Final EIS 2-1993 (Prelim)
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SOUTHWEST YELM
ANNEXA TION
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PREU UiARl
SUBJECllO R\EV~SM)~
FINAL ENVIRONMENTAL
IMPACT STATEMENT
.. cU nU\R1
p R t;.C1' 10 ~EV%S~ON
SUBJE ,u
CITY OF YELM
FEBRUARY 1993
R.W. THORPE AND ASSOCIATES, INC.
BARGHAUSEN CONSULTING ENGINEERS, INC.
S. CHAMBERLAIN AND ASSOCIATES, INC.
INDEPENDENT ECOLOGICAL SERVICES
MUNDY AND ASSOCIATES
I
C> - --'
FINAL ENVIRONMENTAL IMPACT STATEMENT
/
for the
SOUTHWEST YELM ANNEXATION
City of Yelm Planning Department
Y elm, Washington
oncU \t\I\Q'l
r t\1\ ~ ' 10 RE\I\S\ON
SUBJECl
In Compliance With
State Environmental Policy Act (SEP A) of 1971
Revised Code of Washmgton 43.21C
Chapter 197-11 Washington Administrative Code and the Thurston County
SEP A Ordmance NO 7889
State Growth Management Act (GMA)
House Bills 1025 and 2929
- <P
INTRODUCTION
The City of Yelm is considering annexation of approximately 2,000 acres southwest of the current city
limits. The Draft Environmental Impact Statement (DElS) was published on the 14th of December 1992
and presented information concerning potential impacts that may occur from annexation and the general
development plans within the proposed annexation area. Annexation proposals are considered
"nonproject" actions according to the State Environmental Policy Act (SEP A) under the provisions of
WAC 197-11-704 (2) (b) (iv) As such, the contents of The Southwest Yelm Annexation DElS were
limited to general discussion of potential impacts and proposed mitigation measures (WAC 197-11-442),
rather than an examination of impacts specific to those.
In accordance with these rules, The Southwest Yelm Annexation DEIS provided a general review of
impacts associated with the annexation proposal and various conceptual development scenarios within
the proposed annexation area. The DEIS also included several elements that discuss the relationship
of the proposed annexation to requirements mandated by the 1990 Growth Management Act (GMA)
While this analysis provides information on how the proposed annexation would be affected by GMA
requirements, it is not intended to analyze the GMA itself
Unless otherwise noted, the potential impacts and proposed mitigation in the Southwest Yelm
Annexation EIS refer to conceptual development scenarios as presented under the DescriptIon of the
Proposal and Alternatives In some instances mitigating measures refer to various techniques that
would be suitable in a certain case. These are guidelines and mayor may not be used, depending on a
given project. The exact nature of future development within the proposed annexation area is not known
at this time. Future site-specific, project level environmental review will occur as ffidividuJI/
development takes place.
At the time of submittal of a site-specific development proposal, a list of required mitigation will be
prepared based on the final project specific EIS, and the share of mitigation attributed to that
development The developer will be required to a) install all mitigation improvements totally
attributable to the development, and b) pay a fee for their proportionate share of larger area
improvements, with these improvements to be installed upon completion of funding for said
improvements
The State Environmental Policy Act includes public participation in the environmental review process
Opportunities for public involvement are required during the impact statement scoping process and after
publication of a draft environmental impact statement. During the preparatiQn"'~\9n EIS, other
opportunities may arise for public involvement. FreqUentlXJ!' II, eacl i,gg.~~~iW)1\ \\tM'~ii 'i[~:ltPi~ members of
organized groups in technical meetings or other discussion ' 0~ ~~~nt"1n"'fl \11 ~~.~rmal public
meetings may also be held to discuss environmental issue. ~~ p1iOic ,HI in is part of both
nonproject and project actions The Lead Agency, City of Yel~lM s prepared this Final Environmental
Impact Statement (FElS) in accordance with SEP A under the provisions of WAC 197-11-560 All
substantive comments on the proposal submitted during the required comment period, either in written
form or from a speaker at a public hearing, have been considered and responded to in this FEIS
Response to comments were addressed in one of the following forms A) a modification of the
alternatives, including the proposed action, B) identification and evaluation of alternatives not
previously given detailed analysis in the OBIS. C) a supplementation, improvement, or modification
of the analysis provided in the DElS. D) factual corrections to previous data and analysis, or E) an
explanation of why the comment does not warrant further consideration.
~ -'
Fact Sheet
Proposed Action and Alternatives
Alternative 1: No Action
The proposed annexation would not occur and future development would take place under Thurston
County regulations.
Alternative 2: Proponents' Scenario
Local property owners are proposing to annex to Yelm approximately 2000 acres southwest of the current
city limits. Annexation would allow development of the site under City of Yelm regulations. As
proposed, the development mix would include residential, recreational and commercial uses. Proposed
development would include landscaping and buffers as well as roads, open space and public service
improvements. Figures 1 and 2 show the location and vicinity maps of the proposed annexation area.
Figure 3 provides an overview of the site topography and identifies the annexation area boundaries
according to section, township, and range.
Alternative 3. Compact Scenario
The proposed mix of uses under this alternative would remain largely similar to those of the proposal.
Potential land uses would be clustered to allow the same level of development on less land area thus
providing more open space and landscape buffering in the area. This approach would also result in
lower facility costs for the proposed annexation area
Alternative 4. The Village Scenario
The proposed residential uses would decrease under this approach and additional commercial space
would be provided. The overall area of residential uses on the site would be decreased
Proponent:
Thurston Highlands Associates
1917 First Avenue
Seattle, Washington 98101
Contact: Dennis Su, AlA, Project Manager
(206) 443-3537
PREll n'iAR'1,
SUBJECT TO REVlS\ON
Lead Agency:
City of Yelm
105 Yelm Avenue West
POBox 479
Y elm, Washington 98597
Contact: Todd Stamm, Director of Community Development
Phone (206) 458-3244
Authors and Principal Contributors:
This document has been prepared under the direction of the City of Yelm, pursuant to the State
Environmental Policy Act. The following firms have provided research and analysis in this report:
EIS Preparation, Land Use
R.W Thorpe and Associates, Inc.
705 Second A venue, Suite 910
Seattle, Washington 98104
Contacts. Robert W Thorpe, AICP
Gareth V Roe, Environmental/Land Use Planner
Peter Rosen, Environmental Planner
Phone: (206) 624-6239
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R. W. Thorpe & Associates, Inc. Seattle/Anchorage/Denver
910 B _ 705 2nd A....... Sealt I.. , WA 98104 (206) 624 6239
PI.n~ng
Landscap.
. En'lkonm.n'al
Economic.
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Fi
SOUTHWEST YELM ANNEXATION
Vicinity Map
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Ft'W~tfiorpe.-- & Associates, Inc. Seatlle/Anchora~/Denver
BuIdIr' ~2ndA.......... Seattle, WA 98104 (206) 624 6239
. Plan""ng
land.cap.
. En...konl'ft.ntal
Economic.
(ID
SOUTHWEST YELM ANNEXATION
Location Ma
'-
TABLE OF CONTENTS
FACT SHEET
SUMMARY
LETTERS ON DRAFT EIS AND RESPONSE TO COMMENTS
I PUBLIC AGENCY LETTERS
PUBLIC AGENCIES
Washington State Department of Community Development
Washington State Department of Ecology
Washington State Department of Transportation
Washington State Department of Wildlife
Thurston County Planning Department
Intercity Transit
NisqualIy Indian Tribe
Rainier School District - 1/4/93
Rainier School District - 1/13/93
NisquaIIy River Council.
II. INDIVIDUAL LETTERS
Shapiro & Associates, Inc
National Food Corporation
Mary Lou Clemons
III. PUBLIC HEARING COMMENTS
Mark Carpenter
Rainier School District
Ed Kenney
P F,) II:lUit!i il t~~ Ll oy
..., nt; UilfJlnn.n'
SUBJECT TO REVijS~ON
List of Tables
Table 1
Table 2.
Table 3
Table 4
Table 5
Table 6
Table 7
List of Figures
Figure 1
Figure 2.
Figure 3
Figure 4.
Figure 5
Figure 6.
Figure 7
PREl' 'MARY
SUBJECT TO REViSlOINl
DISTRIBUTION LIST
APPENDICES (Forthcoming)
Appendix A. Wetlands Issues / Map
Appendix B. Priority Species Habitat
Appendix C Wastewater Issues
Appendix D' Revised Fiscal Analysis
PREL~ INARY
SUBJECT TO PJEVijS~O~
Civil Engineering, Public Services
Barghausen Consulting Engineers
18215 72nd Avenue South
Kent, Washington 98032
Contact: Dana Mower, P.E.
Phone: (206) 251-6222
Transportation
S. Chamberlain and Associates, Inc.
719 Sleater-Kinney Road SE, Suite 120
POBox 3485
Lacey, W A 98503-0485
Contact: Bob Hazlett, P.E.
Phone: (206) 493-6002
Wetlands, Plants/Animals
Independent Ecological Services
1514 Muirhead Avenue
Olympia, Washington 98502
Contact: Rex Van Wormer, Senior Biologist
(206) 943-0127
~)REll IltARY
SUBJECT TO REV~S~ON
Population Growth and Housing Demand
Mundy and Associates
Watermark Tower, Suite 200
1109 1st Avenue
Seattle, W A 98101
Contact: Rhoda Bliss, Senior Analyst
(206) 623-2935
Date of Issue: February --, 1993
Cost of Copies: $----
Location of EIS Background Material.
City of Yelm
105 Yelm Avenue West
POBox 479
Yelm, Washington 98597
R.W Thorpe and Associates, Inc.
705 Second Avenue, Suite 910
Seattle, Washington 98104
summary
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')10 Ho e Duildin 70~ 2nd Avenue Scattle,WA 96104 (206) 6246239
SOUTHWEST YELM ANNEXATION
Topography and Sections
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stnv1N1A.Rl' N1A. 'TRIX
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,1&' crS Of 1>\' PROPOS'" ,,",,0 '" -rOtl'" "Vf.5
. . A\ternative 1\
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A\\ernati ve 1
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j\\ternatwe 2
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"NeW development would
not be expected to occur at
the same rate as under
annexation, and air
quality would thUS
rernain largely at present
standardS.
'the estimated rate oi
development within the
proposed annexation area
would not take place.
Master planned drainage
'Improvements associated
with potential large
scale development under
the l'roponents' scenario
would not occur
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'this alternatiVe would
have largely the sal11e
in1pactS as thOSe of the
proponents' scenano.
'\he proposed annexation
would result 'In bOth long
and short term air
qualit)' impacts
associated with
constructiOn, potential
development, and traliiC
increases aiter develOP-
ment OCCUrs. NeW
emission levels irom
these sources are not
expected to exceed state
and local standardS.
NeW development would
result in increases in
'ImperviouS suriaces aT\d
suriace water runoH
J\dditiOnal sources oi
potential po\\u\aT\ts to
suriace waters could
result. ExistiT\g
pollutants associated
with some farrn
act'lvities could be
rernoved. Development
ad\aCent to wetland.ar~as
would occur, with hrnlted
wetland {illing proposed
Developn1ent under this
approach would geT\erate
more traHiC and could
result in greater vehicle
emiss'lons than the
proponents' scenario,
although prov'lsions ior
a\ternati ve
transportatiOn methodS
are intended to help
reduce dependence on
automob1\e use within
the area,
Typical dust suppression pr~ctiCes
such as watering exposed SOIls,
landscaping disturbed areas and .
covering vehides during constructIOn
would be iollowed.
Vehicle en'\ission standards. ar,e ,
expected to help control em~sslons
(rom increased traliic. ReSIdences
with wood stoves would be expected
to iolloW State oi washington .
regulat'lons applying to wood burTIlng
devices.
ln1pacts would be similar
to the proponents', '
scenario. J\ reductIon In
impervlOUS suriace and
resulting runoi! Tf@)' OCcur
b)' increasing open space.
Some wetland areaS may
be avoided and a greater
buHer capacity may also
diminish potential water
impacts.
Water impacts under this
scenario would not dlHer
greatly {rom the .
proponents' Scenano.
J\ltMugh the
development miX maY
change, runoH and
potential discharges
would be tne same, as
would potential impacts
to wetland areaS.
SUbsurface and surface conveyance
systernS would be used to hand~e
dditiOnal water irom poten\\al
ad'
development. Storrn :alnage. .
detentiOT\ wi\\ be re<\uned to llrnlt
runoH rates to pre..o.eveloprnent
cOT\d'ltiOns. 13iofiltration swales rnay
be used to preserve surface W,ater .
quality Storm water retentIon WIll
alsO be needed to percolate \,~ater
direCtly into the ground where
conditiOT\S will anow treatrnent
beiore percolatiOn win likely be
required. J\ppropriate wetland
setbackS would be iollOwed,
SOLID W ASTEI
RECYCLING
SYSTEMS
FACILITY
PLANNING AND
CONCURRENCY
Allernative 1
~O ACTION
No Action would not
impact waste water
levels in the city
Additional services
would not be needed and
costs associated with
deli very of services
would not occur
potential neW revenue
sources for Yelm would
not be provided
IMP ACTS OF THE PROPOSAL AND ALTERN A TIVES
Alternative 2
PROPONENT.s.: ~ENARIO
The annexation would
result in increased
amounts of waste water in
the area. The
Proponents' Scenario
would result in
approximately 32,328,000
pounds of new waste each
year Landfill capacity
would be diminished by
5% of the current 10 year
life expectancy
Development under the
proposed annexation
would require additional
services from the city
This would require that
facility extensions or
funding for such
extensions be provided
prior to development.
Costs for services would
increase.
Alternative 3
CQMPACT SCENARIQ
Impacts would be largely
similar to the Proponents
Scenario.
Potential costs for
providing new services
would be less than the
Proponents Scenario
under this approach.
Revenue generated by
future development is
also estimated to be less
than the Proponents
Scenario.
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Alternative 4
yjLLAGE SCENARlQ
Solid waste levels from
residential use would
decline, however, wasle
levels from additional
commercial use could
offset the overall
decrease.
Potential costs for
services and future
revenues generaled by
new land uses, are
estimated to be greatest
under this approach.
MLTIGATlON MEASURES.
Waste reduction efforts should be
encouraged and recycling programs
should be established within the
annexation area.
Developer impact fees could be
required to help fund extensions of
services and I or pay for service
improvements within the area.
Revenue from future development
would be expected to help offset some
costs for services. Identification of
funding sources, according to the
Growth Managment Act provisions,
would be sufficient for development.
WASTEWA.TER
FA.CILlTIES
STORM WATER
DRA.INA.GE SYSTEMS
AND COLLECTION
SYSTEMS
Alternatiye 1
~
No Action would not
affect city sewage flowS.
No Action would not
require additional
services. The present
runoff would continue to
floW into existing
wetland and pothole
depression areas.
1M)' ACTS OF nlE PROPOSAL AND ALTERN A TIVES
A.ltemative 2
~~
The proposed annexation
would result in increased
sewage floWS within the
area. Approximately
1,260,000 gallons per day
would result from fun
buildout. This would
require expansion of the
existing sewage
treatment plant.
The proposed annexation
would necessitate
complete storm drainage
collection and conveyance
facilities. Open water
channels, piping systems,
catch basins and
oil/water separator
pumps would be needed.
Additional storm water
runoff from new
impervious surfaces
would result from the
proposal.
APproximately 3,150,000
cubic feet of detention
volume would be needed.
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A.lternatjye :)
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Impacts would be similar
to the Proponents'
ScenariO.
Wastewater impacts
would be largely the
same as the Proponents
ScenariO.
Due to decreases in
overall impervious
surfaces under this
approach, total detention
volume required would be
approximately 2,050,000
cubic feet. Other impacts
would be similar to the
proponents' ScenariO.
Approximately 3,250,000
cubic feet of detention
volume would be needed.
The need for new
improvements would be
the same as the
Proponents' Scenario.
-
Property owners within the
annexation area should fund
amendments to the comprehensive
sewage plans for the city
Developers and the city would enter
into agreements to fund the sewer
treatment plant and collection
sytems.
Additional sewage treatment plant
costs would be passed on to future
development on a direct cost basis.
Drainage and conveyance systems
would be required for each neW
development. Surface and subsurface
systems would be designed.
Provide storm drainage detention in
areas where a viable downstream
channel or open body of water exists
to accept additional storm drainage
floW
Provide surface retention in areas
without any viable means of surface
discharge.
Provide retention facilities in areas
where retention does not occur
naturally but can be created due to
good soil conditions.
PARl<S p.r-lD
R'E,CREA 'fION
W A 'fER SUFF\.'{
S'{STE}AS
,\uernative 1
~
No Action would not
impact city recreation
service needs.
No Action would not
aHeet water supply for
'{ e\In.
IMP KrS OfT"" PROPOSAL M-'" ALTO'" A TlV"
Alternative 2
~~
The proponents' Scenario
would increase the
demand for reereation
facilities in and around
'{elm. NeighborhoOd and
community facilities
would be affected. The
proponents' Scenario
would include some
addi tiOnal recreatiOnal
opportunities, induding
possible golf course
facilities.
complete build out of the
annexation proposal
would result in exceeding
current water storage
capacities. The required
total would be
approJ<.imate1Y 2,078,000
\;anons of storage. 1\
would be necessary to
build storage capacity for
both standby and
equa\i:z.ing needs to meet
city and state
requirements. Additional
wells and water rights
may also be required to
meet needs wi thin the
annexation area.
;...tternative 3
~
A.lternative 3 would
result in the same type of
increased need as the
Proponents Scenario.
;...tternative 4
~
Alternative 4 would
provide fewer residential
homes and thUS could
have somewhat less
impact on the need for
recreational services.
A.dditiOnal storage
capacity would be needed
as shown for the
proponents Scenario.
lmpacts would be the
same as the Proponents'
scenario.
~
Developer contributions toward park
and recreation improvements could be
required. open space areas should be
coordinated with off site areas to
provide opportunitieS for trails and
or corridors.
The City Parks Plan should be
updated.
constr\lct one or more water
reservoirs with a total 15 million
gallon capacity within the
anneJ<.ation area to serve fun buildout
conditions.
ConstrUct a lOOP water system
throughout the entire anneJ<.atiOn
area to connect to the existing 8-inch
main from the city
Provide onsite fire hydrants and
protection services as required by city
regulations.
The City Water plan should be
amended or updated.
IMPACTS OF THE PROPOSAL AND ALTERNATIVES
Alternative 1
NO ACTION
POLICE
The annexation area
would not be added and
no increase to police
jurisdiction would occur
FIRE
No Action would not
impact city services.
Alternative 2
PROPONENTS' SCENARIO
The Proponents' Scenario
would increase the
demand for police
protection and calls for
service within Yelm. It
would create an
immediate need for
additional full-time
officers and one new
patrol vehicle.
The Proponents Scenario
would result in increasing
the needs for fire
protection within the
city Additional
personnel and equipment
could be needed.
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Alternative 3
COMPACT SCENARIO
Impacts would be the
same as the Proponents
Scenario.
Similar needs would
arise from this
alternative as those of
the Proponents' Scenario.
Alternative 4
VILLAGE SCENARIO
Calls for service could be
reduced somewhat, but
the general needs for new
staff and vehicle would
not change.
Although the potential
development mix might
change, the need to
service the site would
not.
MITIGATION MEASURES
Future development projects could be
designed to include features such as
lighting, alarms, a Blockwatch
program and state of the art traffic
controls to discourage crime and
reduce impacts on police services.
The annexation proposal includes
land for a satellite fire station.
Property tax revenues would
contribute toward purchase of fire
support vehicles or other equipment.
Water facilities would be constructed
within the annexation area to
provide adequate fire flow
conditions.
IMP ACTS OF THE PROPOSAL AND ALTERNATIVES
TRANSPORTATION
PUBLIC SERVICES &
UTILmES
SCHOOLS
Alternative 1
NO ACTION
Traffic increases and
roadways proposed under
the potential annexation
would not occur.
Additional
improvements associated
with potential
annexation scenarios
would not be made. The
Yelm Comprehensive
Transportation Plan
recommends new roads
through the proposed
annexation area.
Impacts to Yelm schools
would be minimal.
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Alternative 2
PROPONENTS' SCENARIO
The proposal would
result in traffic increases
within the annexation
area. Approximately
2,430 peak hour trips
would be generated for
the Proponents' Scenario
and Alternative 3 by the
year 2012.
The Proponents' Scenario
would result in potential
increases in the number of
students to be served by
the Yelm Community
Schools. As development
occurs, increasing demand
would result in the need
for additional classroom
facilities and personnel.
The annexation would
also likely result in a loss
of a portion of the
Rainier School District s
jurisdiction as land is
absorbed by Yelm.
Altern~tive 3
COMPACT SCENARIO
Approximately 2,430
peak hour trips would be
generated for the
Proponents' Scenario and
Alternative 3 by the year
2012.
Alternative 3 would
involve the same
densities and thus would
result in the same
potential increases.
Alternative 4
VILLAGE SCENARIO
Under Alternative 4
approximately 2,560
peak hour trips would be
generated over the same
timeframe.
Alternative 4 would
involve a ten percent
reduction in the number of
residential units and
would have a
corresponding decrease in
potential students.
MITIGATION MEASURES
The primary mitigation option
associated with the Proponents
Scenario would be design of the South
Site Drive/SR-507 intersection for
initial development phases. This
would involve lane improvements
and signalization. Future
development closer to the city core
\vill have new connector roads.
Space for a future school facility is a
part of the annexation proposal.
Impact development fees could be
assessed to provide for future school
district needs. The proposed
development could include retirement
housing that would diminish impacts
on schools.
..
UR"'AN GROWTH
AREA
AFrOROA"'LE
HOUSING
1M!' ,Ct5 Of TIlE rRorOS'C """- "c -"" 11~CS
AHernat\\'e 2
~~
The proponents' Scenario
would result in adding
additional land to the
Ci ty of '{ eln1, I t would
occur within the urban
growth area for the city
The proposed
develOpment would
absorb much of the
projected populatiOn for
'{elm, but would not
exceed this amount. It
would represent
appro:>:imately 20% to
30% of the projected
urban growth area.
Allernative t
~
Urban area bOundaries
would not be aHected.
No Action would leave
the area undcr Thurston
County guidelineS and
would not prov1de the
level of additiOnal
housing opportUnities in
'{elm that anne:>:ation
would aUow The
e:>:isting city core could be
considered loW inCOme
housing.
hnne:>:ation would result
in more area available
for housing in '{elm,
current development
proposals for the area
may include some
affordable housing.
Development within the
anne:>:atiOn area could
result in making more of
the older homes in the
city core available for
lower inCOme persons.
Alternative 3
~
Alternative 3 would be
largely thc same result as
the proponents ScenariO.
Development would be
n10re concentrated,
allowing for some\,,'hat
higher densities, but
more transition area
would be gained adjacent
to e:>:isting uses.
Altemative 2> could
provide a different
housing mi:>:, \'Jith
potentially more
multifamilY units.
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Although the potential
development densitieS
and uses could be
different from the
proponents' Scenario
under this approach,
impacts to the overan
urban growth area \\lould
not differ greatly
Altcrnative 1\ would
provide leSS residential
housing units than the
proponents' Scenario.
~
The urban area bOundary could be
reviewed periodicany to determine
if adjUstments are required. 'the
bOundary shOuld be coordinated with
future population projections.
The city could encourage affordable
housing to be provided within the
proposed anne:>:atiOn area. It could
alSO require future developers to
provide contributions to programs
designed to assist loW inCOme
individualS in finding affordable
housing.
OPEN SPACE
CORRIDORS
AHetnative 1
~
The area would remain
zoned for TUral use under
Thurston County
regulations. potential
development within the
proposed annexation area
would be expected to occur
at much lower densities,
potentially leaving more
open, undeveloped space
in the area.
IMPACTS OFTl1'E PROPOSAL AND Al.TERNATlV'ES
Altemative 2
~~
The Proponents' Scenario
would result in
additional land within
the '{elm city limits.
Approximately 830 acres
may be preserved as open
space or landscape
buffers. As proposed,
development would
include recreational
space which would also
serve some open space
{unctions. Future
development in the area
would occur under city
regulation and could
result in opportunitieS for
neW open space areas.
AHernatiVe 3
~
Alternative 3 would
provide even more area
than the Proponents
Scenario for open space.
Approximately 1200
acres of open space would
result. BecaUse it may
involve use of clustering
techniqueS it n1ay
provide added
opportunities to create
open areas within the
overall annexatiOn area.
AHernalive 4
~
Alternative 4 would
decrease residential
densities, but would also
increase potential
commercial development.
This approach is also
expected to result in
approximately 830 acres
for open space.
~
open space and landscape areas
should be coordinated with offsite
opportunitieS to form greenbelt
corridors. Future development should
be encouraged to provide for open
space in proposed plans.
LAND USE &
POPULhT10N
GROWTHI
HOUSING DEMAND
NATURA-L
RESOURCE. l.A-NDS
A-llerna\\ve 1
~
populatlon growth and
housing demand ratCS
would continue to oecur
under No Action, but arc
expected to take place at
a lesser level than if
af\1\exatiOn were to occur
Housing quality would
remain at existing loW to
moderate income levels.
Existing farm uses would
not be affected, and tM
proposed annexatiOn area
would remain under rural
zoning of Thurston
County
1MI' AcrS 0' "," PROPOSA' ",,0 ACTtI'N A TIVI,s
A-\terua\ive 2
~~
The proposed annexation
would increase local
population considerably
if fun buHdout of the
area occurs within the
twenty year timclrame.
Total population
forecasted for the '{elm
area in the year 2013
would be 21,632 persons.
1\1'1 estimated 5,314
hous1ng units could be
absorbed in the '{elm
area over twenty years.
The potential
development projects
identilied for the
proponents' Scenario
would elimlnate some
e:xisting agricultural use
in the area.
Development would
eliminate use of a limited
area of potentia\\Y
productive agricultural
soils in the area and
would conlinue trends
toward farmland
reductlon.
hllerna\ive :>
~
AlternativC 3 would
result in the same number
of units and the same
level of growtn as the
proponents' scenario.
Rcsidentlal area would
be morc concentrated and
potential hOusing types
could include morc
multifamny units. A
greater amount of open
area around future
development could be
acnieved under tnis
approach.
A-llerna\ive 4
~
Alternative <\ would
represent an approximate
10% reductiOn in proposed
resldential units with a
corresponding decrease in
population. Morc
opportunitieS for
potcntial commercial uses
would be available under
this alterna ti ve.
The Compact scenario
would concentrate future
development wnich could
result in somewnat lesS
encroachment on
agricultural uses than
would occur under the
proponents ScenariO.
Alternative <\ ",'Quid
have much the same
results as the proponents
ScenariO.
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Future development would occur in
phaseS over a tWenty year period.
Market conditionS would help
determine the actual number of units
provided. In addition. the Urban
Growth Area Boundaries should be
phased with popUlatiOn projections
to avoid potential negative impacts
associated with sprawling
developmen t.
Buffer areas around the proposed
annexalion would help form a
separatiOn between tne proposed
development and some offsi te
agricultural and military uses.
Significant resource lands should be
identified and measures to avoid
conflicts or losses should be
coordinated with future devc10pment
proposals within the annexatiOn
area.
~
Er-.'ERGY
AHerna1i'/e 1
~
No Action would not
affect energy
requirements.
1MI' ACfS OF THE PROPOSAL AND ALTERNA TWES
AlIerna1i'/e 2
~~
Development from the
proposal would result in
additional energy
demands within the
area. puget power would
have to build additional
12.5 kV and 115 kV power
lines and one to twO new
substations to serve the
projected loads.
Centralia Light power
lines would still be buried
or relocated, however,
these lines would not be
used {or ener?;f needs
under annexation.
AHerna1i'/e :\
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Impacts on energy
consumption would be
largely similar to the
Proponents' Scenario.
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Atlerna\ive 4
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Under this approach,
energy could be greater
depending on the type of
commercial development
that occurs.
-
Costs would be imposed on neW
development as required by
Washington State regulations. The
developer would be responsible for
relocation or burial of existing power
lines.
Government and utility energy
conservation programs would be
followed. All structures would be
designed to meet Washington energy
codes.
YEGETI\TlON &
VHl..ULlFE
NOISE
I\lternative 1
~
Habitat areas would not
be disturbed by the future
development under the
proponents' Scenario.
E:>:.isting clearcut arC3S,
\"ith natural growth, on
the anne:>:.atiOn site would
remain.
,,", ,crS Of utE YROl'OSh1. AND ,1.","" A"IV<5
I\\ternative 2
~~
current noise levels
would continue and short
and long term impacts
associated with neW
noise sources within the
anne:>:.ation area would
not OCCur The neW
residential and
c011\fOercial uses
associated with the
proponents' Scenario
would not be introduced
adjacent to existing
miUtary facilities under
this scenario.
potential development
under the proposed
annexation would result
in loSS of wildlife and
vegetation habitat in
much of the area.
Wildlife would be
displaced and vegetation
would be removed. These
losses would likely be
greatest under the
proponents' Scenario since
it would consume more
area than the
alternatives.
Short term impacts would
result during constrUction
activity and long tern1
impacts would result from
additional traffic to and
from the annexation area.
and residential
activities. complaintS
regarding military noise
could increase as a result
of neW residents adjacent
to local facilities.
Alternative :>
~
Alternative::' is intended
to include greater buffer
areas and utilize lesS
space than the
proponents' Scenario.
The enhanced open space
is not e:>:.pected to make
the area signHicantly
n10re compatible to plants
and anin1als than the
more dispersed
development under the
proponents' ScenariO.
Additional noise levels
would be similar More
open area would provide
for greater dispersal of
noise belore it leaves the
area. l..arger buffer would
not significantly alter
noise perceptiOns
regarding Ft. l..ewis
activity
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Alternative <\ would
reduce proposed
residential densities
which could provide
more area for open space
for plant and animal use,
than the Proponents
ScenariO. However,
potential future uses
within the area would
stm likely result in
similar displacement as
described by the
proponents' Scenario.
l..ess residences would
reduce some noises, but
commercial area would
potentiany have new,
mostly transport related
noises.
~
Development under the Proponents
Scenario would include landscaping
and open space which would provide
habitat and protect existing species
in theSe areas.
The use of native species for
landscaping shOuld be promoted.
Natural vegetation around ,,,etland
areas would be preserved.
Typical noise reduction measures such
as limiting hours, and requiring
equipment mufflers during
construction could be fonowed.
\..andscaping and buffer areas would
help to reduce offsite noise impacts.
The use of earth berms or barriers to
block traffiC noise could also be
employed if needed.
GROUNDWp.TER 8<
p.QUlfER
RECHP.RGE p.REP.S
FREQUEN'fl. '{
FLOODED p.REP.S
IMP AcrSOF 111E PROPOSM.. A.ND A.l:rERNI\1'lVES
p.lternative 1
~
p.\ternative 2
~~
No I\ction would not
impact the local aquifer
The Proponents' Scenario
would result in
additional demands for
groundwater in the
annexation area. A. wen
system with an estimated
pumping capacity of 2300
to 4400 ga\\ons per minute
would be needed for
future development.
potential recreational
facilities would require
sprinkling zones of 2500
ga\\ons per minute for
irrigation needs. The
proponents' Scenario
could also introdUCe new
sources of poUutants that
could aHect the local
aquifer
Development would not
occur at the the rate
identified by the
proponents' Scenario and
thuS would not impact
these areas. Seasonal
flooding of Thompson
Creek would continue to
OCCUr.
The proponents' Scenario
would contribute
additional surface water
runoH to those areas
identified as being subjcct
to frequent flood
conditions. Post
deve\opment runoH is to
be limited to the pre-
development rate.
AHernalive 3
~
The potential impacts
would be the samc as
those of the Proponents
ScenariO
Alternative <1
~
Alternative 4 would
reduce potential
development densities
and thuS may result in
lcss impact on
groundwater
Alternative 3 would
provide more potential
absorption area. It would
decrease overall
impervious surface and
concentrate developn1cnt
within tt)) ~
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Alternative 4 would
provide similar
developable area as the
proponents' Scenario and
is expected to result in
similar runoH rates.
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OHsile sewage treatment is
rccommended and storage of largc
quantitieS of hazardouS wastes and
chemicals onsite should be
prohibitcd.
Fertilization of aU areas should be
carduUy managed to avoid
ground water contamination.
proposed biofiltration techniqueS
would also be expected to help
prevent potential pollutant impacts
to groundwater
Recycled water could be used for
recreational irrigation.
Siltation control mcasures for storm
drainage control of release rates
should be provided. Design and
construction of biofiltration facilities
prior to discharge of drainage watcr
should be followed.
ImperviOUS surfaces should be
minimized to control flooding.
PRELIMINARY
SUBJECT TO REVISION
Comment Letters and Responses
RESPONSES TO LETTERS FROM PUBLIC AGENCIES
PREll' INARY
SUBJECT TO REVIS&O~
e
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STATE OF WASHINGTON
DEPARTMENT OF COMMUNITY DEVELOPMENT
OFFICE OF ARCHAEOLOGY AND HISTORIC PRESERVATION
111 21st Avenue S.W · PO Box -13843 . Olympia, Washington 98504-83-13 · (206) 753-4011 · SCAN 234-4011
December 28, 1992
J
Mr. Todd stamm, city Planner
City of Yelm
105 Yelm Avenue West
Post Office Box 479
Yelm, WA 98597
Log:
Re
121892-18-TN
Southwest Yelm Annexation, DEIS
Dear Mr. stamm.
The Washington state Office of Archaeology and Historic Preservation (OAHP)
is in receipt of the Draft Environmental Impact statement (DEIS) for the
Southwest Yelm Annexation action. From the project description, I
understand that this proposal entails the annexation of 2,000 acres to the
City of Yelm, for eventual development for residential, recreational, and
commercial uses. Location of the annexation is southwest of the present
'ity limits.
In response, OAHP recommends that the city of Yelm consider the impact of
the annexation upon the area's cultural resources including historic and
archaeological properties. This process should include the identification, 1
evaluation, and protection of such properties. Already, the City of Yelm
and Thurston County have cond1tcted surveys for historic properties in the
Yelm area. To supplement this data, we recommend a survey be conducted to
identify archaeological properties within the proposed annexation.
Following this identification process, identified cultural resources should 2
be evaluated for significance. Those found to be significant should be
protected through various incentives and planning mechanisms. We recommend
these steps be coordinated with the Yelm Historic Preservation Commission
,
the Thurston County Historical Commission, and OAHP. Also, the final
environmental impact statement should acknowledge the potential for
historic and archaeological resources within the annexation and identify
steps to address these issues.
Thank you for the opportunity to comment on this annexation. Should you
have any questions, please feel free to contact me at (206) 753-9116.
S if)ere{) rl.OJrti
G~Xt A. 'r,f:iiith
comp~enslve Planning Specialist
GAG:lms
cc: Shelly Badger
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RESPONSE TO COMMENTS IN LETTER FROM
WASHINGTON STATE DEPARTMENT OF COMMUNITY DEVELOPMENT,
OFFICE OF ARCHEOLOGY AND HISTORIC PRESERVATION
Response to Comment No.1:
Comments acknowledged. Historic and archeological resources were not included
in the anginal scopmg of the DEIS with the City In the process of gathenng
information for the DEIS, no information concernmg cultural or historic resources
on the site was found.
Response to Comment No.2:
Comment acknowledged. A survey of cultural resources and appropriate protection
mechanisms will be addressed during the application process for a specific ~1
development proposal on the property 1:' I~,
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(; Ii ~f.P I'"
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0111
PREll INARY
SUBJECT TO REVISION
OT~.T5-=-9 ~----:TllrcM~\OM-C I n-Ory HM
jilt
STATE OF WASHINGTON
DE? ARTMENT OF ECOLOGY
.'vlail Stop PV.17 . Olympia, Washington 98504-8711 . (206) 459-6000
January 13, 1993
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Mr Todd Stamm
City of Yelm
PO Box 479
Yelm WA 98597
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Dear Mr Stamm
Thank you for the opportunity to comment on the draft environmental impact
statement (DEIS) for the Southwest Yelm Annexation proposed by Thurston
Highlands Associates We reviewed the DEIS and have the following comments
Any ground water withdrawals in excess of 5,000 gallons per day or for the
irrigation of more than one-half acre of lawn or noncommercial garden will 1
require a water right permit from Ecology.
The Department of Ecology encourages the development of public water supply I
systems, whether publicly or privately owned, to provide water to regional 2
areas and developments
If you have any questions, please call Ms Jill Van Hulle with the Water
Resources Program at (206) 586-5560
Sincerely,
/J2dL'Urz'~ xi 4Z<
M Vernice Santee
Environmental Review Section
MVS
92-7742
cc Jill Van Hulle, Sl,lRO
Sarah Barrie, Sl,lRO
~3
o
RESPONSE TO COMMENTS IN LETTER FROM
WASHINGTON STATE DEPARTMENT OF ECOLOGY
Response to Comment No.1:
Comment acknowledged.
Response to Comment No.2:
The City of Yelm will extend the public water supply system to serve the proposed 7
site Mitigation measures addressing water system improvements necessary to
serve the proposed development and to comply with city and state reqmrements are
found on page 113 of the DEIS
PREL~MINARY
SUBJECT TO REVISION
OT~r5-=-9 3-0 S-U 0 .I~-"t<:l ;rL, rnV-rI r:J;"jlj
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Washington State
Department of Transportation
Duane Berentson
Sec~e:ary c! Tra~s:)or.a:':;"
January 14, 1993
District 3
OHice of District Administrator
5720 Cap,rol Boulevard
POBox 47440
Olympia. WA 98504-7440
Todd Stamm
City of Yelm
Planning and Building Dept.
POBox 479
Yelm, W A 98597
5 I9ro
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Southwest Yelm Annexation
SR 510, MP 15.5 Vicinity
E. C File No 93000- T
DEIS
;......'"'-,-~--~
Dear Mr Stamm
We have received and reVIewed the above proposal and have the following comments.
It is noted that the proposed Southwest Yelm Annexation as submitted is 'non-project'
in nature. Although the annexation ill Itself will not create any additJ.onall1l1pacts to the
transportation system, the mtent 15 to increase population densities to a level greater than
the existing transportation infrastructure can accommodate.
The DEIS as submitted does not address the impacts, as far as capacity or level of
service on SR 510 and SR 507 outSide Yelm's UGA. The annexation and subsequent
development of this proposal will have a significant adverse impact on the entrre length
of SR 510 and SR 507 from Old 99 in Tenino (MP 13 64) to the Fort Lewis Access
Rd. (MP 39 04) The traffic parnon of the EIS should be expanded to incorporate those
sections, ldentifying impacts and the appropnate ID.1tigations The Department requests
an opportunity to review and comment upon the revisions
1
2
The proposed development of this annexation rehes heavily on the improvements
outlined in Yelm's Comprehensive Transportation Plan that are yet to be funded.
Should this EIS be used or referenced, for the actual development of this annexation,
the Department requests that the construction of those lffiprovements be in place
concurrent With the demand generated by the proposal. No development shall be
allowed without fIrst securing full funding for the necessary roadway mItigations.
3
Thank you for the opportunity to review the above proposal. If there are any questions
regarding OUf comments, please contact Fred Tharp at (206)357-2667
Sincerely,
PAULAJ HAM:MONDP.E.
Transportation Planning Engineer
:&&I!:m. P.B.
Asst. Trans. Planning Engineer
Distnct 3
PJCH / PB fot
cc N Williams
Bob Hazlett / S Chamberlain & Associates / P.O Box 3485/Lacey, WA 98503-0485
File 93000- T
---_:..: --., ~
RESPONSE TO COMMENTS IN LETTER FROM
WASHINGTON STATE DEPARTMENT OF TRANSPORTATION
Response to Comment No. 1
Comments ,~.cknowledged. The Southwest Yelm Annexation proposal is submitted
as a 'non-project' proposal. However, the alternatives include three scenanos with
specified levels of development. The transportation section estimates the traffic
generation and impacts for each of the specific development alternatives, and
recommends specific improvements and mitigating measures
Response to Comment No.2
The nature of the proposal is non-project specific. Thus, the potential impacts and
proposed mitigation outlined in the transportation section, refer to conceptual
development scenarios The exact nature of future development wlthm the
proposed annexatlOn area IS not fully known at this time Future site-specific,
project level environmental review w1l1 occur as development withm each
property takes place It is anticipated that these pro]ect-speClfic environmental
reviews will address the transportation-related impacts, If any to the state facilIties
outside the Yelm UGA and identify approppriate mitigation to accommodate these
impacts
Response to Comment No.3
Comment acknowledged The Growth Management Act reqUlres that the
construction of public facility improvements Will be m place or funded, concurrent
with the demand generated by a proposal The mitigating measures for Part C
Transportation (page 101, SW Yelm Draft EIS), provides options for determming the
responsibility for improvements related to the direct impacts of the proposal. In a
more general reference, the mitigating measures for SectlOn 9 FaCility Planning and
Conc~r.rency (page 1~1~ suggest t~at developer ~mpact fees(Coul be assessed for
provldmg some faClhty extenslOns and/or lmprovemerils to the oposed
annexa tion area , ( ?
ttrf !,/(p 7
PREll IMARV
SUBJECT TO REVUSION
_URT SMITCH
Director
STATE OF WASHINGTON
DEPARTMENT OF WILDLIFE
905 E Heron '\berdcen W,\ 911520
Tel (206) "33-9335
J2.nuar'y 1.3~ 199-:::
....,...'\f1 1 )
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U~3
i"i1~. T oJ d f3 L'lrntn
C i '1:.: y F' 1 9, n n e I~
Cit.' of '(elm
F. O. 130 479
{ e 1 (n, VJ {..~ ~i (3 ::1 :.t 7
Re: D~aft En~i~onrnental Impact Statern8nt--Southwest
Yf-:?lm ~)nne; i?,tion
Section 19~ Township 17N~ Range 02E and
Sections 23, 24~ 26 and =7~ Township 17N~ Range OlE
T hu, t-S torl CDurl t't
Deal~ ["11'-. Stamm:
The Washington State Depa~tment of Wildlife (WDW) appreciates the
opportunity to re~iew and comment on the above-referenced Draft
Envir-onmeni:al Impact Statement (DEIS) on the anne;:ation of
appro;:imately 2~OOO acres into the Cit} of Yelm with a p~oposed
development dwellinCJ df"!nsity tTf 5.1 units per- <=\I.:r-e \-Jith a ma::irnum
of 5,000 developed units. After ~e~iewing the DEIS and the
Technical Appendices, our agency has the following comments and
concer-ns.
As you h now, the l.tJDW is manda ted to "pt-otec t, preserve and
pel~petl.la tE':!" Washing ton's wi 1 d life, both game and non-game
species. With the growing concern of Washington residents~
counties and cities to p~otect their wildlife and to prevent
e:tirpation and/o~ possible listing of wildlife species~ it is
essential that wildlife issues be adequately add~essed. This
DEIS does not sufficiently address wildlife concerns~ e.g.
p~otection fo~ prio~ity habitats and species~ wildlife corridors~ 1
p~ope~ protection fo~ wetlands and wetland-dependent species~
protection of nest trees (as required by ~CW 77.16.120), and
mitigCl.tion. The statement. on wildli'fe on page 42 that: "t"lost of
the wildlife and ~egetation currently occupying undeveloped land
would be displaced or destroyed when development occurs", shows a
lach of l:oncel~n fOI~ l"'ashington's vJildlife. Since this anne::atiofl
would p~ovide for the increase in housing density from the
cu~~ent one house pe~ five acre designation by Thurston County,
to 5.1 units pe~ ac~e and the large a~ea (2,000 ac~es) which will
be affected, our agency has the following COflce~ns.
~3
to'lr-. Todd StB,rnm
Fag F.? ~
Decembe~ 8~ 199~
In the preceding paragrapll~ I have referenced priority habitats
and species. "'JD~J has developed c~ FI~.ior-ity Habitats <~nd Species
(FHS) prograrn to identify the most important wildlife habitats
and v!ildlife species in cll"del~ to ~.ssist c:oul1ti~s. cities~
developers and others to ta~e a proactive approach to protection
of fish and wildlife. By taking a proacti~e approach as opposed
to a reactive approach~ this will help prevent future wildlife
losses and it will be much less costly to plan nON rather than
r-~cc.i . l~r"" in',] 1 CJsse::;, one e tl"lE} oceLll~. T"hul"s ton Coun t'f is an e a f
the leading counties in protecting our natural resources through
their Critical Areas ordinance.
2
The GElS rioes not address protection for the priorit~ species
1.^,lhich aTe 'found in the pr-oposed ,3,nne::ation c>reCi,. The following
1S a list of priorit~ species which were listed in the DEIS but
were not ac~nowledged dS priority species.
3
1. FileC1.ted l-'lOodpech?/" (Dn,'c.7(::opus p_ilE'.3tuS) (Also <'1. f.3tate
Candidate species)
'....
Western Bluebird (5ialL2 mexicana) (State Candidate and
Federal Sensitive species)
-~
-' .
Fed-tailed Hawk (Buteo jamaicensis)
4. Wood DUC~5 (~ix sponsa)
5. Columbian Blac~-tailed deer (Odocoileus hemLonus
co.lumbianus)
6. Great Blue Heron (~r-dea herodias). There is a heron
roo~ery located in Section 20~ Township 17N, Range 02E,
and this area, with its multiple wetlands and Thompson
Creek, provide the herons with food~ water~ alternate
nesting sites~ roosting and nursery areas.
7. Western Gray Squirrel (Sciurus griseus). This is also
a State Candidate species. Although there were no
sightings in the proposed area, there are known squirrel
sightings in nearby areas. Therefore~ the oak-conifer
.. .
1'1 r-. Todd S tCl,nlm
Paqe ';:
December 8, 199~
habitat should be protected as a potential dispersal area
for the Western Gray Squirrel.
8. EH (Cer.us !=::'laphus) (Possible use as a migration route).
This propoeed area has diverse habitat t,pes including forested,
Opi?n 'I' ie 1 cis:, (\I~h ic I i 2.1"e 1m PDI- .tan t. feed lng a ,-e2 s fOI~ r-a p tor's ) ,
stream corridor and varying types of wetlands. Numerous
wintering waterfowl species utilize the open water wetlands for
feeding and resting h2bitat. In 2ddition, the wetlands and their
upland buffers are used to meet the life needs of numerous
wildlife species who reside in the local area.
4
~~ith the i::\nnE?::i::\tion <~nd hei",vy den~;it'y c1e'/F..:'lopment planned 'for- t.he
area, thesr= divel~se habitats ~\lilJ. be 'fr'a(]fJlE'nted.. destr-oyed and/or-
rendered unusable by area wildlife resulting in severely reduced
populations and/or local population die-offs~ an increase in
animal damage by displaced wildlife~ decreased recreational value
(e.g. wildlife viewing~ hunting~ etc.).
5
Wildlife lS the property of the State and its citizens and
therefore it is important to properl~ address protection and
mitigation for fish, wildlife and their habitats.
Thank you for the opportunity to
proposed anne::ation.
re~iew and comment on this
Sincen?.l y ~
C;;;;U#~ ~ a~/~~
DEBBIE D. CA~NEVALI
Habitat Biologist
cc: Dave Gufler, WOW
Conn.i.e I ten, ~~DW
Paula Ehlers~ Thurston Co. Flanning
RESPONSE TO COMMENTS IN LETTER FROM
WASHINGTON STATE DEPARTMENT OF WILDLIFE
Response to Comment No. 1
Comments acknowledged The Alternative scenarios m the Draft EIS propose
developing the land as a master-planned community or PUD, with large areas set
aside in open space. The open space areas include wetlands, steep slopes, and stream
buffers that provide the highest wildlife habitat values on the site The Draft EIS
discusses opportunities for open space corndors (pages 71-72), addressing the acreage
retained in open space that could serve as areas for recreation, critical area protechon
and wildlife habitat
The development proposed for the annexation area would be served by a
stormwater system that would meet or exceed surface water pomt and non-pomt dJIJ
water quality standards The existing Thurston County land use designation of 1 r
house per 5 acres would likely result m the development of mini-farms or large lot
tracts, which may contribute greater impacts of non-point source water quality
pollutlOn, and disturbance or converSlOn of wetlands for farm land.
Response to Comment No.2
Comments acknowledged. A Pnority Habitat Study was not completed by IES
AssoClates dunng the mitial phase of the Draft EIS investigatlOn. At the hme of the
Wetlands Evaluation and BlOlogical Report, pnonty habitat studies were not
required by Thurston County The presence of wildlife on the site was addressed in
a general format as part of the Draft EIS Because of the limited time and seasonal1ty
of the biological investigations, species were identified as either present or havmg
the potential of being present on the site.
Response to Comment No.3
Comments acknowledged. Additional information on the priority species listed m
the comments is provided in Appendix B of this report.
(!J
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U 1 -1 5-=-3 j-UJ'll LT, !i1-n lnn:JTn-Q r-n:t;j!(
~\)\);:
COUNTY COMMISSIONERS
G~rce L. &mer, Jr
!)i.mkt One
Diane Oberquell
District T we
Linda MedCllf
Di:,,:rict lluee
THURSTON COlJ"NTY
..\~~~ I_~"''-- ~,-..~
PLANNiNG DEPARTMENT
Sl~!: 1~51
Hamld Robertson, AlCP
P!;mnlnll Director
January 15, 1993
Mr Todd Stamm, City Pianner
City of Yelm
PO Box 479
Yelm, WA 98597
SUBJECT. Southwest Yelm Annexation Draft Environment Impact Statement
Dear .Mr. Stamm:
We have reV1ewed the Draft Environmental Impact Statement for the proposed
Southwest Yelm Annexation and offer the foIlowmg comments for your consideration.
NATURAL ENVlRO"NMENT
Groundwater This section does not specifically address the impacts of golf course
development on water quality. Table 18 indicates that Alternatives 2 through 4 would
devote 276 acres to golf courses. The envrronmental impacts of this use, particularly
the potential effects of fertilizers, herbicides, and pesticides on the groundwater
proposed to be used as a public water source, should be addressed. If the development
project proceeds, we suggest that you require a groundwater monitoring and integrated
pest management for the golf course area.
1
Wetlands (Section B. 1 Water)
Additional work is needed in the wetlands section. The report is confusing and the
analysis is not objective Confusion could be reduced by overlaying the delineated
wetlands on the 3 different scenanos. EIS' are supposed to be written for the
jurisdiction as an objective analysis of the probable adverse environmental impacts of
a proposal. Statements made in the wetlarid analysis indicate that the City is assurrung
that the filling of wetlands is not avoidable Filling wetlands is avoidable and should
be the first mitigation tactic. Adequate protective buffers should also be proposed. On
2
2000 Llkcridc~ Drive SW O[ympia. WashirlJlton 985C2.6045 (206) 786-5554 / FAX (206) 754-44 u
@
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UT--C J--:-J~!;'~ -\., ,",--,.,- - -.
Mr. Stamm
January 15, 1993
Page 2
page 32, a large forested wetland is mentioned (identJfied erroneously as #16), and
described as needing a 100 foot buffer. If Yelm's CritIcal Areas Ordinance is similar
to the Ecology Model Ordinance, then 100 feet is not an appropriate buffer width for
this type of wetland. There is also no other mention of appropriate buffenng for any
of the other 19 wetLands delineated. We have several other commentS regarding the
wetland section and they include the following'
Figure 10 The "off-sHe wetland" noted near SR 507 appears to be
pamally on-sIte.
Pg. 32, first paragraph. Appears that you mtend to use the wetlands as
pollutant filters Untreated stomlwater !\hould nor be directed to narnral
wetlands
Pg. 32, 6th paragraph. How will wetlands be impacted?
Pg. 34, last paragraph. It is also difficult to understand how the wetland
losses were calculated at less than one acre 51nce the analysis did not seem
thar specific.
Energy All three development alternatives (2-4) call for the relocation of the Centralia
high-voltage transmission line bisecting Section 27. Since Alternative 2 and 4 show
residential development adjacent to the transmissIon lines, the issue of electromagnetic
radlation should be addressed.
BUILT ENVlR 0 NME NT
Population Grov.rth/Housing Demand. The Draft EIS estimates for population growth
and housing demand in the Yelrn area are consIderably higher than Thurston Regional
Planrnng Council's (TRPC) estimates
Considering this large difference, the methodology and assumptions for the population,
housing and sewer service demands should be reevaluated to ensure that they provide
a reasonable basls for assumptIons supporting the development alternatives described
in the Draft EIS and for related planning in the area.
N amral Resource Lands All of the development proposals would result in the
urbanization of currently rural lands that support agriculture and forestry If urban
development proceeds, the compact scenario, Alternative 3 appears to be most
compatible WIth the resource uses on adjoming propertIes
)1-15-9) 04 2iP~ PO}
3
\4
5
16
7
8
9
10
1 1
u-r--:-:"-"'j-J ~l-UV-~~l-~~\ V:'~-\[CC1-Q r-l-J.:,.-lil'l
Mr. Stamm
January 15, 1993
Page 3
\.
Transportation. This section should address the impact of traffic generated by the
proposed alternatives on county roads and state highways beyond the immedIate area.
These mclude the Yelm Highway, Reservation Road, Ramier Road, Old Highway 99,
SR 507 and SR 510 Impacts on roadway capacIty and any associated improvements
C;hl"llllrl hI' iripntifip,-t <;Inrl rliC'r11"""ti Tn ",4,.lit",n nln nn"^"......c;... ~'''u tQ ooo..d~..t.. ......:.u..
Fort Lewis regarding any anticipated openings of roads within the project Ylcmity.
12
Schools It is likely that any of the development alternatives will generate more
students than contemplar.ed m the EIS. We suggest that the applicant work with the
Yelrn School Distnct to prepare an updated school demand forecast, considering the 13
hkely housing mix, demographics and eXlSl1Ilg school capaclty, and aleer the amount of
land devoted to school uses in the alternatives accordingly.
Tn addiuon. if the project proceeds. we suggest that consideration be given to sitting
schools in close proximity to residential areas to enable access by foot and bicycles, to
reduce traffic and bUSIng, and to foster a greater sense of community.
Wastewater Facilities The Draft EIS indicates that in order to serve the entire proposed
development a new :N"1'DES permit (and approval from Centralia Power) would be
needed to enable an increased sewage outfall to the Nisqually River A detennination
should be made as to whether or not this is possible or likely and generally what the
envirorunental impacts would be. If a penmt for more outfall could be obtained, a
detenninanon should be made as to whether or not me system can be cost-effectively
redeSIgned to accommodate the projected sewage flow from the proposed annexation
(and the remainder of the mterim growth area) WIthin the hmits established by the
existing permits. Also, what would be the alternative density of the annexation area if
sewer was not available?
14
\15
GENERAL COMMENTS
There is no chscussion regarding historic resources. 116
Alternative 3 seems to have the least environmental impacts and appears to be the most
cost-effective to serve of the development alternatives being considered. Therefore, if 17
the city evenrually 4I1Ilexes this area, we urge me City to require this type of
development pattern.
I 1 - i -:.. - "J ~ IJ -1 Z ~ f !.l P u -1
-~~V-J.-.l-oJ-v '01-..- -.-
. .
MrStamm
January IS, 1993
Page 4
Thank you for considering our comments
SinceFely,
~:-~
Paula Ehlers. Senior Planner
37~~d
ce' Thurston County Board of Commissioners
Tom Fitzsimmons, CAO
City of Yelm Planning Commission
City of Yelm City Council
Ol-lS-S~ u~ ~~r~! PuS
RESPONSE TO COMMENTS IN LETTER FROM
THURSTON COUNTY PLANNING DEPARTMENT
PRELIMINARY
SUBJECT TO REVISION
Response to Comment No. 1
Comments acknowledged Golf course development is included in the alternative
scenarios as a development concept. A more specIfic analysis of project-related
impacts will be prepared during the application process for a specific development
proposal on the property
Response to Comment No.2
Comments acknowledged. Figures 1-3, in Appendix A of the Fmal EIS provide
maps with the delineated wetlands overlaying the three proposed alternative
scenarios The alternative scenanos in the Draft EIS are conceptual plans, and
avoidance and mitigation of wetland impacts w1l1 be addressed when a speClfic
development is proposed for the Site.
Response to Comment No.3
Comments acknowledged. The large, forested wetland on the southwest portion of
the property was erroneously identified in the text as wetland #16, and is correctly
identified as wetland #15 The wetland was classified as a Category II wetland,
utlhzmg the wetlands rating system created by the Washmgton Department of
Ecology The Yelm Critical Areas Ordinance requires a 150 foot buffer for Category II
wetlands When speClfic development plans are proposed for the Site, they w1l1
mclude protective buffers as specified m the City's Critical Area Ordmanc:e or
appropriate mihgation measures
Response to Comment No.4
Comment acknowledged. The "off-site" wetland noted near SR-507 appears to be
partially on the site in Figure 10 However, field studies indIcated that the area does
not extend to the property line. A transitional area with marginally wet vegetation
but non-hydric soils was found on the site. It was for this reason that the wetland
boundary was limited to the off-site area.
Response to Comment No.5
Comment acknowledged Portions of some wetlands are proposed to be dIscharge
points for surface water The pre-treatment of these waters will be required by
surface water restrictions No untreated storm water is proposed to be directed to
the natural wetlands.
Response to Comment No.6
Comment acknowledged Because of the number, location and configuration of
wetlands on the property, it may be necessary to cross wetlands to provide road
access Limited filling of wetlands may be unavoidable to allow reasonable use of
the property and to provide for safety and fire access to service development. When
a specific development plan is proposed for the site, wetland impacts wIll be
analyzed and a mitigation plan will be proposed Grade and fill permits and other
'{
vlf"
,vb
development permits will require approval by the City of Yelm and other agencies
with jurisdictional authority
Response to Comment No.7
Comments acknowledged. It is the intent of the development proposals to limit the
total level of impacts to one acre or less to satisfy the U S Army Corps of Engmeers
nationwide permit requirements If, in the final design additional wetland areas are
required to be filled, it will be identified and addressed. No plan will be proposed
which will require more than two acres of wetland fill. This is intended so that all
impacts of the project fall within the less than two acre nationwide permit
regulatlOns of Section 404, of the Clean Water Act, as administered by the US. Army
Corps of Engineers.
Response to Comment No.8
Comments acknowledged.
Response to Comment No.9
The Draft EIS estimates for populahon and housmg demand m the Yelm area are
higher than Thurston Regional Planning Council (TRPC) projections The
differences are based on several major factors which are detailed on Page 62 of the
Draft EIS. The assumptions are summarized below'
. A major, well planned residential commumty will be developed on the subject
property, with a broad market spectrum of housing that will attract prospective
home buyers to the area and capture a larger share of the county populatlOn growth.
The Thurston County projections are based on zoning and urban growth areas that '=::. rJ 0
are currently m place /'
. The City of Yelm IS the only urban area in south Thurston County with fundmg
in place for upgrading and expanding their sewer system The provision of
expanded sewer facilities will allow the area to accommodate higher denSity
development. ProjectlOns in the Draft EIS show absorption beginning when the
sewer is scheduled to be in place.
Response to Comment No. 11
Comments acknowledged
Response to Comment No. 12
Please refer to comment #2 to the Washington State Department of TransportatlOn
Again, it is anticipated that the project-specific environmental reviews w1l1 address
the transportation-related impacts, if any, to both state and county faClhties outSide
the Yelm UGA and identify appropriate mitigation to accommodate these impacts
~'It
PREll ~~ARY
SUBJECT TO REVISION
Response to Comment No. 13
Comments acknowledged. The alternative scenarios described in the Draft EIS are
conceptual and therefore detailed information on a likely housmg mix and
demographics is unavailable for a school demand forecast.
The Yelm School District was unable to provide a methodology for determming the
number of students generated by development. School officials with the North
Thurston School District were contacted and use a development multipher of 83201
students per single family dwelling unit and 41167 students per multi-family
dwelling unit, (inclusive of all school grades) Alternatives 2 and 3 anticipate a
maximum of 5,000 housing units at full buildout. ThiS would result in between
2,058 and 4,160 additional students, depending on the mix of housing units built.
The Draft EIS mitigation measures for schools (page 104), recommend that the
annexahon proponents could aSSist the School Districts m the planning and Siting of
school facihties, at the hme of applymg for a more speClfic development proposal
All of the alternative scenanos include 20 acres of pubhc land, WhiCh could be
allocated for a future school facility
Response to Comment No. 16
Comments acknowledged. Historic and archeological resources were not included
in the original scoping of the DEIS with the City In the process of gathenng
mformation for the DEIS, no information concerning cultural or hlstonc resources
on the site was found.
Response to Comment No. 17
Comment acknowledged.
~D~R nO[jQt'\f1 A DV
r~ ~ f6 ~ ~ ~l~:n~' rUIlI
C;tJBJECT TO REVISION!
o 1 -1 5 - 9 3 _ SOD P M FRO!~ C IT Y 0 F Y E eM _ _ . .
,'.IM ~ TO: ~l'Dc\d ')-b~~", FroM:.0'\r-{\Ie.. ...t\:'~\Y~ r. ~ I II)ruB~
1..1i ~ tV")t('''CI2) Tr~r\.llr ll-tS~~'
FA-XI' 4S1-~c.Y:\~ FAX ,. Pffi\E I: -=r~lO-~O '5 ~ ~
Intercity T ran s ; t
r u-r
January 15, 1993
I .r S ;';':II;',1}I' SI"~~I, P'.XJI C1f,rf il..;. ilU/
,'.'.Ii ~. i'*f';.!:;''::(': :iS50i .~~9
...,t~1 "IS~~o~f,
Todd Stamm
I
Di:e..:tor of Community Development
City of Yelm
POBox 479
Yelm, WA 98597
Dear Todd:
Thank you for the opportumty to comment on the Southwest Yelm Annexation Draft
Environmental Impact Staterr.ent (OEIS).
We appreciate that public t.ransportation has been mentioned throughout the DEIS and
that the transportation sechon identifies pcdestrian-oriented features and transit as
mitigation options We hope that these mltlgnlions will be unplemented regardless of
which alternative is ultlmately settled upon.
We judged the alternatives on the following cnteria'
· pedestrian-friendly orientation;
· connectivity of roads/operational feasibility;
· residential density; and
· mixed-use development.
Alternative 3, the compact scenario, is the most attractive alternative to Intercity
Transit. This alternative, as conceptually designed appears to be the most pedestrian-
friend.1 y. The bulk of the residences will be wi thin 1/4 mile of the major corridor and
the commercial areas, increasing the likelihood that people will walk or bike to the
commercial areas and will access transit for travel either within or out of the 1
gevelopments. Alternative 3 also provides the most efficient through access for transit
vehicles. Service to this area would likely involve vehicles funning northeast on 507
and up through the annexahon area's main corridor, U1en out of the northeast section
into the City.
The residential density within this scenario also makes it more likely to support
effective transit service than the other alternatives. While! it docs include limited
mixed-use development, our hope is that this can be increased, to provide more on-site
employment opportunities.
m
q-l~-n I)~ Z;?'.! POI
O!-15-2~ :~ OOFM FROM CITY OF YELM
ros-
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....~.J//C.<.1
...NIt:::.Kl-~TY
TRANSIT
P.€)2
January 15, 1993
Page 2
Our observations and C01nments regarding the other alternatives are listed below:
Alternative 1 (No Action) - If development is to occur in this area, LT. prefers a higher
level or density than the one dwelling unit per five acres which development under this 2
scenario would allow.
Alternative 2 (Proponents Scenario) . This alternative is less attractive for several
reasons. Much of the housing will be located over 1! 4 mile {ron, the corridor.
Generally speaking, people will not walk further than 1/4 mile to access bus service.
Operationally, this scenario POS(?S problems for transit because of the looping roads, 3
potential dead-end streets, and other barriers to road connectivity. It should be noted
t.iLat this type of development is inconsistent with the Connectivity Policy called out in
the 1992 Yelm Comprehensive Transportation Plan.
Alternative 4 (Village Scenario) . While Intercity Transit does promote mixed-use
development, we have the same concerns with this alternative as listed ill Alternative 2.
While this alternative offers more mixed-use developmer.t, it also lowers the residential
densities. It should be possible to maintain higher densities in some areas of the 4
development. It would also be helpful to know what levels of employment density are
antidoated with this alternative.
.
Thank you again for the opportunity to provide input. Please keep us apprised of the
progress of this proposal. If the annexation takes place, we would be very interested in
parhdpating in future parcel- or project-specific planning efforts.
Sincerely,
;"Y~'yYL~'l 0, +ktue^,-
J...1~ie D. Haven
Planner /PoHcy Analyst
- - -..- -..- .... ~
RESPONSE TO COMMENTS IN LEITER FROM
INTERCITY TRANSIT
Response to Comment No.1
Comments acknowledged. (will be expanded)
Response to Comment No.2
Comment acknowledged. (will be expanded)
Response to Comment No.3
Comments acknowledged. (will be expanded)
Response to Comment No.4
Comments acknowledged. ** (will be expanded)
PRELl ~N~RV
SUBJECT TO REVISION
01-15-93 .J OO?~~
POZ
Nisqually Indian Tribe
20 She-Nah-Num Drive S.E.
lympia, Washington 98503
Phone: (206) 456-5221
January 15, 1993
Yelm Planning commission
city of Yelm
105 Yelm Avenue West
Yelm, Washington 98597
RE: Southwest YeLm Annexation
Draft Enviromnental Impact statement
Dear commission Members,
The Nisqually Indian Tribe offers the following comments on
the Draft Environmental Impact Statement (DEIS) for the proposed
Southwest Yelm Annexation:
Alternatives - The alternatives discussed are so limited that
the DEIS is practically useless as a planning document for the City
of Yelm. other than the No Action alternative, all the
alternatives considered serve the interest of the annexation
proponents. For the Final EIS, Yelm should require analysis of a
much wider range of alternatives.
First, the EIS and the Yelm Planning commission should
consider as an alternate annexation of only a portion of the
Southwest area. The EIS should evaluate the impacts of annexing
only the lands in sections 24 and 25, leaving sections 23, 26, and
27 under Thurston County jurisdiction. A second alternative that 1
should be evaluated would add section 23 to the annexed area. Yelm
is not limited to only the annexation area proposed by the
annexation proponents and, in fact, should evaluate alternatives
independently.
Second, the Final EIS should consider alternatives with a
substantially reduced number of residential units. The EIS, and
the Planning Commission, should consider an alternative of one
residential unit per two acres. This would be a 250% increase in 2
the number of residential units presently authorized, but would
reduce the inevitable impacts of the high number of residential
units proposed in all the alternatives presently under
consideration.
As the Draft EIS states, this is a nonproject planning Ers and
does not have to examine every conceivable alternative.
u!-15-~j .~ OOPM FRO~ CITY OF YELM
Southwest Yelm Annexation EIS
January 15, 1993
page 2
Nevertheless, to be legally sufficient, not to mention to be of use
to the citizens and elected officials of Yelm, the EIS must
evaluate ntl alternatives. The alternatives in the DEIS appear to
be contrived to avoid evaluation of alternatives of substance.
Finally, the No Action alternative is characterized in a
misleading manner. No Action does not require that the land remain
under Thurston County zoning and regulation. Yelm could annex some
or all of the Southwest area but is not obliged to change the
existing zoning of one unit per five acres; you could decide to
annex and retain the current zoning. The EIS should acknowledge
this alternative and the Planning commission should evaluate more
fully its merits.
Wastewater - For the Nisqually Tribe, the primary impact of
the annexation and development proposed in the DEIS is generation
and disposal of wastewater. The DEIS states that the annexed area
will produce 1.26 million gallons/day and that discharge of this
wastewater will be into the Nisqually River. This is over a 400%
increase in the discharge proposed by the current Yelm wastewater
plan.
The Yelm Planning Commission should know that any increase
above the proposed 300,000 gallons/day proposed by the wastewater
plan is not acceptable to the Nisqually Tribe. The Tribe, as a
matter of federal law, has the right to fish unobstructed in the
Nisqually River and to have its homeland and reservation, including
its waters, free of pollution. We cannot allow Yelm to use the
Nisqually River, our reservation and homeland, for its wastewater
disposal. Because Yelm faced a serious threat to its drinking
water, the Tribe in 1990 agreed not to oppose Yelm's proposal to
develop a wastewater treatment facility for the town with discharge
to the river limited to a maximum of 300,000 gallons/day. Yelm
should proceed with an annexation plan only if it will not increase
discharge to the river above this 300,000 gallons/day cap.
The Final EIS should include housing density alternatives
and/or wastewater disposal alternatives that will not require any
increased discharge to the Nisqually River.
General Comments A dramatic impact of the proposed
annexation and vital element of the annexation decision is not
discussed in the DEIS, but should be an important part of the Yelm
Planning commission's decision. This element is the quality of
life and image of the Town of Yelm. The annexation proposed to
increase the number will residences in Yelm from about 500 to 5,500
in ten years. All these new houses will be expensive houses (low-
cost housing is not generally built next to golf courses).
P03
3
4
5
6
17
8
n' 15 ''''
Ul- -:J
C5 OOPM FROM CITY OF YELM
P 0-4
"
Southwest Yelm Annexation EIS
January 15, 1993
Page 3
If the annexation goes through as proposed, in ten years it is
likely that the majority of Yelm's population will reside in the
Southwest area. The current citizens of Yelm will become a
minority in their own community, to be dominated by the relatively
wealthy new citizens of the Southwest area. Yelm has been the
Nisqua11y Tribe's neighbor for generations; we have gone to the
Ye1m schools and have life-long friends in Yelm. We are concerned
that Yelm will no longer be the friendly small town where one can
recognize just about everyone; long-term residents may not even
feel welcome in their own town.
Further, the substantial increase in demand for services will
bring an increase in tax rates and service fees. Some of the
oldest of Yelm's citizens likely will be forced to sell their homes
and property. As a matter of policy, the Yelm Planning Commission
should require that the Final EIS evaluate and document the likely
and possible social and economic impacts of the annexation proposal 9
on the current citizens of Ye1m. These impacts should be a major
element of the Commission's deliberations.
The Yelm Planning commission, and the City of Ye1m, have a
choice. It is not inevitable that Yelm must grow rapidly. The
Growth Management Act allows a community to choose and plan for a
modest pace of growth. You do not have to be a "captive" of the
developer's proposal or the limi ted alternatives for Southwest area
annexation. You can and must evaluate additional alternatives and
include as a viable option saying, "No!1l to rapid urbanization.
Thank you for the opportunity to comment on the DEIS. Your
decision on this annexation proposal will in large part determine
the future quality of life of the Yelm area. We urge you to demand
a full and complete discussion in the Final EIS of a wide range of
a1 ternati ves; only in this way will you be able to make an
adequately informed decision on the proposed Southwest annexation.
. i
SJ~/n
Dorian S. Sanchez
Tribal Chairman
RESPONSE TO COMMENTS IN LETTER FROM
NISQUALL Y INDIAN TRIBE
Response to Comment No.1
Comments acknowledged An alternative that considers less land area for
annexation would not meet the needs of the proponent, and therefore was not
scoped as an economically viable alternative under the present proposal. The State
Environmental Policy Act (SEP A) reqUlres that alternatives include actions that
could feasibly attain or approximate a proposal's objectives (WAC 197-11-440 (5) (b)
Response to Comment No. 2
Comments acknowledged. An alternative that considers a residential density of one
dwelling unit per two acres would not meet the proponent's objectives and was
therefore not considered in the range of alternatives explored. In additlOn, the State
Growth Management Act encourages urban denSity growth for lands wlthm Clty
limits or an urban growth boundary A density of one residential dwelling unit per
two acres would not provide for an efficient urban growth pattern, or provide
sufficient denSity to support an urban level of faCllItles and serVIces
Response to Comment No.3
Comment acknowledged. The scope of the DEIS alternative scenarios was prepared
by the City of Yelm, pursuant to WAC 197-11-08 There were publIc meetmgs held
to consider scoping of the DEIS alternatlves.
Response to Comment No.4
Comment acknowledged. The proposed action is for an annexation to the City of
Yelm, and a No Action alternative to the proposal imphes that the land remams
under the jurisdiction of Thurston County The City of Yelm is not necessanly
obliged to change the zoning on the proposed property With approval of the
annexation. The annexation may be viewed as a strategy to manage the transition of
the land from rural to urban uses. However, the City's policy towards annexatlOn
implies urbanization and the upgrading of facllities and utllities to the City'S
standards. This outlook is supported by the State GMA, which encourages urban
densities and services Within city hmlts and urban growth areas.
Response to Comment No. 5
Response to Comment No.6
PRELi iNAtaY
SUBJECT TO REVISION
Response to Comment No.7
Response to Comment No.8
Comments acknowledged. The alternative scenarios and prelIminary development
concepts anticipate that a mix of housing types will be mcluded. More informatlOn
d
rf
~?
7
~
on housing prices will be available at the time a more specific development is
proposed for the property.
Response to Comment No. 9
Comments acknowledged SectlOn 9 FaCllity Planning and Concurrency estimates
the costs for infrastructure and services and the potential revenue under the
proposed development alternatives The mitigating measures recommend that
developer impact fees could be assessed for providing serVIce or facility extenslOns
and/ or improvements to the proposed annexation area. In addition, revenue from
permit fees and utility taxes would help offset serVice costs.
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SUBJECT TO REVISION
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Kt:NI~rf'll IIART
Kf.NNt7J'1I MAQTIN
DON MARQ1lI,1)
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NATE TURNt:Q
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fRain,er~cfInnl iJiattict
POBox 98
Rainier WA 98576
RM10NA CARNER
Administrative &crclary
Telephone '206.446-'2207
January 4, 1992
Planning Commission
City of Yelm
POBox 479
Yelm, WA 98597
RE. Southwest Yelm Annexation
Dear Members of the Planning Commission
As you are aware, a portion of the Southwest Yelm Annexation Site is located within the boundaries of
the Rainier School District No 307 Due to that fact and the fact that any development near the Rainier
School District will impact the District, on behalf of the Rainier School District, I wish to communicate to
you concerns about the proposed annexation
First, I believe the Planning Commission must give serious consideration to RCW 28A.315.250" the statute
which addresses municipal and school district boundaries Although that statute would not win an award
for clarity, it does establish the basic legislative mandate that each incorporated city or town is to be
comprised in a single school district. The exceptions to that mandate that are stated in the statute are 1
not applicable to the annexation under your consideration Hence, the annexation under consideration
may well not be legally possible without invoking the jurisdiction of the State Board of Education as
described in RCW Chapter 28A.315.
Secondly, the Rainier School District requests the City of Yelm to immediately and specifically declare if
their intent is to change the property in question to the Yelm School District. The Environmental Impact
Statement may suggest this to be the intent.
If the jurisdiction of the State Board of Education is properly sought, I anticipate that the Rainier School
District would find it in its best interest to advocate that the property subject to the proposed annexation
remain in the Rainier School District. The potential concurrent jurisdiction of the State Board of 2
Education and other municipalities will make the issues surrounding the proposed annexation even more
complicated That brings me to another concern of the Rainier School District.
We believe that a number of the issues related to the proposed annexation could have been more refined
or eliminated had planning authorities been more cognizant of the tact that the Rainier School District
would be significantly impacted by the proposed annexation The mitigating measures cited in the Draft 3
Environment Impact Statement are illusory it they are not impacted The stated mitigating measures
were generated with little, if any, direct discussion with representatives of the Rainier School District.
,
.
The Rainier School District had made request of the City Manager of Yelm to be fully informed of all
progress related to the annexation
Further, the district requests that consultants to the city and/or agents of the developers of the
property, keep the district fully informed of all their actions and recommendations related to the
annexation.
Please be on notice that the Rainier School District No 307 is very concerned about the impact on it of
the proposed Southwest Yelm Annexation The District seeks your assurance that its interests will be
conscientiously considered and protected as the proposed annexation is further considered State law
provides a very deliberate process when changes in school district boundaries are being considered The
legislature has recognized the need for such deliberative processes City Planners must be equally
deliberative and conscientious when their actions involve the potentia! need for changes in school district
boundaries.
4
I trust that the City of Yelm's Planning Commission recognizes that the interests of the Rainier School
District must be taken into serious consideration if any phase of the proposed annexation is to go
forward At this point, the exact interests of the District are difficult to determine because changes in
school district boundaries have yet to be formally advocated Once the intentions of the advocates are
known regarding changes in school boundaries, the interests of the Rainier School District will be better
subject to identification.
Very truly yours,
~J4/
.:% 4t: Wc..h~
D Golphen~ .
Superintendent
BDG:lm
cc Attorney Craig Hanson
RESPONSE TO COMMENTS IN LEITER FROM
RAINIER SCHOOL DISTRICT - DATED 1/4/93
PRELl iNARY
SUBJECT TO REVISION
OI-!5-S1 .: :~.M F=OM CITY OF YELM
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POBox 98
Rainier WA 98576
RAMONA GARNEO
Admini&rativc: &crel.sry
January 13, 1993
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Planning Commission
City of Yelm
POBox 479
Yelm, WA 98597
RE. Southwest Yelm Annexation
Dear Members of the Planning Commission.
On behalf of the Rainier School District 1 attended the January 4, 1993 public hearing regarding the
preliminary Environmental Impact Statement for the potential annexation Attached is a copy of the
prepared statement read at the hearing. Our attendance and comments were brought forth because
Section 27 of the potential annexation lies within the boundaries of the Rainier School District
For the record we present these further remarks:
1 Rainier School District, to date, has not been contacted by the property developers regarding
district interests. The property developers have contacted the Yelm School District officials
regarding the property within the Rainier School District property. The Yelm School District
offiCials have been very forthright in communications with Rainier School District offICials and it
is appreciated.
2. The EfS, develcpers requested a written correspondence prior to the EIS Rough Draft. The EIS
does not reNect Rainier School District interests as expressed in the correspondence.
3 During the January 4, 1993 meeting a representative of the property developers commented
that it appeared to be "an accidenr that Section 27 was not originally in the Yelm School
District. We suggest this is speculation and likely a history of development of district lines may 2
suggest otherwise Further, the comment may suggest the developers desire for a school district
changeof the property
1
4 A minimum of fifteen (15) acres must be set aside in Section 27 as a future elementary school 13
site Future potential growth would require an elementary school and this would be an ideal
neightx>rhood school.
01-15-93 09 05AM FROM CITY OF YELM P03
It Is not the Rainier School Districts interest to support or oppose the annexation of the pr~rty by the
City of Yelm However, it is our paramount interest to support the interests of the Rainier School 4
District This interest includes involvement and protection for all properties within its legal boundaries.
On behalf of the Board of Directors these comments are given by
BDG:lm
attach
cc' Craig Hanson, Attorney
RESPONSE TO COMMENTS IN LETTER FROM
RAINIER SCHOOL DISTRICT - DATED 1/13/93
PRELl iNARY
SUBJECT TO REVISION
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Nisqually River Council
P.O. Box 1076
Yelnl, Washington 98597
January 11 1993
Todd Stamm
City Planner
City ofYelm
POBox 479
Yelm, \VA 98597
Dear Mr. Statrun:
The Nlsqually River Council respectfully requests that the
City ofYelm grant the Council a two-week extension for
conmlcnt on the Southwest Yelm Annexation DEIS from
January 15th until January 29U1.
The Council has not determined whether or not it wishes
to comlnent, and will do so at its next meeting on January
15th. Given the current deadline, we would not be able tu
offer meaningful comment unless we receive an extension.
Please convey your response to uur Staff COOl-dlnatOl", Steve
Craig, at 459-6780. Thank you for your'attenUon.
Sincerely,
{)~ O~)
Diane Obenluell
Chairmnn
DO:pcm
RESPONSE TO COMMENTS IN LEITER FROM
NISQUALL Y RIVER COUNCIL - DATED 1/11/93
Response to Comment No.1
Comment acknowledged. A two week extension for comments on the DEIS was
granted by City of Yelm, extending the comment period from January 15 to January
29
~ i \tl~~1
\lft'tL,' 0 ~E\I\S'ON
SUBJECT T
RESPONSES TO LElTERS FROM INDIVIDUALS
""" ,'" bi ~ co, ,; · ," I:rd;'~r ~/1
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SUBJECT TO REVISION
at-i5-93
:O?M ::0~ CITY OF YELM
January 15, 1993
SHAPIRO &
ASSca:IATES~
Mr. Todd Stamm, Duector of Commumty Development
City ofYeIm
P.O. Box 479
Yelm. Washington 98597
Re: Southwest Yelm Annexation Draft EIS
Washington Mutual Tower
Suite 1700
1201 Third Avenue
S~a(de
Washington 98101
Tel: 206/624. 9190
roL-';: 206/62.;.. 1901
Dear Mr S t3.rD.m;
Shaprro and Associates, Inc. represents Vennrre Partners, one of the two largest ownerships
WIthin the annexation area. The Draft EIS is a compreheIlSlve and well-written document covering
a non~project proposaL We support the proposed annexation and appreciate the opportunity to
COIIlIDent on the City's Draft EIS. The following are c1anficarions and questions we have
concerning the Draft.
1) It should be noted that nelther the No Action Alternative, the Compact Scenario nor the Village
Scenario meets Vennrre Partners' objectives. The ownersh1p's objectives are predicated. on
market demand and are to develop a mix of single-family and mnltiple-family residences with a
ncighoorhood commercial center designed to seIVe the project's residents.
2) We senously doubt there 15 a market for the 110 acres of commercia1 and office uses
represented in the Village Scenario. This scenario raises the following questions: What is the
furore land demand for professional service and government office uses, given the projected
population increases? Will there be a demand for approximately 40 acres rerail and 70 acres of
professional service and government uses in Yelm? If there is a demand, would it not be most
appropriate to consolidate those uses near the highway to help suppon existing downtown
commercial uses and reduce automobile dependent trips.
3) We question the conclusion on page 36 that the Village Scenano would mtroduce lower
quannttes of pollutants into the groundwater compared. to the proposal The Village Scenario
would have higher traffic levels associated with 70 additional acres of professional service and
government office uses and In turn would cause higher groundwater pollution levels than
would be expected. by the proposal.
4) In response to Natural Resource Lands mitIgating measures. Henry Dragt has received
complaints from nearby property owners about the smell from his dairy Further, r.otential
pollution from the farm and its impacts on groundwater quality decreases the farm s
desuability TIus is a common phenomenon and underscores the transitional nature of a dairy
in close proxmrity to urban uses.
5) We do not understand how the Village Scenario concept would generate only 130 more peak_
hour trips than the proposal when it would incorporate three times as much commercial and
office-designated land and only ten percent fewer residences.
6) The Draft EIS generally describes the Village Scenario as potentially having the same or less
impacts on public services than would occor under the proposal. Although the Village
Scenario would have approximately ten percent fewer residences, resulting in shghtly fewer
impacts on schools. we would expect that if the commercial and Qf:fice land were built out, this
scenario would place a greater demand on police and fire seIVlCe5. We would also expect that
the employees on 70 more acres of professional service and office developed land under the
JI-I~-~3 04 _SP~ PQ2
P05
1
2
3
4
5
6
.. .
. 01-15-93 05 OOPM FROM CITY OF YELM
FOB
Village Scenario would require as much rCcreational opportunity as the occupants of the 500
m~ residences that might be developed under the proposal.
7) The fiscal impact analysis includes the impacts of infrastructure improvements in terms of
costs. These improvements wooId be paid for by the developer and do not represent costS to 7
the public. In addition, revenue from permit fees and utility taxes would help offset service
costs.
Again. we appreciate the oppornmity to comment on the Draft EIS and welcome any questions or
clarifications you may have.
Sincerely,
S~IROaOOATES. INe.
~
SHAPIro &
ASS<<I:lATESi
y -!S-~ u, 2~~! Py)
RESPONSE TO COMMENTS IN LETTER FROM
JON POTIER, SHAPIRO & ASSOCIATES, INC.
Response to Comment No.1
Comment acknowledged.
Response to Comment No.2
Comments acknowledged Alternative 4, Village Scenario, was an alternative
scoped by staff at the City of Yelm, with the mtention of includmg an employment-
based alternative for analysis in the DEIS It was not based on eXisting or projected
market or land demand for commercial and office uses, but to provide for a range of
reasonable alternahves for analysis Development of commercial and office uses
would be driven by market demand and phasing of development These concerns
will be addressed in more detail during the apphcation process for a speClfic
development proposal on the property In the conceptual plan for the Village
Scenario, commercial and office uses are not consohdated near the highway because
of physical constraints (Le. wetlands, steep slopes) on the property Also, it was
considered that the employment center would function better at the center of the
entire development with easy access to residences, recreatlOn, schools, etc.
Response to Comment No.3
Comments acknowledged.
PREU 'N.~~l
SUBJECT TO REViSlON
Response to Comment No.4
Comments acknowledged. The Dragt dairy farm is located on the proposed site and
would be displaced with development of the site The mitigation measures m
section 2 Natural Resource Lands, recommend pursuing measures to reduce
conflicts between urban development on the Site and surrounding rural, farm uses
Response to Comment No.5
The figures in Table 16 of the DEIS are misquoted A revised Table 16 is presented m
the appendices on page --- of this document. Although the table was misquoted In
the DEIS, all analyses were developed With the correct figures identified in the new
Table 16 There is a 200 peak hour trip dIfference between the vlllage and
preferred/ compact scenarios Although the mcrease may seem small, given the
amount of office development planned in the village concept, a 305 discount factor
was applied to the office and retail developments to allow for mternal traffic within
the annexation parcels. The trip generation values and discount factors used m the
study are consistent with the current edition of the Trzp GeneratlOn Report,
published by the institute of transportatlOn engineers (ITE)
Response to Comment No.6
Comments acknowledged. The additional commercial and office uses proposed
under Alternative 4, Village Scenano, would be serviced With spnnkler systems for
fire prevention and would likely include security alarm systems Therefore, the
,JrVJ
1(1 ~,
~v
increase in commercial and office uses proposed in the alternahve are not expected
to place greater demand on police and fire services than would residenhal uses
Response to Comment No.7
Comments acknowledged.
PREll 'NARY
SUBJECT TO REViSION
Nat,iollal Food Corporal,ion
199;:
206 5466533 and 523 4900
Fox 206 542 0202
PO Box 33745
16740 Aurora Avenue Norlh
Seallle, W ashlnglon 981 33
December 17,
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SUBJECT TO {~EViSIO~"
1992
Yelm Planning Commission
P O. Box 479
Yelm, WA 98597
Re: Southwest Yelm Annexation
Ladies & Gentlemen:
We have received your Notice of Public Hea('ing ('egarding the
proposed annexation of 2,000 ac('es Southwest of the city and wish
to offer our written comment and opposition to the p('oposal
This company ope('ates a 300,000 bi('d egg layer farm which has
existed fo(' nearly 30 years on approxiately 250 acres in Section
35, immediately south of the proposed annexat ion area. The proposed
annexation would convert substantial ag('icultural and timber land
to u('ban uses Even though our property is not proposed to be
included, we would be severely impacted. It would not be ('ealistic
to assume that we could continue our agricultural activity while
bordering an area of dense residential and commercial activity.
Agricultural activity such as ou('s is not compatible with such uses
be ing nearby. Fu('the('more, our ope rat ions ('equire that s ignif icant
acreage of cropland or pasture land be available in close proximity
for utilization of chicken manure as fertilizer. This is becoming
increasingly important as government regulations are beginning to
impose specific requirements of available acreage for manure
utilization. Other agricultural operations in the immediate area
have simila(' requirements for available land.
1
2
Many people believe they can expand a city and engulf or border
farms, so long as they do not require them to discontinue
operations Often times, the belief carries with it a good feeling
about p('eserving a rural environment However, in this ('egard, a
dist inct ion must be made between .. open spaces" and product i ve
farms. The fa('ms which feed this count ry must be allowed to
operate in a t('ue agricultural environment. The proposed
annexation cannot insure such continued operation.
Sincerely yours,
NATIONAL FOOD CORPORATION
~~_o
B(' an V. BOOkey,~p-
P('esident
t>
RESPONSE TO COMMENTS IN LETTER FROM
BRIAN BOOKEY, NATIONAL FOOD CORPORATION
Response to Comment No. 1
Comments acknowledged The Draft EIS acknowledges that as the City of Yelm
expands its jurisdiction, changing land uses may present conflicts to adjacent
agricultural activities However, the site is presently Identified in the Thurston
County 1988 Comprehensive Plan as Rural, and the 1990 Draft Yelm/Thurston
County Joint Plan shows much of the proposed annexatlOn area as RR 1/5 (Rural ~
Residential, one unit per five acres) A residential density of one unit per five acres
does not ensure retention of viable commercial agriculture or forestry activities, and or v'
residential development at this density does not necessanly reduce the potentIal
conflicts with adjacent agriculture
Response to Comment No.2
Comments acknowledged The National Food Corporation egg layer farm is not ?
presently utilizing the proposed site to spread chicken manure.
..' , E.' LtJ EV' 8 R f) F\ tf!;a \:J!
PR\" :'''' Urr~~~~~er~Uu U
SUBJECT TO RE\lIS!CI\J
~
01-l5-9J .~ DO?M ~~J~ CITY OF YELM
Pl5
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1 S030 L01lgmiI~ Sf. SE
161m, WA 98597
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Yt'lm P~.n.I'.ing Commi~sion
RE Southvrest Yebn Annexation Proposal
Dear PlaJ.11'til~ Commission.
I rJaw COflCe:!l'\j regard~ ttJe rfJl~t St6.~m.ent', ,ection on Pollee PlotecOOn foc the
Pl":I}-oS~ ~rll\~xed ~te~.. If it nov requires five 1.~hiclt3 ~ fi'\1e+ o!fi1:e~ b providtl protection for
i<.iO acres ~.nd 1365 people, I fail to uruier31and hov"Ille could l:xptct O!1e Iml'e. vehicle ~.!'Ld tvO more
offkm to adeq'J.8.1ely provide pro1eC1:ion tor 2740 &res and. 13,865 people (5000 uni~ y. 2 5 pe~
p.:r unit + e;(i3~ 1l0pul!1tion) r (Ca.lize the population incre~ wuJd !lOt occur immt;dia1ely, but
cert&jnly tj.e g~og:raphic a.-rea ~ro".1..1d i:ncree..~ imnlf'diatelv upon ~xation, there1:Jy causing the
apparent need for fin IDcrea.5e of more than one police C~ to pa.trol al1.Mxed ~
T~.t1e 1 q - E~M P'J.hlic Sen1U'e CO~, p~E' 126 I does not ~~q ~1.ely Mdm~ tJili either
TILe GIj~t by Population t.d.t1e uses a 10 4% increase figure, which may accurately re!1ect the Yelm
kIea. Captu..ore- ra~ of tilt Count; projection. Hove1ler, d~ it ~curatfoly re~t the e.ctu8l increase
'Within fJ'.te Yelm City Limi:z? In 1994 wl1e, 247 nev [.lOusing units vill supposedly M built and
'vim m a~rage occ~y of 2 5 peI3onshmit, ~ ~uld ~sult in $I!. incre~e o! appro~~ly 617
people This figure l'e'present3 a 5490 IDcrea3e in. popul8.tion. If the ~ !1gures are computed on 8-
r;O~f per pem,n b.~is then the projected dollar ~unts Wied a.re ~ub!tantia11y iMdequa.1e
I ll1l}. )'Ou 10 plea3e give further cormderation to ~ impact 1:Jili annexation wuld have on 1M
?-tlll?ty of Yelm re,iden13 and to be ~ute that accurate p1an.IlirJg in this e.r->A ~ e.ddreg~. I believe the
~~.me conzideralion need., to be ~iven to the p~ for Fire Protection ilia
Th.enk. YJl1. for Y01JI atv.lntion.
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a-.y ~ ~
Maxy Lou C1tw~
PREl~~ti~ARl
SUBJECT TO RE\!~S\ON
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RESPONSE TO COMMENTS IN LETTER FROM
MARY LOU CLEMENS
Response to Comment No.1
Comments acknowledged. The Yelm Police Department provided the estimate that
the proposed annexation would result m the need for two addltlonal officers and
one patrol vehicle, based on a formula used to determine impacts on personnel and
equipment
Response to Comment No.2
Comments acknowledged. Additional work on Table 19 - Estimated Public SerVice
Costs will be provided in a supplemental section on Pubhc Facihtles and
Concurrency
PRELI~~iriARY
SlH~UECT TO REVISION
fUj, D It l ~ me] bl Q.11 ~ ~ ~,r
rr n t. 'r. ~ "'~ ~ n rJ~ w tl tl
SUBJECT TO REVISION
Appendices
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PREl~ :' I~ARY
SURJECT TO REVISION
Distribution List