13,093,018$ 13,485,879$ 13,893,762$ 14,317,305$ 14,757,174$ 15,214,068$
Existing Debt Service 659,447 659,311 657,169 657,253 658,401 656,328 655,274 342,972 342,888 -
New Debt Service - - - - - - - - - -
Rate Funded System Reinvestment 1,000,000 903,142 717,190 782,323 838,652 899,000 958,051 1,330,768 1,388,178 1,790,229
Total Expenses 12,488,055$ 13,374,736$ 13,727,656$ 14,154,146$ 14,590,070$ 15,041,207$ 15,507,087$ 15,991,045$ 16,488,240$ 17,004,297$
Total Surplus (Deficiency)233,628$ (574,242)$ (962,874)$ (1,363,891)$ (1,748,878)$ (2,148,849)$ (2,563,335)$ (2,995,672)$ (3,441,016)$ (3,904,990)$
Annual Rate Adjustment 6.75% 3.00% 3.00% 3.00% 3.00% 3.00% 3.00% 3.00% 3.00%
Cumulative Annual Rate Adjustment 6.75% 9.95% 13.25% 16.65% 20.15% 23.75% 27.47% 31.29% 35.23%
Rate Revenues After Rate Increase 12,458,782$ 13,352,949$ 13,808,552$ 14,279,700$ 14,766,923$ 15,270,770$ 15,791,809$ 16,330,626$ 16,887,827$ 17,464,039$
Additional Taxes from Rate Increase - 97,098 143,738 192,143 242,374 294,493 348,566 404,660 462,845 523,192
Net Cash Flow After Rate Increase 233,628$ 172,992$ 143,288$ 114,778$ 116,348$ 117,469$ 119,109$ 118,451$ 120,876$ 121,315$
Coverage After Rate Increases 4.84 5.87 5.21 4.90 4.99 5.11 5.22 10.15 10.36 n/a
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The financial forecast indicates that at existing rate levels the utility will become deficient in 2025 as
growth in expenses outpaces growth in revenues and the utility phases in rate funded system
reinvestment levels, reaching 67% of annual depreciation by 2033. The City has adopted a 6.75%
increase for 2025, in order to resolve the remaining projected deficiency, rates will need to increase
by 3% annually from 2026 through 2033.
9.5.2.1 City Funds and Reserves
Table 9-7 shows a summary of the projected operating fund and capital fund ending balances
through 2033 based on the rate forecasts presented above. The operating fund is maintained at a
minimum of 60 days of M&O expenses, and the capital fund balance continues to meet or exceed
the minimum target of 1% of fixed assets in every year of the forecast.
Table 9-7. Ending Cash Balance Summary
9.6 Current and Projected Rates
9.6.1 Current Rates
The existing storm drainage rate is a monthly flat rate that is charged to each customer per ESU.
Each single-family customer is considered one ESU. All non-single-family customers are charged
based on the total amount of impervious surface area on-site. The average single family residential
lot has 2,600 square feet of impervious surface area, so the total impervious surface area for a non-
residential lot is divided by 2,600 to calculate the number of ESUs for that site. Table 9-8 shows the
existing City of Auburn storm drainage rate schedule.
Table 9-8. Existing Schedule of Rates
Ending Fund Balances 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033
Operating Fund 1,804,768$ 1,968,714$ 2,058,883$ 2,119,095$ 2,182,170$ 2,247,646$ 2,315,627$ 2,386,218$ 2,459,529$ 2,535,678$
Capital Fund 20,694,062 18,986,240 14,372,092 14,339,309 13,908,111 13,957,671 13,600,577 13,895,557 13,312,629 13,009,799
Total 22,498,830$ 20,954,954$ 16,430,975$ 16,458,404$ 16,090,281$ 16,205,318$ 15,916,204$ 16,281,774$ 15,772,158$ 15,545,477$
Single Family 18.09$
Non-Single Family (NSF)18.09
NSF w/Detention 15.57
NSF w/Retention 13.04
NSF w/Water Quality 16.64
NSF w/Detention & Water Quality 14.12
NSF w/Retention & Water Quality 11.59
Description 2024
Existing
Per ESU Rate
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9.6.2 Projected Rates
The financial forecast discussed above indicates the need for annual rate adjustments in order to
satisfy all forecasted financial obligations. The City has adopted a 6.75% rate increase for 2025, with
annual 3% increases forecasted from 2026 through 2033. Table 9-9 shows the projected rates with
increases applied uniformly to all storm drainage classes.
Table 9-9. Proposed Storm Drainage Rates
9.6.3 Affordability
A common affordability metric used by the EPA to measure the relative financial impact storm
drainage rates have on a community as a whole considers whether rates exceed 2.5% of a
community’s median household income. The average median household income for the City was
$87,406 between 2018 and 2022 according to the U.S. Census Bureau. The 2022 value is
escalated based on the actual rate of inflation in 2023 of 4.31% and the 3% inflation rate used in
the financial forecast to project the median household income in future years. Table 9-10 presents
the City’s monthly storm drainage bill, projected to 2033 and tested against the 2.5% monthly
affordability threshold.
Table 9-10. Community Affordability Test
Applying the 2.50% test, the City’s rates are forecasted to remain within the indicated affordability
range through 2033.
2025 2026 2027 2028 2029 2030 2031 2032 2033
Single Family 18.09$ 19.31$ 19.89$ 20.49$ 21.10$ 21.73$ 22.38$ 23.05$ 23.74$ 24.45$
Non-Single Family (NSF)18.09 19.31 19.89 20.49 21.10 21.73 22.38 23.05 23.74 24.45
NSF w/Detention 15.57 16.62 17.12 17.63 18.16 18.70 19.26 19.84 20.44 21.05
NSF w/Retention 13.04 13.92 14.34 14.77 15.21 15.67 16.14 16.62 17.12 17.63
NSF w/Water Quality 16.64 17.76 18.29 18.84 19.41 19.99 20.59 21.21 21.85 22.51
NSF w/Detention & Water Quality 14.12 15.07 15.52 15.99 16.47 16.96 17.47 17.99 18.53 19.09
NSF w/Retention & Water Quality 11.59 12.37 12.74 13.12 13.51 13.92 14.34 14.77 15.21 15.67
Description Existing Proposed
Per ESU Rate
Year Inflation Median HH
Income
2.5% Monthly
Threshold
Projected
Monthly Bill
% of Median HH
Income
2022 87,406$
2023 4.31%91,173
2024 3.00%93,908 195.64$ 18.09$ 0.23%
2025 3.00%96,726 201.51 19.31 0.24%
2026 3.00%99,627 207.56 19.89 0.24%
2027 3.00%102,616 213.78 20.49 0.24%
2028 3.00%105,695 220.20 21.10 0.24%
2029 3.00%108,866 226.80 21.73 0.24%
2030 3.00%112,132 233.61 22.38 0.24%
2031 3.00%115,495 240.62 23.05 0.24%
2032 3.00%118,960 247.83 23.74 0.24%
2033 3.00%122,529 255.27 24.45 0.24%
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9.7 Conclusion
The results of this analysis indicate that at existing rate levels the utility will be deficient beginning
in 2025. To keep pace with expenses and continue to phase in rate-funded system reinvestment
towards depreciation levels, the City has adopted a 6.75% rate increase in 2025. Forecasting into
the future, a 3% annual rate increase will be required from 2026 through 2033. It is recommended
that the City regularly review and update the key underlying assumptions that compose the
multiyear financial plan to ensure that adequate revenues are collected to meet the City’s total
financial obligations.
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10. Limitations
This document was prepared solely for the City of Auburn in accordance with professional standards
at the time the services were performed and in accordance with the contract between City of Auburn
and Parametrix dated March 16, 2022. This document is governed by the specific scope of work
authorized by the City of Auburn; it is not intended to be relied upon by any other party except for
regulatory authorities contemplated by the scope of work. We have relied on information or
instructions provided by the City of Auburn and other parties and, unless otherwise expressly
indicated, have made no independent investigation as to the validity, completeness, or accuracy of
such information.
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11. References
Booth, D.B. 1991. Glacier Physics of the Puget Lobe, Southwest Cordilleran Ice Sheet. Geographie
Physique et Quaternaire 45:301–316.
Ecology (Washington State Department of Ecology). 2011. Green River Temperature Total Maximum
Daily Load: Water Quality Improvement Report. Publication No. 11-10-046. Northwest Regional
Office, Water Quality Program, Washington State Department of Ecology, Bellevue, WA. June.
Hegewisch, K.C., J.T. Abatzoglou, O. Chegwidden, and B. Nijssen. 2023. Climate Mapper web tool.
Climate Toolbox. https://climatetoolbox.org/. Accessed January 2023.
Lee, S.-Y., G.S. Mauger, and J.S. Won. 2018. Effect of Climate Change on Flooding in King County
Rivers Using New Regional Climate Model Simulations to Quantify Changes in Flood Risk. Report
prepared for King County. Climate Impacts Group, University of Washington, Seattle, WA.
King County DNR (Department of Natural Resources and Parks). 2021.King County Surface Water
Design Manual. King County, Seattle, WA. July.
Mauger, G., and J. Won. 2019. Expanding the Ensemble of Precipitation Projections for King County.
University of Washington Climate Impacts Group, Seattle, WA.
Miller, J.F., R.H. Frederick, and R.J. Tracey. 1973. Precipitation-Frequency Atlas of the Western
United States: NOAA Atlas 2, Volume IX–Washington. United States Department of Commerce,
National Oceanic and Atmospheric Administration, National Weather Service. Silver Spring, MD.
Morgan, H., G.S. Mauger, and J.S. Won. 2021. Climate Change and Stormwater in Portland,
Gresham, and Clackamas County. Report prepared for the City of Portland, City of Gresham, and
Clackamas County by the Climate Impacts Group, University of Washington, Seattle, WA.
PSRC (Puget Sound Regional Council). 2020. Vision 2050: A Plan for the Central Puget Sound
Region. https://www.psrc.org/planning-2050/vision-2050.
Natural Resources Conservation Center (NRCS). June 1986. Urban Hydrology for Small Watershed,
Technical Release 55 (TR-55). United States Department of Agriculture, Natural Resources
Conservation Service, Conservation Engineering Division.
Pierce County. 2023. Pierce County Rivers Flood Hazard Management Plan, Adopted
February 19, 2013, Ordinance 2012-53s. Pierce County Public Works & Utilities Surface Water
Management.
Snover, A.K, G.S. Mauger, L.C. Whitely Binder, M. Krosby, and I. Tohver. 2013. Climate Change
Impacts and Adaptation in Washington State: Technical Summaries for Decision Makers. State of
Knowledge Report prepared for the Washington State Department of Ecology by the Climate
Impacts Group, University of Washington, Seattle, WA.
Troost, K.G., and D.B. Booth, D.B, 2008. Geology of Seattle and the Seattle Area, Washington. The
Geological Society of America, Reviews in Engineering Geology XX, 2008.
U.S. Army Corps of Engineers (USACE). October 2009a. Mud Mountain Dam: White and Puyallup
Rivers Channel Capacity Study. U.S. Army Corps of Engineers, Seattle District, Hydraulic
Engineering Section, Seattle, WA.
Page 170 of 373
Draft Comprehensive Storm Drainage Plan Update
City of Auburn
June 2024 │ 553-1931-052 11-2
USACE. 2009b. Project Management Plan for Wetland 5K Reach Mill Creek Restoration, Green
Duwamish Ecosystem Restoration Program. U.S. Army Corps of Engineers, Seattle District,
Seattle, WA.
WRCC (Western Regional Climate Center). 2014a. “Climate of Washington.”
http://www.wrcc.dri.edu/narratives/WASHINGTON.htm.
WRCC. 2014b. “Period of Record Monthly Climate Summary for Seattle Tcoma Wscmo Ap,
Washington.” http://www.wrcc.dri.edu/cgi-bin/cliMAIN.pl?waseat.
WRCC. 2014c. Period of Record Monthly Climate Summary for Kent, Washington.”
http://www.wrcc.dri.edu/cgi-bin/cliMAIN.pl?wakent.
Page 171 of 373
Draft Comprehensive Storm Drainage Plan Update
City of Auburn
June 2024 │ 553-1931-052 11-3
Appendix A
DRAFT Western Washington
Phase II NPDES MS4 Permit
Page 172 of 373
Issuance Date: July 1, 2024
Effective Date: August 1, 2024
Expiration Date: July 31, 2029
DRAFT WESTERN WASHINGTON PHASE II
MUNICIPAL
STORMWATER PERMIT
National Pollutant Discharge Elimination System and
State Waste Discharge General Permit for discharges from
Small Municipal Separate Storm Sewer Systems
In Western Washington
State of Washington
Department of Ecology
Olympia, WA 98504-7600
In compliance with the provisions of
The State of Washington Water Pollution Control Law
Chapter 90.48 Revised Code of Washington
and
The Federal Water Pollution Control Act
(The Clean Water Act)
Title 33 United States Code, Section 1251 et seq.
Until this Permit expires, is modified, or revoked, Permittees that have properly obtained
coverage under this Permit are authorized to discharge to waters of the State in
accordance with the special and general conditions which follow.
_____________________________________
Vincent McGowan, PE
Water Quality Program Manager
Department of Ecology
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TABLE OF CONTENTS
TABLE OF CONTENTS....................................................................................................................... 3
LIST OF APPENDICES ....................................................................................................................... 5
ADA ACCESSIBILITY.......................................................................................................................... 6
SPECIAL CONDITIONS ...................................................................................................................... 7
S1. PERMIT COVERAGE AREA AND PERMITTEES .................................................................. 7
A. Geographic Area of Permit Coverage ........................................................................... 7
B. Regulated Small Municipal Separate Storm Sewer Systems (MS4s) ............................ 7
C. Permit Waivers ............................................................................................................. 9
D. Obtaining Coverage Under this Permit ...................................................................... 10
S2. AUTHORIZED DISCHARGES ........................................................................................... 14
A. Stormwater Discharges .............................................................................................. 14
B. Non-Stormwater Discharges ...................................................................................... 14
C. Responsibilities and Liabilities .................................................................................... 15
D. Compliance with State and Local Authorizations ....................................................... 15
E. Indian Country ............................................................................................................ 15
S3. RESPONSIBILITIES OF PERMITTEES ............................................................................... 16
A. Compliance with Conditions ...................................................................................... 16
B. Reliance on Another Entity ........................................................................................ 16
S4. COMPLIANCE WITH STANDARDS .................................................................................. 17
A. Prohibition of Discharge of Toxicants......................................................................... 17
B. Compliance with Standards ....................................................................................... 17
C. MEP Standard ............................................................................................................. 17
D. AKART Standard ......................................................................................................... 17
E. Responsibilities of Permittees .................................................................................... 17
F. Violations of Water Quality Standards and Adaptive Management .......................... 17
G. Revoke and Reissue Permit ........................................................................................ 20
S5. STORMWATER MANAGEMENT PROGRAM FOR CITIES, TOWNS, AND COUNTIES ........... 21
A. Stormwater Management Program General Requirements ...................................... 21
B. Stormwater Management Program Standards .......................................................... 23
C. Stormwater Management Program Components...................................................... 23
Stormwater Planning............................................................................................ 23
Public Education and Outreach ............................................................................ 26
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Page 175 of 373
Public Involvement and Participation .................................................................. 29
MS4 Mapping and Documentation ...................................................................... 30
Illicit Discharge Detection and Elimination ........................................................... 31
Controlling Runoff from New Development, Redevelopment, and Construction
Sites ...................................................................................................................... 36
Stormwater Management for Existing Development .......................................... 41
Source Control Program for Existing Development ............................................. 43
Operations and Maintenance .............................................................................. 46
S6. STORMWATER MANAGEMENT PROGRAM FOR SECONDARY PERMITTEES..................... 54
A. Secondary Permittees and New Secondary Permittees Coverage ............................. 54
B. Coordination .............................................................................................................. 55
C. Legal Authority ........................................................................................................... 55
D. Stormwater Management Program for Secondary Permittees ................................. 55
Public Education and Outreach ............................................................................ 55
Public Involvement and Participation .................................................................. 56
Illicit Discharge Detection and Elimination ........................................................... 56
Construction Site Stormwater Runoff Control ..................................................... 59
Post-Construction Stormwater Management for New Development and
Redevelopment .................................................................................................... 60
Pollution Prevention and Good Housekeeping for Municipal Operations ........... 60
S7. COMPLIANCE WITH TOTAL MAXIMUM DAILY LOAD REQUIREMENTS ............................ 64
A. TMDL Specific Requirements ..................................................................................... 64
S8. MONITORING AND ASSESSMENT ................................................................................. 64
A. Regional Status and Trends Monitoring ..................................................................... 64
B. Stormwater Management Program (SWMP) Effectiveness and Source Identification
Studies ........................................................................................................................ 65
C. Stormwater discharge monitoring. ............................................................................ 66
D. Payments into the Stormwater Action Monitoring Collective Fund. ......................... 67
S9. REPORTING & RECORDKEEPING REQUIREMENTS ......................................................... 68
A. Annual Report Submittal ............................................................................................ 68
B. Records Retention ...................................................................................................... 68
C. Records Available to the Public .................................................................................. 68
D. Annual Report for Cities, Towns, and Counties .......................................................... 68
E. Annual Report for Secondary Permittees................................................................... 69
GENERAL CONDITIONS .................................................................................................................. 70
A. Representative Sampling ........................................................................................... 72
B. Records Retention ...................................................................................................... 72
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C. Recording of Results ................................................................................................... 72
D. Test Procedures ......................................................................................................... 72
E. Flow Measurement .................................................................................................... 73
F. Lab Accreditation ....................................................................................................... 73
G. Additional Monitoring ................................................................................................ 73
DEFINITIONS AND ACRONYMS ..................................................................................................... 79
LIST OF APPENDICES
Stormwater Action Monitoring Collective
Funds
IDDE Reporting Data and Format
DRAFT
Page 177 of 373
ADA Accessibility
The Department of Ecology is committed to providing people with disabilities access to
information and services by meeting or exceeding the requirements of the Americans with
Disabilities Act (ADA), Section 504 and 508 of the Rehabilitation Act, and Washington State
Policy #188.
To request ADA Accommodation, contact Water Quality Reception at 360-407-6600. For
Washington Relay Service or TTY call 711 or 877-833-6341. Visit Ecology’s accessibility
webpage 1 for more information.
For document translation services, call Water Quality Reception at 360-407-6600.
Por publicaciones en espanol, por favor llame Water Quality Reception al 360-407-6600.
1 https://ecology.wa.gov/About-us/Accessibility-equity/Accessibility/
DRAFT
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S1.A Geographic Area of Permit Coverage
Western Washington Phase II Municipal Page 7 of 88
Stormwater Permit – August 1, 2024
SPECIAL CONDITIONS
S1. PERMIT COVERAGE AREA AND PERMITTEES
A. Geographic Area of Permit Coverage
This Permit is applicable to owners or operators of regulated small Municipal
Separate Storm Sewer Systems (MS4s) located west of the eastern boundaries of the
following counties: Whatcom, Skagit, Snohomish, King, Pierce, Lewis, and Skamania.
1. For all cities required to obtain coverage under this Permit, the geographic area
of coverage is the entire incorporated area of the city.
2. For all counties required to have coverage under this Permit, the geographic area
of coverage is the urban areas and urban growth areas associated with
permitted cities under the jurisdictional control of the county. The geographic
area of coverage also includes any urban growth area contiguous to permitted
urban areas under the jurisdictional control of the county.
3. For Whatcom County, the geographic area of coverage also includes the
unincorporated Birch Bay urban growth area.
For Thurston County, the geographic area of coverage also includes the
unincorporated Yelm urban growth area.
4. For Secondary Permittees required to obtain coverage under this Permit, the
minimum geographic area of coverage is all areas identified under S1.A.1 and
S1.A.2. At the time of permit coverage, the Washington State Department of
Ecology (Ecology) may establish a geographic area of coverage specific to an
individual Secondary Permittee.
5. All regulated small MS4s owned or operated by the Permittees named in
S1.D.2.a(i), and (ii), and S1.D.2.b and located in another city or county area
requiring coverage under this Permit, or the Phase I Municipal Stormwater
Permit or the Eastern Washington Phase II Municipal Stormwater Permit, are
also covered under this Permit.
B. Regulated Small Municipal Separate Storm Sewer Systems (MS4s)
All operators of regulated small MS4s are required to apply for and obtain coverage
under this Permit or be permitted under a separate individual permit, unless waived
or exempted in accordance with condition S1.C.
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S1.B Regulated Small Municipal Separate Storm Sewer Systems (MS4s)
Western Washington Phase II Municipal Page 8 of 88
Stormwater Permit – August 1, 2024
1. A regulated small MS4:
2. All other operators of MS4s, including special purpose districts, which meet the
criteria for a regulated small MS4 shall obtain coverage under this Permit. Other
operators of small MS4s may include, but are not limited to: flood control, or
diking and drainage districts; schools, including universities; and correctional
facilities that own or operate a small MS4 serving non-agricultural land uses.
3. Any other operators of small MS4s may be required by Ecology to obtain
coverage under this Permit or an alternative NPDES permit if Ecology determines
the small MS4 is a significant source of pollution to surface waters of the State.
Notification of Ecology’s determination that permit coverage is required will be
through the issuance of an Administrative Order issued in accordance with
Chapter 90.48 RCW.
4. The owner or operator of a regulated small MS4 may obtain coverage under this
Permit as a Permittee, Co-Permittee, or Secondary Permittee as defined in
S1.D.1, below.
5. Pursuant to 40 CFR 122.26(f), any person or organization may petition Ecology to
require that additional small MS4s obtain coverage under this Permit. The
process for petitioning Ecology is:
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S1.C Permit Waivers
Western Washington Phase II Municipal Page 9 of 88
Stormwater Permit – August 1, 2024
i. The geographic area of permit coverage for the MS4;
ii. Any modified dates or deadlines for developing and implementing this
Permit, as appropriate to the MS4, and for submitting their first annual
report; and
iii. A deadline for the operator of the MS4 to submit a complete Notice of
Intent (NOI, provided on Ecology’s website) to Ecology.
C. Permit Waivers
Owners and operators of an otherwise regulated small MS4 are not required to
obtain coverage under this Permit if:
1. The small MS4 is operated by:
Or
2. The portions of the small MS4 located within the census defined urban area(s)
serve a total population of less than 1000 people and a, b, and c, below all apply:
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Page 181 of 373
S1.D Obtaining Coverage Under this Permit
Western Washington Phase II Municipal Page 10 of 88
Stormwater Permit – August 1, 2024
In determining the total population served, both resident and commuter
populations shall be included. For example:
• For publicly operated school complexes including universities and colleges,
the total population served would include the sum of the average annual
student enrollment plus staff.
• For flood control, diking, and drainage districts, the total population
served would include residential population and any non-residents
regularly employed in the areas served by the small MS4.
D. Obtaining Coverage Under this Permit
All operators of regulated small MS4s are required to apply for and obtain coverage
in accordance with this Section, unless waived or exempted, in accordance with
S1.C.
1. Unless otherwise noted, the term “Permittee” shall include a city, town, or
county Permittee, New Permittee, Co-Permittee, Secondary Permittee, and New
Secondary Permittee as defined below:
2. Operators of regulated small MS4s have submitted, or shall submit, to Ecology
either a Notice of Intent (NOI) for Coverage under National Pollutant Discharge
Elimination System (NPDES) Municipal Stormwater General Permit or a Duty to
Reapply - NOI provided on Ecology’s website.
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S1.D Obtaining Coverage Under this Permit
Western Washington Phase II Municipal Page 11 of 88
Stormwater Permit – August 1, 2024
i. Cities and towns: Aberdeen, Algona, Anacortes, Arlington, Auburn,
Bainbridge Island, Battle Ground, Bellevue, Bellingham, Black Diamond,
Bonney Lake, Bothell, Bremerton, Brier, Buckley, Burien, Burlington,
Camas, Centralia, Clyde Hill, Covington, Des Moines, DuPont, Duvall,
Edgewood, Edmonds, Enumclaw, Everett, Federal Way, Ferndale, Fife,
Fircrest, Gig Harbor, Granite Falls, Issaquah, Kelso, Kenmore, Kent,
Kirkland, Lacey, Lake Forest Park, Lake Stevens, Lakewood, Longview,
Lynden, Lynnwood, Maple Valley, Marysville, Medina, Mercer Island, Mill
Creek, Milton, Monroe, Mountlake Terrace, Mount Vernon, Mukilteo,
Newcastle, Normandy Park, Oak Harbor, Olympia, Orting, Pacific, Port
Orchard, Port Angeles, Poulsbo, Puyallup, Redmond, Renton,
Sammamish, SeaTac, Sedro-Woolley, Shelton, Shoreline, Snohomish,
Snoqualmie, Steilacoom, Sumner, Tukwila, Tumwater, University Place,
Vancouver, Washougal, and Woodinville.
ii. Counties: Cowlitz, Kitsap, Thurston, Skagit, and Whatcom.
iii. Secondary Permittees: Bainbridge Island School District #303, Bellingham
School District, Bellingham Technical College, Cascadia College, Central
Kitsap School District, Centralia College, Clark College, Consolidated
Diking Improvement District #1 of Cowlitz County, Edmonds Community
College, Evergreen College, Highline Community College, Kelso School
District, Kent School District, Longview School District, Lower Columbia
College, Port of Anacortes, Port of Bellingham, Port of Everett, Port of
Olympia, Port of Skagit County, Port of Vancouver, Skagit County
Drainage District #19, Skagit Valley College, University of Washington
Bothell, Washington State University Vancouver, Washington State
Department of Enterprise Services (Capitol Campus), Washington
Department of Corrections (Larch Corrections Center, Monroe
Correctional Complex, Washington Corrections Center for Women, and
Washington State Penitentiary), Western Washington University, and
Whatcom Community College.
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Page 183 of 373
S1.D Obtaining Coverage Under this Permit
Western Washington Phase II Municipal Page 12 of 88
Stormwater Permit – August 1, 2024
i. Operators of regulated small MS4s located in the Cities of Ridgefield and
Yelm, and Sound Transit a shall submit a NOI or application to Ecology no
later than 30 days after the effective date of this Permit.
ii. Operators of regulated small MS4s listed in S1.D.2.a do not need to
submit a new application to be covered under this Permit.
3. Application Requirements
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S1.D Obtaining Coverage Under this Permit
Western Washington Phase II Municipal Page 13 of 88
Stormwater Permit – August 1, 2024
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S2.A Stormwater Discharges
Western Washington Phase II Municipal Page 14 of 88
Stormwater Permit – August 1, 2024
S2. AUTHORIZED DISCHARGES
A. Stormwater Discharges
This Permit authorizes the discharge of stormwater to surface waters and to
groundwaters of the State from MS4s owned or operated by each Permittee
covered under this Permit, in the geographic area covered pursuant to S1.A. These
discharges are subject to the following limitations:
1. Discharges to groundwaters of the State through facilities regulated under the
Underground Injection Control (UIC) program, Chapter 173-218 WAC, are not
authorized under this Permit.
2. Discharges to groundwaters not subject to regulation under the federal Clean
Water Act are authorized in this Permit only under state authorities, Chapter
90.48 RCW, the Water Pollution Control Act.
B. Non-Stormwater Discharges
This Permit authorizes discharges of non-stormwater flows to surface waters and to
groundwaters of the State from MS4s owned or operated by each Permittee
covered under this Permit, in the geographic area covered pursuant to S1.A, only
under one or more of the following conditions:
1. The discharge is authorized by a separate NPDES or State Waste Discharge
permit.
2. The discharge is from emergency firefighting activities and does not involve
PFAS-containing aqueous film-forming foams (AFFFs). After the emergency has
ceased, non-stormwater discharges (e.g., discharges associated with cleanup) to
the MS4 are prohibited. Determination of cessation of the emergency is at the
discretion of the emergency on-scene coordinator.
3. The discharge is from emergency firefighting activities and involves PFAS-
containing AFFFs, the following conditions apply:
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S2.C Responsibilities and Liabilities
Western Washington Phase II Municipal Page 15 of 88
Stormwater Permit – August 1, 2024
4. The discharge is from another illicit or non-stormwater discharge that is
managed by the Permittee as provided in S5.C.5 or S6.D.3.
These discharges are also subject to the limitations in S2.A.1 and S2.A.2, above.
C. Responsibilities and Liabilities
This Permit does not relieve entities that cause illicit discharges, including spills of oil
or hazardous substances, from responsibilities and liabilities under state and federal
laws and regulations pertaining to those discharges.
D. Compliance with State and Local Authorizations
Discharges from MS4s constructed after the effective date of this Permit shall
receive all applicable state and local permits and use authorizations, including
compliance with Chapter 43.21C RCW (the State Environmental Policy Act).
E. Indian Country
This Permit does not authorize discharges of stormwater to waters within Indian
Country as defined in 18 U.S.C. §1151, or to waters subject to water quality
standards of Indian Tribes, including portions of the Puyallup River and other waters
on trust or restricted lands within the 1873 Survey Area of the Puyallup Tribe of
Indians Reservation, except where authority has been specifically delegated to
Ecology by the U.S. Environmental Protection Agency. The exclusion of such
discharges from this Permit does not waive any rights the State may have with
respect to the regulation of the discharges. Indian Country includes:
1. All land within any Indian Reservation notwithstanding the issuance of any
patent, and including rights-of-way running through the reservation. This
includes all federal, tribal, and Indian and non-Indian privately owned land within
the reservation.
2. All off-reservation Indian allotments, the Indian titles to which have not been
extinguished, including rights-of-way running through the same.
3. All off-reservation federal trust lands held for Native American Tribes. Puyallup
Exception: Following the “Puyallup Tribes of Indians Land Settlement Act of
1989,” 25 USC §1773; the permit does apply to land within the Puyallup
Reservation except for discharges to surface water on land held in trust by the
federal government.
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S3.A Compliance with Conditions
Western Washington Phase II Municipal Page 16 of 88
Stormwater Permit – August 1, 2024
S3. RESPONSIBILITIES OF PERMITTEES
A. Compliance with Conditions
Each Permittee covered under this Permit is responsible for compliance with the
terms of this Permit for the regulated small MS4s that they own or operate.
Compliance with (1) or (2) below is required as applicable to each Permittee,
whether the Permittee has applied for coverage as a Permittee, Co-Permittee, or
Secondary Permittee.
1. All city, town, and county Permittees are required to comply with all conditions
of this Permit, including any appendices referenced therein, except for S6 –
Stormwater Management Program for Secondary Permittees.
2. All Secondary Permittees are required to comply with all conditions of this
Permit, including any appendices referenced therein, except for S5 – Stormwater
Management Program for Cities, Towns, and Counties and S8 – Monitoring and
Assessment.
B. Reliance on Another Entity
Permittees may rely on another entity to satisfy one or more of the requirements of
this Permit. Permittees that are relying on another entity to satisfy one or more of
their permit obligations remain responsible for permit compliance if the other entity
fails to implement permit conditions. Permittees may rely on another entity
provided all the requirements of 40 CFR 122.35(a) are satisfied including, but not
limited to:
1. The other entity, in fact, implements the Permit requirements.
2. The other entity agrees to take on responsibility for implementation of the
Permit requirement(s) on the Permittee’s behalf. This shall be indicated on the
NOI or Annual Report.
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S4.A Prohibition of Discharge of Toxicants
Western Washington Phase II Municipal Page 17 of 88
Stormwater Permit – August 1, 2024
S4. COMPLIANCE WITH STANDARDS
A. Prohibition of Discharge of Toxicants
In accordance with Chapter 90.48.520 RCW, the discharge of toxicants to waters of
the State of Washington which would violate any water quality standard, including
toxicant standards, sediment criteria, and dilution zone criteria is prohibited. The
required response to such discharges is defined in S4.F, below.
B. Compliance with Standards
This Permit does not authorize a discharge which would be a violation of
Washington State Surface Water Quality Standards (Chapter 173-201A WAC),
Groundwater Quality Standards (Chapter 173-200 WAC), Sediment Management
Standards (Chapter 173-204 WAC), or human health-based criteria in the National
Toxics Rule (40 CFR 131.45). The required response to such discharges is defined in
S4.F, below.
C. MEP Standard
The Permittee shall reduce the discharge of pollutants to the Maximum Extent
Practicable (MEP).
D. AKART Standard
The Permittee shall use All Known, Available, and Reasonable methods of
prevention, control, and Treatment (AKART) to prevent and control pollution of
waters of the State of Washington.
E. Responsibilities of Permittees
In order to meet the goals of the Clean Water Act, and comply with S4.A, S4.B, S4.C,
and S4.D, each Permittee shall comply with all of the applicable requirements of this
Permit as identified in S3 – Responsibilities of Permittees.
F. Violations of Water Quality Standards and Adaptive Management
A Permittee remains in compliance with S4 despite any discharges prohibited by
S4.A or S4.B, when the Permittee undertakes the following response toward long-
term water quality improvement:
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S4.F Violations of Water Quality Standards and Adaptive Management
Western Washington Phase II Municipal Page 18 of 88
Stormwater Permit – August 1, 2024
1. A Permittee shall notify Ecology in writing within 30 days of becoming aware,
based on credible site-specific information that a discharge from the MS4 owned
or operated by the Permittee is causing or contributing to a known or likely
violation of Water Quality Standards in the receiving water. Written notification
provided under this subsection shall, at a minimum, identify the source of the
site-specific information, describe the nature and extent of the known or likely
violation in the receiving water, and explain the reasons why the MS4 discharge
is believed to be causing or contributing to the problem. For ongoing or
continuing violations, a single written notification to Ecology will fulfill this
requirement.
2. In the event that Ecology determines, based on a notification provided under
S4.F.1 or through any other means, that a discharge from an MS4 owned or
operated by the Permittee is causing or contributing to a violation of Water
Quality Standards in a receiving water, Ecology will notify the Permittee in
writing that an adaptive management response, outlined in S4.F.3, below, is
required, unless:
3. Adaptive Management Response
i. A description of the operational and/or structural BMPs that are
currently being implemented to prevent or reduce any pollutants that are
causing or contributing to the violation of Water Quality Standards,
including a qualitative assessment of the effectiveness of each Best
Management Practice (BMP).
ii. A description of potential additional operational and/or structural BMPs
that will or may be implemented in order to apply AKART on a site-
specific basis to prevent or reduce any pollutants that are causing or
contributing to the violation of Water Quality Standards.
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S4.F Violations of Water Quality Standards and Adaptive Management
Western Washington Phase II Municipal Page 19 of 88
Stormwater Permit – August 1, 2024
iii. A description of the potential monitoring or other assessment and
evaluation efforts that will or may be implemented to monitor, assess, or
evaluate the effectiveness of the additional BMPs.
iv. A schedule for implementing the additional BMPs including, as
appropriate: funding, training, purchasing, construction, monitoring, and
other assessment and evaluation components of implementation.
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S4.G Revoke and Reissue Permit
Western Washington Phase II Municipal Page 20 of 88
Stormwater Permit – August 1, 2024
G. Revoke and Reissue Permit
Ecology may modify or revoke and reissue this General Permit in accordance with
G14 – General Permit Modification and Revocation, if Ecology becomes aware of
additional control measures, management practices, or other actions beyond what is
required in this Permit that are necessary to:
1. Reduce the discharge of pollutants to the MEP;
2. Comply with the state AKART requirements; or
3. Control the discharge of toxicants to waters of the State of Washington.
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S5.A.1 Stormwater Management Program General Requirements
Western Washington Phase II Municipal Page 21 of 88
Stormwater Permit – August 1, 2024
S5. STORMWATER MANAGEMENT PROGRAM FOR CITIES, TOWNS, AND
COUNTIES
A. Stormwater Management Program General Requirements
Each Permittee shall develop and implement a Stormwater Management Program
(SWMP). A SWMP is a set of actions and activities comprising the components listed
in S5 and any additional actions necessary to meet the requirements of applicable
TMDLs pursuant to S7 – Compliance with Total Maximum Daily Load Requirements
and S8 – Monitoring and Assessment. This Section applies to all cities, towns, and
counties covered under this Permit (termed as “Permittee,” including cities, towns,
and counties that are Co-Permittees).
New Permittees subject to this Permit, as described in S1.D.1.b, shall fully meet the
requirements in S5 as modified in footnotes below or as specified in an alternate
schedule as a condition of coverage by Ecology. Permittees obtaining coverage after
the issuance date of this Permit shall fully meet the requirements in S5 as specified
in an alternate schedule as a condition of coverage by Ecology.
1. At a minimum, the Permittee’s SWMP shall be implemented throughout the
geographic area subject to this Permit as described in S1.A.2
2. Each Permittee shall prepare written documentation of the SWMP, called the
SWMP Plan. The SWMP Plan shall be organized according to the program
components in S5.C or a format approved by Ecology and shall be updated at
least annually for submittal with the Permittee’s annual reports to Ecology (see
S9 – Reporting Requirements). The SWMP Plan shall be written to inform the
public of the planned SWMP activities for the upcoming calendar year, and shall
include a description of:
3. The SWMP shall include an ongoing program for gathering, tracking, maintaining,
and using information to evaluate SWMP development, implementation, permit
compliance and to set priorities.
2 New Permittees shall fully develop and implement the SWMP in accordance with the schedules contained in this
Section no later than March 31, 2029.
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4. Permittees shall continue implementation of existing stormwater management
programs until they begin implementation of the updated stormwater
management program in accordance with the terms of this Permit, including
implementation schedules.
5. Coordination among Permittees
i. Coordination mechanisms clarifying roles and responsibilities for the
control of pollutants between physically interconnected MS4s covered by
a municipal stormwater permit; and
ii. Coordinating stormwater management activities for shared water bodies,
or watersheds among Permittees to avoid conflicting plans, policies, and
regulations.
3 New Permittees shall begin cost tracking as required in S5.A.3.a, no later than January 1, 2026.
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B. Stormwater Management Program Standards
The SWMP shall be designed to reduce the discharge of pollutants from regulated
small MS4s to the MEP, meet state AKART requirements, and protect water quality.
C. Stormwater Management Program Components
The SWMP shall include the components listed below. To the extent allowable under
state or federal law, all components are mandatory for city, town, or county
Permittees covered under this Permit.
Stormwater Planning
Each Permittee shall implement a Stormwater Planning program to inform and
assist in the development of policies and strategies as water quality
management tools to protect receiving waters.
The minimum performance measures are:
i. Each Permittee shall describe how stormwater management needs and
protection/improvement of receiving water health are (or are not)
informing the long-range or comprehensive planning update processes
and influencing policies and implementation strategies in their
jurisdiction in the Annual Report due March 31, 2027. The report shall
describe the water quality and watershed protection policies, strategies,
codes, and other measures intended to protect and improve local
receiving water health through planning, considering stormwater
management needs or limitations.
i. Permittees shall continue to require LID Principles and LID BMPs when
updating, revising, and developing new local development-related codes,
rules, standards, or other enforceable documents, as needed.
The intent shall be to make LID the preferred and commonly used
approach to site development. The local development-related codes,
rules, standards, or other enforceable documents shall be designed to
4 New Permittees shall convene an interdisciplinary team no later than August 1, 2025.
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minimize impervious surfaces, native vegetation loss, and stormwater
runoff in all types of development situations, where feasible.
(a) Annually, each Permittee shall assess and document any newly
identified administrative or regulatory barriers to implementation of
LID Principles or LID BMPs since local codes were updated in
accordance with the 2013 Permit, and the measures developed to
address the barriers. If applicable, the report shall describe
mechanisms adopted to encourage or require implementation of LID
principles or LID BMPs.
ii. By December 31, 2028, New Permittees shall review, revise, and make
effective their local development-related codes, rules, standards, or
other enforceable documents to incorporate and require LID principles
and LID BMPs. New Permittees shall conduct a similar review and revision
process, and consider the range of issues, outlined in the following
document: Integrating LID into Local Codes: A Guidebook for Local
Governments (Puget Sound Partnership, 2012).
New Permittees shall submit a summary of the results of the review and
revision process with the annual report due no later than March 31,
2029. This summary shall be in the required format described in
Appendix 5 and include, at a minimum, a list of the participants (job title,
brief job description, and department represented), the codes, rules,
standards, and other enforceable documents reviewed, and the revisions
made to those documents which incorporate and require LID principles
and LID BMPs. The summary shall include existing requirements for LID
principles and LID BMPs in development-related codes. The summary
shall be organized as follows:
(a) Measures to minimize impervious surfaces;
(b) Measures to minimize loss of native vegetation; and
(c) Other measures to minimize stormwater runoff.
iii. No later than December 31, 2028, Permittees shall adopt and implement
tree canopy goals and policies to support stormwater management and
water quality improvement in receiving waters.
5 New Permittees are exempt from S5.C.1.d. for this permit term.
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i. Stormwater Management Action Plan (SMAP). No later than December
31, 2026, Permittees shall complete a SMAP for at least one new high
priority catchment area, or additional actions for an existing SMAP, that
identifies all of the following:
(a) A description of the stormwater facility retrofits needed for the area,
including the BMP types and preferred locations. Include projects that
address transportation-related runoff, such as projects that address
tire wear runoff.
(b) Land management/development strategies and/or actions identified
for water quality management.
(c) Targeted, enhanced, or customized implementation of stormwater
management actions related to permit sections within S5, including:
• IDDE field screening;
• Prioritization of Source Control inspections;
• O&M inspections or enhanced maintenance; or
• Public Education and Outreach behavior change programs.
Identified actions shall support other specifically identified
stormwater management strategies and actions for the basin overall,
or for the catchment area in particular.
(d) If applicable, identification of changes needed to local long-range
plans to address SMAP priorities.
(e) A proposed implementation schedule and budget sources for:
• Short-term actions (i.e., actions to be accomplished within six
years); and
• Long-term actions (i.e., actions to be accomplished within seven
to 20 years).
(f) A process and schedule to provide future assessment and feedback to
improve the planning process and implementation of procedures or
projects.
6 City of Shelton shall follow the SMAP requirements outlined in Appendix 14.
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Public Education and Outreach
The SWMP shall include an education and outreach program designed to:
• Build general awareness about methods to address and reduce impacts
from stormwater runoff;
• Effect behavior change to reduce or eliminate behaviors and practices that
cause or contribute to adverse stormwater impacts; and
• Create stewardship opportunities that encourages community engagement
in addressing the impacts from stormwater runoff.
Permittees may choose to meet these requirements individually or as a member
of a regional group. Regional collaboration on general awareness or behavior
change programs, or both, includes Permittees developing a consistent message,
determining best methods for communicating the message, and when
appropriate, creating strategies to effect behavior change. If a Permittee chooses
to adopt one or more elements of a regional program, the Permittee should
participate in the regional group and shall implement the adopted element(s) of
the regional program in the local jurisdiction.
The minimum performance measures are:
i. General awareness. To build general awareness, Permittees shall
annually select, at a minimum, one priority audience and one subject
area from either (a) or (b):
(a) Priority audiences: General public (including overburdened
communities, school age children, college/university, or trade
students) or businesses (including home-based, or mobile
businesses). Subject areas:
• General impacts of stormwater on surface waters, including
impacts from impervious surfaces; or
• Low impact development (LID) principles and LID BMPs.
7 New Permittees shall begin implementing the requirements of S5.C.2.a no later than August 1, 2027.
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(b) Priority audiences: Engineers, contractors, developers, property
owners/managers, or land use planners. Subject areas:
• Technical standards for stormwater site and erosion control
plans;
• LID principles and LID BMPs;
• Stormwater treatment and flow control BMPs/facilities; or
• Source control BMPs for building materials to reduce pollution to
stormwater, including but not limited to stormwater pollution
from PCB-containing materials.
(c) Permittees shall provide subject area information to the priority
audience on an ongoing or strategic schedule.
ii. Behavior change. To affect behavior change, Permittees shall select, at a
minimum, one priority audience and one BMP.
(a) Priority Audiences: Residents, landscapers, property
managers/owners, developers, school age children,
college/university, or trade students, or businesses (including home-
based or mobile businesses).
BMPs:
• Use and storage of: pesticides, fertilizers, and/or other household
chemicals;
• Use and storage of: automotive chemicals, hazardous cleaning
supplies, carwash soaps, and/or other hazardous materials;
• Prevention of illicit discharges;
• Yard care techniques protective of water quality;
• Carpet cleaning;
• Repair and maintenance BMPs for: vehicles, equipment, and/or
home/buildings;
• Pet waste management and disposal;
• LID Principles and LID BMPs;
• Stormwater facility maintenance, including LID facilities;
• Dumpster and trash compactor maintenance;
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• Litter and debris prevention;
• Sediment and erosion control;
• (Audience specific) Source control BMPs (refer to S5.C.8); or
• (Audience specific) Locally important, municipal stormwater-
related subject area.
(b) No later than July 1, 2025, each Permittee shall evaluate the
effectiveness of an ongoing behavior change campaign (required
under S5.C.2.a.ii of the 2019 Permit). Permittees shall document
lessons learned and recommendations for which option to select
from S5.C.2.a.ii(c), below.
Permittees that select option S5.C.2.a.ii(c)3, below, may forgo this
evaluation if it will not add value to the overall behavior change
program.
(c) Based on the recommendation from S5.C.2.a.ii(b), by July 1, 2026,
each Permittee shall follow social marketing practices and methods
and develop a campaign that is tailored to the community, including
development of a program evaluation plan. Each Permittee shall:8
1. Develop a strategy and schedule to more effectively implement the
existing campaign;
2. Develop a strategy and schedule to expand the existing campaign
to a new priority audience or BMPs; or
3. Develop a strategy and schedule for a new priority audience and
BMP behavior change campaign.
(d) No later than September 1, 2026, begin to implement the strategy
developed in S5.C.2.a.ii.(c).9
(e) No later than March 31, 2029, evaluate and submit report on:
1. The changes in understanding and adoption of targeted behaviors
resulting from the implementation of the strategy; and
8 No later than August 1, 2025, New Permittees shall follow social marketing practices and methods to develop a
behavior change program that is tailored to the community per S5.C.2.a.ii(c).
9 No later than October 1, 2025, New Permittees shall begin to implement the strategy developed in S5.C.2.a.ii(d).
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2. Any planned or recommended changes to the campaign to be
more effective; describe the strategies and process to achieve the
results.
(f) Permittees shall use results of the evaluation to continue to direct
effective methods and implementation of the ongoing behavior
change program.
iii. Stewardship. Each Permittee shall partner or promote (or both)
stewardship opportunities to encourage residents or businesses to
participate in activities or events planned and organized within the
community, such as: stream teams, storm drain marking, volunteer
monitoring, and riparian plantings. Permittees may partner or promote
(or both) stewardship opportunities created or organized by existing
organizations (including non-permittees).10
Public Involvement and Participation
Permittees shall provide ongoing opportunities for public involvement and
participation through advisory councils, public hearings, watershed committees,
participation in developing rate-structures or other similar activities. Each
Permittee shall comply with applicable state and local public notice
requirements when developing elements of the SWMP and SMAP.
The minimum performance measures are:
i. Annually, Permittees shall document specific public involvement
opportunities provided to overburdened communities.
ii. No later than December 31, 2026, document methods used to identify
overburdened communities.
10 New Permittees shall implement the stewardship requirements according to S5.C.2.a.iii no later than August 1,
2027.
11New Permittees shall develop and begin to implement requirements according to S5.C.3.a no later than August 1,
2025. New Permittees are exempt from SMAP this permit term.
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MS4 Mapping and Documentation
The SWMP shall include an ongoing program for mapping and documenting the
MS4.12
The minimum performance measures are:
i. Known MS4 outfalls and known MS4 discharge points:
a. Map outfall size and material, where known;
ii. Receiving waters, other than groundwater;
iii. Stormwater treatment and flow control BMPs/facilities owned or
operated by the Permittee;
iv. Geographic areas served by the Permittee’s MS4 that do not discharge
stormwater to surface waters;
v. Tributary conveyances to all known outfalls and discharge points with a
24-inch nominal diameter or larger, or an equivalent cross-sectional area
for non-pipe systems. The following features or attributes (or both) shall
be mapped:
(a) Tributary conveyance type, material, and size where known;
(b) Associated drainage areas; and
(c) Land use.
vi. Connections between the MS4 owned or operated by the Permittee and
other municipalities or public entities;
vii. All connections to the MS4 authorized or allowed by the Permittee after
February 16, 2007;13,14 and
viii. All known connections from the MS4 to a privately owned stormwater
system.
12New Permittees shall meet the requirements to map the MS4 according to S5.C.4 no later than March 31, 2029,
except where otherwise noted in this Section.
13New Permittees shall meet the requirements of S5.C.4.a.vii after August 1, 2024, for all connections to the MS4
authorized after August 1, 2024.
14Permittees do not need to map the following residential connections: individual driveways, sump pumps, or roof
downspouts.
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i. No later than March 31, 2026, Permittees shall submit locations of all
known MS4 outfalls according to the standard templates and format
provided in the Annual Report. This reporting shall include the size and
material of the outfalls.
ii. No later than December 31, 2027, develop a methodology to map and
assess acreage of MS4 tributary basins to outfalls or discharge points that
have stormwater treatment and flow control BMPs/facilities owned or
operated by the Permittee. Submit with the Annual Report a map and
breakdown of acres managed or unmanaged by stormwater treatment
and flow control BMPs/facilities.
iii. No later than December 31, 2028, begin mapping of Permittee-owned or
operated properties with tree canopy based on available, existing data.
Illicit Discharge Detection and Elimination
The SWMP shall include an ongoing program designed to prohibit non-
stormwater discharges into the MS4, prevent, detect, characterize, trace, and
eliminate illicit connections and illicit discharges into the MS4.15
The minimum performance measures are:
15New Permittees shall meet the requirements of S5.C.5 no later than August 1, 2026 except where otherwise
noted in this Section.
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Illicit connections and illicit discharges shall be identified through, but not
limited to, field screening, inspections, complaints/reports, construction
inspections, maintenance inspections, source control inspections, and/or
monitoring information, as appropriate.
i. Allowable Discharges: The regulatory mechanism does not need to
prohibit the following categories of non-stormwater discharges:
(a) Diverted stream flows;
(b) Rising groundwaters;
(c) Uncontaminated groundwater infiltration (as defined at 40 CFR
35.2005(b)(20));
(d) Uncontaminated pumped groundwater;
(e) Foundation drains;
(f) Air conditioning condensation;
(g) Irrigation water from agricultural sources that is commingled with
urban stormwater;
(h) Springs;
(i) Uncontaminated water from crawl space pumps;
(j) Footing drains;
(k) Flows from riparian habitats and wetlands;
(l) Non-stormwater discharges authorized by another NPDES or State
Waste Discharge permit; and
(m) Non-stormwater discharges from emergency firefighting activities in
accordance with S2 Authorized Discharges. After the emergency has
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ceased, non-stormwater discharges (e.g., discharges associated with
cleanup) to the MS4 are prohibited.
ii. Conditionally allowable discharges: The regulatory mechanism may allow
the following categories of non-stormwater discharges only if the stated
conditions are met:
(a) Discharges from potable water sources, including but not limited to
water line flushing, hyperchlorinated water line flushing, fire hydrant
system flushing, and pipeline hydrostatic test water. Planned
discharges shall be dechlorinated to a total residual chlorine
concentration of 0.1 ppm or less, pH-adjusted, if necessary, and
volumetrically and velocity controlled to prevent re-suspension of
sediments in the MS4.
(b) Discharges from lawn watering and other irrigation runoff. These
discharges shall be minimized through, at a minimum, public
education activities and water conservation efforts.
(c) Discharges from swimming pool, spa, and hot tub. The discharges
shall be dechlorinated to a total residual chlorine concentration of 0.1
ppm or less; pH-adjusted; reoxygenated, if necessary; and
volumetrically and velocity controlled to prevent re-suspension of
sediments in the MS4. Discharges shall be thermally controlled to
prevent an increase in temperature of the receiving water. Swimming
pool cleaning wastewater and filter backwash shall not be discharged
to the MS4.
(d) Street and sidewalk wash water and water used to control dust that
does not use detergents. The Permittee shall reduce these discharges
through, at a minimum, public education activities and/or water
conservation efforts. To avoid washing pollutants into the MS4
Permittees shall minimize the amount of street wash and dust control
water used.
(e) Routine external building washdown that does not use detergents for
buildings built or renovated before 1950 and after 1980. The
Permittee shall reduce these discharges through, at minimum, public
education activities or water conservation efforts, or both. To avoid
washing pollutants into the MS4 Permittees shall minimize the
amount of wash water used.
Commercial, industrial, and multi-story residential structures
constructed or remodeled between the years 1950 and 1980 (i.e.
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those most likely to have PCB containing building materials), shall be
assessed for PCB-containing materials consistent with How to find
and address PCBs in building materials (Ecology, October 2022,
Publication No. 22-04-024) prior to routine building washdown.
Structures confirmed or suspected to have PCB-containing materials
shall not discharge washdown to the MS4. Single-family residential
buildings are exempt from PCB assessment. Structures built or
renovated between 1950-1980 and determined to be without PCB-
containing materials may conduct routine building washdown
(without detergents) as described above.
(f) Other non-stormwater discharges. The discharges shall be in
compliance with the requirements of a pollution prevention plan
reviewed by the Permittee which addresses control of such
discharges.
iii. The Permittee shall further address any category of discharges in (i) or
(ii), above if the discharges are identified as significant sources of
pollutants to waters of the State.
iv. The ordinance or other regulatory mechanism shall include escalating
enforcement procedures and actions.
i. Procedures for conducting investigations of the Permittee’s MS4,
including field screening and methods for identifying potential sources.
These procedures may also include source control inspections.
The Permittee shall implement a field screening methodology
appropriate to the characteristics of the MS4 and water quality concerns.
Screening for illicit connections may be conducted using Illicit Connection
and Illicit Discharge Field Screening and Source Tracing Guidance Manual
(Herrera Environmental Consultants, Inc.; May 2020), or another
methodology of comparable or improved effectiveness. The Permittee
shall document the field screening methodology in the Annual Report.
(a) All Permittees shall complete field screening for an average of 12% of
the MS4 each year.17
16New Permittees shall fully implement the requirements of S5.C.5.d no later than August 1, 2028.
17New Permittees shall complete S5.C.5.d.i requirements for field screening covering at least 40% of the MS4
within the Permittee’s coverage area no later than December 31, 2028, and on average 12% each year thereafter.
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ii. A publicly listed and publicized hotline or other telephone number for
public reporting of spills and other illicit discharges.
iii. An ongoing training program for all municipal field staff who, as part of
their normal job responsibilities, might come into contact with or
otherwise observe an illicit discharge and/or illicit connection to the MS4,
on the identification of an illicit discharge and/or connection, and on the
proper procedures for reporting and responding to the illicit discharge
and/or connection. Follow-up training shall be provided, as needed, to
address changes in procedures, techniques, requirements, or staffing.
Permittees shall document and maintain records of the trainings
provided and the staff trained.18
i. Procedures for characterizing the nature of, and potential public or
environmental threat posed by, any illicit discharges found by or reported
to the Permittee. Procedures shall address the evaluation of whether the
discharge must be immediately contained and steps to be taken for
containment of the discharge.
ii. Procedures for tracing the source of an illicit discharge; including visual
inspections and, when necessary, opening manholes, using mobile
cameras, collecting and analyzing water samples, and/or other detailed
inspection procedures.
iii. Procedures for eliminating the discharge including notification of
appropriate authorities (including owners or operators of interconnected
MS4s), notification of the property owner, technical assistance, follow-up
inspections, and use of the compliance strategy developed pursuant to
S5.C.5.c.iv, including escalating enforcement and legal actions if the
discharge is not eliminated.
iv. Compliance with the provisions in (i), (ii), and (iii), above, shall be
achieved by meeting the following timelines:
18New Permittees shall develop and begin implementing the ongoing training program described in S5.C.5.d.iii no later than
March 31, 2026.
19New Permittees shall fully develop and implement the requirements of S5.C.5.e no later than August 1, 2028.
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(a) Immediately respond to all illicit discharges, including spills, which are
determined to constitute a threat to human health, welfare, or the
environment, consistent with General Condition G3.
(b) Investigate (or refer to the appropriate agency with the authority to
act) within 7 days, on average, any complaints, reports, or monitoring
information that indicates a potential illicit discharge.
(c) Initiate an investigation within 21 days of any report or discovery of a
suspected illicit connection to determine the source of the
connection, the nature and volume of discharge through the
connection, and the party responsible for the connection.
(d) Upon confirmation of an illicit connection, use the compliance
strategy in a documented effort to eliminate the illicit connection
within 6 months. All known illicit connections to the MS4 shall be
eliminated.
Controlling Runoff from New Development, Redevelopment, and Construction
Sites
Each Permittee shall implement and enforce a program to reduce pollutants in
stormwater runoff to a regulated small MS4 from new development,
redevelopment, and construction site activities. The program shall apply to
20New Permittees shall meet the requirements of S5.C.5.f no later than March 31, 2026.
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private and public development, including transportation projects.21The
minimum performance measures are:
No later than June 30, 2027, each Permittee shall adopt and make effective a
local program, that meets the requirements of S5.C.6.b(i) through (iii), below,
and shall apply to all applications22 submitted:
i. On or after July 1, 2027;
ii. Prior to January 1, 2017, that have not started construction23 by July 1,
2022;24
iii. Prior to July 1, 2022, that have not started construction by July 1, 2027;
and
iv. Prior to July 1, 2027, that have not started construction by July 1, 2032.
i. The Minimum Requirements, thresholds, and definitions in Appendix 1,
or the 2019 Appendix 1 amended to include the changes identified in
Appendix 10, or Phase I program approved by Ecology and amended to
include Appendix 10, for new development, redevelopment, and
construction sites. Adjustment and variance criteria equivalent to those
in Appendix 1 shall be included. More stringent requirements may be
used, and/or certain requirements may be tailored to local circumstances
through the use of Ecology-approved basin plans or other similar water
quality and quantity planning efforts. Such local requirements and
21For continuing Permittees, this means continuing to implement existing programs developed under previous
permits until updates are made to meet the schedules defined. New Permittees shall meet the requirements of
S5.C.6 no later than June 30, 2027, except where otherwise specified in this Section.
22In this context, “application” means, at a minimum a complete project description, site plan, and, if applicable, SEPA
checklist. Permittees may establish additional elements of a completed application.
23In this context “started construction” means the site work associated with, and directly related to the approved project
has begun. For example: grading the project site to final grade or utility installation. Simply clearing the project site does
not constitute the start of construction. Permittees may establish additional requirements related to the start of
construction.
24For Lynden, Snoqualmie S5.C.6.a.ii is replaced with these dates: Prior to January 1, 2018, that have not started
construction by January 1, 2023. For Aberdeen S5.C.6.a.ii is replaced with these dates: Prior to July 1, 2018, that have not
started construction by June 30, 2023. Shelton S5.C.6.a.ii and iii is replaced with these dates: Prior to January 1, 2023,
which have not started construction by January 1, 2028.
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thresholds shall provide equal protection of receiving waters and equal
levels of pollutant control to those provided in Appendix 1.
ii. The local requirements shall include the following requirements,
limitations, and criteria that, when used to implement the minimum
requirements in Appendix 1 (or program approved by Ecology under the
2024 Phase I Permit), will protect water quality, reduce the discharge of
pollutants to the MEP, and satisfy the State requirement under Chapter
90.48 RCW to apply AKART prior to discharge:
(a) Site planning requirements;
(b) BMP selection criteria;
(c) BMP design criteria;
(d) BMP infeasibility criteria;
(e) LID competing needs criteria; and
(f) BMP limitations.
Permittees shall document how the criteria and requirements will protect
water quality, reduce the discharge of pollutants to the MEP, and satisfy
the state AKART requirements.
Permittees who choose to use the requirements, limitations, and criteria
above in the Stormwater Management Manual for Western Washington,
or a Phase I program approved by Ecology, may cite this choice as their
sole documentation to meet this requirement.
iii. The legal authority, through the approval process for new development
and redevelopment, to inspect and enforce maintenance standards for
private stormwater facilities approved under the provisions of this
Section that discharge to the Permittee’s MS4.
i. Review of all stormwater site plans for proposed development activities.
ii. Inspect, prior to clearing and construction, all permitted development
sites that have a high potential for sediment transport as determined
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through plan review based on definitions and requirements in Appendix 7
– Determining Construction Site Sediment Damage Potential. As an
alternative to evaluating each site according to Appendix 7, Permittees
may choose to inspect all construction sites that meet the minimum
thresholds adopted pursuant to S5.C.6.b.i, above.
iii. Inspect all permitted development sites during construction to verify
proper installation and maintenance of required erosion and sediment
controls. Enforce, as necessary, based on the inspection.
iv. Each Permittee shall manage maintenance activities to inspect all
stormwater treatment and flow control BMPs/facilities, and catch basins,
in new residential developments every six months, until 90% of the lots
are constructed (or when construction has stopped and the site is fully
stabilized), to identify maintenance needs and enforce compliance with
maintenance standards as needed.
v. Inspect all permitted development sites upon completion of construction
and prior to final approval or occupancy to ensure proper installation of
permanent stormwater facilities. Verify that a maintenance plan is
completed and responsibility for maintenance is assigned for stormwater
treatment and flow control BMPs/facilities. Enforce, as necessary, based
on the inspection.
vi. Compliance with the inspection requirements in (ii) through (v), above,
shall be determined by the presence and records of an established
inspection program designed to inspect all sites. Compliance shall be
determined by achieving at least 80% of required inspections annually.
The inspections may be combined with other inspections provided they
are performed using qualified personnel.
vii. The program shall include a procedure for keeping records of inspections
and enforcement actions by staff including inspection reports, warning
letters, notices of violations, and other enforcement records. Records of
maintenance inspections and maintenance activities shall be maintained.
viii. An enforcement strategy shall be implemented to respond to issues of
non-compliance.
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25New Permittees shall meet the requirements of S5.C.6.d beginning no later than August 1, 2024.
26New Permittees shall meet the requirements of S5.C.6.e no later than December 31, 2027.
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Stormwater Permit – August 1, 2024
Stormwater Management for Existing Development
Each Permittee shall implement a Program to control or reduce stormwater
discharges to waters of the State from areas of existing development.27 The
Program shall aim to focus on strategic stormwater investments over longer
planning timeframes.
Minimum performance measures:
i. Strategic stormwater investments identified in Stormwater Management
Action Plan(s) (SMAPs, S5.C.1.d.), or similar stormwater planning process;
and/or
ii. Opportunistic stormwater investments identified by leveraging projects
outside of SMAP areas to improve stormwater management and
infrastructure.
i. Projects that started construction on or after January 1, 2023, may be
included towards achieving the acres required.
ii. Permittees may contribute to meeting an overall regional goal to satisfy
this permit requirement as described in S5.C.7.c.
iii. Permittees that complete projects by the expiration date of this permit
that will exceed the area required for this permit term may use the
excess as a credit to be used for the 2029 Permit term, not to exceed 50%
of the next Permit’s requirement.
iv. Each Permittee is required to manage at least 0.3 acres within their own
jurisdiction but may receive acreage credit for contributing to meeting an
overall regional goal outside their defined MS4 Permit coverage area. For
Permittees assigned 0.3 acres, participation and in-kind services to
27 New Permittees are exempt from this permit section.
28 In this context, “fully fund” means stormwater facility retrofits are at or beyond 60% design and there is a
documented source of funding and commitment to complete the project during the next permit cycle.
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Stormwater Permit – August 1, 2024
regional collaboration projects may count as the contribution for this
permit term if there is regional agreement on the strategy.
v. Permittees may contribute to a regional goal, that is the sum of Phase II
partners assigned acreage from Appendix 12. Projects may be
implemented outside of permit coverage areas to meet their individual
requirement as part of a regional goal where benefits to receiving waters
within the permit coverage are identified and anticipated.
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Stormwater Permit – August 1, 2024
Source Control Program for Existing Development
The Permittee shall implement a program to prevent and reduce pollutants in
runoff from areas of existing development that discharge to the MS4. The
program shall include application of source control BMPs, inspections, and
enforcement.
The minimum performance measures are:
The requirements of this subsection are met by using the source control
BMPs in the SWMMWW, or a Phase I Program approved by Ecology. In cases
where the manual(s) lack guidance for a specific source of pollutants, the
Permittee shall work with the owner/operator to implement or adapt BMPs
based on the best professional judgement of the Permittee.
Applicable operational source control BMPs shall be required for all pollutant
generating sources. Structural source control BMPs, or treatment
BMPs/facilities, or both, shall be required for pollutant generating sources if
operational source control BMPs do not prevent illicit discharges or
violations of surface water, groundwater, or sediment management
standards because of inadequate stormwater controls. Implementation of
source control requirements may be done through education and technical
assistance programs, provided that formal enforcement authority is available
to the Permittee and is used as determined necessary by the Permittee, in
accordance with S5.C.8.a.iii, below.
i. Businesses and/or sites identified based on the presence of activities that
are pollutant generating (refer to Appendix 8); and
ii. Other pollutant generating sources, based on complaint response, such
as: home-based businesses and multi-family sites.
29 No later than August 1, 2026, New Permittees shall adopt and make effective ordinance(s), or other enforceable
documents, requiring the application of source control BMPs for pollutant generating sources associated with
existing land uses and activities (see Appendix 8 to identify pollutant generating sources).
30 No later than August 1, 2027, New Permittees shall establish an inventory that follows this permit section.
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Stormwater Permit – August 1, 2024
i. All identified sites with a business address shall be provided information
about activities that may generate pollutants and the source control
requirements applicable to those activities. This information shall be
provided by mail, telephone, electronic communications, or in person.
This information may be provided all at one time or spread out over the
permit term to allow for tailoring and distribution of the information
during site inspections.
ii. The Permittee shall annually complete the number of inspections equal
to 20% of the businesses and/or sites listed in their source control
inventory to assess BMP effectiveness and compliance with source
control requirements. The Permittee may count follow-up compliance
inspections at the same site toward the 20% inspection rate. The
Permittee may select which sites to inspect each year and is not required
to inspect 100% of sites over a 5-year period. Sites may be prioritized for
inspection based on their land use category, potential for pollution
generation, proximity to receiving waters, or to address an identified
pollution problem within a specific geographic area or sub-basin.
iii. Each Permittee shall inspect 100% of sites identified through credible
complaints.
iv. Permittees may count inspections conducted based on complaints, or
when the property owner denies entry, to the 20% inspection rate.
v. Annual Reporting of inspections shall be organized by business type or
activities with potential to generate pollutants to the MS4. Standard
Industrial Code (SIC), Major Group, and NAICS numbers may be provided
for reference as noted in Appendix 8.
i. If the Permittee determines, through inspections or otherwise, that a site
has failed to adequately implement required BMPs, the Permittee shall
take appropriate follow-up action(s), which may include phone calls,
reminder letters, emails, or follow-up inspections.
31 No later than January 1, 2028, New Permittees shall implement an inspection program for sites identified.
32 No later than January 1, 2028, New Permittees shall implement a progressive enforcement policy as described in
this permit section.
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ii. When a Permittee determines that a site has failed to adequately
implement BMPs after a follow-up inspection(s) the Permittee shall take
enforcement action as established through authority in its municipal
codes or ordinances, or through the judicial system.
iii. Each Permittee shall maintain records including documentation of each
site visit, inspection reports, warning letters, notices of violations, and
other enforcement records demonstrating an effort to bring sites into
compliance. Each Permittee shall also maintain records of sites that are
not inspected because the property owner denies entry.
iv. A Permittee may refer non-emergency violations of local ordinances to
Ecology provided the Permittee also makes a documented effort of
progressive enforcement. At a minimum, a Permittee’s enforcement
effort shall include documentation of inspections and warning letters or
notices of violation.
v. Application and enforcement of local ordinances at sites identified
pursuant to S5.C.8.a.i including sites with discharges authorized by a
separate NPDES permit. Permittees that are in compliance with the terms
of this Permit will not be held liable by Ecology for water quality standard
violations or receiving water impacts caused by industries and other
Permittees covered, or which should be covered, under an NPDES permit
issued by Ecology.
33 New Permittees shall develop and implement a training program no later than December 31, 2027.
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S5.C.9 Stormwater Management Program Components
Western Washington Phase II Municipal Page 46 of 88
Stormwater Permit – August 1, 2024
Operations and Maintenance
Each Permittee shall implement and document a program to regulate
maintenance activities and to conduct maintenance activities by the Permittee
to prevent or reduce stormwater impacts.34
The minimum performance measures are:
i. The purpose of the maintenance standard is to determine if maintenance
is required. The maintenance standard is not a measure of the facility’s
required condition at all times between inspections. Exceeding the
maintenance standard between inspections and/or maintenance is not a
permit violation.
ii. Unless there are circumstances beyond the Permittee’s control, when an
inspection identifies an exceedance of the maintenance standard,
maintenance shall be performed:
• Within 1 year for typical maintenance of facilities, except catch
basins;
• Within 6 months for catch basins; and
• Within 2 years for maintenance that requires capital construction of
less than $25,000.
Circumstances beyond the Permittee’s control include denial or delay of
access by property owners, denial or delay of necessary permit approvals,
and unexpected reallocations of maintenance staff to perform
emergency work. For each exceedance of the required timeframe, the
Permittee shall document the circumstances and how they were beyond
their control.
34New Permittees shall develop and implement the requirements of S5.C.9 no later than June 30, 2027 except
where otherwise noted in this Section.
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Stormwater Permit – August 1, 2024
i. The program shall include provisions to verify adequate long-term O&M
of stormwater treatment and flow control BMPs/facilities that are
permitted and constructed pursuant to S.5.C.6.c and shall be maintained
in accordance with S5.C.9.a.
The provisions shall include:
(a) Implementation of an ordinance or other enforceable mechanism
that:
• Clearly identifies the party responsible for maintenance in
accordance with maintenance standards established under
S5.C.9.a.
• Requires inspection of facilities in accordance with the
requirements in (b), below.
• Establishes enforcement procedures.
(b) Annual inspections, by qualified personnel, of all stormwater
treatment and flow control BMPs/facilities that discharge to the MS4
and were permitted by the Permittee according to S5.C.6.c, including
those permitted in accordance with requirements adopted pursuant
to the 2007-2024 Ecology municipal stormwater permits, unless there
are maintenance records to justify a different frequency.
Permittees may reduce the inspection frequency based on
maintenance records of double the length of time of the proposed
inspection frequency. In the absence of maintenance records, the
Permittee may substitute written statements to document a specific
less frequent inspection schedule. Written statements shall be based
on actual inspection and maintenance experience and shall be
certified in accordance with G19 – Certification and Signature.
ii. Compliance with the inspection requirements in (b), above, shall be
determined by the presence and records of an established inspection
program designed to inspect all facilities, and achieving at least 80% of
required inspections annually.
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iii. If deemed necessary for post-construction access, the ordinance or other
regulatory mechanism may, in lieu of requiring that continued access be
granted to the Permittee’s staff or qualified personnel, instead require
private property owners to provide annual certification by a qualified
third party that adequate maintenance has been performed and the
facilities are operating as designed to protect water quality.
iv. The program shall include a procedure for keeping records of inspections
and enforcement actions by staff, including inspection reports, warning
letters, notices of violations, and other enforcement records. Records of
maintenance inspections and maintenance activities shall be maintained.
i. Each Permittee shall implement a program to annually inspect all
municipally owned or operated stormwater treatment and flow control
BMPs/facilities. Permittees shall implement appropriate maintenance
action(s) in accordance with the adopted maintenance standards. The
inspection program shall be implemented by qualified personnel.
Permittees may reduce the inspection frequency based on maintenance
records of double the length of time of the proposed inspection
frequency. In the absence of maintenance records, the Permittee may
substitute written statements to document a specific less frequent
inspection schedule. Written statements shall be based on actual
inspection and maintenance experience and shall be certified in
accordance with G19 – Certification and Signature.
ii. Each Permittee shall spot check potentially damaged stormwater
treatment and flow control BMPs/facilities after major storm events (24-
hour storm event with a 10 year or greater recurrence interval). If spot
checks indicate widespread damage/maintenance needs, inspect all
stormwater treatment and flow control BMPs/facilities that may be
affected. Conduct repairs or take appropriate maintenance action in
accordance with maintenance standards established above, based on the
results of the inspections.
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Stormwater Permit – August 1, 2024
iii. Each Permittee shall continue to inspect all catch basins and inlets owned
or operated by the Permittee every two years by December 31.35,36 Clean
catch basins if the inspection indicates cleaning is needed to comply with
maintenance standards established in the Stormwater Management
Manual for Western Washington. Decant water shall be disposed of in
accordance with Appendix 6 – Street Waste Disposal.
The following alternatives to the standard approach of inspecting all
catch basins every two years may be applied to all or portions of the
system:
(a) The catch basin inspection schedule of every two years may be
changed as appropriate to meet the maintenance standards based on
maintenance records of double the length of time of the proposed
inspection frequency. In the absence of maintenance records for
catch basins, the Permittee may substitute written statements to
document a specific, less frequent inspection schedule. Written
statements shall be based on actual inspection and maintenance
experiences and shall be certified in accordance with G19 –
Certification and Signature.
(b) Inspections every two years may be conducted on a “circuit basis”
whereby 25% of catch basins and inlets within each circuit are
inspected to identify maintenance needs. Include an inspection of the
catch basin immediately upstream of any MS4 outfall, discharge
point, or connections to public or private storm systems, if applicable.
Clean all catch basins within a given circuit for which the inspection
indicates cleaning is needed to comply with maintenance standards
established under S5.C.7.a, above.
(c) The Permittee may clean all pipes, ditches, and catch basins and inlets
within a circuit once during the permit term. Circuits selected for this
alternative must drain to a single point.
iv. Compliance with the inspection requirements in S5.C.7.c.i-iii, above, shall
be determined by the presence of an established inspection program
achieving at least 95% of required inspections.
35 Continuing Permittees shall implement the two-year schedule established under previous permits, except
inspections shall be completed by December 31.
36 New Permittees shall inspect and, if needed, clean all catch basins and inlets owned or operated by the
Permittee in accordance with the requirements of S5.C.7.c once during the permit term, to be completed no later
than December 31, 2028.
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Stormwater Permit – August 1, 2024
The following activities shall be addressed:
i. Pipe cleaning;
ii. Cleaning of culverts that convey stormwater in ditch systems;
iii. Ditch maintenance;
iv. Street cleaning;
v. Road repair and resurfacing, including pavement grinding;
vi. Snow and ice control;
vii. Utility installation;
viii. Pavement striping maintenance;
ix. Maintaining roadside areas, including vegetation management;
x. Dust control;
xi. Application of fertilizers, pesticides, and herbicides according to the
instructions for their use including reducing nutrients and pesticides
using alternatives that minimize environmental impacts;
xii. Sediment and erosion control;
xiii. Landscape maintenance and vegetation disposal;
xiv. Trash and pet waste management;
xv. Building exterior cleaning and maintenance; and
(a) For Permittee-owned buildings built or renovated between 1950-
1980, update policies, practices, or procedures to include Source
Control BMPs to minimize PCBs from entering the MS4. Permittees
shall not discharge washdown water to the MS4 if the building is
confirmed or suspected to have PCB-containing materials.
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xvi. Preparing Permittee-owned buildings for renovation or demolition.
(a) Update policies, practices, or procedures to include Source Control
BMPs for building materials to prevent PCBs from entering the MS4 in
preparation for and during demolition and renovations.
i. Apply street sweeping program to publicly owned roads in MS4 drainage
areas that discharge to outfalls. Within those areas, sweep the following
high priority areas, where applicable:
(a) High traffic roads, such as arterials;
(b) Accessible curb and gutter streets - permittees may need to
implement parking restrictions or other effective methods to
optimize pollutant removal;
(c) Areas with significant tire wear, e.g. roundabouts, high traffic
intersections, municipal-operated parking lots;
(d) Areas with significant tree canopy with seasonal leaf litter drop;
(e) Municipal roads that serve commercial or industrial land use areas;
and
(f) MS4 basins that discharge to surface receiving waters that support
salmonids.
ii. Sweep high priority areas at least once between July and September each
year and two additional times a year as determined by the Permittee to
provide additional water quality benefits. For calendar year 2027, only
one sweeping event is required.
a. Permittees may document reasoning for alternative sweeping timing
and frequency based on local conditions (e.g., climate) and estimated
pollutant deposition quantities. Documentation shall also be based on
actual maintenance experience and be certified in accordance with
G19 – Certification and Signature.
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Stormwater Permit – August 1, 2024
b. If a Permittees’ existing overall street sweeping program provides
equivalent or greater street sweeping frequency relative to the
requirements above, the Permittee may continue to implement its
existing street sweeping program. Documentation shall be certified in
accordance with G19 – Certification and Signature.
iii. Annually sweep at least 90% of high priority areas within the MS4
drainage areas.
iv. Follow equipment design performance specifications to ensure that
street sweeping equipment is operated at the proper design speed with
appropriate verification, and that it is properly maintained.
v. Permittee shall dispose of sweeper waste material in accordance with
Appendix 6- Street Waste Disposal.
vi. Document the road type and level of traffic served (e.g. AADT or
estimated # of vehicles served) of roads swept, frequency, type of
sweeper, lane miles, a map of the areas and land uses swept, and
approximation of street waste removed. Begin reporting with the Annual
Report March 31, 2029.
i. A detailed description of the operational and structural BMPs in use at
the facility and a schedule for implementation of additional BMPs when
needed. BMPs selected shall be consistent with the Stormwater
Management Manual for Western Washington, or a Phase I program
approved by Ecology. The SWPPP shall be updated as needed to maintain
relevancy with the facility.
ii. At minimum, annual inspections of the facility, including visual
observations of discharges, to evaluate the effectiveness of the BMPs,
identify maintenance needs, and determine if additional or different
BMPs are needed. The results of these inspections shall be documented
in an inspection report or check list.
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Stormwater Permit – August 1, 2024
iii. An inventory of the materials and equipment stored on-site, and the
activities conducted at the facility which may be exposed to precipitation
or runoff and could result in stormwater pollution.
iv. A site map showing the facility’s stormwater drainage, discharge points,
and areas of potential pollutant exposure.
v. A plan for preventing and responding to spills at the facility which could
result in an illicit discharge.
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S6.A Secondary Permittees and New Secondary Permittees Coverage
Western Washington Phase II Municipal Page 54 of 88
Stormwater Permit – August 1, 2024
S6. STORMWATER MANAGEMENT PROGRAM FOR SECONDARY PERMITTEES
A. Secondary Permittees and New Secondary Permittees Coverage
This Section applies to all Secondary Permittees and all New Secondary Permittees,
whether coverage under this Permit is obtained individually or as a Co-Permittee
with a city, town, county, or another Secondary Permittee.
New Secondary Permittees subject to this Permit shall fully meet the requirements
of this Section as modified in the footnotes in S6.D below, or as established as a
condition of coverage by Ecology.
1. To the extent allowable under state, federal or local law, all components are
mandatory for each Secondary Permittee covered under this Permit, whether
covered as an individual Permittee or as a Co-Permittee.
2. Each Secondary Permittee shall develop and implement a Stormwater
Management Program (SWMP). A SWMP is a set of actions and activities
comprising the components listed in S6 and any additional actions necessary to
meet the requirements of applicable TMDLs pursuant to S7 – Compliance with
Total Maximum Daily Load Requirements. The SWMP shall be designed to reduce
the discharge of pollutants from regulated small MS4s to the MEP and protect
water quality.
3. Unless an alternate implementation schedule is established by Ecology as a
condition of permit coverage, the SWMP shall be developed and implemented in
accordance with the schedules contained in this Section and shall be fully
developed and implemented no later than four and one-half years from the
initial permit coverage date. Secondary Permittees that are already
implementing some or all of the required SWMP components shall continue
implementation of those components.
4. Secondary Permittees may implement parts of their SWMP in accordance with
the schedule for cities, towns, and counties in S5, provided they have signed a
memorandum of understanding or other agreement to jointly implement the
activity or activities with one or more jurisdictions listed in S1.D.2.a or S1.D.2.b
and submitted a copy of the agreement to Ecology.
5. Each Secondary Permittee shall prepare written documentation of the SWMP,
called the SWMP Plan. The SWMP Plan shall be updated annually to include a
description of program activities for the upcoming calendar year, and shall be
submitted with the Annual Report.
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S6.B Coordination
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Stormwater Permit – August 1, 2024
B. Coordination
Secondary Permittees shall coordinate stormwater-related policies, programs, and
projects within a watershed and interconnected MS4s. Where relevant and
appropriate, the SWMP shall coordinate among departments of the Secondary
Permittee to ensure compliance with the terms of this Permit.
C. Legal Authority
To the extent allowable under state law and federal law, each Secondary Permittee
shall be able to demonstrate that they can operate pursuant to legal authority which
authorizes or enables the Secondary Permittee to control discharges to and from
MS4s owned or operated by the Secondary Permittee.
This legal authority may be a combination of statutes, ordinances, permits,
contracts, orders, interagency agreements, or similar instruments.
D. Stormwater Management Program for Secondary Permittees
The SWMP for Secondary Permittees shall include the following components:
Public Education and Outreach
Each Secondary Permittee shall implement the following stormwater education
strategies:
37New Secondary Permittees shall label all inlets as described in S6.D.1.a no later than four years from the initial
date of permit coverage.
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S6.D Stormwater Management Program for Secondary Permittees
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Stormwater Permit – August 1, 2024
i. How stormwater runoff affects local water bodies;
ii. Proper use and application of pesticides and fertilizers;
iii. Benefits of using well-adapted vegetation;
iv. Alternative equipment washing practices, including cars and trucks that
minimize pollutants in stormwater;
v. Benefits of proper vehicle maintenance and alternative transportation
choices; proper handling and disposal of vehicle wastes, including the
location of hazardous waste collection facilities in the area;
vi. Hazards associated with illicit connections and illicit discharges;
vii. Benefits of litter control of pet waste; and
viii. Source control BMPs for building materials to reduce pollution to
stormwater, including but not limited to, stormwater pollution from PCB-
containing materials.
Public Involvement and Participation
Each year, no later than May 31, each Secondary Permittee shall:
Illicit Discharge Detection and Elimination
Each Secondary Permittee shall:
38New Secondary Permittees shall develop and implement appropriate policies prohibiting illicit discharges and
identify possible enforcement mechanisms as described in S6.D.3.b no later than one year from the initial date of
permit coverage.
39New Secondary Permittees shall develop and implement an enforcement plan as described in S6.D.3.b no later
than 18 months from the initial date of permit coverage.
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S6.D Stormwater Management Program for Secondary Permittees
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Stormwater Permit – August 1, 2024
i. Allowable discharges: The policies do not need to prohibit the following
categories of non-stormwater discharges:
(a) Diverted stream flows;
(b) Rising groundwaters;
(c) Uncontaminated groundwater infiltration (as defined at 40 CFR
35.2005(b)(20));
(d) Uncontaminated pumped groundwater;
(e) Foundation drains;
(f) Air conditioning condensation;
(g) Irrigation water from agricultural sources that is commingled with
urban stormwater;
(h) Springs;
(i) Uncontaminated water from crawl space pumps;
(j) Footing drains;
(k) Flows from riparian habitats and wetlands;
(l) Discharges from emergency firefighting activities in accordance with
S2 – Authorized Discharges; and
(m) Non-stormwater discharges authorized by another NPDES or State
Waste Discharge permit.
ii. Conditionally allowable discharges: The policies may allow the following
categories of non-stormwater discharges only if the stated conditions are
met and such discharges are allowed by local codes:
(a) Discharges from potable water sources, including but not limited to
water line flushing, hyperchlorinated water line flushing.
(b) Fire hydrant system flushing, and pipeline hydrostatic test water.
Planned discharges shall be dechlorinated to a total residual chlorine
concentration of 0.1 ppm or less, pH-adjusted if necessary, and
volumetrically and velocity controlled to prevent resuspension of
sediments in the MS4.
(c) Discharges from lawn watering and other irrigation runoff. These
discharges shall be minimized through, at a minimum, public
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Stormwater Permit – August 1, 2024
education activities and water conservation efforts conducted by the
Secondary Permittee and/or the local jurisdiction.
(d) Discharges from swimming pools, spas, and hot tubs. The discharges
shall be dechlorinated to a total residual chlorine concentration of 0.1
ppm or less, pH-adjusted and reoxygenated if necessary, and
volumetrically and velocity controlled to prevent resuspension of
sediments in the MS4. Discharges shall be thermally controlled to
prevent an increase in temperature of the receiving water. Swimming
pool cleaning wastewater and filter backwash shall not be discharged
to the MS4.
(e) Street and sidewalk wash water, water used to control dust that does
not use detergents. The Secondary Permittee shall reduce these
discharges through, at a minimum, public education activities and/or
water conservation efforts conducted by the Secondary Permittee
and/or the local jurisdiction. To avoid washing pollutants into the
MS4, the Secondary Permittee shall minimize the amount of street
wash and dust control water used.
(f) Routine external building washdown that does not use detergents for
buildings built before 1950 and after 1980. The Permittee shall reduce
these discharges through, at minimum, public education activities or
water conservation efforts, or both. To avoid washing pollutants into
the MS4, Permittees shall minimize the amount of wash water used.
Commercial, public, institutional, and industrial structures
constructed or remodeled between the years 1950 and 1980 (i.e.
those most likely to have PCB containing building materials), shall be
assessed for PCB-containing materials consistent with How to Find
PCBs in Building Materials guidance (Ecology, 2022; Publication No.
22-040-024) prior to routine building washdown. Structures
confirmed or suspected to have PCB-containing materials shall not
discharge washdown water to the MS4. Structures built between
1950-1980, without PCB-containing materials, may proceed with
routine building washdown (without detergents) as described above.
(g) Other non-stormwater discharges shall be in compliance with the
requirements of a pollution prevention plan reviewed by the
Permittee which addresses control of such discharges.
iii. The Secondary Permittee shall address any category of discharges in (i) or
(ii), above, if the discharge is identified as a significant source of
pollutants to waters of the State.
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S6.D Stormwater Management Program for Secondary Permittees
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Stormwater Permit – August 1, 2024
i. No later than December 31, 2026, the required format for mapping is an
electronic format with fully described mapping standards.40
ii. No later than March 31, 2027, Permittees shall submit locations of all
known MS4 outfalls according to the standard templates and format
provided in the Annual Report. This reporting shall include the size and
material of the outfalls.
Construction Site Stormwater Runoff Control
From the initial date of permit coverage, each Secondary Permittee shall:
40New Secondary Permittees shall meet the requirements of S6.D.3.c no later than four and one-half years from
the initial date of permit coverage.
41New Secondary Permittees shall develop and implement a spill response plan as described in S6.D.3.e no later
than four and one-half years from the initial date of permit coverage.
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S6.D Stormwater Management Program for Secondary Permittees
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Post-Construction Stormwater Management for New Development and
Redevelopment
From the initial date of permit coverage, each Secondary Permittee shall:
Pollution Prevention and Good Housekeeping for Municipal Operations
Each Secondary Permittee shall:
i. Stormwater collection and conveyance systems including catch basins,
stormwater pipes, open channels, culverts, and stormwater treatment
42New Secondary Permittees shall develop and implement the operation and maintenance plan described in
S6.D.6.a no later than three years from initial date of permit coverage.
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S6.D Stormwater Management Program for Secondary Permittees
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and flow control BMPs/facilities. The O&M Plan shall address, at a
minimum: scheduled inspections and maintenance activities including
cleaning and proper disposal of waste removed from the system.
Secondary Permittees shall properly maintain stormwater collection and
conveyance systems owned or operated by the Secondary Permittee and
annually inspect and maintain all stormwater facilities to ensure facility
function.
Secondary Permittees shall establish maintenance standards that are as
protective or more protective of facility function than those specified in
the Stormwater Management Manual for Western Washington.
Secondary Permittees shall review their maintenance standards to ensure
they are consistent with the requirements of this Section.
Secondary Permittees shall conduct spot checks of potentially damaged
permanent stormwater treatment and flow control BMPs/facilities
following major storm events (24-hour storm event with a 10-year or
greater recurrence interval).
ii. Roads, highways, and parking lots. The O&M Plan shall address, at a
minimum: deicing, anti-icing, and snow removal practices; snow disposal
areas; material (e.g., salt, sand, or other chemical) storage areas; and all-
season BMPs to reduce road and parking lot debris and other pollutants
from entering the MS4.
iii. Vehicle fleets. The O&M Plan shall address, at a minimum: storage,
washing, and maintenance of Secondary Permittee vehicle fleets; and
fueling facilities. Secondary Permittees shall conduct all vehicle and
equipment washing and maintenance in a self-contained covered
building or in designated wash and/or maintenance areas.
iv. External building maintenance. The O&M Plan shall address, at a
minimum: building exterior cleaning and maintenance including cleaning,
washing, painting; maintenance and management of dumpsters; and
other maintenance activities. For buildings owned by the Secondary
Permittee and built between 1950 and 1980, the O&M Plan shall include
building material assessment for PCBs consistent with How to Find and
Address PCBs in Building Materials guidance (Ecology, 2022; Publication
No. 22-040-024) prior to exterior building washdown. Structures
confirmed or suspected to have PCB-containing materials shall not
discharge washdown water to the MS4.
v. Preparing Permittee-owned buildings for renovation or demolition. The
O&M Plan shall address Source Control BMPs for building materials to
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S6.D Stormwater Management Program for Secondary Permittees
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Stormwater Permit – August 1, 2024
prevent PCBs from entering the MS4 in preparation for and during
demolition and renovations.
vi. Parks and open space. The O&M Plan shall address, at a minimum:
proper application of fertilizer, pesticides, and herbicides; sediment and
erosion control; BMPs for landscape maintenance and vegetation
disposal; and trash and pet waste management.
vii. Material storage facilities and heavy equipment maintenance or storage
yards. Secondary Permittees shall develop and implement a Stormwater
Pollution Prevention Plan to protect water quality at each of these
facilities owned or operated by the Secondary Permittee and not covered
under the Industrial Stormwater General Permit or under another NPDES
permit that authorizes stormwater discharges associated with the
activity.
viii. Other facilities that would reasonably be expected to discharge
contaminated runoff. The O&M Plan shall address proper stormwater
pollution prevention practices for each facility.
i. The importance of protecting water quality;
ii. The requirements of this Permit;
iii. Operation and maintenance requirements;
iv. Inspection procedures;
v. Ways to perform their job activities to prevent or minimize impacts to
water quality; and
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S6.D Stormwater Management Program for Secondary Permittees
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vi. Procedures for reporting water quality concerns, including potential illicit
discharges (including spills).
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S8.A TMDL Specific Requirements
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Stormwater Permit – August 1, 2024
S7. COMPLIANCE WITH TOTAL MAXIMUM DAILY LOAD REQUIREMENTS
The following requirements apply if an applicable TMDL is approved for stormwater
discharges from MS4s owned or operated by the Permittee. Applicable TMDLs are
TMDLs which have been approved by EPA on or before the issuance date of this Permit
or prior to the date that Ecology issues coverage under this Permit, whichever is later.
A. TMDL Specific Requirements
1. For applicable TMDLs listed in Appendix 2, affected Permittees shall comply with
the specific requirements identified in Appendix 2. Each Permittee shall keep
records of all actions required by this Permit that are relevant to applicable
TMDLs within their jurisdiction. The status of the TMDL implementation shall be
included as part of the annual report submitted to Ecology. Each annual report
shall include a summary of relevant SWMP and Appendix 2 activities conducted
in the TMDL area to address the applicable TMDL parameter(s).
2. For applicable TMDLs not listed in Appendix 2, compliance with this Permit shall
constitute compliance with those TMDLs.
S8. MONITORING AND ASSESSMENT
A. Regional Status and Trends Monitoring
1. All Permittees that chose S8.A.2 Regional Status and Trends Monitoring Option
in the Phase II Western Washington Municipal Stormwater Permit, August 1,
2019 – July 31, 2024, shall make a one-time payment into the Stormwater Action
Monitoring (SAM) collective fund to implement regional small streams and
marine nearshore areas status and trends monitoring in Puget Sound or, urban
streams in the Lower Columbia River basin. This payment is due on or before
December 1, 2024. Submit payment according to S8.D, below.
2. All City and County Permittees covered under the Phase II Western Washington
Municipal Stormwater Permit, August 1, 2019 – July 31, 2024, except the Cities
of Aberdeen and Centralia, shall notify Ecology in writing which of the following
two options for regional status and trends monitoring (S8.A.2.a or S8.A.2.b) the
Permittee chooses to carry out during this permit term. The written notification
with G19 signature is due to Ecology no later than December 1, 2024. Either
option will fully satisfy the Permittee’s obligations under this Section (S8.A.2).
Each Permittee shall select a single option for this permit term.
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S8.B Stormwater Management Program (SWMP) Effectiveness and Source Identification Studies
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Stormwater Permit – August 1, 2024
Or
B. Stormwater Management Program (SWMP) Effectiveness and Source
Identification Studies
1. All Permittees that chose S8.B Effectiveness Studies Option in the Phase II
Western Washington Municipal Stormwater Permit, August 1, 2019 – July 31,
2024, shall make a one-time payment into the collective fund for Stormwater
Action Monitoring (SAM) to implement effectiveness studies and source
identification studies. The payment is due on or before December 1, 2024.
Submit payment according to S8.D, below.
2. All City and County Permittees covered under the Phase II Western Washington
Municipal Stormwater Permit, August 1, 2019 – July 31, 2024, shall notify
Ecology in writing which of the following two options (S8.B.2.a or S8.B.2.b) for
effectiveness and source identification studies the Permittee chooses to carry
out during this permit term. The written notification with G19 signature is due to
Ecology no later than December 1, 2024. Either option will fully satisfy the
Permittee’s obligations under this Section (S8.B.2). Each Permittee shall select a
single option for this permit term.
Or
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S8.C Stormwater discharge monitoring.
Western Washington Phase II Municipal Page 66 of 88
Stormwater Permit – August 1, 2024
3. All Permittees shall provide information as requested for effectiveness and
source identification studies that are under contract with Ecology as active
Stormwater Action Monitoring (SAM) projects. These requests will be limited to
records of SWMP activities and associated data tracked and/or maintained in
accordance with S5 – Stormwater Management Program for Cities, Towns, and
Counties and/or S9 – Reporting Requirements. A maximum of three requests
during the permit term from the SAM Coordinator will be transmitted to the
Permittee’s permit coordinator via Ecology’s regional permit manager. The
Permittee shall have 90 days to provide the requested information.
C. Stormwater discharge monitoring.
1. This Section applies only to Permittees who choose to conduct stormwater
discharge monitoring per S8.A.2.b and/or S8.B.2.b in lieu of participation in the
regional status and trends monitoring and/or effectiveness and source
identification studies. These Permittees shall conduct monitoring in accordance
with Appendix 9 and an Ecology-approved Quality Assurance Project Plan (QAPP)
as follows:
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S8.D Payments into the Stormwater Action Monitoring Collective Fund.
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Stormwater Permit – August 1, 2024
vii. Within 60 days of completing the study, or no later than March 31, 2029,
publish a final report with the results of the study and recommended
future actions based on findings, include a summary of results.
D. Payments into the Stormwater Action Monitoring Collective Fund.
1. This Section applies to all Permittees who choose to make annual payments into
the SAM collective funds for S8.A Regional Status and Trends Monitoring and/or
S8.B Effectiveness and Source Identification Studies.
2. Each Permittee’s S8.A and S8.B payment amounts are listed in Appendix 11 and
in the invoices that will be sent to the Permittee approximately three months in
advance of each payment due date. Mail payments according to the instructions
in the invoice.
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S9.A Annual Report Submittal
Western Washington Phase II Municipal Page 68 of 88
Stormwater Permit – August 1, 2024
S9. REPORTING & RECORDKEEPING REQUIREMENTS
A. Annual Report Submittal
1. No later than March 31 of each year beginning in 2025, each Permittee shall
submit an Annual Report. The reporting period for the first Annual Report will be
from January 1, 2024, through December 31, 2024. The reporting period for all
subsequent Annual Reports will be the previous calendar year unless otherwise
specified.
2. Permittees shall submit Annual Reports electronically using Ecology’s Water
Quality Permitting Portal (WQWebPortal) available on Ecology’s website.
3. Permittees unable to submit electronically through Ecology’s WQWebPortal shall
contact Ecology to request a waiver and obtain instructions on how to submit an
annual report in an alternative format.
B. Records Retention
Each Permittee is required to keep all records related to this Permit and the SWMP
for at least five years after the expiration date of this Permit.
C. Records Available to the Public
Each Permittee shall make all records related to this Permit and the Permittee’s
SWMP available to the public at reasonable times during business hours. The
Permittee will provide a copy of the most recent annual report to any individual or
entity, upon request.
1. A reasonable charge may be assessed by the Permittee for making photocopies
of records.
2. The Permittee may require reasonable advance notice of intent to review
records related to this Permit.
D. Annual Report for Cities, Towns, and Counties
Each annual report shall include the following:
1. A copy of the Permittee’s current Stormwater Management Program Plan
(SWMP Plan), as required by S5.A.2.
2. Submittal of the annual report form as provided by Ecology pursuant to S9.A,
describing the status of implementation of the requirements of this Permit
during the reporting period.
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S9.E Annual Report for Secondary Permittees
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Stormwater Permit – August 1, 2024
3. Attachments to the annual report form including summaries, descriptions,
reports, and other information as required, or as applicable, to meet the
requirements of this Permit during the reporting period, or as a required
submittal. Refer to Appendix 3 for annual report questions.43
4. If applicable, notice that the MS4 is relying on another entity to satisfy any of the
obligations under this Permit.
5. Certification and signature pursuant to G19.D, and notification of any changes to
authorization pursuant to G19.C.
6. A notification of any annexations, incorporations or jurisdictional boundary
changes resulting in an increase or decrease in the Permittee’s geographic area
of permit coverage during the reporting period.
E. Annual Report for Secondary Permittees
Each annual report shall include the following:
1. A copy of the Permittee’s current Stormwater Management Program Plan
(SWMP Plan), as required by S6.A.2.
2. Submittal of the annual report form as provided by Ecology pursuant to S9.A,
describing the status of implementation of the requirements of this Permit
during the reporting period.
3. Attachments to the annual report form including summaries, descriptions,
reports, and other information as required, or as applicable, to meet the
requirements of this Permit during the reporting period. Refer to Appendix 4 for
annual report questions.
4. If applicable, notice that the MS4 is relying on another entity to satisfy any of the
obligations under this Permit.
5. Certification and Signature pursuant to G19.D, and notification of any changes to
authorization pursuant to G19.C.
6. A notification of any jurisdictional boundary changes resulting in an increase or
decrease in the Secondary Permittee’s geographic area of permit coverage
during the reporting period.
43New Permittees refer to Appendix 5 for annual report questions.
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General Conditions G1-G3
Western Washington Phase II Municipal Page 70 of 88
Stormwater Permit – August 1, 2024
GENERAL CONDITIONS
G1. DISCHARGE VIOLATIONS
All discharges and activities authorized by this Permit shall be consistent with the terms
and conditions of this Permit.
G2. PROPER OPERATION AND MAINTENANCE
The Permittee shall, at all times, properly operate and maintain all facilities and systems
of collection, treatment, and control (and related appurtenances) which are installed or
used by the Permittee for pollution control to achieve compliance with the terms and
conditions of this Permit.
G3. NOTIFICATION OF DISCHARGE, INCLUDING SPILLS
If a Permittee has knowledge of a discharge, including spills, into or from a MS4 which
could constitute a threat to human health, welfare, or the environment, the Permittee
shall:
A. Take appropriate action to correct or minimize the threat to human health, welfare
and/or the environment;
B. Notify the Ecology regional office and other appropriate spill response authorities
immediately but in no case later than within 24 hours of obtaining that knowledge;
C. Immediately report spills or other discharges which might cause bacterial
contamination of marine waters, such as discharges resulting from broken sewer
lines and failing onsite septic systems, to the Ecology regional office and to the
Department of Health, Shellfish Program; and
D. Immediately report spills or discharges of oils or hazardous substances to the
Ecology regional office and to the Washington Emergency Management Division at
1-800-258-5990.
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General Conditions G4-G7
Western Washington Phase II Municipal Page 71 of 88
Stormwater Permit – August 1, 2024
G4. BYPASS PROHIBITED
The intentional bypass of stormwater from all or any portion of a stormwater treatment
BMP whenever the design capacity of the treatment BMP is not exceeded, is prohibited
unless the following conditions are met:
A. Bypass is: (1) unavoidable to prevent loss of life, personal injury, or severe property
damage; or (2) necessary to perform construction or maintenance-related activities
essential to meet the requirements of the Clean Water Act (CWA); and
B. There are no feasible alternatives to bypass, such as the use of auxiliary treatment
facilities, retention of untreated stormwater, or maintenance during normal dry
periods.
"Severe property damage" means substantial physical damage to property, damage
to the treatment facilities which would cause them to become inoperable, or
substantial and permanent loss of natural resources which can reasonably be
expected to occur in the absence of a bypass.
G5. RIGHT OF ENTRY
The Permittee shall allow an authorized representative of Ecology, upon the
presentation of credentials and such other documents as may be required by law at
reasonable times:
A. To enter upon the Permittee's premises where a discharge is located or where any
records shall be kept under the terms and conditions of this Permit;
B. To have access to, and copy at reasonable cost and at reasonable times, any records
that shall be kept under the terms of the Permit;
C. To inspect at reasonable times any monitoring equipment or method of monitoring
required in the Permit;
D. To inspect at reasonable times any collection, treatment, pollution management, or
discharge facilities; and
E. To sample at reasonable times any discharge of pollutants.
G6. DUTY TO MITIGATE
The Permittee shall take all reasonable steps to minimize or prevent any discharge in
violation of this Permit which has a reasonable likelihood of adversely affecting human
health or the environment.
G7. PROPERTY RIGHTS
This Permit does not convey any property rights of any sort, or any exclusive privilege.
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General Conditions G8-G9
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Stormwater Permit – August 1, 2024
G8. COMPLIANCE WITH OTHER LAWS AND STATUTES
Nothing in the Permit shall be construed as excusing the Permittee from compliance
with any other applicable federal, state, or local statutes, ordinances, or regulations.
G9. MONITORING
A. Representative Sampling
Samples and measurements taken to meet the requirements of this Permit shall be
representative of the volume and nature of the monitored discharge, including
representative sampling of any unusual discharge or discharge condition, including
bypasses, upsets, and maintenance-related conditions affecting effluent quality.
B. Records Retention
The Permittee shall retain records of all monitoring information, including all
calibration and maintenance records and all original recordings for continuous
monitoring instrumentation, copies of all reports required by this Permit, and
records of all data used to complete the application for this Permit, for a period of at
least five years. This period of retention shall be extended during the course of any
unresolved litigation regarding the discharge of pollutants by the Permittee or when
requested by the Ecology. On request, monitoring data and analysis shall be
provided to Ecology.
C. Recording of Results
For each measurement or sample taken, the Permittee shall record the following
information: (1) the date, exact place and time of sampling; (2) the individual who
performed the sampling or measurement; (3) the dates the analyses were
performed; (4) who performed the analyses; (5) the analytical techniques or
methods used; and (6) the results of all analyses.
D. Test Procedures
All sampling and analytical methods used to meet the monitoring requirements in
this Permit shall conform to the Guidelines Establishing Test Procedures for the
Analysis of Pollutants contained in 40 CFR Part 136, unless otherwise specified in this
Permit or approved in writing by Ecology.
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General Conditions G10-G10
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Stormwater Permit – August 1, 2024
E. Flow Measurement
Appropriate flow measurement devices and methods consistent with accepted
scientific practices shall be selected and used to ensure the accuracy and reliability
of measurements of the volume of monitored discharges. The devices shall be
installed, calibrated, and maintained to ensure that the accuracy of the
measurements is consistent with the accepted industry standard for that type of
device. Frequency of calibration shall be in conformance with manufacturer's
recommendations or at a minimum frequency of at least one calibration per year.
Calibration records should be maintained for a minimum of three years.
F. Lab Accreditation
All monitoring data, except for flow, temperature, conductivity, pH, total residual
chlorine, and other exceptions approved by Ecology, shall be prepared by a
laboratory registered or accredited under the provisions of, Accreditation of
Environmental Laboratories, Chapter 173-50 WAC. Soils and hazardous waste data
are exempted from this requirement pending accreditation of laboratories for
analysis of these media by Ecology. Quick methods of field detection of pollutants
including nutrients, surfactants, salinity, and other parameters are exempted from
this requirement when the purpose of the sampling is identification and removal of
a suspected illicit discharge.
G. Additional Monitoring
Ecology may establish specific monitoring requirements in addition to those
contained in this Permit by administrative order or permit modification.
G10. REMOVED SUBSTANCES
With the exception of decant from street waste vehicles, the Permittee shall not allow
collected screenings, grit, solids, sludges, filter backwash, or other pollutants removed in
the course of treatment or control of stormwater to be resuspended or reintroduced to
the MS4 or to waters of the State. Decant from street waste vehicles resulting from
cleaning stormwater facilities may be reintroduced only when other practical means are
not available and only in accordance with the Street Waste Disposal guidelines in
Appendix 6. Solids generated from maintenance of the MS4 may be reclaimed, recycled,
or reused when allowed by local codes and ordinances. Soils that are identified as
contaminated pursuant to Chapter 173-350 WAC shall be disposed at a qualified solid
waste disposal facility (see Appendix 6).
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General Conditions G11-G13
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Stormwater Permit – August 1, 2024
G11. SEVERABILITY
The provisions of this Permit are severable, and if any provision of this Permit, or the
application of any provision of this Permit to any circumstance, is held invalid, the
application of such provision to other circumstances, and the remainder of this Permit
shall not be affected thereby.
G12. REVOCATION OF COVERAGE
The director may terminate coverage under this General Permit in accordance with
Chapter 43.21B RCW and Chapter 173-226 WAC. Cases where coverage may be
terminated include, but are not limited to the following:
A. Violation of any term or condition of this General Permit;
B. Obtaining coverage under this General Permit by misrepresentation or failure to
disclose fully all relevant facts;
C. A change in any condition that requires either a temporary or permanent reduction
or elimination of the permitted discharge;
D. A determination that the permitted activity endangers human health or the
environment, or contributes significantly to water quality standards violations;
E. Failure or refusal of the Permittee to allow entry as required in Chapter 90.48.090
RCW; and
F. Nonpayment of permit fees assessed pursuant to Chapter 90.48.465 RCW.
Revocation of coverage under this General Permit may be initiated by Ecology or
requested by any interested person.
G13. TRANSFER OF COVERAGE
The director may require any discharger authorized by this General Permit to apply for
and obtain an individual permit in accordance with Chapter 43.21B RCW and Chapter
173-226 WAC.
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General Conditions G14-G16
Western Washington Phase II Municipal Page 75 of 88
Stormwater Permit – August 1, 2024
G14. GENERAL PERMIT MODIFICATION AND REVOCATION
This General Permit may be modified, revoked and reissued, or terminated in
accordance with the provisions of Chapter 173-226-230 WAC. Grounds for modification,
revocation and reissuance, or termination include, but are not limited to, the following:
A. A change occurs in the technology or practices for control or abatement of
pollutants applicable to the category of dischargers covered under this General
Permit;
B. Effluent limitation guidelines or standards are promulgated pursuant to the CWA or
Chapter 90.48 RCW, for the category of dischargers covered under this General
Permit;
C. A water quality management plan containing requirements applicable to the
category of dischargers covered under this General Permit is approved;
D. Information is obtained which indicates that cumulative effects on the environment
from dischargers covered under this General Permit are unacceptable; or
E. Changes in state law that reference this Permit.
G15. REPORTING A CAUSE FOR MODIFICATION OR REVOCATION
A Permittee who knows or has reason to believe that any activity has occurred, or will
occur, which would constitute cause for modification or revocation and reissuance
under General Condition G12, G14, or 40 CFR 122.62 shall report such plans, or such
information, to Ecology so that a decision can be made on whether action to modify, or
revoke and reissue, this Permit will be required. Ecology may then require submission of
a new or amended application. Submission of such application does not relieve the
Permittee of the duty to comply with this Permit until it is modified or reissued.
G16. APPEALS
A. The terms and conditions of this General Permit, as they apply to the appropriate
class of dischargers, are subject to appeal within thirty days of issuance of this
General Permit in accordance with Chapter 43.21B RCW, and Chapter 173-226 WAC.
B. The terms and conditions of this General Permit, as they apply to an individual
discharger, are appealable in accordance with Chapter 43.21B RCW within thirty
days of the effective date of coverage of that discharger. Consideration of an appeal
of General Permit coverage of an individual discharger is limited to the General
Permit's applicability or non-applicability to that individual discharger.
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General Conditions G17-G19
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Stormwater Permit – August 1, 2024
C. The appeal of General Permit coverage of an individual discharger does not affect
any other dischargers covered under this General Permit. If the terms and conditions
of this General Permit are found to be inapplicable to any individual discharger(s),
the matter shall be remanded to Ecology for consideration of issuance of an
individual permit or permits.
D. Modifications of this Permit are appealable in accordance with Chapter 43.21B RCW
and Chapter 173-226 WAC.
G17. PENALTIES
40 CFR 122.41(a)(2) and (3), 40 CFR 122.41(j)(5), and 40 CFR 122.41(k)(2) are hereby
incorporated into this Permit by reference.
G18. DUTY TO REAPPLY
The Permittee shall apply for permit renewal at least 180 days prior to the specified
expiration date of this Permit.
G19. Certification and Signature
All formal submittals to Ecology shall be signed and certified.
A. All permit applications shall be signed by either a principal executive officer or
ranking elected official.
B. All formal submittals required by this Permit shall be signed by a person described,
above, or by a duly authorized representative of that person. A person is a duly
authorized representative only if:
1. The authorization is made in writing by a person described, above, and
submitted to Ecology; and
2. The authorization specifies either an individual or a position having responsibility
for the overall development and implementation of the stormwater
management program. A duly authorized representative may thus be either a
named individual or any individual occupying a named position.
C. Changes to authorization. If an authorization under condition G19.B.2 is no longer
accurate because a different individual or position has responsibility for the overall
development and implementation of the stormwater management program, a new
authorization satisfying the requirements of condition G19.B.2 shall be submitted to
Ecology prior to or together with any reports, information, or applications to be
signed by an authorized representative.
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General Conditions G20-G21
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Stormwater Permit – August 1, 2024
D. Certification. Any person signing a formal submittal under this Permit shall make the
following certification:
“I certify, under penalty of law, that this document and all attachments were
prepared under my direction or supervision in accordance with a system designed to
assure that Qualified Personnel properly gathered and evaluated the information
submitted. Based on my inquiry of the person or persons who manage the system or
those persons directly responsible for gathering information, the information
submitted is, to the best of my knowledge and belief, true, accurate, and complete. I
am aware that there are significant penalties for submitting false information,
including the possibility of fine and imprisonment for willful violations.”
G20. Non-compliance notification
In the event a Permittee is unable to comply with any of the terms and conditions of this
Permit, the Permittee shall:
A. Notify Ecology of the failure to comply with the permit terms and conditions in
writing within 30 days of becoming aware that the non-compliance has occurred.
The written notification shall include all of the following:
1. A description of the non-compliance, including dates;
2. Beginning and end dates of the non-compliance, and if the compliance has not
been corrected, the anticipated date of correction; and
3. Steps taken or planned to reduce, eliminate, or prevent reoccurrence of the non-
compliance.
B. Take appropriate action to stop or correct the condition of non-compliance.
G21. UPSETS
Permittees shall meet the conditions of 40 CFR 122.41(n) regarding “Upsets.” The
conditions are as follows:
A. Definition. “Upset” means an exceptional incident in which there is unintentional
and temporary noncompliance with technology-based permit effluent limitations
because of factors beyond the reasonable control of the Permittee. An upset does
not include noncompliance to the extent caused by operational error, improperly
designed treatment facilities, inadequate treatment facilities, lack of preventive
maintenance, or careless or improper operation.
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General Conditions G21-G21
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Stormwater Permit – August 1, 2024
B. Effect of an upset. An upset constitutes an affirmative defense to an action brought
for noncompliance with such technology-based permit effluent limitations if the
requirements of paragraph (C) of this condition are met. Any determination made
during administrative review of claims that noncompliance was caused by upset, and
before an action for noncompliance, will not constitute final administrative action
subject to judicial review.
C. Conditions necessary for demonstration of upset. A Permittee who wishes to
establish the affirmative defense of upset shall demonstrate, through properly
signed contemporaneous operating logs, or other relevant evidence that:
1. An upset occurred and that the Permittee can identify the cause(s) of the upset;
2. The permitted facility was at the time being properly operated;
3. The Permittee submitted notice of the upset as required in 40 CFR
122.41(l)(6)(ii)(B) (24-hour notice of noncompliance); and
4. The Permittee complied with any remedial measures required under 40 CFR
122.41(d) (Duty to Mitigate).
D. Burden of proof. In any enforcement proceeding the Permittee seeking to establish
the occurrence of an upset has the burden of proof.DRAFT
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DEFINITIONS AND ACRONYMS
This Section includes definitions for terms used in the body of the Permit and in all the
appendices except Appendix 1. Terms defined in Appendix 1 are necessary to implement
requirements related to Appendix 1.
40 CFR means Title 40 of the Code of Federal Regulations, which is the codification of the
general and permanent rules published in the Federal Register by the executive departments
and agencies of the federal government.
AKART means All Known, Available, and Reasonable methods of prevention, control, and
Treatment. See also state Water Pollution Control Act, Chapters 90.48.010 and 90.48.520 RCW.
All Known, Available and Reasonable Methods of Prevention, Control and Treatment (AKART)
refers to the state Water Pollution Control Act, Chapters 90.48.010 and 90.48.520 RCW.
Applicable TMDL means a TMDL which has been approved by EPA on or before the issuance
date of this Permit, or prior to the date that Ecology issues coverage under this Permit,
whichever is later.
Arterial Road – means a road or street intended to move high volumes of traffic over long
distances at high speed, with partial control of access, having some intersections at grade. A
major arterial connects an interstate highway to cities and counties. A minor arterial connects
major arterials to collectors. A collector connects an arterial to a neighborhood (a collector is
not an arterial). A local access road connects individual residences to a collector.
Beneficial Uses means uses of waters of the State which include, but are not limited to: use for
domestic, stock watering, industrial, commercial, agricultural, irrigation, mining, fish and
wildlife maintenance and enhancement, recreation, generation of electric power and
preservation of environmental and aesthetic values, and all other uses compatible with the
enjoyment of the public waters of the State.
Best Management Practices are the schedules of activities, prohibitions of practices,
maintenance procedures, and structural and/or managerial practices approved by Ecology that,
when used singly or in combination, prevent or reduce the release of pollutants and other
adverse impacts to waters of Washington State.
BMP means Best Management Practice.
Bypass means the diversion of stormwater from any portion of a stormwater treatment facility.
Circuit means a portion of a MS4 discharging to a single point or serving a discrete area
determined by traffic volumes, land use, topography, or the configuration of the MS4.
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Component or Program Component means an element of the Stormwater Management
Program listed in S5 - Stormwater Management Program for Cities, Towns, and Counties, S6 –
Stormwater Management Program for Secondary Permittees, S7 – Compliance with Total
Maximum Daily Load Requirements, or S8 – Monitoring and Assessment, of this Permit.
Conveyance System means that portion of the municipal separate storm sewer system
designed or used for conveying stormwater.
Co-Permittee means an owner or operator of an MS4 which is in a cooperative agreement with
at least one other applicant for coverage under this Permit. A Co-Permittee is an owner or
operator of a regulated MS4 located within or in proximity to another regulated MS4. A Co-
Permittee is only responsible for permit conditions relating to discharges from the MS4 the Co-
Permittee owns or operates. See also 40 CFR 122.26(b)(1).
CWA means the federal Clean Water Act (formerly referred to as the federal Water Pollution
Control Act or federal Water Pollution Control Act Amendments of 1972) Pub.L. 92-500, as
amended Pub. L. 95-217, Pub. L. 95-576, Pub. L. (6-483 and Pub. L. 97-117, 33 U.S.C. 1251 et
seq.).
Director means the Director of the Washington State Department of Ecology, or an authorized
representative.
Discharge Point means the location where a discharge leaves the Permittee’s MS4 through the
Permittee’s MS4 facilities/BMPs designed to infiltrate.
Entity means a governmental body, or a public or private organization.
EPA means the U.S. Environmental Protection Agency.
Fully Stabilized means the establishment of a permanent vegetative cover, or equivalent
permanent stabilization measures (such as riprap, gabions, or geotextiles) which prevents
erosion.
General Permit means a permit which covers multiple dischargers of a point source category
within a designated geographical area, in lieu of individual permits being issued to each
discharger.
Groundwater means water in a saturated zone or stratum beneath the surface of the land or
below a surface water body. Refer to Chapter 173-200 WAC.
Hazardous Substance means any liquid, solid, gas, or sludge, including any material, substance,
product, commodity, or waste, regardless of quantity, that exhibits any of the physical,
chemical, or biological properties described in Chapter 173-303-090 WAC or Chapter 173-303-
100 WAC.
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Heavy Equipment Maintenance or Storage Yard means an uncovered area where any heavy
equipment, such as mowing equipment, excavators, dump trucks, backhoes, or bulldozers are
washed or maintained, or where at least five pieces of heavy equipment are stored on a long-
term basis.
Highway means a main public road connecting towns and cities.
Hydraulically Near means runoff from the site discharges to the sensitive feature without
significant natural attenuation of flows that allows for suspended solids removal. See Appendix
7- Determining Construction Site Sediment Damage Potential for a more detailed definition.
Hyperchlorinated means water that contains more than 10 mg/Liter chlorine.
Illicit Connection means any infrastructure connection to the MS4 that is not intended,
permitted or used for collecting and conveying stormwater or non-stormwater discharges
allowed as specified in this Permit (S5.C.5 and S6.D.3). Examples include sanitary sewer
connections, floor drains, channels, pipelines, conduits, inlets, or outlets that are connected
directly to the MS4.
Illicit Discharge means any discharge to a MS4 that is not composed entirely of stormwater or
of non-stormwater discharges allowed as specified in this Permit (S5.C.5 and S6.D.3).
Impervious Surface means a non-vegetated surface area that either prevents or retards the
entry of water into the soil mantle as under natural conditions prior to development. A non-
vegetated surface area which causes water to run off the surface in greater quantities or at an
increased rate of flow from the flow present under natural conditions prior to development.
Common impervious surfaces include, but are not limited to, roof tops, walkways, patios,
driveways, parking lots or stormwater areas, concrete or asphalt paving, gravel roads, packed
earthen materials, and oiled, macadam or other surfaces which similarly impede the natural
infiltration of stormwater.
Land Disturbing Activity means any activity that results in a change in the existing soil cover
(both vegetative and non-vegetative) and/or the existing soil topography. Land disturbing
activities include, but are not limited to clearing, grading, filling and excavation. Compaction
that is associated with stabilization of structures and road construction shall also be considered
land disturbing activity. Vegetation maintenance practices, including landscape maintenance
and gardening, are not considered land disturbing activity. Stormwater facility maintenance is
not considered land disturbing activity if conducted according to established standards and
procedures.
LID means Low Impact Development.
LID BMP means Low Impact Development Best Management Practices.
DRAFT
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LID Principles means land use management strategies that emphasize conservation, use of on-
site natural features, and site planning to minimize impervious surfaces, native vegetation loss,
and stormwater runoff.
Low Impact Development (LID) means a stormwater and land use management strategy that
strives to mimic pre-disturbance hydrologic processes of infiltration, filtration, storage,
evaporation and transpiration by emphasizing conservation, use of on-site natural features, site
planning, and distributed stormwater management practices that are integrated into a project
design.
Low Impact Development Best Management Practices (LID BMP) means distributed
stormwater management practices, integrated into a project design, that emphasize pre-
disturbance hydrologic processes of infiltration, filtration, storage, evaporation and
transpiration. LID BMPs include, but are not limited to, bioretention, rain gardens, permeable
pavements, roof downspout controls, dispersion, soil quality and depth, vegetated roofs,
minimum excavation foundations, and water re-use.
Material Storage Facilities means an uncovered area where bulk materials (liquid, solid,
granular, etc.) are stored in piles, barrels, tanks, bins, crates, or other means.
Maximum Extent Practicable refers to paragraph 402(p)(3)(B)(iii) of the federal Clean Water
Act which reads as follows: Permits for discharges from municipal storm sewers shall require
controls to reduce the discharge of pollutants to the maximum extent practicable, including
management practices, control techniques, and system, design, and engineering methods, and
other such provisions as the Administrator or the State determines appropriate for the control
of such pollutants.
MEP means Maximum Extent Practicable.
MS4 means Municipal Separate Storm Sewer System.
Municipal Separate Storm Sewer System means a conveyance, or system of conveyances
(including roads with drainage systems, municipal streets, catch basins, curbs, gutters, ditches,
manmade channels, or storm drains):
1. Owned or operated by a state, city, town, borough, county, parish, district,
association, or other public body (created by or pursuant to state law) having
jurisdiction over disposal of wastes, stormwater, or other wastes, including
special districts under State law such as a sewer district, flood control district or
drainage district, or similar entity, or an Indian tribe or an authorized Indian
tribal organization, or a designated and approved management agency under
Section 208 of the CWA that discharges to waters of Washington State;
2. Designed or used for collecting or conveying stormwater;
3. Which is not a combined sewer;
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4. Which is not part of a Publicly Owned Treatment Works (POTW) as defined at 40
CFR 122.2.; and
5. Which is defined as “large” or “medium” or “small” or otherwise designated by
Ecology pursuant to 40 CFR 122.26.
National Pollutant Discharge Elimination System means the national program for issuing,
modifying, revoking, and reissuing, terminating, monitoring and enforcing permits, and
imposing and enforcing pretreatment requirements, under Sections 307, 402, 318, and 405 of
the federal Clean Water Act, for the discharge of pollutants to surface waters of the State from
point sources. These permits are referred to as NPDES permits and, in Washington State, are
administered by the Washington State Department of Ecology.
Native Vegetation means vegetation comprised of plant species, other than noxious weeds,
that are indigenous to the coastal region of the Pacific Northwest, and which reasonably could
have been expected to naturally occur on the site. Examples include trees such as Douglas Fir,
western hemlock, western red cedar, alder, big-leaf maple; shrubs such as willow, elderberry,
salmonberry, and salal; and herbaceous plants such as sword fern, foam flower, and fireweed.
New Development means land disturbing activities, including Class IV General Forest Practices
that are conversions from timber land to other uses; structural development, including
construction or installation of a building or other structure; creation of hard surfaces; and
subdivision, short subdivision and binding site plans, as defined and applied in Chapter 58.17
RCW. Projects meeting the definition of redevelopment shall not be considered new
development. Refer to Appendix 1 for a definition of hard surfaces.
New Permittee means a city, town, or county that is subject to the Western Washington
Municipal Stormwater General Permit and was not subject to the permit prior to July 1, 2024.
New Secondary Permittee means a Secondary Permittee that is covered under a Municipal
Stormwater General Permit and was not covered by the permit prior to July 1, 2024.
NOI means Notice of Intent.
Notice of Intent (NOI) means the application for, or a request for coverage under, a General
Permit pursuant to Chapter 173-226-200 WAC.
Notice of Intent for Construction Activity means the application form for coverage under the
Construction Stormwater General Permit.
Notice of Intent for Industrial Activity means the application form for coverage under the
Industrial Stormwater General Permit.
NPDES means National Pollutant Discharge Elimination System.
DRAFT
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Outfall means a point source as defined by 40 CFR 122.2 at the point where a discharge leaves
the Permittee’s MS4 and enters a surface receiving waterbody or surface receiving waters.
Outfall does not include pipes, tunnels, or other conveyances which connect segments of the
same stream or other surface waters and are used to convey primarily surface waters (i.e.,
culverts).
Overburdened Community means a geographic area where vulnerable populations face
combined, multiple environmental harms and health impacts, and includes, but is not limited
to, highly impacted communities.
“Vulnerable populations" means population groups that are more likely to be at higher
risk for poor health outcomes in response to environmental harms, due to:
(i) Adverse socioeconomic factors, such as unemployment, high housing and
transportation costs relative to income, limited access to nutritious food and
adequate health care, linguistic isolation, and other factors that negatively affect
health outcomes and increase vulnerability to the effects of environmental
harms; and
(ii) Sensitivity factors, such as low birth weight and higher rates of hospitalization.
"Vulnerable populations" includes, but is not limited to:
• Racial or ethnic minorities;
• Low-income populations;
• Populations disproportionately impacted by environmental harms; and
• Populations of workers experiencing environmental harms.
“Highly impacted community" means a community designated by the Department of
Health based on cumulative impact analyses or a community located in census tracts
that are fully or partially on "Indian country" as defined in 18 U.S.C. Sec. 1151.
PCBs means Polychlorinated biphenyls.
Permittee unless otherwise noted, the term “Permittee” includes city, town, or county
Permittee, Co-Permittee, New Permittee, Secondary Permittee, and New Secondary Permittee.
PFAS means Per and Polyfluorinated Substances
Physically Interconnected means that one MS4 is connected to another storm sewer system in
such a way that it allows for direct discharges to the second system. For example, the roads
with drainage systems and municipal streets of one entity are physically connected directly to a
storm sewer system belonging to another entity.
DRAFT
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Project site means that portion of a property, properties, or rights-of-way subject to land
disturbing activities, new hard surfaces, or replaced hard surfaces. Refer to Appendix 1 for a
definition of hard surfaces.
QAPP means Quality Assurance Project Plan.
Qualified Personnel means someone who has had professional training in the aspects of
stormwater management for which they are responsible and are under the functional control
of the Permittee. Qualified Personnel may be staff members, contractors, or trained volunteers
with professional certification. Permittees may train and certify volunteers.
Qualified Third Party means someone who has had professional training in the aspects of
stormwater management for which they are responsible but are hired by private entities and
not under the functional control of the Permittee. Qualified Third Parties may be contractors,
or consultants.
Quality Assurance Project Plan means a document that describes the objectives of an
environmental study and the procedures to be followed to achieve those objectives.
RCW means the Revised Code of Washington State.
Receiving Waterbody or Receiving Waters means naturally and/or reconstructed naturally
occurring surface water bodies, such as creeks, streams, rivers, lakes, wetlands, estuaries, and
marine waters, or groundwater, to which a MS4 discharges.
Redevelopment means, on a site that is already substantially developed (i.e., has 35% or more
of existing hard surface coverage), the creation or addition of hard surfaces; the expansion of a
building footprint or addition or replacement of a structure; structural development including
construction, installation or expansion of a building or other structure; replacement of hard
surface that is not part of a routine maintenance activity; and land disturbing activities. Refer to
Appendix 1 for a definition of hard surfaces.
Regulated Small Municipal Separate Storm Sewer System means a Municipal Separate Storm
Sewer System which is automatically designated for inclusion in the Phase II stormwater
permitting program by its location within an Urban Area, or by designation by Ecology and is
not eligible for a waiver or exemption under S1.C.
Runoff is water that travels across the land surface and discharges to water bodies either
directly or through a collection and conveyance system. See also “Stormwater.”
SAM means Stormwater Action Monitoring
Secondary Permittee is an operator of a regulated small MS4 which is not a city, town or
county. Secondary Permittees include special purpose districts and other public entities that
meet the criteria in S1.B.
DRAFT
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Sediment/Erosion-Sensitive Feature means an area subject to significant degradation due to
the effects of construction runoff, or areas requiring special protection to prevent erosion. See
Appendix 7 Determining Construction Site Sediment Damage Potential for a more detailed
definition.
Shared Water Bodies means water bodies, including downstream segments, lakes and
estuaries that receive discharges from more than one Permittee.
Significant Contributor means a discharge that contributes a loading of pollutants considered
to be sufficient to cause or exacerbate the deterioration of receiving water quality or instream
habitat conditions.
Small Municipal Separate Storm Sewer System means an MS4 that is not defined as “large” or
“medium” pursuant to 40 CFR 122.26(b)(4) & (7) or designated under 40 CFR 122.26 (a)(1)(v).
Source Control BMP means a structure or operation that is intended to prevent pollutants from
coming into contact with stormwater through physical separation of areas or careful
management of activities that are sources of pollutants. The SWMMWW separates source
control BMPs into two types. Structural Source Control BMPs are physical, structural, or
mechanical devices, or facilities, that are intended to prevent pollutants from entering
stormwater. Operational BMPs are non-structural practices that prevent or reduce pollutants
from entering stormwater.
Stormwater means runoff during and following precipitation and snowmelt events, including
surface runoff, drainage or interflow.
Stormwater Action Monitoring (SAM) is the regional stormwater monitoring program for
Washington State. This means a stormwater-focused monitoring and assessment program
consisting of these components: status and trends monitoring in small streams and marine
nearshore areas, stormwater management program effectiveness studies, and source
identification projects. The priorities and scope for SAM are set by a formal stakeholder group
that selects the studies and oversees the program’s administration.
Stormwater Associated with Industrial and Construction Activity means the discharge from
any conveyance which is used for collecting and conveying stormwater, which is directly related
to manufacturing, processing, or raw materials storage areas at an industrial plant, or
associated with clearing, grading and/or excavation, and is required to have an NPDES permit in
accordance with 40 CFR 122.26.
Stormwater Facility Retrofits means both: projects that retrofit existing treatment and/or flow
control facilities; and new flow control or treatment facilities or BMPs that will address impacts
from existing development.
DRAFT
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Stormwater Management Program (SWMP) means a set of actions and activities designed to
reduce the discharge of pollutants from the MS4 to the MEP and to protect water quality, and
comprising the components listed in S5 (for cities, towns, and counties) or S6 (for Secondary
Permittees) of this Permit and any additional actions necessary to meet the requirements of
applicable TMDLs pursuant to S7 –Compliance with TMDL Requirements, and S8– Monitoring
and Assessment.
Stormwater Treatment and Flow Control BMPs/Facilities means detention facilities,
permanent treatment BMPs/facilities; and bioretention, vegetated roofs, and permeable
pavements that help meet Appendix 1 Minimum Requirements #6 (treatment), #7 (flow
control), or both.
Surface Waters includes lakes, rivers, ponds, streams, inland waters, salt waters, and all other
surface waters and water courses within the jurisdiction of the State of Washington.
SWMMWW or Stormwater Management Manual for Western Washington means the
technical manual published by the Department of Ecology in 2024 (Publication No. 19-10-021)
(2024).
SWMP means Stormwater Management Program.
TMDL means Total Maximum Daily Load.
Total Maximum Daily Load (TMDL) means a water cleanup plan. A TMDL is a calculation of the
maximum amount of a pollutant that a water body can receive and still meet water quality
standards, and an allocation of that amount to the pollutant’s sources. A TMDL is the sum of
the allowable loads of a single pollutant from all contributing point and nonpoint sources. The
calculation must include a margin of safety to ensure that the water body can be used for the
purposes the state has designated. The calculation must also account for seasonable variation
in water quality. Water quality standards are set by states, territories, and tribes. They identify
the uses for each water body, for example, drinking water supply, contact recreation
(swimming), and aquatic life support (fishing), and the scientific criteria to support that use. The
Clean Water Act, Section 303, establishes the water quality standards and TMDL programs.
Tributary Conveyance means pipes, ditches, catch basins, and inlets owned or operated by the
Permittee and designed or used for collecting and conveying stormwater.
UGA means Urban Growth Area.
Urban Growth Area (UGA) means those areas designated by a county pursuant to Chapter
36.70A.110 RCW.
Urban Area means urban areas with a population of 50,000 or more people. Urban Areas are
designated by the U.S. Census Bureau based on the most recent decennial census.
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Vehicle Maintenance or Storage Facility means an uncovered area where any vehicles are
regularly washed or maintained, or where at least 10 vehicles are stored.
Water Quality Standards means Surface Water Quality Standards, Chapter 173-201A WAC,
Groundwater Quality Standards, Chapter 173-200 WAC, and Sediment Management Standards,
Chapter 173-204 WAC.
Waters of the State includes those waters as defined as "waters of the United States" in 40 CFR
Subpart 122.2 within the geographic boundaries of Washington State and "waters of the State"
as defined in Chapter 90.48 RCW which includes lakes, rivers, ponds, streams, inland waters,
underground waters, salt waters and all other surface waters and water courses within the
jurisdiction of the State of Washington.
Waters of the United States refers to the definition in 40 CFR 122.2.
DRAFT
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Draft Comprehensive Storm Drainage Plan Update
City of Auburn
June 2024 │ 553-1931-052 11-4
Appendix B
Hydrologic and Hydraulic
Modeling Analysis
Page 261 of 373
Draft Technical Memorandum
Limitations:
This is a draft memorandum and is not intended to be a final representation of the work done or recommendations made by Brown and Caldwell. It
should not be relied upon; consult the final report.
This document was prepared solely for Parametrix, Inc. in accordance with professional standards at the time the services were performed and in
accordance with the contract between Parametrix, Inc. and Brown and Caldwell dated 5/23/2022. This document is governed by the specific scope
of work authorized by Parametrix, Inc.; it is not intended to be relied upon by any other party except for regulatory authorities contemplated by the
scope of work. We have relied on information or instructions provided by Parametrix, Inc. and other parties and, unless otherwise expressly
indicated, have made no independent investigation as to the validity, completeness, or accuracy of such information.
701 Pike Street, Suite 1300
Seattle, WA 98101-2310
T: 206.624.0100
Prepared for: Parametrix
Project Title: 2024 Comprehensive Storm Drainage Plan
Project No.: 158561
Draft Technical Memorandum
Subject: Hydrologic and Hydraulic Modeling for Capital Improvement Projects
Date: March 26, 2024
To: Paul Fendt, PE
Alex Van Kirk, EIT
From: Margaret Ales, PE
Copy to: Madison Thompson, EIT
Prepared by:
Margaret Ales, PE
Reviewed by:
Mike Milne
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ii
DRAFT for review purposes only. Use of contents on this sheet is subject to the limitations specified at the beginning of this document.
Table of Contents
Section 1: Introduction ............................................................................................................................................. 1
Section 2: Input Data and Model Updates .............................................................................................................. 2
2.1 Precipitation Record Extension ......................................................................................................................... 2
2.2 Model Refinement ............................................................................................................................................. 2
2.2.1 GHI Subbasin Model .......................................................................................................................... 3
2.2.2 BCDF Subbasin Model ....................................................................................................................... 4
2.2.3 AZ Subbasin Model ............................................................................................................................ 4
2.2.4 R Subbasin Model.............................................................................................................................. 4
2.3 Flow Frequency and Design Storms ................................................................................................................. 4
2.4 Potential Project Evaluations ............................................................................................................................ 6
2.4.1 Included Projects ............................................................................................................................... 7
2.4.2 Excluded Projects ............................................................................................................................ 12
References .............................................................................................................................................................. 17
List of Figures
Figure B-1. Subbasin Models Updated on Behalf of Auburn’s 2024 Comprehensive Storm Drainage Plan ..... 3
Figure B-2. R Street SE Widening Project Subbasins ............................................................................................. 8
Figure B-3. Plan View of R Street SE Widening and Future CIP (BCDF Subbasin Model,
25-year storm flows [1/9/1990]) ..................................................................................................................... 9
Figure B-4. Hydraulic Grade Line Profile View of R Street SE Widening and Future CIP (BCDF Subbasin Model,
25-year storm flows [1/9/1990]) ..................................................................................................................... 9
Figure B-5. Plan View of R Street SE Widening and Future CIP (AZ Subbasin Model,
25-year storm flows [9/7/2019]) ................................................................................................................... 10
Figure B-6. Hydraulic Grade Line Profile View of R Street SE Widening and Future CIP (AZ Subbasin Model,
25-year storm flows [9/7/2019]) ................................................................................................................... 10
Figure B-7. Plan View of R Street SE Widening and Future CIP (R Subbasin Model, 25-year storm flows
[10/20/2003]) ................................................................................................................................................. 11
Figure B-8. Hydraulic Grade Line Profile View of R Street SE Widening and Future CIP (R Subbasin Model,
25-year storm flows [10/20/2003]) .............................................................................................................. 11
Figure B-9. Flooding impacts of 30th Street NE Area Flooding, Phase 3 Project at the Airport Property Low
Area (catch basin 409-I51) ............................................................................................................................. 13
Figure B-10. Hydraulic Grade Line in 30th Street NE (from the Airport Property to I Street NE)
Comparison of Existing Conditions and Proposed Conditions from the 30th Street NE Area Flooding,
Phase 3 Project ................................................................................................................................................ 14
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DRAFT for review purposes only. Use of contents on this sheet is subject to the limitations specified at the beginning of this document.
Figure B-11. Comparison of Hydraulic Grade Line in Vicinity of Auburn Way South and
SR 18 Westbound Off-Ramp Intersection for Evaluation Scenarios ............................................................ 15
Figure B-12. Flooding at Low Inlet (809-B33) near Auburn Way South and
SR 18 Westbound Offramp Intersection for Evaluation Scenarios............................................................... 16
List of Tables
Table B-1. 2024 Plan Potential Project Modeling Summary ................................................................................. 1
Table B-2. Auburn Composite Precipitation Record Summary .............................................................................. 2
Table B-3. GHI Subbasin Frequency Analysis Summary ........................................................................................ 5
Table B-4. BCDF Subbasin Frequency Analysis Summary ..................................................................................... 5
Table B-5. AZ Subbasin Frequency Analysis Summary .......................................................................................... 6
Table B-6. R Subbasin Frequency Analysis Summary ............................................................................................ 6
Table B-7. Design Storms by Subbasin Summary .................................................................................................. 6
Table B-8. 2024 Plan Potential Projects and Evaluation Status ........................................................................... 7
Table B-9. R Street SE Widening Project and Future CIP Recommendations .................................................... 12
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DRAFT for review purposes only. Use of contents on this sheet is subject to the limitations specified at the beginning of this document.
Section 1: Introduction
As part of the City of Auburn (City) 2024 Comprehensive Storm Drainage Plan (Plan) update, Brown and
Caldwell (BC) performed hydrologic and hydraulic (H&H) modeling analysis to evaluate existing drainage
problems and capital solutions. BC performed the analysis with updated existing models and an extended
meteorological time series.
The City initiated an extensive drainage system data inventory and H&H modeling effort to support the
2009 and 2015 Comprehensive Storm Drainage Plans (2009 Plan and 2015 Plan, respectively). After
the 2009 and 2015 Plans, the City refined and developed new H&H models. As a result, 16 storm drainage
system models have been created or refined for areas throughout the City. Each model is identified by the
lettered subbasin drainage area(s) covered with the model extent. For example, the GHI model covers three
subbasins: G, H, and I. Two of the 16 models (BCDF and GHI) were calibrated as part of the 2015 Plan and
then updated after the 2015 Plan with new stormwater infrastructure, refined subbasin delineations, and
refined calibration with monitored flow data.
The City reviewed the projects from the 2015 Plan and other more recent potential projects considered on
behalf of this Plan. Of these, six potential projects were chosen for H&H modeling to evaluate whether they
should be included as capital improvement projects (CIP) in the 2024 Plan.
Table B-1 summarizes the potential projects modeled as part of the 2024 Plan.
Table B-1. 2024 Plan Potential Project Modeling Summary
2024
Project ID1 Project Name
Subbasin Model
Name Project Description and Status
CP2116 R Street SE Widening - 22nd Street SE to
33rd Street SE BCDF, AZ, and R Stormwater capacity project evaluated as part of a comprehensive
roadway improvement project. Currently at 60% design.
9 30th Street NE Area Flooding, Phase 2 GHI
Stormwater capacity capital improvement project (CIP) identified in the
2015 Plan (2015 Plan CIP ID is 4A).
Minor piping improvements in 2018 may have reduced flooding problem.
- 30th Street NE Area Flooding, Phase 3 GHI Stormwater capacity CIP previously identified in the 2015 Plan (2015
Plan CIP ID is 4B).
- West Hills Drainage Improvements near S
314th Street & 54th Avenue S No model Relocate stormwater flows to public conveyance. CIP was previously
identified in 2015 Drainage Plan (2015 Plan CIP ID is 5B).
11 Christa Ministries Facility Retrofit GHI New water quality improvement CIP identified as part of the 2024 Plan.
- 17th Street Pond Capacity BCDF New stormwater system capacity improvement project identified as part
of the 2024 Plan.
1 If the project was selected to carry forward as one of the capital improvement projects (CIP) within the 2024 Plan, it was given a numerical ID ranging from 1 to 16. Projects
that were included within the City’s capital facilities plan (CFP) follow the format of CPXXXX for their project IDs, where the Xs represent numeric placeholders. Line items
with neither a CIP ID on behalf of the 2024 Plan, nor a CFP ID were evaluated as part of the modeling effort but were not chosen to carry forward as a 2024 CIP or within
the CFP.
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Section 2: Input Data and Model Updates
This section describes updates to the precipitation record and H&H models used to evaluate the potential
projects listed in Table B-1.
2.1 Precipitation Record Extension
Auburn’s H&H models use historical meteorological data to estimate stormwater flows and storage within
the City’s storm drainage system. The data consists of monthly evaporation and 15-minute precipitation
depths. As part of the 2024 Plan, BC extended the 15-minute precipitation record to September 30, 2022,
creating a 75-year precipitation record.
The Auburn precipitation record used for modeling is a composite from several rain gauges. The preferred
rain gauge is located at Auburn City Hall and is maintained and operated by King County (King County 2022).
Rainfall is used from other gauges when the City Hall gauged data is not available. Table B-2 summarizes
the data sources for the composite precipitation record.
Table B-2. Auburn Composite Precipitation Record Summary
Source Period Notes
SeaTac Rainfall from WWHM2012 10/01/1948 00:00 to
11/30/2007 23:45
Lakeland Hills 12/01/2007 00:00 to
12/06/2007 23:45
SeaTac 15-minute data not representative of Auburn hourly data.
SeaTac Rainfall from WWHM2012 12/07/2007 00:00 to
12/31/2009 23:45
City of Auburn 15-minute rainfall 01/01/2010 00:00 to
12/31/2010 23:45
City of Auburn aggregated 5-minute 01/01/2011 00:00 to 11/14/2012
Lakeland Hills 11/14/2012 to 12/05/2012 City Hall rain gauge error (rain gauge top blew off).
City of Auburn aggregated 5-minute 12/05/2011 00:00 to
09/30/2022 23:45
WWHM2012 = Western Washington Hydrology Model
2.2 Model Refinement
Auburn’s H&H models have been updated and refined since the calibration efforts performed on behalf of
the 2015 Plan. Updates include refining basin delineation and adding storm drainage features (conveyance
and structures) from recently constructed projects. Four subbasin models were updated as part of the
2024 Plan or under a separate modeling contract, GHI, BCDF, AZ, and R. The model updates are described
below. Figure B-1 shows the four subbasin models updated as part of the 2024 Plan relative to the
City extent.
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Figure B-1. Subbasin Models Updated on Behalf of Auburn’s 2024 Comprehensive Storm Drainage Plan
2.2.1 GHI Subbasin Model
Since the 2015 Plan, BC has updated the calibrated GHI subbasin model with new stormwater projects at
the City of Auburn Airport and used updated geographic information system (GIS) data to refine subbasin
boundaries in the vicinity of the Brannan Park pump station.
Airport Area Updates. Model updates at the airport include those associated with CP1516 Runway
16-34 Extension and Change Order #2 and CP2118 North Airport Stormwater Improvements Phase 2.
Key model updates from these projects included:
• Adding new impervious area, refining subbasin boundaries, and adding ChamberMaxx stormwater
detention for the 16-34 runway extension.
• Isolating Pond I and the low elevation area (north hangar area) on airport property from the stormwater
system in 30th Street NE so that high flows in the 30th Street NE system do not backwater to the pond
and flood the low north hangar area.
• Making better use of storage in Pond I by reconfiguring connecting airport property stormwater pipes.
• Filling in Pond F and routing the Corporate Park Pump Station flows to Pond G.
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Brannan Park Pump Station Area Updates. BC refined the GHI model in the vicinity of Brannan Park Pump
Station. Upstream of the pump station near I Street NE and 32nd Place NE, new storm pipe was added that
routes roadway runoff to the main trunk line in 30th Street NE. Downstream of the pump station, the model
was updated from a simplified outfall to a force main connection to the outfall at Reddington wet
biofiltration swale.
2.2.2 BCDF Subbasin Model
BC updated the calibrated BCDF model to reflect recent or imminent stormwater conveyance projects.
• CP1726–2019 Local Street Reconstruction As-Builts (M Street between 25th Street SE and
29th Street SE, and 28th Street SE between M Street SE and T Street SE). This project was part of a
street improvement project that helped improve conveyance capacity. The project included new pipe
alignments and changes to the drainage basin delineation adding 7 acres to the B subbasin from the
adjacent AZ subbasin.
• CP1614–2017 Local Street Reconstruction and Preservation As-Builts (R Street from 28th Street SE to
25th Street SE, 28th Street SE from R Street SE to T Street SE and portions of T Street SE, U Street SE,
27th Street SE and 26th Street SE). This project was part of a street improvement project that helped
improve conveyance capacity. The project resulted in a new pipe alignment and changes to the drainage
basin delineation. In addition, approximately 1.9 acres of the CIP1614 project is routed to infiltration
facilities. The effective impervious area of the model was reduced by the amount of area routed to
infiltration pipes and facilities.
• CP2125–D Street SE and 23rd Street SE Storm Improvements 90% Submittal. This project, identified
as Project 7 and Project 8 in the 2015 Plan, will improve system capacity by constructing new
conveyance in D Street SE (Project 7) from 27th Street SE to 21st Street SE, in 21st Street SE near
D Street SE and in 25th Street SE near D Street SE. Improvements in 23rd Street SE and K Street SE
(Project 8) were included in the plan set but may not be included in the imminent bid set. However,
Project 8 improvements were included in the model update to reflect ultimate post-project conditions.
These include conveyance improvements in 23rd Street SE near F Street SE and in K Street SE between
23rd Street SE and 21st Street SE.
2.2.3 AZ Subbasin Model
BC updated the uncalibrated AZ model to reflect recent improvements associated with CP1726 and CP1614
projects described above.
2.2.4 R Subbasin Model
BC updated the uncalibrated R basin model conveyance, hydrologic parameters, and basin delineation to be
current with other adjacent models (AZ subbasin model). The City has not used the R Basin for any existing
or proposed condition evaluations since the subbasin model was developed as part of the 2009 Plan.
2.3 Flow Frequency and Design Storms
After the basin models were updated to reflect existing and imminent CIP conditions, a frequency analysis
was completed for each model by performing a long-term simulation (from 1948 to 2022). The long-term
flow timeseries were then used to determine the 2% and 4% exceedance storms (one-in-50-year and one-in-
25-year flows, respectively) per subbasin model. These storms are used as design storms to evaluate the
potential projects listed in Table B-1.
For the long-term simulations, the hydraulic networks of the models were modified so that there were no
restrictions to flow and there was free discharge at outfalls. As a result, all simulated runoff could be
conveyed without substantial system storage and attenuation.
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The event peak flows from the simulations were selected in PCSWMM 1 using two event-based criteria:
Minimum inter-event time (time between peak storms) of 12 hours and a flow threshold (varies by subbasin).
The peak flows were ranked, and the flow frequencies were established with estimators derived from
Cunnane plotting position formulae. The events associated with the 25-year peak flows were used to size
storm drainage conveyance to meet the relevant level of service. The results of the flow frequency analysis
for the GHI, BCDF, AZ, and R subbasin models are provided in Tables B-3, B-4, B-5, and B-6, respectively.
Table B-7 lists the storms that generated the 100-, 50-, and 25-year flows for the subbasin models.
Flow frequencies are unique to each subbasin because of the different hydrologic and hydraulic
characteristics of each subbasin. As a result, the storms associated with the return periods are different for
each basin.
Table B-3. GHI Subbasin Frequency Analysis Summary
Peak flow rank Event start date/time Peak event flow (cubic feet per second) a Return period (year)
1 10/20/2003 4:30 105.0 123.7
2 9/18/2021 15:25 88.6 46.4
3 11/6/2006 0:20 88.5 28.5
4 1/9/1990 4:35 87.4 20.6
5 11/18/2003 10:25 86.0 16.1
6 11/4/2006 15:15 84.4 13.3
7 11/24/1990 4:50 80.1 11.2
8 10/5/1981 23:20 76.4 9.8
a. Peak flow measured at inflow to Brannan Park pump station.
Table B-4. BCDF Subbasin Frequency Analysis Summary
Peak flow rank Event start date/time Peak event flow (cubic feet per second) a Return period (year)
1 10/20/2003 4:15 109.6 125.3
2 11/6/2006 0:20 94.5 47.0
3 1/9/1990 4:30 73.8 28.9
4 10/5/1981 23:15 61.3 20.9
5 11/4/1998 19:30 45.5 16.3
6 11/4/2006 16:05 44.6 13.4
7 11/18/2003 10:25 39.9 11.4
8 11/24/1990 4:45 39.5 9.9
a. Peak flow measured at inflow to 17th Street Pond.
1 PCSWMM is a GIS-based hydraulic and hydrologic modeling platform developed by Computational Hydraulics International
(CHI). The software fully supports the Environmental Protection Agency (EPA) SWMM5 hydrology and hydraulics engine, thus
providing comparable computation between EPA SWMM and PCSWMM models. Information about PCSWMM software can
be found at http://www.chiwater.com/Software/PCSWMM/index.asp.
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Table B-5. AZ Subbasin Frequency Analysis Summary
Peak flow rank Event start date/time Peak event flow (cubic feet per second) a Return period (year)
1 9/18/2021 15:20 35.8 125.3
2 10/20/2003 4:25 33.1 47.0
3 9/7/2019 20:40 32.7 28.9
4 9/12/2004 1:20 32.3 20.9
5 11/4/1998 19:20 32.2 16.3
6 11/4/2006 15:15 31.15 13.4
7 1/9/1990 4:45 31.08 11.4
8 12/14/1979 21:05 31.07 9.9
a. Peak flow measured at inflow to 36th Street Pond at M Street.
Table B-6. R Subbasin Frequency Analysis Summary
Peak flow rank Event start date/time Peak event flow (cubic feet per second) a Return period (year)
1 9/18/2021 15:15 27.7 125.3
2 9/7/2019 20:35 26.3 47.0
3 10/20/2003 9:20 25.5 28.9
4 9/12/2004 1:15 25.0 20.9
5 12/14/1979 21:00 23.7 16.3
6 7/6/2018 18:30 23.1 13.4
7 11/4/2006 15:10 23.0 11.4
8 1/9/1990 5:00 22.8 9.9
a. Peak flow measured at outfall to White River at R Street and 37th.
Table B-7. Design Storms by Subbasin Summary
Basin
100-year 50-year 25-year
Flow Measurement Location
Start Date
Peak Flow Duration
(hour) Start Date
Peak Flow
Duration
(hour) Start Date
Peak Flow Duration
(hour)
GHI 10/20/2003 32 9/18/2021 1 11/6/2006 38 Inflow to Brannan Park Pump
Station
BCDF 10/20/2003 20 11/6/2006 17 1/9/1990 8 Inflow to 17th Street Pond
AZ 9/18/2021 1 10/20/2003 16 9/7/2019 1 Inflow to 36th Street Pond
R 9/18/2021 1 9/7/2019 1 10/20/2003 11 Outfall to White River at R Street
2.4 Potential Project Evaluations
Of the six projects considered for inclusion in the 2024 Plan (see Table B-1), two were evaluated with the
updated subbasin models and considered viable projects. Another two were evaluated but considered not
viable because the proposed project would provide little improvement to capacity or reduce conveyance
capacity. The City initially decided to defer the remaining two projects to the next planning period, so BC did
not evaluate them. However, after reevaluation, the City decided to include one of these two projects, the
30th Street NE Area Flooding, Phase 2 project, as a CIP in the 2024 Plan.
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Table B-8 lists the potential projects, associated model(s), and status.
Table B-8. 2024 Plan Potential Projects and Evaluation Status
2024 Project
ID1 Project Name
Associated Model
Name Project Evaluation Status
CP2116 R Street SE Widening - 22nd Street SE to 33rd Street SE BCDF, AZ, and R Evaluated and included in 2024 Plan. 11 Christa Ministries Facility Retrofit GHI
- 30th Street NE Area Flooding, Phase 3 GHI Evaluated and not included in 2024 Plan. - 17th Street Pond Capacity BCDF
- West Hills Drainage Improvements near S 314th Street & 54th
Avenue S No model Not evaluated. Deferred to later planning
period.
9 30th Street NE Area Flooding, Phase 2 GHI Not evaluated but included in 2024 Plan.
1 If the project was selected to carry forward as one of the capital improvement projects (CIP) within the 2024 Plan, it was given a numerical ID ranging from 1-16. Projects
that were included within the City’s capital facilities plan (CFP) follow the format of CPXXXX for their project IDs, where the Xs represent numeric placeholders. Line items
with neither a CIP ID on behalf of the 2024 Plan, nor a CFP ID were evaluated as part of the modeling effort but were not chosen to carry forward as a 2024 CIP or within
the CFP.
2.4.1 Included Projects
2.4.1.1 CP2116–R Street SE Widening - 22nd Street SE to 33rd Street SE
The R Street SE Widening project CP2116 is currently in design and estimated to begin construction
in 2025. The project will improve the R Street SE/29th Street SE intersection, add a new southbound lane
from 22nd Street NE to 33rd Street NE, and provide new roadway surface from 22nd Street SE to the White
River bridge. As part of the project, the City is improving underground utilities as needed, including storm
drainage, sewer pipe, and water lines.
The project lies within three drainage subbasins (B, A, and R subbasins) and, as a result, is represented in
three of the City’s subbasin models (BCDF, AZ, and R). Figure B-2 shows the project extent and the modeled
subbasin delineation.
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Figure B-2. R Street SE Widening Project Subbasins
BC evaluated the project at the 60% design phase with the 25-year storm flows developed for the BCDF, AZ,
and R subbasin models. For all three model evaluations, the design storm simulation showed flooding within
the project area resulting from downstream backwater. City staff recommended sizing the R Street SE
project pipes assuming downstream impacts are alleviated as part of a future CIP. This evaluation resulted
in increased pipe sizes for the R Street SE Project and the identification of the need for a future
downstream CIP.
Figures B-3 through B-8 show the plan and profile for the 25-year design storm of the R Street SE Widening
project and the future CIP needed to alleviate flooding in the project area from backwater. Table B-9
summarizes the recommended pipe sizes for the R Street SE Widening project and the future CIP.
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Figure B-3. Plan View of R Street SE Widening and Future CIP (BCDF Subbasin Model,
25-year storm flows [1/9/1990])
Figure B-4. Hydraulic Grade Line Profile View of R Street SE Widening and Future CIP (BCDF Subbasin Model,
25-year storm flows [1/9/1990])
R Street SE and 28th
Street SE
R Street SE and 21st
Street SE
21st Street SE and K
Street SE
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Figure B-5. Plan View of R Street SE Widening and Future CIP (AZ Subbasin Model, 25-year storm flows [9/7/2019])
Figure B-6. Hydraulic Grade Line Profile View of R Street SE Widening and Future CIP (AZ Subbasin Model,
25-year storm flows [9/7/2019])
R Street SE and 28th
Street SE 29th Street SE and M
Street SE
M Street SE and 37th
Street SE
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Figure B-7. Plan View of R Street SE Widening and Future CIP (R Subbasin Model, 25-year storm flows [10/20/2003])
Figure B-8. Hydraulic Grade Line Profile View of R Street SE Widening and Future CIP (R Subbasin Model,
25-year storm flows [10/20/2003])
R Street SE near 31st
Street SE
R Street SE and 37th Way
SE
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Table B-9. R Street SE Widening Project and Future CIP Recommendations
Street
Location
Subbasin
Model Name
25-year Design
Storm Start
Date
2024 CIP Recommendations Future CIP Recommendations
R Street SE
from 28th
Street SE to
25th Street SE
R Street SE
from 25th
Street SE to
22nd Street SE
BCDF 1/9/1990
Upgrade pipe from 12-inch diameter to 18-inch
diameter in R Street SE from 28th Street SE to
25th Street SE
Upgrade pipe from 18-inch diameter to 24-inch
diameter in 1st Street SE
Upgrade pipe from 18-inch diameter to 24-inch
diameter in 21st Street SE from R Street SE to M
Street SE
Upgrade pipe from 24-inch diameter to 36-inch
diameter in 21st Street SE from M Street SE to K
Street SE
R Street SE
from 28th
Street SE to
29th Street SE
AZ 9/7/2019
Upgrade pipe from 10-inch diameter to 24-inch
diameter in R Street SE from 28th Street SE
south to approximately 225 ft of 29th Street SE
Upgrade pipe from 10-inch diameter to 24-inch
diameter in 29th Street SE from R Street SE to M
Street SE
Upgrade pipe from 18-inch diameter to 24-inch
diameter in M Street SE from 29th Street SE to 32nd
Street SE
Upgrade pipe from 24-inch diameter to 30-inch
diameter in M Street SE from 32nd Street SE to 37th
Street SE
33rd Street SE
to White River
Outfall
R 10/20/2003
Upgrade pipe from 10-inch/12-inch diameter
to 18-inch diameter in R Street SE from 31st
Street SE to 34th Street SE
Upgrade pipe from 12-inch diameter to 24-inch
diameter in R Street SE from 34th Street SE to
37th Way SE
Upgrade pipe from 18-inch diameter to 24-inch
diameter south of 37th Way SE to the White River
outfall
2.4.1.2 CIP 11 - Christa Ministries Facility Retrofit
The Christa Ministries Facility Retrofit project is a retrofit of an existing swale resized to meet the water
quality flow volume for flows discharging from the Brannan Park pump station. Currently, the swale is part of
a wetland and detention pond system on a City-owned parcel.
Modeling efforts for the project consisted of estimating the water quality flow volume discharged from the
Brannan Park pump station force main using the Continuous Simulation Method from the 2019 Stormwater
Management Manual for Western Washington (2019 SWMMWW) (Ecology 2019). The 2019 SWMMWW
describes the methodology as “Using an approved continuous runoff model, the water quality design volume
shall be the simulated daily volume that represents the upper limit range of daily volumes that accounts for
91% of the entire runoff volume over a multi-decade period of record.”
BC ran the existing conditions GHI model for the 1949 to 2022 period of record to generate daily flow
volumes from the Brannan Park pump station. To determine the 91% flow volume, BC removed the days
without flow from the daily record and then used the Excel function PERCENTRANK.EXC to determine the
rank percentile for each day’s flow volume (100 to 0). The Excel formula PERCENTILE.INC was then used to
return the flow volume associated with the 91% rank. The resulting water quality flow volume is
375,448 cubic feet or 8.6 acre-feet.
2.4.2 Excluded Projects
Two potential projects were evaluated with H&H models and determined to be not viable because the
proposed changes did not provide sufficient benefit or exacerbated simulated downstream flooding
conditions during design storms.
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2.4.2.1 30th Street NE Area Flooding, Phase 3 (2015 Plan CIP ID 4B)
The 30th Street NE Area Flooding, Phase 3 project was identified in the 2009 and 2015 Plans to reduce
flooding along C Street NE between 30th Street NE and 37th Street NE in the GHI subbasin. The area
experienced significant flooding during the December 3, 2007, storm and previous model results indicate
the system’s capacity may be limited by low pipe gradient and shallow inverts. The proposed project would
collect stormwater from C Street NE in a new larger and higher gradient pipe and then pump flows to the
42-inch-diameter trunk line in 30th Street NE. The force main connection to the 30th Street NE pipe is also
where the airport stormwater system connects to the 42-inch-diameter trunk line.
BC evaluated the impact of this project on the hydraulic grade line (HGL) in the 30th Street NE trunk with the
updated GHI subbasin model (update described in Section 2.2) for the 25-year design storm (11/6/2006).
The project raised the simulated HGL in the 30th Street NE trunkline by approximately 1 foot, which resulted
in flooding at the airport property’s lowest inlet rim (409-I51) near the north hangar. In addition, Figure B-9
shows the airport property flooding that resulted from the project. Figure B-10 compares the HGL in the
30th Street NE trunkline with and without this project.
Because of the simulated flooding during the design storm and the lack of reports of flooding on C Street NE
since the December 2007 storm, the City opted to remove the 30th Street NE Area Flooding, Phase 3 project
from consideration in the 2024 Plan.
Figure B-9. Flooding impacts of 30th Street NE Area Flooding, Phase 3 Project at the Airport Property Low Area
(catch basin 409-I51)
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Figure B-10. Hydraulic Grade Line in 30th Street NE (from the Airport Property to I Street NE)
Comparison of Existing Conditions and Proposed Conditions from the 30th Street NE Area Flooding, Phase 3 Project
2.4.2.2 17th Street Pond Improvements Project
The 17th Street Pond is one of several infiltration ponds in the BCDF subbasin. Currently, the control
structure manhole for the 17th Street Pond is in the right-of-way (ROW) downstream of the pond outlet pipe.
The standpipe portion of the control structure is dislodged, allowing stored water to discharge from the pond
without control. Also, without the standpipe, model simulations show that downstream capacity limitations
during large events cause water to back up in the system and into the ponds, allowing the pond to act as
backwater storage. Prior to repairing the pond control, the City asked BC to review several scenarios to
optimize the storage and operation of the 17th Street Pond to help reduce flooding in the downstream
system, specifically at the low area near the intersection of Auburn Way S and the State Route (SR) 18
overpass. To help compare existing and proposed conditions, BC modeled several 17th Street Pond
configurations:
1) Scenario 1: Outlet control as designed (control structure in ROW).
2) Scenario 2: Outlet control under current conditions (no control structure).
a) Scenario 2a: Scenario 2 plus an increase in pond volume.
b) Scenario 2b: Scenario 2 plus double the pond volume (as a sensitivity test only, does not represent
space available to expand pond).
3) Scenario 3: Outlet control moved inside pond.
a) Scenario 3a: Scenario 3 plus an increase in pond volume by replacing sloped sides with walls around
the entire pond perimeter.
C Street NE Force Main
Connection
30th Street NE and Auburn
Way N
30th Street NE and I
Street NE 30th Street NE and Airport
Pond H
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Figure B-11 shows the HGL in Auburn Way South at the SR 18 westbound offramp for the various scenarios.
The HGL varies slightly between the scenarios. Figure B-12 shows the flooding rate and volume during the
25-year storm for the scenarios at the low area. The difference in the amount of flooding between the
scenarios is minimal.
Figure B-11. Comparison of Hydraulic Grade Line in Vicinity of Auburn Way South and SR 18
Westbound Off-Ramp Intersection for Evaluation Scenarios
Auburn Way S and SR18 westbound offramp
A Street SE and 14th
Street SE Auburn Way S and 6th Street
SE A Street SE and 6th
Street SE
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Figure B-12. Flooding at Low Inlet (809-B33) near Auburn Way South and SR 18
Westbound Offramp Intersection for Evaluation Scenarios
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References
Brown and Caldwell. 2009. City of Auburn Comprehensive Stormwater Drainage Plan, amended December 2011. Prepared
for the City of Auburn by Brown and Caldwell.
Brown and Caldwell. 2015. City of Auburn Comprehensive Stormwater Drainage Plan. Prepared for the City of Auburn by
Brown and Caldwell.
Ecology (Washington State Department of Ecology). 2019. Stormwater Management Manual for Western Washington.
King County. 2022. Hydrologic Information Center. Last updated November 2, 2016.
https://green2.kingcounty.gov/hydrology/GaugeMap.aspx. Accessed October 5, 2022.
Page 281 of 373
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City of Auburn
June 2024 │ 553-1931-052 11-5
Appendix C
Asset Management Evaluation
Page 282 of 373
Appendix C
City of Auburn
June 2024 │ 553-1931-052 C-1
1. Condition Assessment and Data Gaps Analysis
1.1 Existing Conditions
The City uses Cartegraph, a computerized maintenance management system (CMMS), to manage its
active asset inventory. Cartegraph may be used to develop work requests, document the time and
cost of the work performed, keep track of resources available, and produce reports of various kinds
related to asset management. The City uses a Cartegraph mobile app during field assessments, but
any further updates/changes to the asset is done on the desktop in a geographic information
system (GIS). The City assured that the information between GIS and Cartegraph is universal for
active assets.
Figure C-1 shows the City’s Cartegraph Asset dashboard. The type and count of stormwater assets
within the City’s asset inventory is listed on the lefthand side of the figure. Each stormwater asset
has several attributes that may be tracked and documented alongside the feature. Some assets
have an overall condition index (OCI) rating set up in Cartegraph. However, it is not universal to
all stormwater assets, and the City expressed interest in reviewing and revising how the rating
was generated.
City field staff noted the Cartegraph mobile app allows users a few options for scoring or making
notes, but not all conditions can be accurately noted in the field. For example, one staff member
noted that an aspect of a pipe was observed to be failing in the field, but since the failure condition
wasn’t explicitly asked for in the Cartegraph mobile app, the condition was rated as 100% (signifying
an excellent condition). Staff must ensure the conditions are accurately conveyed and update them
as necessary after returning from the field.
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Appendix C
City of Auburn
C-2 June 2024 │ 553-1931-052
Figure C-1. City’s Cartegraph Asset Dashboard and Stormwater Asset Inventory
Screenshot was taken June 4, 2024. Because most of the asset management review was performed more than 6 months prior to taking the screenshot, it is likely there may be some
differences in total asset count shown in Figure C-1 and total counts reported elsewhere in this document.
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1.2 Critical Attribute Data
One of the goals of this evaluation is to develop criteria for preparing a criticality and risk analysis for
the City’s stormwater assets. This involved preparing a method for scoring the likelihood of failure
and criticality of failure of each type of asset. The likelihood of failure score reflects the expected
asset condition based on specified attributes, and the criticality of failure score is demonstrative of
the anticipated response should the asset fail.
Each stormwater asset was reviewed, and the criteria necessary for developing its scores was
determined based on professional judgment and considered the data available. Some asset types
were grouped together because they were anticipated to require similar levels of
management/maintenance from the Storm Drainage Utility. Other asset types listed in Cartegraph,
specifically fences, infalls, outlets, meters, and auxiliary equipment, were not grouped because they
are linked to one of the greater asset types reviewed and should be assigned the same likelihood of
failure and criticality of failure as the greater asset it is linked to (as work/inspection is anticipated to
occur at the same time).
Another asset type listed in Cartegraph, Storm Channels (ditches), was not assigned criteria for
criticality scores either because its condition is based on maintenance and will not be repaired or
replaced (see the Ditch Maintenance and Operations Program).
Details regarding the critical attributes used in assigning the criticality scores are listed below.
Scoring is discussed in the Criticality Review section.
Age: Based on the installation date of the asset (current year minus installation year).
Useful life: The expected amount of time an asset is expected to perform its function. Based
on either the material (pipes, culverts, network structures) or type of asset (pumps, ponds).
Useful life estimates are given in the Criticality Review section.
Previous inspection data: The previously inspected condition of the asset.
Proximity to critical facilities: Based on a GIS analysis where a buffer was placed around
critical facilities within the City. Assets were assumed to have a higher criticality of failure if
they were closer to a critical facility.
Adjacency to critical roadways: Based on a GIS analysis where a buffer was placed around
critical roadways within the City. Assets were assumed to have a higher criticality of failure if
they were adjacent to a critical roadway.
Adjacency to priority roadways: Based on a GIS analysis where a buffer was placed around
priority roadways within the City. Assets were assumed to have a higher criticality of failure if
they were adjacent to a priority roadway.
Table C-1 lists the recommended criteria to consider in calculating the likelihood of failure and
criticality of failure scores for each category of stormwater asset.
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Table C-1. Recommended Criteria for Calculating Criticality Scores of Stormwater Assets
Asset Name in Cartegraph Asset Category Likelihood of Failure
Attributes
Criticality of Failure
Attributes
Storm Pipes Pipes
Age
Useful life
Previous inspection data
Proximity to critical facilities
Adjacency to critical
roadways
Adjacency to priority
roadways
Storm Culverts Culverts
Age
Useful life
Previous inspection data
Proximity to critical facilities
Adjacency to critical
roadways
Adjacency to priority
roadways
Storm Pumps Pumps Installation date
Useful life
Proximity to critical facilities
Adjacency to critical
roadways
Adjacency to priority
roadways
Street Tree Grates
Network structures
Age
Useful life
Previous inspection data
Proximity to critical facilities
Adjacency to critical
roadways
Adjacency to priority
roadways
Storm Manholes
Storm Catch Basins
Storm Facilities
Ponds Installation date
Type
Proximity to critical facilities
Adjacency to critical
roadways
Adjacency to priority
roadways
Storm Det WQs
1.3 Data Gaps
After the critical attributes were identified for stormwater assets, a data gaps analysis was
performed to see what needed to be addressed. This followed a previous effort led by the City to
address data gaps in its stormwater asset inventory using a high precision antenna. As there were
several stormwater assets, stormwater pipes and culverts were used as examples to demonstrate
the completeness of the asset inventory.
Figure C-2 shows the distribution and availability of data for several attributes in the pipe dataset
(namely, material, size, start elevation, and installation date). Figure C-3 shows the same for the
culvert dataset (with the addition of end elevation). The figures demonstrate a fair amount of the
attributes reviewed had <Null> entries. Most significantly, stormwater pipes are missing
approximately 10% of their installation dates, while culverts are missing 75%.
Installation date was deemed to be a critical attribute for all of the stormwater assets in determining
criticality scores. Lacking this attribute would then have the potential to prioritize an asset for work,
even if it were expected to have been installed recently (and more likely to be in good condition),
over an asset that is expected to have been installed 50 years ago. The goal of the criticality review
is to simplify and provide reasoning for the prioritization of work, so it was deemed beneficial to
perform a desktop GIS analysis to provide placeholder estimates for installation year. The
stormwater pipe dataset was used for this process.
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A copy of the stormwater pipes layer was made, and a new attribute column created for the
estimated installation date. This was to make sure that the estimated installation dates entered
could be distinguished from the installation dates in the dataset previously. Professional judgment
was used to estimate installation dates by considering adjacent infrastructure, parcel build-out years,
and historical imagery, as needed. Another attribute column was also created to provide notes as to
why the estimated installation date was chosen for that feature. In this way, the remaining pipe
dataset was assigned estimated installation dates and used to carry forward in the criticality review.
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Appendix C
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Figure C-2. Stormwater Pipe Attribute Data Available in Cartegraph
Note: Attribute data were reviewed prior to capturing a screenshot of Cartegraph (Figure C-1), hence there may be some differences in asset count.
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Figure C-3. Culvert Attribute Data Available in Cartegraph
Note: Attribute data were reviewed prior to capturing a screenshot of Cartegraph (Figure C-1), hence there may be some differences in asset count.
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1.4 Recommendations
The findings from the condition assessment and data gaps analysis resulted in the following
recommendations for the program:
City field staff should be able to accurately report/enter asset conditions in the field. If there
are features that are consistently being scored incorrectly due to issues with the Cartegraph
app, this should be reviewed and amended to simplify the entry process from the field.
The OCI rating should be reviewed and revised.
The likelihood of failure and criticality of failure attributes from Table C-1 should be used as
the criteria for criticality scoring.
A similar GIS desktop analysis may be beneficial for other asset types with missing
installation dates. Specifically, culverts are expected to benefit as they were missing 75% of
their installation dates.
2. Criticality Review
2.1 Likelihood of Failure
To develop the likelihood of failure score, assumptions had to be made regarding the critical
attributes listed in Table C-1.
2.1.1 Useful Life
The useful life estimates based on pipe material are given in Table C-2 below.
Table C-2. Useful Life Estimates for Pipe Material
Pipe Material (Cartegraph) Description Useful Life Estimate
<Null> No material listed 50
ADS Advanced drainage system (type of high density polyethylene pipe) 50
CAST IRON Cast iron pipe 75
CLAY Vitrified clay pipe 100
CMP1 Corrugated metal pipe 50
CONCRETE1 Concrete pipe 100
CPEP Corrugated polyethylene pipe 50
DUCTILE IRON1 Ductile iron pipe 75
HDPE1 High density polyethylene pipe 100
LCPE Line corrugated polyethylene pipe 50
PERFORATED Perforated pipe 50
POLYETHYLENE Polyethylene pipe 50
PVC1 Polyvinyl chloride pipe 100
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Pipe Material (Cartegraph) Description Useful Life Estimate
RCP1 Reinforced concrete pipe 100
RPVC Rigid polyvinyl chloride pipe 50
STEEL1 Ductile steel pipe 75
1 Useful life estimates were sourced from a similar process performed for the Multnomah County Drainage District. The remaining
materials were not included in this process and were assigned a conservative estimate of 50 years as a placeholder value. This value
may be updated by the City as they see fit.
Useful life estimates can be made in a similar way for culverts and network structures based on their
material. These have not been prepared as a part of this assessment.
Useful life estimates for the ponds category from Table C-1 are given in Table C-3. The possible
components for each type of facility was listed, and an estimate of useful life given using
professional judgment. The most conservative useful life of one of the facility’s components should
be used to assign the useful life of the facility. These estimates were given as a basis for developing
a likelihood of failure score for the ponds asset category. The useful life of pumps can be estimated
in a similar manner as shown in Table C-3, but has not been estimated as a part of this assessment.
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Appendix C
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Table C-3. Useful Life Estimates for Ponds (Stormwater Facilities and Detention/Water Quality Treatment Facilities)
Facility Type
Total1 Useful Life of Components Assumption (Years)2
Useful Life
Assumption
(Years)
Control
Structure
Replacement
Mechanism
Replacement
In-
Place
Soil
Media
Media Box
Replacement Vault Rebuild Notes
<Null> – – – – – – – –
BAFFLE OIL/WATER SEPARATOR 20 – 20 – – 50 – –
BASIC BIOFILTRATION SWALE N/A3 – – – – – – Maintenance based
BIORETENTION 25 – – 25 – – – Full media replacement
CARTRIDGE FILTER 20 – – – 20 50 – –
CP OIL/WATER SEPARATOR 20 – 20 – – 50 – –
DETENTION POND 25 25 – – – – – Assume 25 years for control structure
DETENTION TANK 25 25 – – – 50 – Assume 25 years for control structure
DETENTION VAULT 25 25 – – – 50 – Assume 25 years for control structure
FILTER STRIPS 25 – – 25 – – – Full media replacement
FLOOD STORAGE 25 25 – – – – – Assume 25 years for control structure
HYDRODYNAMIC SEPARATOR 10 – 10 – – 50 – –
INFILTRATION 20 – – 20 – – – Full media replacement
INFILTRATION POND 20 – – 20 – – – Full media replacement
MODULAR WETLAND 20 – – – 20 – – –
PERMEABLE PAVEMENT 10 – – – – – 10 –
TREE BOX 20 – – – 20 – – –
WET BIOFILTRATION SWALE N/A3 – – – – – – Maintenance based
WET POND 25 25 – – – – – Assume 25 years for control structure
WET VAULT 25 25 – – – 50 – Assume 25 years for control structure
1 Total useful life is based on the most conservative estimate listed for one of the facility’s component parts.
2 Estimates were made using professional judgment regarding the useful life expectancy for the components of each facility. There is not a value listed for each facility for the possible
components as they do not apply to each facility listed.
3 Facilities that do not have a useful life assumption are maintenance based and should be managed as part of routine maintenance rather than a repair and replacement program.
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2.1.2 Remaining Useful Life
The remaining useful life is calculated using its age and its useful life, as shown below. 𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅 𝑢𝑢𝑢𝑢𝑅𝑅𝑢𝑢𝑢𝑢𝑢𝑢 𝑢𝑢𝑅𝑅𝑢𝑢𝑅𝑅=𝑅𝑅𝑢𝑢𝑢𝑢𝑅𝑅𝑎𝑎 𝑅𝑅𝑅𝑅𝑅𝑅−𝑢𝑢𝑢𝑢𝑅𝑅𝑢𝑢𝑢𝑢𝑢𝑢 𝑢𝑢𝑅𝑅𝑢𝑢𝑅𝑅
This is the basis for the likelihood of failure score for the stormwater assets.
2.1.3 Previous Inspection Data
The previous condition of the asset feature was used to make an adjustment to the likelihood of
failure score, if it was available, since this would be the most reliable source of data regarding
its condition.
Thus, the remaining useful life equation would be: 𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅 𝑢𝑢𝑢𝑢𝑅𝑅𝑢𝑢𝑢𝑢𝑢𝑢 𝑢𝑢𝑅𝑅𝑢𝑢𝑅𝑅=𝑅𝑅𝑢𝑢𝑢𝑢𝑅𝑅𝑎𝑎 𝑅𝑅𝑅𝑅𝑅𝑅−𝑢𝑢𝑢𝑢𝑅𝑅𝑢𝑢𝑢𝑢𝑢𝑢 𝑢𝑢𝑅𝑅𝑢𝑢𝑅𝑅+𝑝𝑝𝑝𝑝𝑅𝑅𝑝𝑝𝑅𝑅𝑝𝑝𝑢𝑢𝑢𝑢 𝑅𝑅𝑅𝑅𝑢𝑢𝑝𝑝𝑅𝑅𝑖𝑖𝑎𝑎𝑅𝑅𝑝𝑝𝑅𝑅 𝑑𝑑𝑅𝑅𝑎𝑎𝑅𝑅 𝑅𝑅𝑑𝑑𝑎𝑎𝑢𝑢𝑢𝑢𝑎𝑎𝑅𝑅𝑅𝑅𝑅𝑅𝑎𝑎
Table C-4 shows the adjustment to the useful life based on the previous OCI assigned. These
estimated adjustments were only considered for stormwater pipes and should be evaluated to see
whether a similar adjustment can be made for network structures. This is not recommended for
ponds and pumps.
Table C-4. Remaining Useful Life Adjustment for Pipes and Culverts Based on
Previous Inspection Data
Overall Condition
Index Description Useful Life Year Adjustment
0 Failed 0
20 Poor 10
40 Fair 20
60 Good 30
80 Excellent 40
2.1.4 Likelihood of Failure Score
Table C-5 shows how the likelihood of failure score was assigned based on remaining useful life. A
score of 5 is the most likely to fail, while a score of 1 is the least likely to fail.
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Appendix C
City of Auburn
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Table C-5. Likelihood of Failure Score
Score Description
Useful Life Years Remaining with Updated
Inspection Results
5 Structure is greater than 25 years beyond useful life and
should be prioritized for inspection -75
4 Structure is past end of useful life and must be inspected -25
3 Structure is nearing end of useful life and should be
inspected 0
2 Failure not expected for 25+ years 25
1 Unlikely failure in foreseeable future 75
2.2 Criticality of Failure Score
To develop the criticality of failure score, assumptions had to be made regarding the critical
attributes listed in Table C-1. Each critical attribute metric was scored independently and then
averaged to result in the criticality of failure score.
2.2.1 Proximity to Critical Facilities
A 1,000-foot buffer was placed around the critical facilities within the City of Auburn in GIS. If any
asset was within 1,000 feet of a critical facility, then its failure was assumed to be most critical. The
score for this assessment is shown in Table C-6 below.
Table C-6. Proximity to Critical Facilities Score
Distance from Critical Facility Proximity to Critical Facilities Score
0–1000 feet 5
Greater than 1000 feet 1
This GIS analysis was only performed for stormwater pipes for this assessment but can be easily
performed for other stormwater assets by applying the same GIS buffer.
2.2.2 Adjacency to Critical Roadways
The roadways considered as critical in this assessment are listed below.
Emergency evacuation route.
Snow plow route.
King County Metro bus route.
Sound Transit bus route.
Pierce Transit bus route.
A buffer was placed around the critical roadways in the City in GIS. If any asset was within this buffer,
it was deemed to be most critical of failure. The score for this assessment is shown in
Table C-7 below.
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Table C-7. Adjacency to Critical Roadways Score
Distance from Critical Roadway Proximity to Critical Roadways Score
Within right-of-way buffer of critical roadway 5
Outside of critical roadway buffer 1
This GIS analysis was only performed for stormwater pipes for this assessment but can be easily
performed for other stormwater assets by applying the same GIS buffer.
2.2.3 Proximity to Priority Roadways
A priority rank was assigned to the different functional classifications of roads within the City. A GIS
analysis was performed where a buffer was placed around each street. Assets were then assigned a
proximity to priority roadways score equal to the priority rank of the street right-of-way where it lay.
The priority rank (and proximity to priority roadways score) based on street functional classification is
shown in Table C-8 below.
Table C-8. Priority Rank based on Street Functional Classification
Street Functional Classification Priority Rank
ALLEY 4
HIGHWAY 5
LOCAL 3
MINOR ARTERIAL 1
NON RESIDENTIAL COLLECTOR 2
PRINCIPAL ARTERIAL 1
RAMP 4
RESIDENTIAL COLLECTOR 2
RURAL COLLECTOR 4
#N/A 3
<Null> 3
This GIS analysis was only performed for stormwater pipes for this assessment but can be easily
performed for other stormwater assets by applying the same GIS buffer.
2.2.4 Criticality of Failure Score
The criticality of failure score was calculated by taking the average of the proximity to critical facilities
score, adjacency to critical roadways score, and adjacency to priority roadways score. The criticality
of failure score is summarized in Table C-9 below.
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Table C-9. Criticality of Failure Score
Criticality of Failure
Score Description
5
Structure has critical facilities <1000 ft away, is adjacent to a critical roadway, and adjacent to a
higher priority roadway functional classification
4
3
2
1 Structure is not adjacent to critical facilities, critical roadways, or higher priority roadways.
2.3 Results
The criticality of failure and likelihood of failure scores can be summed to create a combined score
or used independently. A spreadsheet was created to score the stormwater pipes inventory using the
methods described above. A screenshot is shown in Figure C-4 below of the first page of results. This
spreadsheet may be used as an example for the other stormwater assets in creating a likelihood of
failure and criticality of failure score.
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June 2024 │ 553-1931-052 C-15
Figure C-4. Criticality Spreadsheet Results for Stormwater Pipes
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2.4 Recommendations
The following actions are recommended after the criticality review:
Estimate useful life for culverts, pumps, and network structures
Consider whether previous inspection data should be used in adjusted useful life for network
structures
Perform GIS desktop analysis needed for the other stormwater assets in Table C-1 based on
the methods described for the criticality of failure score.
Enact the criticality of failure and likelihood of failure scores in Cartegraph for stormwater
pipes, then follow suit with the stormwater assets listed in Table C-1.
3. Pipe Depreciation Analysis
The resulting failure scores allow for the City to rank different assets both on likelihood and criticality
of failure. It is recommended to use this ranking strategy to develop an inspection program where
inspections of different types of assets are prioritized based on their rank. The asset inspection
program will serve to fill data gaps, update the likelihood of failure score based on field verification,
and identify asset features requiring repair or replacement. After inspection data are input for an
asset feature, the results of the inspection will supersede the use of estimated remaining useful life
and installation date (where applicable) in calculating a likelihood of failure score. Using this system
to prioritize maintenance allows resources to be used more efficiently and fills in data gaps resulting
in a more robust asset inventory.
3.1 Inspection of Pipes, Culverts, and Network Structures
For the City’s pipe system, the recommended program would prioritize inspection based on likelihood
of failure and then criticality of failure. In this way, pipes with likelihood of failure scores greater than
or equal to 4 (or a negative useful life estimate) will be inspected first. The next tier of inspections
should address pipes with likelihood of failure scores equal to 3 and pipes with unknown installation
dates. After pipes are inspected, they should be assigned a condition score, which will supersede the
installation date and useful life expectancy in determining the likelihood of failure. The likelihood of
failure for a pipe will increase over time, and this prioritization method will take this into account
while integrating field inspection data. Table C-10 summarizes the length of pipe requiring inspection
using this method.
Table C-10. Pipes Requiring Inspection Summary
Feet Miles Relative to Existing
City Total (%) Notes
Total length of pipe in
Cartegraph 2,439,196 461.97 This includes all jurisdictions and
statuses.
Total length of pipe in City 1,292,737.73 244.84 100% Jurisdiction = "CoA" and
Status = "Existing"
Total pipe length requiring
inspection 52,954.92 10.03 4.10%
Applies for any pipe whose
Likelihood of Failure Score = 4 or 5
(Useful Life <0)
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Since storm catch basins and storm manholes are related to pipes, it is recommended to inspect
these at the same time as adjacent pipes. The same inspection prioritization method is
recommended for culverts because the failure consequences are similar.
3.2 Inspection of Remaining Stormwater Assets
For storm pumps, it is recommended to closely evaluate their condition as their useful life nears the
end (e.g., 5 or fewer years) and upgrade or replace them before probable failure. Stormwater control
facilities should be routinely inspected and prioritized for inspection when critical feature data
are unavailable.
4. Pipe Replacement Cost Projection
A brief review of costs were included in the asset management evaluation for consideration in
setting the repair and replacement budget and resource planning goals for the 2024 Plan. A
comprehensive cost estimate was prepared for both pipe replacement and the replacement of catch
basins and manholes within the City. The assumptions and results of this analysis are noted below.
4.1 Method and Assumptions
The cost estimate for pipe replacement is meant to function as a generic cost estimate for the as
opposed to being based off a particular project or area. The primary cost estimation calculations
assume the replacement of 5,000 linear feet of pipe as well as the associated conveyance
structures, such as manholes and catch basins. The estimate also includes work commonly
associated with a pipe replacement project, including temporary erosion and sediment control
(TESC); site prep, such as the removal of surface pavement and existing structures; the installation
of the conveyance system structures, such as trenching and backfill; surface/pavement repair; and
project costs, such as design contingency and permitting.
Additional assumptions and further explanation of cost breakdown for the cost of pipe replacement
are as follows:
General:
→ All pipes and structures are assumed to be within the same/connecting system.
→ Pipes and structures are under existing asphalt, cement concrete, or landscaping that
would need to be replaced in kind.
→ The City of Auburn GIS map was used to provide information about average pipe sizes,
pipe lengths, types of catch basins, and land surface cover in the area that was used to
make a general calculation of cost to replace 5,000 linear of pipe.
→ The City of Auburn Engineering Design Standards (February 2024) as well as the
Standard Details (February 2024) was used to inform typical design for the purpose of
cost and quantity calculations.
TESC and site prep: Site prep costs include the removal and cutting of surfaces that may be
over the top of existing conveyance systems as well as Utility Conflict Resolution. Other costs
for site prep, such as TESC, mobilization, and project temporary traffic control are calculated
based on percentages commonly used in projects of a similar nature. Project temporary
traffic control for the replacement of conveyance systems may vary depending on the
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amount of work done in arterials or heavily trafficked areas. For this cost estimate, it was
assumed that the work will need a medium amount of traffic control.
Conveyance system and structural/asphalt repair: For the simplification of calculations,
certain generalizations were made in calculating quantities and costs, such as the
assumption that all pipes are the same size, material, and depth. See Figures C-5 through
C-8 for assumptions.
Project costs: Project costs percentages were based off the percentages used for the
Stormwater Management Action Plan “One Sheets” completed for the City of Auburn in
2023. They include project costs for design contingency, permitting, design, City project
management administration, and construction management.
Unit costs: Unit costs were based off the assumption of 5,000 or 10,000 linear feet of pipe
replacement and associated quantities for other conveyance system replacement
appurtenances. Unit costs were estimated using the Washington State Department of
Transportation Unit Bid Analysis tabs as well as other project cost estimates that have similar
attributes to the general cost estimate of replacing conveyance system structures and pipes.
4.2 Results
Cost estimates were made to show the average cost of replacing 5,000 feet of pipe within the City of
Auburn (Figure C-5), replacing 5,000 linear feet of pipe in downtown (Figure C-6), and 10,000 linear
feet of pipe in rural areas (Figure C-7). A cost estimate was also made for replacing catch basins
without replacing any adjacent pipes (Figure C-8).
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Figure C-5. Average Cost of Replacing 5,000 Feet of Stormwater Pipe in the City of Auburn
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Figure C-5 (continued). Average Cost of Replacing 5,000 Feet of Stormwater Pipe in the City of Auburn
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Figure C-6. Average Cost of Replacing 5,000 Feet of Stormwater Pipe in Downtown Auburn
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Figure C-6 (continued). Average Cost of Replacing 5,000 Feet of Stormwater Pipe in Downtown Auburn
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Figure C-7. Average Cost of Replacing 10,000 Feet of Stormwater Pipe in Rural Auburn
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Figure C-7 (continued). Average Cost of Replacing 10,000 Feet of Stormwater Pipe in Rural Auburn
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Figure C-8. Average Cost of Replacing Catch Basins in Rural Auburn
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4.3 Discussion
The resulting cost opinion is intentionally conservative, approximately $1,500 per linear foot, to
account for the wide range of generalizations and assumptions inherent in the process. Notably, the
analysis indicated that pipe replacement in rural areas is expected to be less costly than in the City
center. Additionally, replacing a larger quantity of pipe is only marginally more cost-effective.
As a prudent practice, it is recommended to diligently track the costs associated with installation,
repair, and replacement of asset features on an annual basis. This data serve as valuable reference
information for future asset replacement budget planning. As additional data are collected, cost
opinions can be updated to enhance accuracy.
5. Pipe Depreciation Analysis
A life cycle analysis was performed for stormwater pipes to demonstrate the expected depreciation
rate of each asset and provide background for the recommended maintenance frequency of the
entire system. To do so, a spreadsheet was created to analyze the remaining useful life estimate for
the City’s pipe database over time. A screenshot of the first page of the spreadsheet is shown in
Figure C-9. This shows the existing condition dataset of the stormwater pipes. In the spreadsheet, a
cumulative total was calculated for the pipes whose remaining useful life score had gone negative.
This represented the total linear feet of pipe “lost.” As shown in Figure C-9, at the time of this
assessment, approximately 53,000 feet of pipe is expected to be beyond its useful life.
An average rate of pipe loss was calculated by dividing each pipe’s useful life from its length and
then summing to find the total for the system. As shown in Figure C-9, the average rate of pipe value
“lost” is approximately 15,700 feet per year.
To show the sensitivity of the results, a copy of the spreadsheet was created, and all useful life
estimates were increased by 20 years. A screenshot of the first page is shown in Figure C-10. This
scenario shows the total linear feet of pipe beyond its useful life to be approximately 14,500 feet,
and the average rate of pipe loss per year to be approximately 12,500 feet.
Both scenarios were used to project the amount of pipe replacement needed over 10-, 20-, and
50-year replacement durations. The costs estimated in the previous section were used to provide
estimates for these replacements for reference. Figure C-11 shows the results of this projection.
Page 308 of 373
Appendix C
City of Auburn
June 2024 │ 553-1931-052 C-27
Figure C-9. Screenshot of Stormwater Pipe Depreciation Spreadsheet
Page 309 of 373
Appendix C
City of Auburn
C-28 June 2024 │ 553-1931-052
Figure C-10. Screenshot of Stormwater Pipe Depreciation Spreadsheet Adding 20 Years to Useful Life
Page 310 of 373
Appendix C
City of Auburn
June 2024 │ 553-1931-052 C-29
Figure C-11. Cost Projection Results for 10-,20-, and 50-Year Pipe Replacement Durations
Page 311 of 373
Appendix C
City of Auburn
C-30 June 2024 │ 553-1931-052
5.1 Discussion
The depreciation analysis was performed to provide a point of comparison on which to base the
City’s resource planning recommendations. Though the costs of pipe replacement are conservative,
the anticipated cost of the various replacement durations was considered too great for the asset
repair and replacement program. Thus, the escalated budget for repair and replacement from
previous years was used as the basis for the asset repair and replacement program for the
2024 Plan. However, the results from this analysis can be used to inform the budget for future plans
should it be of interest to expand the scope of the repair and replacement program. A similar
depreciation analysis could be done for culverts.
6. Future Work & Maintenance
This asset management assessment provides a starting point from which the City can base its asset
management program. The following actions will be needed to implement the discussed variables
into the City’s program.
Review issues with scoring in the Cartegraph app. Ensure that any features being scored
incorrectly are reviewed and amended to simplify the entry process from the field.
The OCI rating should be reviewed and revised as needed.
Enact the criticality of failure and likelihood of failure scores in Cartegraph for stormwater
pipes and use these to prioritize inspections for pipes and adjacent network structures.
The criticality of failure metrics should be periodically run in GIS and updated in Cartegraph
for criticality of failure score.
Future actions that should be considered to expand upon the work described in this assessment are
listed below.
A GIS desktop analysis to fill in estimated installation dates should be considered for other
asset types (specifically, culverts are expected to benefit, as they were missing 75% of their
installation dates.
Perform a GIS desktop analysis needed for the other stormwater assets in Table C-1 based
on the methods described for the criticality of failure score.
Estimate useful life for culverts, pumps, and network structures.
Consider whether previous inspection data should be used in adjusted useful life for
network structures.
Enact the criticality of failure and likelihood of failure scores in Cartegraph for the remaining
stormwater assets. Then follow suit with the stormwater assets listed in Table C-1.
Page 312 of 373
Draft Comprehensive Storm Drainage Plan Update
City of Auburn
June 2024 │ 553-1931-052 11-6
Appendix D
Regulatory-Driven
Improvements Assessment
The Regulatory-Driven Improvements technical
memorandum will be completed and included as
Appendix D of this Plan after the final version of
the Western Washington Phase II NPDES MS4
permit is issued in August 2024.
Page 313 of 373
Draft Comprehensive Storm Drainage Plan Update
City of Auburn
June 2024 │ 553-1931-052 11-7
Appendix E
Ditch Maintenance and
Operations Program -
Development and
Recommended Actions
Page 314 of 373
Appendix E
719 2nd Avenue, Suite 200 • Seattle, WA 98104 | 206.394.3700 | Parametrix.com
DATE: June 6, 2024
TO: Tim Carlaw, PE
FROM: Paul Fendt, PE
SUBJECT: Ditch Maintenance and Operations Program
CC: Michael Murray, PE
Alex Van Kirk, EIT
PROJECT NUMBER: 553-1931-052
PROJECT NAME: Comprehensive Storm Drainage Plan Update
Overview and Introduction
This memorandum documents the proposed ditch maintenance and operations (M&O) program of
the Stormwater Programs Task for the Comprehensive Storm Drainage Plan (Plan) for the City. This
effort has been implemented to improve the M&O of the City’s ditch inventory to control stormwater
runoff and improve the quality of downstream receiving waters. The analysis considers the existing
ditch M&O program and determines if additional controls and resources are required to meet needs
and address potential liabilities. This technical memorandum discusses the City’s ditch inventory,
existing ditch M&O program, an outline for the proposed ditch M&O program, and future
recommendations for consideration.
Ditch Inventory Evaluation
The evaluation of the City’s existing ditch M&O program began with an assessment of its asset
inventory. The City’s ditch inventory is mapped under the “Channels” layer in the City’s
computerized maintenance management system, Cartegraph. At the time of investigation,
there were 1,698 features within the Channels layer. Figure E-1 at the end of this memorandum
demonstrates the extent of the channel inventory within Cartegraph.
The evaluation of the inventory included reviewing the available attribute and location data for the
Channels layer features. The feature attribute review revealed an incomplete dataset with several
attributes having little to no data inputs. While the data may be incomplete for the entire inventory,
the following attribute fields were available for input and were either beneficial during evaluation or
are anticipated to be of use in the program once data is made available.
Owner: The jurisdiction responsible for M&O of the feature.
Installed: The date the feature was constructed.
Channel type: Labels the feature as a ditch or a stream.
Channel shape: Identifies the feature as having a parabolic, v-bottom, or trapezoidal shape.
Bottom width: The width of the bottom face of the feature.
Bottom material: Identifies the feature as having a concrete, grass, plastic, riprap, or
soil bottom.
Slope: The longitudinal slope of the feature from inlet to outlet.
Length: The length of the feature from inlet to outlet.
Easement: A yes/no field that indicates whether the feature is within an easement.
Page 315 of 373
Appendix E
City of Auburn 553-1931-052
Ditch Maintenance and Operation Program E-2 June 6, 2024
Having feature data for these attributes would help with determining maintenance needs and
options for water quality retrofits, making an educated guess for the useful life of component parts,
and identifying the parties responsible for feature M&O. It is recommended to update features with
these attributes upon implementing the ditch M&O program.
Channel features were further evaluated to determine whether they should be considered ditches
and, consequently, whether they should be included in the City’s ditch M&O program. A copy of the
Channels layer was created to classify features accordingly. Attachment E1 describes the process
used in classifying layer features and demonstrates the different categories created within the
copied layer. The result of this process was a copy of the Channels layer broken into four categories
based on expectations from the City’s M&O program. These categories are summarized below.
Roadside conveyance: Ditches within road right-of-way that are assumed to be capturing
road runoff. This is the most common form of ditch.
Facility-related: Ditches within close proximity to stormwater facilities that solely convey
stormwater to and from the stormwater facilities.
Collection (other): The remaining City-owned channel features that are expected to be
maintained by the Storm Drainage Utility. This excludes any surface water linework (streams,
rivers, etc.), ditches owned by other jurisdictions (including private ownership), and ditches
maintained by other divisions within the City (for example, ditches within the median of the
airport).
N/A: All features not included in the preceding categories and not maintained by the City’s
Storm Drainage Utility.
The tasks proposed on behalf of each of these categories are discussed in a later section of
this memorandum.
Existing Ditch Maintenance and Operation Program
The City was consulted regarding the existing M&O program for their ditch inventory. Maintenance
activities include regrading and removal of sediment; nuisance vegetation; and isolated obstructions
such as trash, trees, and accumulated debris. Because vegetation is important for erosion control,
removal of beneficial vegetation is minimized.
Maintenance of the City’s ditch inventory is time intensive. Six M&O staff are required for a single
ditch maintenance crew to operate the City-owned excavator, control traffic, and manually regrade or
remove obstructions. While the City aims to implement a ditch maintenance program, the City’s ditch
inventory is only maintained on an as-needed basis.
Proposed Ditch Maintenance and Operation Program
The components of the program are listed and discussed below.
Incorporation of Ditch Classifications
Depending on the type of ditch, there may be a specific inspection regime and go-to maintenance
activities. It is recommended that the City incorporate the earlier-listed classifications as feature
attributes in their Channels layer in Cartegraph.
As detailed in Attachment E1, all channels classified as streams were shown to overlap with surface
water linework in the geographic information system (GIS) and assumed to be streams. No streams
are included in the ditch M&O program; however, complaints and observations, such as erosion
around structures, may be addressed and included in customer service. For the purpose of this
technical memorandum, none of the stream features will be discussed further.
Page 316 of 373
Appendix E
City of Auburn 553-1931-052
Ditch Maintenance and Operation Program E-3 June 6, 2024
Inspection and Routine Maintenance
All ditches will need to be inspected regularly to determine whether further maintenance or
construction is required. Routine maintenance will occur during inspection and will include
smaller-scale tasks, such as picking up trash, clearing out shopping carts, addressing spot
complaints, and mowing. A full inspection will involve evaluating the system for any structural or
vegetation issues and documenting the results to determine whether a work order is needed.
Ditches identified in a work order should result in a follow up within 15 days.
Roadside ditches are expected to require constant maintenance. The collection ditches will require
additional routine maintenance, such as annual mowing and sediment removal. Facility-related
ditches are recommended to be maintained and inspected with the facilities they are related to. A
checklist for the full inspection and routine maintenance task, along with any additional tasks
required for certain types of ditches, should be developed as a follow-up to this memorandum.
Overall System Management
A general management system will be needed to ensure features are mapped, add new ditches to
the City inventory, investigate encroachments, develop capital items, coordinate complaint response,
make recommendations for water quality retrofits, promote general environmentally friendly
practices, and facilitate the generation of work orders. These items are covered in more detail below.
Mapping Update
In addition to updating the Channels layer with the attribute classifications described earlier, the
mapped features will need to be evaluated for accuracy after field inspection and confirm they are
classified correctly. Similarly, attributes and linework for the feature should be reviewed and
modified after field work.
It is recommended that in addition to the attributes listed in the Ditch Inventory Evaluation section,
the following attributes be defined and verified for each feature as work orders are developed.
Inverts (as available).
Average bottom and top width.
Permitted encroachments (utility structures, driveways, etc.).
Ownership and easements.
Some of the attributes may be field verified during inspection, while others may involve
desktop research.
Adding New Ditches
There should be a protocol in place where any ditches observed in the field should be noted and
then verified of their existence in the City’s ditch inventory. This will aim to pick up on any unmapped
ditches within the City to ensure features are maintained and operated appropriately. Newly added
ditches will require ownership and responsibility research and subsequent easements or purchase.
Encroachment Investigation
Any encroachments observed in the ditch features while in the field must be documented. Examples
of encroachments include utility boxes, utility poles, driveway locations, and driveway pipes. These
items will need to be investigated and handled appropriately.
Page 317 of 373
Appendix E
City of Auburn 553-1931-052
Ditch Maintenance and Operation Program E-4 June 6, 2024
Capital Development
The results of the feature inspection may warrant minor capital repairs or replacement. The projects
should be added as a program to the Storm Drainage Utility’s capital improvement plan. Items noted
during inspection that may require capital repair or replacement include sedimentation, erosion, and
system/structural failures.
Responding to Complaints
The program does not deal with private ditches. However, if a complaint is received, the City may
need to respond. The City may either notify the owner of the complaint and insist they handle it
appropriately, or the City may handle the complaint and then bill the owner for the work.
Water Quality Retrofits
As part of the program, the City’s ditches should be evaluated for potential water quality retrofits,
focusing on roadside ditches. Retrofits would implement strategies to provide treatment for the
various pollutants found in road runoff (6PPD-quinone, road maintenance chemicals, heavy metals,
eroded soil, etc.). Determining potential retrofits to consider and deciding how a ditch is chosen for
retrofit should be determined as a follow-up to this memorandum.
General Environmentally Friendly Practices
It is recommended to follow general environmentally friendly practices when performing ditch
maintenance. A few of these practices have been listed below and can be researched further in
Volume IV of the Pierce County Stormwater and Site Development Manual.
Encourage vegetation by not mowing too low.
Avoid using chemicals where possible.
Perform regular inspections.
Conduct vegetative maintenance in the late spring or early fall.
Work Order Development
The following items will need to be addressed and managed in incorporating the proposed ditch
M&O program.
How does inspection turn into a work order?
How often should ditches be inspected?
What are the thresholds for action?
Recommendations
It is recommended to implement the proposed ditch maintenance program as detailed above.
Further work to develop the inspection checklists, decide on how to implement water quality retrofits,
and address the work order development items is necessary as a follow-up to this memorandum. It is
recommended to reflect upon the program after 5 years to assess whether any adjustments would
be beneficial to the program.
Page 318 of 373
Appendix E
City of Auburn 553-1931-052
Ditch Maintenance and Operation Program E-5 June 6, 2024
Figure E-1. Extent of Channels Layer in Cartegraph
Page 319 of 373
Appendix E
City of Auburn 553-1931-052
Ditch Maintenance and Operation Program E-7 June 6, 2024
Attachment E1
Channel Classification
Page 320 of 373
Appendix E
City of Auburn 553-1931-052
Ditch Maintenance and Operation Program E1-1 June 6, 2024
Attachment E1
Channel Classification
The Channel layer was exported from the City’s Cartegraph inventory and was used as the basis for
the data review. At the time of export, there were 1,698 features with a total of more than
440,000 feet in summed length.
After reviewing the channel inventory, it was determined that a categorization of the channels by type
would be beneficial in developing the required inspection criteria, frequency, and maintenance
needs. Two attribute columns were added to the Channel layer, named “Source_Drainage” and
“Source_Drainage_Note” to ease this process. Features were assigned a common category in the
“Source_Drainage” attribute column, and any notes or reasoning for the assignment were justified in
the ”Source_Drainage_Note” attribute column. The process for classification of the channel
inventory (and filling out the Source_Drainage attribute column) is detailed in the following sections.
The characteristics evaluated for classification along with a description of the process for each are
listed below.
Ownership
The channels were first broken down using the feature’s Owner attribute. The process for this
breakdown is listed below.
Any ditches marked as Owner = "COA"1 or "0" or blanks were assumed to be City owned and
broken down further.
Any ditches marked as Owner = "Private" were marked as "Private – Ditch."
Any ditches marked as Owner = "WSDOT" were marked as "WSDOT – Ditch."
Any ditches marked as any owner not previously identified were marked as "Other
Jurisdiction – Ditch."
Surface Water
The Channels layer was overlaid in GIS with linework from surface water and stream network layers.
Any features from the Channels layer that overlapped with the surface water and stream network
linework were marked as “Streams.” These features would not be considered in the ditch
maintenance and operations program.
If any features appeared to be visually similar to streams in GIS but did not overlap with any surface
water linework, they were marked as “COA – Channelized Streams.” An example of this instance is
shown in Figure E1-1 below.
1 Where COA is an abbreviation for City of Auburn.
Page 321 of 373
Appendix E
City of Auburn 553-1931-052
Ditch Maintenance and Operation Program E1-2 June 6, 2024
Figure E1-1. COA – Channelized Streams and Roadside Ditches Example
Roadside Ditch
A buffer was applied around roadways in GIS to capture any of the channel features within
right-of-way. Any ditches within this buffer were marked as “COA – Roadside Ditch.” These features
are assumed to be capturing road runoff and are anticipated to be the most common form of a ditch.
Examples of these features are shown in green in Figure E1-1.
Stormwater Facility
In a similar fashion to roadside ditches, a buffer was applied around the City’s existing stormwater
facilities. Any channels that lay within this buffer were visually evaluated to confirm that they seemed
to be associated with a stormwater facility. Channel features that were confirmed to be associated
with a stormwater facility were marked as “COA – Facility.” Maintenance for ditches associated with
an existing facility are anticipated to follow a schedule dictated by maintenance of the overall facility.
An example of this feature type is shown below in Figure E1-2.
Features classified as
channelized streams
are shown in cyan.
Features
classified as
roadside ditches
are shown in
green.
Page 322 of 373
Appendix E
City of Auburn 553-1931-052
Ditch Maintenance and Operation Program E1-3 June 6, 2024
Figure E1-2. COA – Facility Features Example
Airport Median
There were three channel features shown in the airport median that were classified separately.
These features were marked as “COA – Other.” These are likely not ditches and would follow a
different maintenance schedule than what is recommended elsewhere. Maintenance would be
dictated by airport requirements. The three channel features of this type are shown below in
Figure E1-3.
Linework in cyan
symbolizes channel
features classified
as COA - Facility
Blue hatched polygons
symbolize a stormwater
detention facility
Page 323 of 373
Appendix E
City of Auburn 553-1931-052
Ditch Maintenance and Operation Program E1-4 June 6, 2024
Figure E1-4. COA – Other Features
Features shown in
yellow linework are
classified as “COA
– Other”
Page 324 of 373
Appendix E
City of Auburn 553-1931-052
Ditch Maintenance and Operation Program E1-5 June 6, 2024
Public Ditches
The remaining channel features that were City owned and not surface water, not receiving roadside
drainage, not associated with a stormwater facility, and not within the airport median were classified
as “COA – Public.” These features will require different inspection and maintenance techniques than
the roadside ditches because access may be more challenging and captured runoff is anticipated to
be sourced from more than roadways. An example of a channel feature classified as “COA – Public”
is shown below in Figure E1-4.
Figure E1-4. COA – Public Feature Example
Features shown in
red linework are
classified as “COA –
Public”
Page 325 of 373
Appendix E
City of Auburn 553-1931-052
Ditch Maintenance and Operation Program E1-6 June 6, 2024
Results
After classifying the Channels layer as detailed above, the resulting breakdown of features in each
category is demonstrated below in Table E1-1.
Table E1-1. Channel Classification Breakdown
Owner1 Classification2
Length3
(feet)
Length
(miles)
Percent of City-
Owned Channels
Percent of Total
Channels
Various Stream 84,000 16 - 19%
WSDOT WSDOT - Ditch 29,000 5 - 6%
Other Jurisdictions Other Juris - Ditch 9,000 2 - 2%
Private Private - Ditch 101,000 19 - 23%
COA COA - Channelized Stream 14,000 3 6% 3%
COA COA - Roadside Ditch 176,000 33 79% 39%
COA COA - Facility 5,000 ~1 2% 1%
COA COA - Other 3,000 ~1 1% 1%
COA COA - Public 26,000 5 12% 6%
- COA Total 224,000 42 100% 50%
- Total 447,000 85 - 100%
1 Owner corresponds to the data for the feature attribute of the same name. COA = City of Auburn; WSDOT = Washington Department of
Transportation. “Other Jurisdictions” includes any other ownership not included in COA, WSDOT, or Private. Other jurisdictions listed as
owners of channel features include City of Algona, City of Kent, King County, and the Muckleshoot Indian Tribe.
2 Classification also refers to the “Source_Drainage” attribute column developed for this evaluation.
3 Length has been rounded up to the nearest thousand. The columns to the right have all been calculated based on this rounded
number.
Work Implications
The review of the channel inventory layer was conducted as part of a larger effort to develop a
drainage ditch maintenance program for the City. Breaking down the layer into the classifications
identified in Table 1 allow for resources to be evaluated appropriately. While the channel
classifications aid in giving additional context for the features within the Channel layer, some of the
classifications are expected to require the same work items and maintenance frequencies, while
others are not maintained by the storm drainage utility and will not be included within the ditch
maintenance program. To simplify drainage ditch M&O needs, features can be split into broader
categories based on expected work. Table E1-2 shows the groupings for ditch M&O work as they
relate to the COA channel classifications.
Page 326 of 373
Appendix E
City of Auburn 553-1931-052
Ditch Maintenance and Operation Program E1-7 June 6, 2024
Table E1-2. COA Drainage Ditch M&O Categories Relative to Channel Classifications
COA Drainage Ditch M&O
Category Channel Classification Length (feet) Length (miles)
Roadside Conveyance COA - Roadside Ditch 176,000 33
Facility-Related COA - Facility 5,000 ~1
Collection (Other)1 COA - Channelized Stream 40,000 8
COA - Public
Total Maintained by Storm
Drainage Utility 221,000 42
N/A2 COA - Other 226,000 43
COA = City of Auburn; M&O = maintenance and operation
1 This grouping combines all other COA ditches maintained by the storm drainage utility collecting stormwater. For the purposes of this
preliminary ditch maintenance program, these ditches are expected to have the same maintenance needs and frequency of work.
2 N/A includes all features in the channel classifications layer not sorted into one of the other three M&O categories, and not included in
the City’s ditch maintenance program. COA-Other is included in this category as it is not expected to be maintained by the storm
drainage utility. It is expected to have different maintenance expectations dictated by the airport. If this is proven otherwise, it should
be sorted into one of the other M&O categories based on expected level of need.
Facility-related ditches will largely be maintained alongside the facilities they correspond with. This
may require a first step in associating facility-related features with the respective facility they serve in
Cartegraph to ensure that these features are not missed. After this exercise, facility maintenance
may include maintenance of any associated ditches (depending on recommended maintenance
frequency, facilities may be maintained several times per year, while facility-related ditches may not
need as many visits). While these features are still included within the ditch maintenance program,
the frequency and scheduling of work is dependent on timing for associated facilities. Though, the
work associated with ditch inspection and maintenance will be dictated by the ditch inspection
program.
In terms of M&O tasks, features classified as COA-Channelized Stream are expected to have the
same inspection and maintenance requirements as those in COA-Public, so these will be treated the
same in terms of recommended M&O actions.
Page 327 of 373
Draft Comprehensive Storm Drainage Plan Update
City of Auburn
June 2024 │ 553-1931-052 11-8
Appendix F
SEPA Compliance
Documentation
The SEPA Compliance Documentation will
be included as Appendix F of the final Plan.
Page 328 of 373
AGENDA BILL APPROVAL FORM
Agenda Subject:
Capital Facilities Element (Steiner)
Date:
June 11, 2024
Department:
Community Development
Attachments:
Attachment C - Capital Facilities Element
Presentation
Attachment D - V1 Draft 2024 Capital Facilities
Element
Budget Impact:
Current Budget: $0
Proposed Revision: $0
Revised Budget: $0
Administrativ e Recommendation:
Background for Motion:
Background Summary:
See Attachments
Rev iewed by Council Committees:
Councilmember:Staff:Steiner
Meeting Date:June 18, 2024 Item Number:
Page 329 of 373
AUBURN
VALUES
SERVICE
ENVIRONMENT
ECONOMY
CHARACTER
SUSTAINABILITY
WELLNESS
CELEBRATION
CITY DEPARTMENTS
2024 COMPREHENSIVE PLAN
–CAPITAL FACILITIES
ELEMENT
JOSH STEINER, AICP, SENIOR PLANNER
PLANNING COMMISSION
JUNE 18, 2024
Department of Community Development
Planning Building Development Engineering Permit Center
Economic Development Community Services ● Code Enforcement
Page 330 of 373
(3) A capital facilities plan element consisting of:
(a)An inventory of existing capital facilities owned by public entities, including green infrastructure, showing the locations and capacities of the capital facilities;
(b)Forecast of the future needs for such capital facilities;
(c)Proposed locations and capacities of expanded or new capital facilities;
(d)At least a six-year plan that will finance such capital facilities within projected funding capacities and clearly identifies sources of public money for such purposes; and
(e)Requirement to reassess the land use element if probable funding falls short of meeting existing needs and to ensure that the land use element, capital facilities plan element, and financing plan within the capital facilities plan element are coordinated and consistent. Park and recreation facilities shall be included in the capital facilities plan element.
.
Core Changes to Land Use Element
SERVICE ENVIRONMENT ECONOMY CHARACTER SUSTAINABILITY WELLNESS CELEBRATION
2024 PERIODIC COMPREHENSIVE PLAN –
CAPITAL FACILITIES ELEMENT
Regulatory Requirements (RCW 36.70A.070)
Page 331 of 373
Pull in policy and non-financial text from Capital Facilities Plan
Incorporate information from Utilities Element as appropriate
Include inventories for capital facilities
Reference on goals, policies, and technical information from other Elements
as appropriate to avoid duplication
Overall formatting and refinements for readability
Few comments from agencies
Capital Facilities Plan is included as part of CFE package (6-year CIP)
Multi-Department Effort
Core Changes to Land Use Element
SERVICE ENVIRONMENT ECONOMY CHARACTER SUSTAINABILITY WELLNESS CELEBRATION
2024 PERIODIC COMPREHENSIVE PLAN –
CAPITAL FACILITIES ELEMENT
Element Update Framework
Page 332 of 373
Capital Facilities Inventory – list of facilities and attributes (condition,
age, size, etc.)
Level of Service – Adopted Level of Service standards that apply to
facilities for identification of future needs. May be a reference to
another document.
Known Capacity Issues – Deficiencies identified by Level of Service
analysis and/or capacity issues identified in other documents
(systems plans, etc.)
Future Plans – Summary of identified future projects or reference to
other documents where information is found (systems plans, etc.)
Not all information is provided for each facility type
Core Changes to Land Use Element
SERVICE ENVIRONMENT ECONOMY CHARACTER SUSTAINABILITY WELLNESS CELEBRATION
2024 PERIODIC COMPREHENSIVE PLAN –
CAPITAL FACILITIES ELEMENT
Element Update Framework
Page 333 of 373
Municipal Facilities
Community Facilities (golf courses, cemeteries, etc.)
Public Libraries
Police
Fire Protection
Parking
Parks and Recreation
Transportation
Public Utilities (city -provided and other)
Public Education Facilities
Core Changes to Land Use Element
SERVICE ENVIRONMENT ECONOMY CHARACTER SUSTAINABILITY WELLNESS CELEBRATION
2024 PERIODIC COMPREHENSIVE PLAN –
CAPITAL FACILITIES ELEMENT
Capital Facilities Types
Page 334 of 373
Majority of policies are from existing CFE, CFP, and related Elements
New or amended policies address gaps in GMA requirements
CF-6 Provide additional public facility capacity when existing facilities
are used to their maximum level of efficiency (consistent with adopted
standards for level of service).
CF-10. The city will perform its activities and make capital budget
decisions in conformity with the comprehensive plan. The Land Use
Element of the comprehensive plan shall be reassessed if probable
funding falls short of meeting existing needs.
CF-11 Establish land use patterns that optimize the use of public
facilities.
Core Changes to Land Use Element
SERVICE ENVIRONMENT ECONOMY CHARACTER SUSTAINABILITY WELLNESS CELEBRATION
2024 PERIODIC COMPREHENSIVE PLAN –
CAPITAL FACILITIES ELEMENT
Policy Updates
Page 335 of 373
July 2nd – Public Hearing
Requested updates based on feedback
October 23rd – Planning Commission Action (same night as
Utilities Element and Water Comprehensive Plan action)
Next Steps
SERVICE ENVIRONMENT ECONOMY CHARACTER SUSTAINABILITY WELLNESS CELEBRATION
2024 PERIODIC COMPREHENSIVE PLAN –
CAPITAL FACILITIES ELEMENT
Page 336 of 373
Questions, Discussion, and Feedback
SERVICE ENVIRONMENT ECONOMY CHARACTER SUSTAINABILITY WELLNESS CELEBRATION
2024 PERIODIC COMPREHENSIVE PLAN –
CAPITAL FACILITIES ELEMENT
Page 337 of 373
DRAFT – June 18, 2024 Planning Commission Transmittal
City of Auburn
Capital Facilities
Element
Page 338 of 373
DRAFT – June 18, 2024 Planning Commission Transmittal
Table of Contents
Introduction ....................................................................................................................................................... 1
Vision ..................................................................................................................................................................... 1
Conditions and Trends ................................................................................................................................ 1
Planning Approach ...................................................................................................................................... 2
Values ................................................................................................................................................................... 2
Concurrency and Levels of Service ...................................................................................................... 3
Levels of Service ......................................................................................................................................... 3
Concurrency ................................................................................................................................................. 3
Capital Facilities and Services ................................................................................................................ 5
Municipal Facilities ................................................................................................................................... 5
Parks and Recreation ............................................................................................................................ 10
Transportation ........................................................................................................................................... 11
Public Utilities ............................................................................................................................................13
Public Education Facilities ................................................................................................................. 22
Goals and Policies ....................................................................................................................................... 24
Page 339 of 373
DRAFT – June 18, 2024 Planning Commission Transmittal
City of Auburn Capital Facilities Element | CFE- 1
Introduction
This volume provides overall policy direction for the different capital facility plans
and programs provided by the City. Capital facilities belonging to privately owned
utilities (electricity, natural gas lines, etc.) and those that are city-operated (water,
sewer, stormwater, etc.) are covered in the Utilities Element (Volume 4). Certain
City plans and programs are further refined in other sections of this volume, such
as Parks, Recreation, and Open Space, and Transportation. Overall, however, this
volume acts as a reference for all of the City’s various capital facility plans except for
those found in other Elements, including the City of Auburn Six-Year Capital
Facilities Plan (a key component of and adopted with this plan), comprehensive
plans, capital improvement and investment programs, inventories, and studies that
together represent the planning and financing mechanisms required to serve the
capital facility needs of Auburn. For more details on a particular capital facility or
the City’s overall capital facility plan, see the most recently adopted version of the
following:
• City of Auburn Airport Master Plan
• City of Auburn Capital Facilities Plan
• City of Auburn Comprehensive Water Plan
• City of Auburn Comprehensive Sewer Plan
• City of Auburn Comprehensive Stormwater Plan
• City of Auburn Parks and Recreation Master Plan
• City of Auburn Comprehensive Transportation Plan
• Auburn School District Capital Facilities Plan
• Kent School District Capital Facilities Plan
• Dieringer School District Capital Facilities Plan
• Federal Way School District Capital Facilities Plan
• Valley Regional Fire Authority (VRFA) Capital Facilities Plan
Vision
Capital facilities in Auburn are planned, designed, and constructed in a manner
that adequately supports the future growth scenarios in the City’s Land Use
Element and that meets the needs of residents, visitors, and businesses.
Sustainability is a principle that guides decisions about where facilities are placed,
how they are constructed, how they are operated and maintained, and how all
aspects of design, construction, and operation are funded.
Conditions and Trends
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Growth: The provision and sizing of public facilities such as streets or waterlines
and sewer lines can influence the rate or timing of development and is an
important means of managing growth. Timed provision of facilities also ensures
that new development can be assimilated into the existing community without
serious disruptions or adverse impacts. This Plan establishes policies to allow
development when and where all public facilities are adequate or can be made
adequate, but only if such development can be adequately served by public
facilities and services consistent with the adopted level-of-service standards.
A key provision of the Growth Management Act is concurrency. In general,
concurrency seeks to ensure that development is permitted only if adequate public
facilities are, or can be guaranteed to be, available to support new development.
Concurrency requires that facilities needed to maintain a locally adopted level of
service be provided “concurrently” with development. Concurrency places the
finance function of local government in a much more prominent role in the land
use development process. While the concept of concurrency is new to many
jurisdictions, it has been used in Auburn since the adoption of its 1986
Comprehensive Plan.
The Act requires concurrency only for transportation facilities, though if a
jurisdiction desires, concurrency can be applied to other public facilities as well.
With respect to transportation facilities, concurrent is defined within the Act as
being provided at the time of or within 6 years of development (this is done to
coincide with the six-year time frame of most capital facilities plans). If the facility is
not available at the time of development, the funding to construct the facility must
be included in the six-year capital facilities plan.
Regardless of whether a local jurisdiction applies concurrency to public facilities
beyond those for transportation, new development must be coordinated with the
provision of capital facilities. This ensures that all relevant public facilities and
services are planned and available to serve the demands of new growth.
Planning Approach
The Capital Facilities planning approach is to manage growth in a manner that
enhances from community quality and values by actively coordinating land use
type and intensity with City facility and service development and provision.
Values
Character: Public buildings and spaces incorporate high-quality building and
landscape design so that they positively impact the surrounding built environment.
Wellness: Public spaces that are purchased and developed for capital facilities also
incorporate features and infrastructure that provide more complete nonmotorized
connections.
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Service: City utilities and buildings are of high quality and complete, reliable, and
available to residents and business owners.
Economy: City utilities are available or planned to be available to serve allowed
commercial, recreational, and residential uses.
Celebration: Capital facility spaces will be available, designed, and programmed in
a manner that promotes public gathering.
Environment: Development of capital facilities will place a premium on
environmental preservation and protection.
Sustainability: Our philosophy of designing, constructing, and maintaining utilities
and buildings embraces a long-term investment horizon rather than concepts that
only provide short-term benefits and outcomes.
Concurrency and Levels of Service
Levels of Service
Level of Service (LOS) is a common measure used to determine the efficiency or
effectiveness of services. For the City of Auburn, LOS targets serve as a means to
assess the adequacy of public facilities in meeting the needs of the population for
which it serves. The GMA requires that LOS be established for certain
transportation facilities for the purposes of applying concurrency to development
proposals. The State GMA guidelines recommend the adoption of LOS standards for
other capital facilities to measure the provision of adequate public facilities.
Typically, measures of level of service are expressed as ratios of facility capacity to
demand (i.e., actual or potential users). Table 1-1 lists generic examples of level of
service measures for some capital facilities:
For example, in the case of park space, when there is an increase in population
without a corresponding increase in park acreage, the LOS unit of measure (acres
per 1,000 population) will decline, indicating a potential need to increase the total
amount of park acreage to keep pace with population growth. On the other hand, a
slight increase in population, coupled with a large increase in facilities, will result in
an increased LOS. For example, facilities such as buildings or burial plots may be
constructed or expanded to keep pace with anticipated population growth. While
this will have the effect of increasing LOS in the short-term, in the longer-term, the
LOS will gradually decline to the targeted level based on forecasted population. The
impact of population growth to the LOS for facilities will vary depending on the
type of facility and long-range planning by the City.
Concurrency
The GMA requires that jurisdictions have certain capital facilities in place or
available within a specified time frame when development occurs. This concept is
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called concurrency. Under the GMA, concurrency is required for transportation
facilities and is recommended by the State for certain other public facilities, namely
potable water and sanitary sewer.
Concurrency has a direct relationship to level of service. The importance of
concurrency to capital facilities planning is that development may be denied if it
reduces the level of service for a capital facility below the locally adopted minimum.
The level of service is unique for each type of facility and is presented in the
subsequent sections. Concurrency has a direct relationship to level of service. The
importance of concurrency to capital facilities planning is that development may
be denied if it reduces the level of service for a capital facility below the locally
adopted minimum. The level of service is unique for each type of facility and is
presented in the subsequent sections.
The need for capital facilities is largely determined by a community’s adopted LOS
standards and whether or not the community has formally designated capital
facilities, other than transportation, as necessary for development to meet the
concurrency test. The CFP itself is therefore largely influenced by the selection of
the level of service standards. Level of service standards are measures of the quality
of life in the City. The standards should be based on the City’s vision of its future
and its values.
Level of Service Standards and Needs
Based on the proposed six-year capital projects and the projected population
increase of 4,585 (5.1%) between 2023 and 2028, the LOS for the following City-
owned public facilities will change as follows:
The LOS for the following facilities will be increased as a result of the Capital
Facilities Plan (CFP), comparing the 2023 LOS to the projected 2028 LOS.
Capital Facility LOS Units 2023 LOS 2028 LOS
(Projected)
Cemetery Burial Plots per 1,000 population 29.00 56.00
Community Parks Acres per 1,000 population 2.62 2.95
Linear Parks Acres per 1,000 population 0.18 0.21
Neighborhood Parks Acres per 1,000 population 0.72 0.78
The LOS for the following facilities will be maintained as a result of the CFP.
Capital Facility LOS Units 2023 LOS 2028 LOS
(Projected)
Transportation See Comprehensive Transportation Plan
Airport % of Air Operations Support 100% 100%
Sanitary Sewer Residential GPCPD1 171.00 171.00
Storm Drainage N/A N/A N/A
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Water Residential GPCPD1 182.00 181.00
1 – GPCPD = Gallons per Customer per Day
The LOS for the following facilities will be decreased as a result of the CFP,
comparing the 2023 LOS to the projected 2028 LOS.
Capital Facility LOS Units 2023 LOS 2028 LOS
(Projected)
General Municipal Buildings Square Feet per 1,000 population 3,290.44 3,173.11
Open Space Acres per 1,000 population 4.25 4.10
Senior Center Square Feet per 1,000 population 135.70 129.12
Special Use Areas Acres per 1,000 population 2.83 2.69
Other Level of Service metrics and thresholds related to specific capital facilities are
located in the sections below.
Capital Facilities and Services
Municipal Facilities
The current inventory of City government administration and operations facilities
include 207,629 square feet for general government operations, 66,469 square feet
for police services, and 21,726 square feet for fire protection, for a total of 295,824
square feet. Table GM – 1 “Facilities Inventory” lists the facilities along with their
current capacity and location.
Community Facilities
GM- 1 Facilities Inventory
Facility Name Location Size
Community Center 910 9th St SE 19,804 sq ft
Senior Center 808 9th St SE 11,667 sq ft
Cemetery 2020 Mountain View Dr 4,011 sq ft (out buildings
not included)
Golf Course 29630 Green River Rd 14,114 sq ft (out buildings
not included)
Postmark Center for the Arts 20 Auburn Ave 8,744 sq ft
GSA 2905 C St SW 11,837 sq ft
4910 A Street 4910 A Street 5,920 sq ft
City Hall 25 W Main St 57, 316 sq ft
City Hall Annex 1 E Main St 47,000 sq ft
Justice Center 340 E Main St 36,000 sq ft
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Maintenance & Operations 1305 C St SW 18,232 sq ft (out buildings
not included)
Parks Maintenance 1403 C St SW 6,094 sq ft (out buildings
not included)
Les Gove MPP Building 1040 Deal’s Way 1,262 sq ft (out buildings
not included)
R Street Building 2840 Riverwalk Drive SE 4,798 sq ft (out buildings
not included)
Warren Building 411 E Street NE 1,813 sq ft (out buildings
not included)
Herr Storage 1140 Auburn Way S 3,600 sq ft
Auburn Ave Theatre (scheduled for
demolition) 10 Auburn Ave 7,590 sq ft
Auburn valley Humane Society 4910 A Street SE 5,920 sq ft
Level of Service
The current LOS of 3,290 square feet per 1,000 population is based on the existing
inventory divided by the 2023 citywide population of 89,904. The proposed LOS of
3,173 square feet per 1,000 population is based on the projected inventory divided
by the 2028-projected citywide population of 94,489.
Future Plans
As of 2024, the City is in the process of designing and constructing a replacement
for the Auburn Ave Theatre, which was damaged when the adjacent historic
mixed-use building on E Main Stret was damaged beyond repair due to fire. The
new theatre is anticipated to be an activity anchor in downtown with its central
location.
Public Library Facilities
The City of Auburn is served by the King County Library System in 15,000 square
foot Auburn Library building at 1102 Auburn Way S. The library opened in 2000 after
moving first from the Carnegie Library building in downtown (constructed in 1914),
then from another facility in Les Gove Park (constructed in 1964). The current
building has continued to be renovated and expanded over the past 25 years, with
the last construction completed in 2012. Detailed information regarding the King
County Library System is available at www.kcls.org.
Police
Facility Inventory
Name Location Size
Auburn Justice Center (Police) 340 E Main St 16,000 sq ft
Evidence Building 340 E Main St 4,400 sq ft
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The Auburn Police Department has a staff of the Chief, Assistant Chief, 5
Commanders, 13 Sergeants, 57 Patrol Officers, 20 Detectives, 5 Traffic Officers, and
multiple supervisors, specialists, technicians, and other staff as of 2023.
Police services are centered around the Auburn Justice Center that serves the
entire City and supports the required staff, the majority of who are assigned to the
patrol division. In 2004, the police department took occupancy of a portion of the
Justice Center, primarily in the basement, with the Court located on the primary
level. The police portion occupies just over 16,000 square feet. Currently the police
facility houses 118 sworn police officers in addition to 22 civilian staff. Police
headquarters provides both designated and temporary workspace, meeting rooms,
common areas, locker rooms, storage space, utility space, electrical and utility
space, and records storage space. A separate evidence building at the same site
houses evidence storage, general equipment storage, and records archives.
Additionally, the department maintains temporary evidence storage in the
basement of city hall, utilizing approximately 200 square feet of space.
A facility needs assessment was completed in 2020 and was incorporated in the
2020 Facilities Master Plan.
Known Capacity Issues
Police facilities lack adequate space to support current staff and operations, and
future growth.
• Suboptimal climate control, especially on ground floor as HVAC zone
configuration does not align with current space configuration due to
renovations.
• Facility too small to accommodate both Court and Police in long-term.
• Severely space-constrained, especially for Police, which grew 40% between
2004 and 2019.
• Undersized public lobby and soft interview space.
• Limited meeting/briefing space for all meeting types, including large groups,
confidential discussions, and interviews.
Police office space is primarily in basement areas that have limited natural light.
• Defensive tactics and classroom training occur in a room with irregular
column placement which impedes sightlines, creates barriers for physical
training, and complicates furniture/mat reconfiguration.
• Evidence building is at capacity.
• Undersized parking; unsecured parking for marked vehicles.
Future Plans
A property located near 12th street southeast property has been acquired by the
City. 2023-2024 budget allocated funding for facility planning at new location.
Other than planning, there is no funding allocated for this project.
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Fire Protection
The Valley Regional Fire Authority (VRFA) provides critical fire and life safety
services to the approximately 97,000 citizens residing in the 37 square miles of
Algona, Auburn, and Pacific. Oversight of the VRFA is provided by a nine-member
Governance Board consisting of the Mayor and two council members from each
participating city. Twenty personnel respond from five fire stations. These stations
are staffed 24 hours a day, seven days a week, by four shifts. A battalion chief
oversees each shift, and a deputy chief manages the entire division.
The Auburn Fire Department was formed over a century ago as a result of a
devastating fire in August of 1890. The fire destroyed an entire city block of
businesses in what was then known as the town of Slaughter. The original
department, consisting of volunteer firefighters and a hand-drawn hose cart, was
first named the Auburn Bucket Brigade. The name changed to the Auburn
Volunteer Fire Department in 1908. On January 1, 2007, as a result of a voter-
approved measure, the Auburn Fire Department combined with the Pacific Fire
Department and the City of Algona to form the Valley Regional Fire Authority,
which provides fire and EMS services to all three cities.
In an emergency, every second counts. The VRFA has established a Total Response
Time (TRT) benchmark of seven minutes and 34 seconds (7:34) for EMS Calls and
seven minutes and 49 seconds (7:49) for fire calls. TRT is the time it takes a unit to
arrive at a scene once the call is received at the Fire Alarm Center. In 2022, we
achieved those benchmarks 51% of the time for fire response and 57% for EMS
response.
The VRFA’s Capital Facilities Plan (CFP), which was adopted by the Board of
Governance in 2021, made four recommendations:
• Priority 1: build an additional station in the northern part of VRFA’s service
area
• Priority 2: relocate and rebuild Station 38 in Pacific
• Priority 3: remodel or replace Station 31
• Priority 4: find a permanent location for Support Services
In 2022, the VRFA took several significant steps to implement the CFP, including:
• Purchasing property on 30th and I Street Northeast for a new north end fire
station. Evaluating property on the Ellingson corridor in Pacific in order to
relocate Station 38.
• Contracting with the leading architectural firm TCA to consult on land
acquisition and complete preliminary design concepts on each element of
the CFP.
• Initiating a discussion on the best way to fund these critical projects.
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In 2022, 45% of revenue was from Property Taxes, 34% from Fire Benefit Charges,
and 21% from other sources such as grants and permit fees. Expenditures in 2022
include 52% for wages, 15% for capital projects, 19% for benefits and 14% for other
services and supplies.
Valley Regional Fire Authority Capital Facility Plans, Annual Reports, and other
documents can be found at www.vrfa.org.
Level of Service
The current LOS of 0.20 fire apparatus per 1,000 population is based on the existing
inventory (18 fire apparatus) divided by the 2023 citywide population estimate of
89,904. The proposed LOS of 0.20 fire apparatus per 1,000 is based on the 2028-
planned inventory (19 fire apparatus) divided by the 2028-projected citywide
population of 94,489.
Parking
Facilities Inventory
Facility Name Location Capacity Condition
Kiss-n-Ride Parking Lot Parcel #7815700172 21 Non-Handicap spaces; 1 accessible
space Fair
11 A Street NW Parking Lot 11 A Street NW 47 Non-Handicap spaces; 2 accessible
spaces Poor
B Street Parking Lot 137 E Main Street 60 Non-Handicap spaces; 13 accessible
spaces Fair
Safeway Parking Lot Parcel #7331400135 122 Non-Handicap spaces; 4 accessible
spaces Poor
D Street Parking Lot 350 E Main St 20 Non-Handicap spaces; 0 accessible
spaces Very Poor
JC Employee Parking Lot 20 D Street SE 55 Non-Handicap spaces; 1 accessible
spaces Fair
Future Plans
On April 1, 2024, the City of Auburn relinquished possession and use of 113 off-site
parking stalls to Sound Transit. The 113 parking stalls were code required parking
stalls tied to two office-condominiums owned by the City and utilized as office
space by City employees. The City will need to replace these 113 parking stalls
within the code required 1,000/ft radius of the office condominiums with which
they serve. Funding for the parking replacement will come in whole or in part from
the monetary amount awarded to the City by the arbitrator who presided over the
arbitration hearing.
Replacement of the 113 parking stalls relinquished to Sound Transit will likely need
to be accomplished by constructing a multi-story parking garage.
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Cemeteries
The City owns two cemeteries. The Mountain View Cemetery is a fully developed
facility (60 acres and five buildings) that provides burial services and related
merchandise for the community. The Pioneer Cemetery is a historic cemetery that
is no longer used for burial purposes.
Level of Service
The current LOS of 29 burial plots/niches and cremation in ground plots per 1,000
population is based on the existing inventory divided by the estimated 2023
citywide population. The proposed LOS of 56 burial and plots/niches and
cremation in ground plots per 1,000 population is based on the projected inventory
divided by the 2028-projected citywide population.
Parks and Recreation
The Parks, Recreation, and Open Space (PROS) Plan is needed to meet legal
requirements and secure funding for the City’s parks and recreation areas for the
next six to ten years. Developed with public involvement, city staff, and several city
commissions, this plan provides a summary of the city’s parks, recreation programs,
and open spaces, and gathers information on the community’s recreational needs
through surveys, outreach, and online tools. This Plan establishes a vision, goals,
and assesses the current level of service provided by city parks and open spaces.
The Capital Improvement Plan (CIP) and its formal approval adoption completes
the PROS Plan suggesting a series of recommended improvements to better serve
the citizens of Auburn for the next six years and beyond, each tied to potential
grant funding sources, serving to guide the City’s response and priorities to the
desired quality of life envisioned from its citizens.
Facilities Inventory
Currently, the City manages a diverse range of parks and recreation assets,
including 23 neighborhood, or local, parks, 14 community parks, 7 parcels of
dedicated open space including a golf course, trail systems, and 16 special use
facilities. More information parks and recreation assets can be found in Appendix F
– PROS Plan of the Comprehensive Plan.
Level of Service (LOS)
A 10-minute walk is considered an important park access metric for several reasons.
A 10-minute walk (approximately 1/2 mile on level ground) as a park access metric is
important because it promotes physical activity, equity, sustainability, social
interaction, and overall community well-being. It aligns with various health,
environmental, and social goals the City has and should encourage staff and
policymakers to prioritize accessible green spaces as a fundamental part of
Auburn’s development and the community’s desired quality of life.
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Future Plans
A Needs Analysis and Capital Improvement Program (CIP) project list can be found
in Appendix F – PROS Plan of the Comprehensive Plan.
Transportation
Roadways: The City’s street system consists of a network of approximately 249
miles of arterials, collectors, local streets and alleys. Existing nonmotorized facilities
include a mix of trails, sidewalks, and both dedicated and shared bicycle facilities.
Signals and ITS: The City’s transportation system also includes 95 traffic signals, a
Traffic Control Center employing Intelligent Transportation Systems (ITS), which
centrally directs the signals, 89 traffic cameras, and various traffic beacons all
communicating on a network of copper wire and fiber optic cable. The City also has
three roundabouts.
Transit: King County Metro Transit, Sound Transit and Pierce Transit serve the
Auburn area. Auburn is currently served by six Metro, two Sound Transit, and one
Pierce Transit bus route. In addition, Sound Transit “Sounder” commuter trains
provide peak hour and midday service at the Auburn Station. The Sounder also
provides special event service to selected sporting events. Park and Ride facilities
and the Auburn Station support bus and rail service.
Facilities Inventory
Quantity Description
249 Miles of Streets
17 Bridges
11,000 Street Signs
13,389 Feet of Guardrail
96 Traffic Signals
31 Rapid Rectangular Flashing Beacons
3.684 Street Lights - City Owned
2,261 Street Lights - PSE Owned
53 School Zone Flashing Beacons
19 Speed Radar Feedback Signs
89 Traffic Cameras
12 Speed Photo Enforcement Locations
(School Zones)
4 Dynamic Message Signs
43.86 Miles of Fiber Optic Systems
2 Community Banner Locations
22.62 Miles of Class I Bikeways
1.29 Miles of Class II Bikeway with Buffer
(Both Sides of Roadway)
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15.95 Miles of Class II Bikeway (Both Sides of
Roadway)
4.21 Miles of Class II Bikeway (Intermittent or 1
Side of Roadway)
2.60 Miles of Class III Bikeway with Pavement
Markings
298.21 Miles of City Sidewalk
Level of Service
The City’s Comprehensive Transportation Plan (CTP) establishes multimodal level of
service standards for City streets, active transportation facilities, and access to
transit service, and freight movement to provide guidance to evaluate the
multimodal facilities, identify deficiencies, and prioritize projects to eventually
reach a complete multimodal network that can support and promote mode shift,
reducing the vehicle capacity demand on the roadways. The following policies
relate to vehicle level of service which the City primarily utilizes to evaluate
transportation system capacity. Other level of service standards are utilized for
concurrency and planning but generally focus on the existing or absence of
facilities and services and the quality of those facilities and services rather than
their capacity.
• Policy TR6-1-1: The City adopts the following Vehicle Level of Service (LOS)
Standards for the AM and PM peak periods per the Highway Capacity
Manual:
o Signalized: The LOS standard for signalized intersections is “D”, with
the following exceptions: for signalized intersections of two principal
arterial roads the LOS standard is “E”.
o Stop Controlled: The LOS standard stop controlled intersections is “D”.
o Roundabout: The LOS standard for roundabout controlled
intersections is “D” with a V/C ratio for each lane group of less than
0.90.
o Queuing: The LOS standard for intersection queuing is the 95th
percentile queue shall not extend across an adjacent driveway, alley,
or street intersection, except if the driveway, alley, or street
intersection is within the functional intersection boundary of the
queue in which case the queue may extend to the limit of the
functional intersection boundary. Additionally, queuing for a
designated turn lane shall not exceed turn lane storage area and
cause a blockage of through lane(s).
Known Capacity Issues
The City utilizes the vehicle intersection delay level of service standard to evaluate
general transportation system capacity for concurrency. Of the 157 intersections
evaluated with the CTP, the following 11 (or 8%) were operating below the City’s
adopted level of service standard under existing conditions:
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• Auburn Way North & 45th Street NE
• 116th Avenue SE & SE 304th Street
• 46th Place S/44th Avenue S & S 321st Street/51st Avenue S
• 51st Avenue S & 316th Avenue
• Henry Road NE/Pike Street NE & 8th Street NE
• C Street SW & 3rd Street NW
• M Street SE & Auburn Way South
• Auburn Way South & 17th Street SE
• A Street SE & 44th Street SE
• Lakeland Hills Way SE & Oravetz Road SE
• R Street SE & 33rd Street SE
Initial modeling of future conditions (2044) added another 10 intersections to the
list of intersections that would be operating below the City’s adopted level of
service standard:
• Auburn Way N & 42nd Street NE
• I Street NE & 37th Street NE
• 30th Street NE & I Street NE
• 112th Avenue SE & SE 304th Street
• SE 304th Street & 118th Avenue SE
• 56th Avenue S & S 316th Avenue
• 15th Street NE & M Street NW
• A Street SE & 12th Street SE
• A Street SE & 21st Street SE
• A Street SE & Ellingson Road/41st Street SE
Transportation Project List
The Comprehensive Transportation Plan (CTP) includes projects and programs to
address the vehicle level of service issues at intersections identified in the existing
and future conditions. Those projects include new traffic signals, new roundabouts,
modified lane configurations, new roadways, and other measures intended to
reduce intersection vehicle delays. The CTP also includes projects, programs, and
other actions intended to address to address level of service issues related to active
transportation (bicycle and pedestrian), transit, and freight movement. Please refer
to the CTP for lists and summaries of the projects, programs, and actions.
Public Utilities
The City of Auburn manages sanitary sewer, water, and storm drainage utilities as
well as solid waste collection. The sanitary sewer and water utilities serve the City
and several areas outside the City limits. The efficient provision of these services
can play a significant role in managing the growth of the City as well as affecting
the quality of life for residents of Auburn and the surrounding areas. Public utilities
can serve the following goals:
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• To protect the public health and safety by providing efficient and cost-
effective water, sanitary sewer, storm drainage, and solid waste services to
the community.
• Ensure that development will only occur if the urban services necessary to
support such development will be available when it is developed.
Water
The City provided water service to over 15,000 service connections as of 2024. The
City’s water sources include the Coal Creek Springs and West Hill Springs
watersheds and are supplemented by a system of ten wells (6 active) and two
connections to the regional water system operated by Tacoma Public Utilities.
Storage facilities are found on the Enumclaw plateau, at Lakeland Hills, and at Lea
Hill. For more background information, see the Comprehensive Water Plan.
Facilities Inventory
• Approximately 306 miles of Water Main
• Over 15,000 Service Connections
• 8 Pump Stations
• 8 Reservoirs
• 1 Satellite Water System
• 6 Active Wells
• 2 Springs
Levels of Service Standards
The System Policies included in Appendix A of the Comprehensive Water Plan and
provide direction for City Staff in the management of the utility. The City of Auburn
(City) manages the water utility in accordance with established water system
policies that govern various facets of utility operations. City policies are established
by the City to provide a vision or mission of the water utility and to provide a
framework for the design, operation, and ongoing wellbeing of the City’s water
utility.
The policies included in Appendix A of the Comprehensive Water Plan are
developed specifically for the City’s multi-source municipal water system and seek
to provide consistent treatment to all utility customers and to provide
documentation to current water-system customers as well as those considering
service from the City.
The City’s Comprehensive Water Plan is based upon the following mission
statement for the water utility:
“The City will provide for the efficient, environmentally sound and safe
management of the existing and future water system within Auburn’s service
area.”
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The City’s Water utility policies are grouped within goal statements that are
headlined under the following categories:
• Business Practices
• Service Area
• Operations and Maintenance
• Financial
• Planning
• Environmental Stewardship
• Design and Construction
A few examples of policies related to level of service standards provided by the
water system include:
• Policy 5.3 - System-Wide Reliability
The City shall invest the resources necessary to construct, maintain, and
renew water-system infrastructure and equipment to ensure that customers
are provided consistent, reliable service in accordance with WAC 246-290-
420 Reliability and Emergency Response. Wherever possible, the City should
anticipate system interruptions and design and operate the system to
minimize the impact of such interruptions to customers.
• Policy 5.8 - Water Supply Planning
The City's objective is to ensure a continuous, safe water supply to meet firm
customer demands. Provision of water service must be consistent with the
goals, objectives, and policies of the City of Auburn Comprehensive Water
Plan. Effects of past water conservation will be considered when projecting
future water needs. Future water demands will be estimated using existing
water usage patterns and projected future populations developed by the
City’s comprehensive Plan and consistent with the Puget Sound Regional
Council data.
• Policy 5.10 - Service Pressure
The City should provide potable water to customers in sufficient quantity to
meet maximum day demands at a pressure that meets or exceeds all
minimum applicable regulations, except during emergency conditions.
Property owners may install private booster pumps to achieve higher
pressures under supervision of the City and in accordance with WAC 246-
290-230 Distribution Systems.
Known Capacity Issues (based on Level of Service or other
standards)
The preparation of the Comprehensive Water Plan included hydraulic modeling for
existing and future conditions. Issues derived from the modeling with respect to
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pipeline improvements needed to meet fire flow conditions were ranked, with
those locations ranked higher given more priority to be completed. The projects
are anticipated to be completed under the Repair and Replacement program
identified in Chapter 7 of the Comprehensive Water Plan. In addition, other known
capacity issues with respect to water facilities and sources, include:
• Lea Hill Intertie Booster Pump Station - the Intertie Booster Pump Station
(serves the Lea Hill 648 pressure zone) has a pumping capacity deficit, and
the Pump Station lacks emergency power, impacting water supply during
power outages.
• Lea Hill Service Area Storage - There is a reservoir/storage capacity shortage
of 0.54 MG for the Lea Hill service area.
• Valley Service Area Storage - There is a reservoir/storage capacity shortage of
1.28 MG in the Valley service area.
• Wells 3A/3B - are offline due to high manganese levels.
• Wells 7 - is offline due to high manganese levels.
• Coal Creek Springs - is underutilizing its water right, leading to inefficiency.
• Well 5 - needs upgrades and property acquisition for expansion.
• Well 4 - requires facility and electrical improvements for efficient operation.
• Well 1 and Well 4 - Liquid chlorine degradation at the facilities affect water
treatment during low winter demand periods.
• West Hill Springs - Aging chlorination building.
• Lea Hill Pump Station – pump station lacks redundancy.
• Game Farm Wilderness Park - pumps need replacement and building
repairs.
• Reservoir 2 - Limited maintenance access to Reservoir 2 valves and lack of
earthquake resiliency.
• Coal Creek Springs Transmission Main- 100+ year old pipe that needs to be
replaced and is susceptible to leaks.
• West Hill Springs - Poor condition of existing cast iron transmission main.
• Howard Road Corrosion Control Treatment Facility (CCTF) - will exceed
capacity after Coal Creek Springs Rehabilitation project completion.
• Howard Road Corrosion Control Treatment Facility (CCTF) - Existing liquid
chlorine generating equipment reaching the end of its useful life at Fulmer
CCTF.
Stormwater
The System consists of a combination of open ditches, closed conveyance pipes,
water quality facilities, and pump stations. For more details, see the Comprehensive
Storm Drainage Plan.
Facilities Inventory
• Over 240 miles of storm drainage pipe
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• Over 40 miles of open channels and ditches
• Over 13,900 junction structures (catch basins, manholes)
• 167 detention ponds
• 7 pump stations.
Levels of Service Standards
The System Policies included in Chapter 3 of the Comprehensive Storm Drainage
Plan provide direction for City Staff in the management of the utility. The following
policies are specifically related to designed capacity level of service provided by the
sewer conveyance system:
• Policy 1.1 -The City shall seek to manage stormwater runoff within the public
Right of Way (ROW):
o to provide access to and functionality of critical services.
o to preserve mobility on major transportation routes (i.e., arterial roads)
and residential roads.
o to protect real property structures (e.g., residences and businesses.)
• Policy 1.2 - The City shall seek to provide pump redundancy and backup
power generators or dual power feeds at City- owned and -operated
drainage pump stations.
• Policy 1.3 - The City shall routinely assess the performance of pumped
systems with a focus on capacity and vulnerability. This review aims to
ensure that these systems operate efficiently, meet their intended capacity,
and remain resilient against potential risks.
Known Capacity Issues
The preparation of the Comprehensive Storm Drainage Plan included hydraulic
modeling focused on updating models within locations of proposed capital
projects. In addition, existing drainage problems have been observed by the staff
and are known to cause flooding of roadways at the following locations:
• Auburn Way South/ SR 18 Underpass - minor roadway flooding causes
disruptions to traffic during periods of certain intense rainfall events.
• I St NE between 33rd St NE and 35th St NE – minor flooding has been
observed when the Green River flows are high, and the gravity discharge is
impacted.
• There are areas within the city not served by the public storm system, such
as paved alleys or residential streets where minor flooding is observed.
Future Plans
The 6-year capital improvements are discussed in detail in Chapter 7 and the
implementation schedule presented in Chapter 8 of the Comprehensive Storm
Drainage Plan.
Sewer
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The system is primarily a collection system with treatment provided by Metro. The
system includes approximately 205 miles of sewers and force mains and 17 sewer
pump stations. Significant portions of the City’s service area are currently on septic
systems, although plans for future expansion of sewer service into these areas is
included in the Comprehensive Sewer Plan. For more details, see the
Comprehensive Sewer Plan.
Facilities Inventory
Sewer facilities in the City currently consist of:
• 205 miles of gravity sanitary sewer main
• 17 sewer pump stations
• 5 miles of force main associated with pump stations
• 3 siphons (1 single pipe, and one double pipe under the Green River
• 2,700 sewer service connections
Level of Service Standards
The System Policies included in Chapter 2 of the Comprehensive Sewer Plan
provide direction for City Staff in the management of the utility. The following
policies are specifically related to designed capacity level of service provided by the
sewer conveyance system:
Policy 3.3 - Require the transport of sewage by gravity whenever feasible in order to
increase reliability, sustainability, and long-term cost effectiveness.
Policy 4.5 - Size the sewer collection system for peak wet weather flow rates that
include I/I flows. Gravity sewers will be sized to convey the once-per-20-year peak
hour flow without surcharging.
Policy 4.6 - Size pump stations and force mains for peak wet weather flow rates
that include I/I flows. Pump stations will be sized to convey the once per 5-year flow
with one pump out of service and convey the once per 20-year flow with all pumps
in service.
Known Capacity Issues
The preparation of the Comprehensive Sewer Plan included hydraulic modeling for
three scenarios. The first used existing system wastewater flows and applied the
expected additional flow during a design storm (with a 20-year recurrence). The
second was to escalate wastewater base flows based on population and
employment projections for the year 2044, and the last was to increase the
intensity and duration of the design storm based on anticipated rainfall changes
associated with climate change.
• The existing system is shown to have few deficient pipes, none of which
cause overflows.
• For future scenarios (2044-both including and not including climate change
effects) show the following deficiencies:
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o The Rainier Ridge Pump Station’s capacity is anticipated to be under
capacity; however, a project is currently underway to replace that
station in 2025.
o The Dogwood Pump Station is anticipated to be under capacity in
2044.
o Approximately 4,000 feet of gravity sewer in Roegner Park is expected
to be under capacity in 2044.
o Individual pipe segments upstream of each of the Green River
crossings are expected to be under capacity at various times
throughout the 20-year planning period. The precise timing is
dependent on the rate and distribution of population and
employment growth.
Future Plans
Conceptual plans for future sewer extensions and facilities are shown on Figure 5.5
of the Comprehensive Sewer Plan. Those extensions are to be funded by the
property owners of the parcels served by them, so the timing of their construction
is unknown. The Capital Improvement Plan is described in detail in Chapter 7 of the
Comprehensive Sewer Plan. The Plan includes projects related to system capacity,
repair and replacement, and system evaluation.
Solid Waste
The City of Auburn contracts with Waste Management (WM) for collection of
municipal garbage, recycling, and yard waste. Waste Management disposes of
Auburn’s garbage at a King County Solid Waste transfer station. Recycling is
processed at WM’s material recycling facility in Tacoma, WA. WM takes the yard
and food waste to either DTG in Tacoma, WA or Cedar Grove in Maple Valley, WA to
be converted into compost. There is a small area of Auburn that was recently
annexed. This area is serviced by Republic Services. Republic Services takes the
garbage to a King County Solid Waste transfer station, the recycling is processed at
their material recycling center in Seattle, WA, and yard and food waste is taken to
Cedar Grove in Maple Valley, WA.
Telecommunications
The City of Auburn owns and maintains a robust fiber optic Metropolitan Area
Network (MAN) that connects most City owned facilities throughout the Auburn
area. This infrastructure delivers secure, high-speed broadband capabilities
essential for supporting various government functions, including public safety,
public works, planning, permitting, and tourism.
Additionally, our fiber optic network enhances city operations by facilitating
interconnections with regional partners and service providers such as City of
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Algona, City of Pacific, King County, The Community Connectivity Consortium,
University of Washington, Valley Communications and Microsoft.
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Public Education Facilities
Auburn’s residential areas are served by a combination of Auburn School District,
Dieringer School District, Federal Way Public Schools, and Kent School District.
Detailed inventories of school district capital facilities and levels-of-service are
contained in the Capital Facilities Plan (CFP) of each school district. The CFPs of the
four school districts serving Auburn residential areas and the associated school
impact fees are adopted annually as part of the Annual Comprehensive Plan
amendment process. Locations of schools and school districts within the City of
Auburn which are illustrated in the map below.
Future Plans
To accommodate projected growth, the school districts have noted the following
projects in their 2023 Capital Facilities Plans:
Auburn School District
• Portable Relocation – Opens 2023-2024
• Middle School #5 – Opens 2027-2028
Dieringer School District
• Elementary School #3 – Opens 2027
• North Tapps Middle School Classroom Addition – Opens 2027
Federal Way Public Schools
• Illahee Middle School Modernization and Expansion – Opens 2024
• Former DeVry/ES 24 Site Acquisition – Opens 2028
• Portables Expansion – Through 2030
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Goals and Policies
Goal # 1 - Keeping Pace with Growth
Ensure that new development does not outpace the City’s ability to provide and
maintain adequate public facilities and services, by allowing new development to
occur only when and where adequate facilities exist or will be provided, and by
encouraging development types and locations that can support the public services
they require.
Policies:
CF-1. Lands designated for urban growth by this Plan shall have public facilities
(streets, sewer, water, storm drainage, and parks) that meet City standards prior to
or concurrent with development.
CF-2. Encourage development where new public facilities can be provided in an
efficient manner.
CF-3. If adequate facilities are currently unavailable and public funds are not
committed to provide such facilities, developers must provide such facilities at their
own expense to develop their proposed projects.
CF-4. The City shall encourage and approve development only where adequate
public services including police protection, fire and emergency medical services,
education, parks and other recreational facilities, solid waste collection, drinking
water, storm drainage, roadway and nonmotorized and other governmental
services are available or will be made available at acceptable levels of service prior
to project occupancy or use.
CF-5. Provide additional public facility capacity when existing facilities are used to
their maximum level of efficiency (consistent with adopted standards for level of
service).
CF-6. Encourage development where new public facilities can be provided in an
efficient manner.
CF-7. 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.
CF-8. New development shall not be approved that is not supported by a
minimum of facilities to support the development and that does not provide for its
proportionate share of related system needs.
CF-9. The city will perform its activities and make capital budget decisions in
conformity with the comprehensive plan. The Land Use Element of the
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comprehensive plan shall be reassessed if probable funding falls short of meeting
existing needs.
CF-10. Establish land use patterns that optimize the use of public facilities.
CF-11. Exempt the following from the concurrency management program:
• Development vested by RCW 19.27.095, 58.17.033 or 58.17.170.
• Development that creates no added impact on public facilities.
• Expansions of existing development that were disclosed and tested for
concurrency as part of the original application.
Goal # 2 – Public Facilities and Funding
Provide needed public facilities that are within the ability of the City to fund or
within the City’s authority to require others to provide.
Policies:
CF-12. Establish level of service standards that are achievable with the financing
plan of this Capital Facilities Plan.
CF-13. Base the financing plan for public facilities on realistic estimates of current
local revenues and external revenues that are reasonably anticipated to be received
by the City.
CF-14. Match revenue sources to capital projects based on sound fiscal policies.
• The City shall continue to fund utility costs through utility enterprise funds,
based on user fees and grants. Public facilities included in utilities are sewer,
solid waste, storm drainage, and water.
• Where feasible pursue joint venture facility construction, construction
timing, and other facility coordination measures for City provided facilities, as
well as with school districts and other potential partners in developing public
facilities.
• The City shall continue to assist through direct participation, LIDs and
payback agreements, where appropriate and financially feasible. Where
funding is available, the City may participate in developer-initiated facility
extensions or improvements, but only to the extent that the improvements
benefit the broader public interest and are consistent with the policies of this
Capital Facilities Plan.
CF-15. If the projected funding is inadequate to finance needed public facilities and
utilities based on adopted level of service standards and forecasted growth, the
City will do one or more of the following to achieve a balance between available
revenue and needed public facilities:
• Lower the level of service standards;
• Increase the amount of revenue from existing sources;
• Adopt new sources of revenue;
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• Require developers to provide such facilities at their own expense; and/or
• Amend the Land Use Element to reduce the need for additional public
facilities.
CF-16. Both existing and future development will pay for the costs of needed capital
improvements.
• Ensure that existing development pays for capital improvements that reduce
or eliminate existing deficiencies and pays for some or all of the cost to
replace obsolete or worn-out facilities. Existing development may also pay a
portion of the cost of capital improvements needed by future development.
Existing development’s payments may take the form of user fees, charges for
services, special assessments, and taxes.
• Ensure that future development pays a proportionate share of the cost of
new facilities that it requires. Future development may also pay a portion of
the cost to replace obsolete or worn-out facilities. Future development’s
payments may take the form of voluntary contributions for the benefit of any
public facility, impact fees, mitigation payments, capacity fees, dedications of
land, provision of public facilities, and future payments of user’s fees, charges
for services, special assessments, and taxes.
CF-17. The City will determine the priority of public facility capital improvements
using the following criteria as general guidelines. Any revenue source that cannot
be used for the highest priority will be used beginning with the highest priority for
which the revenue can legally be expended.
• Projects that eliminate hazardous conditions.
• Refurbishment of existing facilities that contribute to achieving or
maintaining standards for adopted level of service.
• New or expanded facilities that reduce or eliminate deficiencies in level of
service for existing demand.
• New or expanded facilities that provide the adopted level of service for new
development and redevelopment during the next six fiscal years.
• Capital improvements that significantly reduce the operating cost of
providing a service or facility, or otherwise mitigate impacts of public
facilities on future operating budgets.
• Capital improvements that contribute to stabilizing and developing the
economy of the City.
• Project priorities may also involve additional criteria that are unique to each
type of public facility, as described in other elements of this Comprehensive
Plan.
CF-18. Ensure that the ongoing operating and maintenance costs of a capital
facility are financially feasible prior to constructing the facility.
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Goal # 3 – Public and Environmental Health
Protect public health, environmental quality, and neighborhood stability and
viability through the appropriate design and installation of public facilities.
Policies:
CF-19. Promote conservation of energy, water and other natural resources in the
location and design of public facilities.
CF-20. Require the separation of sanitary and storm sewer facilities wherever
combined sewers may be discovered.
CF-21. Practice efficient and environmentally responsible maintenance and
operating procedures.
CF-22. The siting, design, construction and improvement of all public buildings shall
be done in full compliance with the Americans with Disabilities Act (ADA).
CF-23. Promote economic and community stability and growth through strategic
investments in public facilities and public/private partnerships.
Goal # 4 – Community Benefits of Public Facilities
Provide public facilities that provide a sense of community that is inclusive of
diverse populations.
Policies:
CF-24. Contribute to community pride and foster a sense of community through
provision of public facilities that create a community-gathering place for neighbors,
family and friends.
CF-25. Through provision of public facilities, offer a broad range of activities
promoting social interactions especially with new residents.
CF-26. Provide maximum flexibility and multiple uses through design of public
facilities that are adaptable to changing interests.
CF-27. Provide a community center facility that is financially feasible, affordable for
participants, and can generate revenue to offset a portion of the operating costs.
Goal # 5 – Consistency with Other Adopted Plans
Make the Capital Facilities Plan consistent with other elements of the
comprehensive plan, and with other city, county, regional and state adopted plans.
Policies:
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CF-28. Ensure that the growth and development assumptions used in the Capital
Facilities Plan are consistent with similar assumptions in other elements of the
comprehensive plan.
CF-29. Coordinate with non-city providers of public facilities on a joint program for
maintaining applicable level of service standards, concurrency requirements,
funding, and construction of public facilities.
Goal # 6 - Solid Waste
To provide area residents and businesses with a universal and compulsory system
for collection and disposal of all solid waste, including ample waste reduction and
recycling opportunities intended to maximize diversion of the City’s waste stream
away from costly landfills, incineration, or other solid waste disposal facilities, and
to conserve exhaustible resources.
Policies:
CF-30. The King County Solid Waste Management Plan and Solid Waste Interlocal
Forum, except as modified by City of Auburn Ordinance No. 4413 and this Plan shall
form the basis for solid waste management activities within the City.
CF-31. The City shall continue to fund solid waste collection, disposal and waste
reduction and recycling programs and services through the existing solid waste
utility, with supplemental funding provided through available grants.
CF-32. The City shall implement solid waste management programs and services
that provide ample opportunities and incentives to maximize the community’s
participation in local and regional waste reduction and recycling efforts.
CF-33. The City’s solid waste management programs shall be developed to make
waste reduction and recycling efficient, reliable, cost-effective, and convenient for
all residents and businesses.
CF-34. The City encourages and should promote the use of products manufactured
from recycled materials, and the use of materials that can be recycled. City
Departments and contractors shall use recycled and recyclable products whenever
and wherever feasible.
CF-35. The City shall implement solid waste reduction and recycling programs that
have the cumulative effect maintaining the 50 percent waste reduction and
recycling goal (recycling tons/total solid waste stream).
CF-36. The City shall periodically monitor and evaluate the effectiveness of Auburn’s
waste reduction and recycling programs to ensure that local and state goals and
policies are being met.
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CF-37. The City shall promote the recycling of solid waste materials by providing
opportunities for convenient recycling and by developing educational materials on
recycling, composting and other waste reduction methods.
Goal #7 - Public and Institutional Buildings
To site public and institutional buildings in accord with their service function and
the needs of the members of the public served by the facility.
Policies:
CF-38. All “people-oriented” City facilities should be located near high-amenity
sites. Les Grove Park and downtown are particularly appropriate sites for senior
services, community centers, libraries, museums, etc.
CF-39. City park buildings should be developed in accordance with the Parks,
Recreation, and Open Space Element.
CF-40. Public and institutional facilities should incorporate practices that reduce
energy consumption, reduce the emission of greenhouse gases, conserve water,
provide electric vehicle infrastructure, and preserve native vegetation.
CF-41. Public and institutional facilities that attract a large number of visitors (City
Hall, museums, libraries, educational facilities, permit and license offices, health
and similar facilities, etc.) should be sited in areas that are accessible (within 1/4
mile) by transit.
CF-42. The City shall encourage other agencies to follow these siting principles in
considering new sites for public buildings.
CF-43. The location of religious institutions, private schools, community centers,
parks and similar public or institutional facilities shall be related to the size of the
facility and the area served. Citywide facilities should be sited in visible and
accessible locations.
CF-44. Small public or institutional facilities intended to serve one or two residential
neighborhoods may be located within a neighborhood. Larger public or
institutional facilities intended to serve mainly Auburn residents or businesses shall
be located along major arterial roads within the community-serving area of
Auburn; however, elementary schools should be given flexibility to locate along
smaller roads. Buffering from adjacent land uses may be required.
CF-45. The location of utility facilities is often dependent upon the physical
requirements of the utility system. Sewage lift stations, pump stations, water
reservoirs, and other similar facilities should be sited, designed, and buffered
(through extensive screening and/or landscaping) to fit in harmoniously with their
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surroundings. When sited within or adjacent to residential areas, special attention
should be given to minimizing noise, light, and glare impacts.
CF-46. Public facilities of an industrial or heavy commercial character should be
confined to the region-serving area of Auburn, unless no other reasonable siting
opportunity exists, in which case siting still must comply with applicable zoning
standards. Examples of such facilities are the City maintenance and operations
facility, state and regional solid waste facilities, and the Auburn School District bus
barn.
CF-47. The siting and relocation of City maintenance and operation facilities shall
be responsive to growing demands for utility, transportation, and fleet services, and
shall also account for the City’s role in emergency preparedness and response.
Goals # 8 - Essential Public Facilities
The Growth Management Act requires that a local comprehensive plan include a
process for siting essential public facilities. This section contains Auburn’s process
for siting essential public facilities.
Policies:
CF-48. The City will review proposals through the process outlined in Policies 3
through 8 below, if the essential public facility largely serves a regional,
countywide, statewide, or national need, and is included in a policy sense within an
adopted state or regional plan that meets both of the following criteria:
a. The state or regional plan was developed through an appropriate public
process (including at least one local public hearing) and has undergone a
NEPA and/or SEPA review.
b. A clear policy statement supporting the type of facility proposed must be
included. The plan should also include, in a policy sense, a set of siting
guidelines to be used for such a facility. Such criteria may include but are not
limited to the type and sufficiency of transportation access, colocation
requirements, preferred adjacent land uses, on- or off-site security and/or
mitigation, and required public facilities and services.
CF-49. If the essential public facility largely serves a regional, countywide, statewide
or national need and is not part of an adopted state or regional plan, the proponent
will be required to request that the appropriate state or regional plan be amended
to include the proposal meeting the criteria contained in Policy CF-1 above. The
proposal will also be reviewed following the process outlined in Policies CF-3
through CF-4.
CF-50. Essential Public Facilities of a regional, countywide, statewide, or national
nature:
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a. Essential public facilities of a regional, countywide, statewide or national
nature will be reviewed by the City through the special area plan process.
The boundaries of the special area plan will be set at a scale directly related
to the size and magnitude of the proposal. For facilities of regional, state, and
national need, an alternative analysis will be performed, but will not be
limited to, the guidelines described in Policy CF-1 above. Auburn staff shall
participate in the review process outlined in Policy 1 above, and use the data,
analysis, and environmental documents prepared in that process to aid the
City’s special area plan review, if Auburn determines that those documents
are adequate. If the facility requires other development permits, those
approvals also shall be considered within the review process.
b. Impacts of the proposed essential public facility must be identified and an
appropriate mitigation plan developed. Unless otherwise governed by state
law, the financing strategy for the mitigation plan shall be structured so that
the costs of the plan shall be allocated proportionally on a benefit basis using
nonlocal sources of funding, although local sources of funding may also be
used.
c. The special area plan process to be used for essential public facilities of a
regional, countywide, statewide, or national nature shall follow the City’s
Comprehensive Plan amendment process that includes multiple
opportunities for public involvement.
d. An analysis of the facility’s impact on City finances shall be undertaken. If
the study shows that locating a facility in a community would result in a
disproportionate financial burden on the City of Auburn, an agreement with
the project’s proponents must be executed to mitigate the adverse financial
impact or the approval shall be denied.
CF-51. Essential Public Facilities of a primarily local nature:
If the essential public facility meets largely local needs (for example, in-patient
facilities, including substance abuse facilities, mental health facilities and group
homes), the facility shall be considered based upon Policy CF-52 below.
CF-52. All Essential Public Facilities:
a. The following criteria shall be used to evaluate all applications to site
essential public facilities:
1) Whether there is a public need for the facility.
2) The impact of the facility on the surrounding uses and environment,
the City and the region.
3) Whether the design of the facility or the operation of the facility can be
conditioned, or the impacts mitigated, in a manner similar to those used
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in traditional private development, in order to make the facility
compatible with the affected area and the environment.
4) Whether a package of mitigating measures can be developed that
would make siting the facility within the community more acceptable.
5)Whether the factors that make the facility difficult to site can be
modified to increase the range of available sites or to minimize impacts
on affected areas and the environment.
6) Whether the proposed essential public facility is consistent with the
Auburn Comprehensive Plan.
7) Essential public facilities shall comply with any applicable state siting
and permitting requirements (e.g., hazardous waste facilities).
8) Whether the State proves by clear, cogent, and convincing evidence
that (1) a sufficient and reasonable number of alternative sites have been
fully, fairly, and competently considered, and (2) such sites were found to
be unsuitable for an SCTF for reasons other than the cost of property.
9) Whether careful analysis has been completed to show that siting of the
facility will have no undue impact on any one racial, cultural, or
socioeconomic group, and that there will not be a resulting concentration
of similar facilities in a particular neighborhood, community, jurisdiction,
or region.
CF-53. The Planning Director or designee shall determine whether a development
application will result in a significant change of use or a significant change in the
intensity of use of an existing essential public facility. If the Planning Director or
designee determines that the proposed changes are significant, the proposal will
be subject to the essential public facility siting process as defined in Goal #4, Policy
CF-10. If the Planning Director or designee determines that the proposed changes
are insignificant, the application shall be reviewed through the City’s standard
development review procedures. The Planning Director or designee's
determination shall be based upon:
a. The proposal’s impacts on the surrounding area.
b. The likelihood that there will be future additions, expansions, or further
activity related to or connected with the proposal.
CF-54. One of the difficulties of siting essential public facilities is that they are
allowed in some but not all appropriate areas. To help address this problem,
Auburn shall allow essential public facilities in all zones where they would be
compatible. The types of facilities that are compatible will vary with the impacts
likely from the facility and the zoning district. In the M-2 Zoning District, many
essential public facilities will be compatible uses and broad use categories allowing
such uses should be included in the zone.
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CF-55. Essential public facilities shall be allowed in those zoning districts in which
they would be compatible, and impacts can be mitigated. In situations where
specific development standards cannot be met, but it is determined that the
facility can be made compatible, the City Council can waive those specific
standards with the requirement that appropriate mitigation is provided. The M-2
Zoning District should include broad use categories that allow all essential public
facilities that are difficult to site as permitted or conditional uses as appropriate.
CF-56. Essential public facilities should be equitably located throughout the City,
county and state. No jurisdiction should absorb a disproportionate share.
CF-57. Essential public facilities of a regional, countywide, statewide, or national
nature should be restricted to the region-serving area of Auburn. Such facilities
should be located in relationship to transportation facilities in a manner
appropriate to their transportation needs. Extensive buffering from adjacent uses
may be required. Facilities that generate a significant amount of truck traffic
should be located such that they are served by existing truck routes or mitigation
provided to address impacts on the street network.
Page 372 of 373
AGENDA BILL APPROVAL FORM
Agenda Subject:
Comprehensive Plan DEIS (Steiner)
Date:
June 11, 2024
Department:
Community Development
Attachments:
No Attachments Av ailable
Budget Impact:
Current Budget: $0
Proposed Revision: $0
Revised Budget: $0
Administrativ e Recommendation:
Background for Motion:
Background Summary:
Rev iewed by Council Committees:
Councilmember:Staff:Steiner
Meeting Date:June 18, 2024 Item Number:
Page 373 of 373