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Final EIS 2-1993 (Prelim) J' (y!9) , 0/ 11 ij\ SOUTHWEST YELM ANNEXA TION I " Co ~-' 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 --.---.- ------.- ---- ----.-- -------.. - --.---- \-5 TO SEATTLE ). t~ Thurston count:~~~\, , '~ .~ Pierce County q ,1 t' (l ~ B' \ "G \1 , LI1 \1\'1 0~J TO TENINO NTS 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. @ Fi SOUTHWEST YELM ANNEXATION Vicinity Map ;;; l() ...!. . Longview NTS Ckd 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. 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S..lIle'An<holaOo ')10 Ho e Duildin 70~ 2nd Avenue Scattle,WA 96104 (206) 6246239 SOUTHWEST YELM ANNEXATION Topography and Sections ~~ p,.lR ,.. /I:rF. R stnv1N1A.Rl' N1A. 'TRIX ~ ,1&' crS Of 1>\' PROPOS'" ,,",,0 '" -rOtl'" "Vf.5 . . A\ternative 1\ ,,,._~.h"- -- . ,r..\'. ~ A\\ernati ve 1 ~ j\\ternatwe 2 ~~ J'\.........J.~....-' ::- 3 ~ "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 (/)~ c. 03:= ~m nr-- ~ ..... - O~.' ~ ::o~ l'fi ~!iD S~ '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. CI) C~ OJ~ c... €!l'Jj;<" 'n m'~ () ta i'l'~ -4~ ....,~ O~ ~~ :o~ m~ ,"'~12l1 -~ cn~ O~ 4? G'4'(irJ ~ 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. , _ . ~~e~~;~~~ ~1 A.lternatjye :) ~ 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. cn~ ~~ ffirn ~t; """ O~ .,,~ 5~ c.a~ O~ z 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. CP)~ C OO~ c...~ MtllHI n~ 4Ci!i'llBBl 9 o - :lO~,'" fTi .' , <> ~= O~~ :z ~~:'J 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. (/)~ ,- '5i t... rn~ ~~ -- ...\ O~ ""'~ '" ~"'... "';) ~~ -... r:J;,/ '; ,~ ~, ~:~~ Alternative 1\ ~ 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. (J)~ e~ ~t: -\ O~ ~ :n ~'$3 ~ ~t'fJ -~ <!J ~~ O~ 'Z ~ 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 :\ ~ Impacts on energy consumption would be largely similar to the Proponents' Scenario. (J)~ ~= c...~ m Ii .Jlil qF ~ -t OfD2il1i ~Z ~~ ~= ~=< Atlerna\ive 4 ~ 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 (.J')~ C ~} ~~ (..~ fflt!l.!13 CJ~ ~ -I - o ~ :n~ F(i~ 'S~ <!2~ O~ z. Alternative 4, ~ 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)) ~ C tP~ (....~,' rt'\ ~ '01 ~ n~ :....\~ ~---"'" O~ j)~ ~~ ~~ O~ ~ Alternative 4 would provide similar developable area as the proponents' Scenario and is expected to result in similar runoH rates. ~ 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 \C' . 'l':;;~:\t~;.;;, '. DEe 2 9'i992 ~ ) I.~ !' ;'....-' 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 '''~~:J 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~, ' ,. 11 ~ 11 ;, / i 0\ / /1 (; Ii ~f.P I'" &~ ~ ,,01,-111 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 --..#~_.. .~~ -...-..... \ .--. .,.",\ "",\ .----,.:=.?-~- - , .., -., \~ ~.: 'C.- ~ \ \. " i- s\993 Mr Todd Stamm City of Yelm PO Box 479 Yelm WA 98597 \. -~...-~.-.' ..... .--,., ...-' 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 l-l ::.J ~ .. 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 \ ....-...-..-- II ~/ j ! ll/J 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 ) ,"!.\ .~ '- 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 @ f4 rf~/ 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 @ ~l'\o?< 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- '" ....~.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. D D fE" L' ~ Y,~' rU F:llll lid,', ~,' 'i" VV"I rn mJf?li~nftri r SUBJECT TO REVISION , fJircd6rs Kt:NI~rf'll IIART Kf.NNt7J'1I MAQTIN DON MARQ1lI,1) I~[TI\ WRIGI.[,I)WOQTII NATE TURNt:Q I~O!'J D GOI.PIIENEE ~uperinlendenl 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 POZ " D,recl.1r.. BOD D GOLDtl[NU ~uperinlc:ndcnl KENNf.TH HART Krlili(Tll \t.'RTI~ DO," MAQQ!:L" f)ETH WR\ClfJ.l, ~'(\QTll hATt: TUR\m Iafnfer'.1;ctn1n lilfnttict POBox 98 Rainier WA 98576 RAMONA GARNEO Admini&rativc: &crel.sry January 13, 1993 ~ iI~ f5 e@[1\\.O f'2 ~ 1 II : ~-.1 'V !.:.~ W . i ,-:! qr\\ \ Ii "r-.'-,. -'. ...c- ._1 Ii II :d~ '! - '.':; I i!r(l J !l I:, /".. AN 14~ ,;.:, 11"~t ~ ,", 'UUiJ~ L _~ ~ Tclcph00e 206-446;;07 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 J, C\lllndl M~1llb('r&},;r: J'h:f,~' ('\'Wlly 'jhllr~l(>n County I .<::wi" County ~;l.:lle of \VI"hillf;I\>Il: P;\l\.;S end Recreation (l'lll" ll\"'~lotl [)(T~ of NO(tlroll{c:'o\lrc<~1 Dcpl of ^i:rl.:ulllUl' 1)"1'1 01 E((Jll,&.\' n"l't of n~hl.'rl<;>~ D<:'I)\' (If Wildlife ~;I'l:.rtl,H)' cd ~tate U ",,' f'ack E:Xpl:llll1l:l\llll rort:~t U.S. Arm)', r~,rt lewis NlsqllSlly Indian Tnbo Niscjllull)' N"UOlll\1 Wildli{\, Hcfu!;l! Giflord Plllchol Nollonol F(,~JC='l Mounl Ralnl('1' Nllljol1oll-'alK 'I'acomo City Ul:ht Tl)Wll o{ ),\:Im Town of Eololl\'ill" elf)' of Roy CJIIZl'IlS ^dvJ~)r)' COllllJ\lll\~: TIlT"" Clti%<:n M~tl1l"'rH ..:;.....-....-J.~.~....-_-_ _ 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 r& ri E L~ ~~'i ~ ~i~t~ lf~ ~ 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, ~~,~.'"' l', m,H"~,,n,.'i WI' [:,,9 [\,,'1 ~,i' )\(.q 1- ~1) n;' M ~\j cl ~ m'\1 ~ Hl ~. 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 M8I)' Lou GltrrX:Il:l 1 S030 L01lgmiI~ Sf. SE 161m, WA 98597 Jau 1.18IY 13, 1 993 l~ [C.' r;::::.. r;::'I .,... , I D]l5 ~ u:: ;J '. · ~ 1'---- --. - .- " JI . ,~~I .wl I 5 ~ I i .1:' \8/' I 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. 1 2 ~".. --rel'l1 "II a-.y ~ ~ Maxy Lou C1tw~ PREl~~ti~ARl SUBJECT TO RE\!~S\ON .. 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 " -'I ... PREl~ :' I~ARY SURJECT TO REVISION Distribution List