DOEJuly 28, 2008
Mr. Grant Beck, Community Development Director
City of Yelm
Community Development Department
PO Box 479
Yelm, WA 98597
Dear Mr. Beck:
Thank you for the opportunity to comment on the draft environmental impact statement (DEIS) for the Highlands Master Planned Community project, located within the City of Yelm. The
Department of Ecology (Ecology) reviewed the environmental checklist and has the following comment(s):
SHORELANDS & WETLANDS: Sarah Lukas (360) 407-7459
The proposed 2.43 acres of impacts to wetlands will require authorization from both the U.S. Army Corps of Engineers (Corps) as well as Ecology including those wetlands that are not
considered jurisdictional by the City of Yelm.
The wetland section of the DEIS identifies that the impacts to wetlands total 0.4% of all of the wetlands present on site. This implies that the site contains roughly 600 acres of wetlands,
when only approximately 68 acres were identified in the wetland tables of the DEIS. This is a large discrepancy of the reported wetlands in the project area that should be remedied
in the final environmental impact statement (FEIS).
The wetland summary identifies that the majority of the wetlands present on site are isolated depressions, these wetlands may not be regulated by the Corps, but it will be necessary
for the applicant to receive a jurisdictional determination from the Corps identifying those wetlands as isolated. If wetlands on site are found to be isolated by the Crops, Ecology
will still regulate these waters of the state under RCW 90.48, and require compensatory mitigation for the impacts.
TOXICS CLEANUP: Laura Klasner (360) 407-6265
If contamination is suspected or discovered during development or construction activities, sampling must be conducted. If contamination is confirmed during testing, Ecology must be
notified. Contact the Environmental Report Tracking System Coordinator at Ecology’s Southwest Regional Office at (360) 407-6300. For assistance and information about subsequent cleanup
and to identify the type of testing that will be required, contact Laura Klasner at the phone number given above.
WATER QUALITY: Roberta Woods (360) 407-6269
Erosion control measures must be in place prior to any clearing, grading, or construction. These control measures must be effective to prevent stormwater runoff from carrying soil and
other pollutants into surface water or storm drains that lead to waters of the state. Sand, silt, clay particles, and soil will damage aquatic habitat and are considered to be pollutants.
Any discharge of sediment laden runoff or other pollutants to waters of the state is in violation of Chapter 90.48 RCW, Water Pollution Control, and WAC 173-201A, Water Quality Standards
for Surface Waters of the State of Washington, and is subject to enforcement action.
Proper disposal of construction debris must be on land in such a manner that debris cannot enter waters of the state or cause water quality degradation of state waters.
Soil in stockpiles should be stabilized or protected with sediment-trapping measures to prevent soil loss. All exposed areas of final grade or areas that are not scheduled for work,
whether at final grade or otherwise, shall not remain exposed and un-worked for more than two days, between October 1 and April 30. Between May 1 and September 30, no soils shall remain
exposed and un-worked for more than 7 days.
Clearing limits and/or any easements or required buffers should be identified and marked in the field, prior to the start of any clearing, grading, or construction. Some suggested methods
are staking and flagging or high visibility fencing.
A permanent vegetative cover should be established on denuded areas at final grade if they are not otherwise permanently stabilized.
Properties adjacent to the site of a land disturbance should be protected from sediment deposition through the use of buffers or other perimeter controls, such as filter fence or sediment
basins.
All temporary erosion control systems should be designed to contain the runoff from the developed two year, 24-hour storm without eroding.
Provisions should be made to minimize the tracking of sediment by construction vehicles onto paved public roads. If sediment is deposited, it should be cleaned every day by shoveling
or sweeping. Water cleaning should only be done after the area has been shoveled out or swept.
Wash water from paint and wall finishing equipment should be disposed of in a way which will not adversely impact waters of the state. Untreated disposal of this wastewater is a violation
of State Water Quality laws and statutes and as such, would be subject to enforcement action.
Source control Best Management Practices (BMPs) such as plastic covering, mulch, temporary seeding, and phased clearing (for example) should be used to control erosion during construction.
More examples of effective source control BMPs can be found in Ecology’s two stormwater management manuals, Stormwater Management Manual for Puget Sound (1992) and Stormwater Management
Manual for Western Washington (2001).
Ecology’s comments are based upon information provided by the lead agency. As such, they do not constitute an exhaustive list of the various authorizations that must be obtained or
legal requirements that must be fulfilled in order to carry out the proposed action.
If you have any questions or would like to respond to these comments please contact the appropriate reviewing staff listed above.
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Department of Ecology
Southwest Regional Office