East Gateway Final EIS Appendix AFinal Environmental Impact Statement
APPENDIX B: DEIS COMMENTS
AND RESPONSES
SO Alliance
Page 64
March 2015
Yelm East Gateway DEIS Comments
No.
Agency
Comment
Response
1.
Ecology — Gail Sandlin
The environmental impact statement should include
A GHG assessment could be included in the FEIS,
a discussion of Greenhouse gas assessment.
Section 3.2 — Air Quality but based on traffic
information, new Vehicle trips will be no more than
2,000; therefore, it is anticipated less than 10,000 total
metric tons of GHG will result from this project and
does not meet the threshold per Ecology of 25,000
metric tons. The anticipated uses in the Planned Action
EIS do not include uses that would result in significant
air emissions.
2.
Ecology — Thomas
If contamination is suspected, discovered, or occurs
Based on historical site conditions, contamination is not
Middleton
during the proposed SEPA action, testing of the
anticipated to be found on the project properties. The
potentially contaminated media must be conducted.
City of Yelm will contact Ecology should any
If contamination of soil or groundwater is readily
contamination be discovered during site construction.
apparent, or is revealed by testing, Ecology must be
notified. Contact the Environmental Report
Tracking System Coordinator in the Southwest
Regional Office at (360) 407 -6300.
3.
Washington State
Page 14, Yelm Avenue (SR 507) /Grove Road, 2nd
The wording from page 30 of the TIA has been added to
Department of
Paragraph: WSDOT is advocating for a roundabout
page 14, 3rd paragraph of the EIS.
Transportation
and not a signal at Grove Road. This should be made
( WSDOT)
explicitly clear. Page 30 (Section 6.4.13) of the TIA,
the second paragraph of this section is more explicit
in its wording about the roundabout and should be
mimicked in the DEIS
4.
Washington State
Page 42, Figure 8 Existing PM Peak Hour Traffic
Figure 8 corresponds to Figure 5, on Page 14 of the TIA
Department of
Volumes and Page 47, Figure 11 Projected 2020 PM
and Figure 11 corresponds to Figure 9 on page 23 of the
Transportation
peak hour traffic volumes preferred alternative: The
TIA. These references were added to the FEIS.
( WSDOT)
turning movement numbers on these pages are too
small to read (Pixelated). Recommend that these
figures include a reference to the applicable page
number in Appendix A, Traffic Impact Analysis
where the volumes can be read.
Yelm East Gateway DEIS Comments
5.
Washington State
Is there a reason the easterly approach is only right
Right In Right Out access will be explored as part of the
Department of
out? Why not right in and right out? If possible
"Site Circulation Analysis" discussed in the TIA, Section
Transportation
joint access with adjacent property owners at the
8 — Mitigation page 43, which is required for
( WSDOT)
common lot line should be considered.
development in the planned action area.
6.
Washington State
Appendix A, Traffic Impact Analysis (TIA), Page 21
The growth rates were calculated based on straight line
Department of
(Section 5.2.1 2020 Horizon): What is the source of
(uncompounded) growth between the 2009 and 2035
Transportation
the growth rates; this should be clarified in the
scenarios in the current adopted Thurston Regional
( WSDOT)
document.
Planning Council, regional travel demand model, this is
stated in the TIA, Section 4.2, page 16. The growth
rates were approved for use by the City of Yelm during
the EIS traffic scoping process.
7.
Washington State
Appendix A, TIA: Traffic mitigation seems to be
Section 6 describes the intersection operational
Department of
vague. It is clear when no mitigation is required
analysis and describes potential improvements.
Transportation
(section6.5), but other sections should be clarified
Proposed traffic mitigation specific to this development
( WSDOT)
that the proposed solutions are traffic mitigation
is listed in the TIA report Section 8 - Mitigation (page
measures.
41).
8.
Washington State
WSDOT discussed the potential of a roundabout at
The Wal -Mart Boulevard /Yelm Avenue intersection is a
Department of
the Walmart Boulevard, the discussion is lacking in
properly functioning signalized intersection that is
Transportation
the text.
designed to accommodate high traffic flows. The
( WSDOT)
proposed development will require adding a
northbound approach to the intersection for access,
but does not generate the need to convert the
intersection to a different control type.
9.
Washington State
Why wasn't a four -lane divided highway with
The Wal -Mart Boulevard /Yelm Avenue intersection is a
Department of
multilane roundabouts at both Grove Road
properly functioning signalized intersection that is
Transportation
Intersection and Wal -Mart Blvd considered? Both
designed to accommodate high traffic flows. This
( WSDOT)
Figure 12 and Figure 13 (Year 2020 and Year 2035
development does not create a need to change
Channelization Plans) of the TIA essentially depict a
intersection control type.
four -lane divided facility between the two
intersections. Converting the Wal -Mart Blvd from
The completion of SR 510 Alternative (Yelm Loop) will
Signal Control to an Urban Multilane Roundabout
reduce travel demand on Yelm Avenue such that a four -
would reduce all fatal and injury collisions by 66%
lane section is not needed. We have included a four -
per WSDOT Crash Modification Factor (CFM) "Short
lane section on Yelm Avenue between Grove Road and
Yelm East Gateway DEIS Comments
List ", Revised October 10, 2014. WSDOT is
beginning to use Highway Safety Manual excel
software to perform no build and build alternative
safety analysis in Interchange Justification Reports,
but the tool could be helpful in comparing safety
impacts within the Gateway's study limits (Between
Yelm Creek and Wal- Mart's second access). In
planning studies, WSDOT typically compares signal
with channelization alternatives against
roundabout alternatives in order to determine
mobility and safety performance.
Wal -Mart Boulevard to allow right -turn movements
into /out -of driveways and adjacent intersections.
10.
Washington State
WSDOT is interested in how mitigation measures
The mitigation section (TIA Section 8) describes the
Department of
will be implemented, particularly implementing
complete mitigation program for the development. As
Transportation
improvements to address potential impacts to state
individual projects within the Planned Action EIS area
( WSDOT)
facilities. It is our understanding that under this
are developed, they will be required to prepare Site
process, the city's adoption of the planned action
Circulation Analyses (TIA page 43) to identify the trip
would exempt future Gateway developments from
generation potential and specific site driveway
individual review, substituting the case -by -case
configuration of each development on a case by case
evaluation that WSDOT would normally do under
basis.
State Environmental Policy Act. We are interested
in how mitigation measures for state facilities will
The overall roadway improvements on Yelm Avenue
be addressed.
will be detailed in a Plan For Approval (PFA) prepared
per WSDOT guidelines. Each individual driveway,
frontage improvement and off -site improvement will
be constructed within the context of the overall PFA.
Changes to the approved plan would require WSDOT
review and approval.
11.
Washington State
The planned action mitigation threshold and
These two thresholds serve different purposes. Any
Department of
measures seem unclear how they will effectively
development on the south side of Yelm Avenue that
Transportation
implement the discussed improvements. The DEIS
uses Grove Road as the primary access will be required
( WSDOT)
on page 51 identifies a cumulative traffic threshold
to construct the south leg of the intersection and
within the Yelm East Gateway area to be 2,000 new
improvements to the intersection to accommodate the
PM peak hour trips. While in the TIA portion of the
fourth leg. It is anticipated 25 PM peak hour trips added
DEIS (Section 8.4 Phasing of the On -Site and Off-
to the north or south leg of the intersection will require
12. Washington State
Department of
Transportation
( WSDOT)
Yelm East Gateway DEIS Comments
Site Traffic Mitigation Improvements) identifies a
threshold of 25 PM peak hour trips of development
traffic (new -to- network and pass -by) using various
legs of the intersection and /or the fourth developer
to trigger construction of a roundabout. Are these
thresholds mutually exclusive? What is the
threshold for triggering the right turn only
accommodations for the right in channelization,
which is not discussed? How will WSDOT be kept
informed as the area is developed? How the
mitigation is to implemented should be clearly
spelled out since this plan be taking the place of
individual SEPA reviews.
Will there be provisions to revisit the plan's
recommendation at some future threshold or
timeline? The concern is that, when development
does occur, it could take the form of something very
different than what the DEIS and preferred
alternative assumes. If so, this would require a new
look at mitigation described in the EIS.
the need for construction of a modern roundabout
unless the Site Circulation Analysis clearlyshows it is not
yet warranted. The 2,000 trip threshold is the maximum
trip growth allowed under the Planned Action EIS.
The proposed "four -lane" section on Yelm Avenue
between Wal -Mart boulevard and Grove Road is
intended to provide for right- turning traffic into and out
of site driveways and intersections. Rather than have a
single lane in each direction with right -turn lanes at
intersections, it was proposed to have second
continuous lanes in each direction through the
commercial corridor. Each development proposal that
moves forward within the EIS project will be required
to complete a Site Circulation Analysis (TIA Section 8) to
identify the specific driveway configuration. Each
individual development will be required to construct
improvements that will accommodate the overall
design concept for the corridor.
If a proposed development is substantially different
from what is discussed in the EIS, the proposed
development is not covered under the Planned Action
EIS and will be required to go through individual
development review, including SEPA.
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STATE OF WASHINGTON
DEPARTMENT OF ECOLOGY
PO Box 47775 • Olympia, Washington 98504 -7775 • (360) 407 -6300
711 for Washington Relay Service • Persons with a speech disability can call 877- 833 -6341
February 5, 2015
Tami Merriman, Associate Planner
City of Yelm
Community Development Department
105 Yelm Avenue West
Yelm, WA 98597
Dear Ms. Merriman:
Your address
is in the
Nisqually
watershed
Thank you for the opportunity to comment on the draft environmental impact statement for the
Yelm East Gateway Planned Action. The Department of Ecology (Ecology) reviewed the
environmental checklist and has the following comment(s):
AIR QUALITY /GREEN HOUSE GAS: Gail Sandlin (360) 407 -6860
The environmental impact statement should include a discussion of greenhouse gas
assessment.
TOXICS CLEANUP: Thomas Middleton (360) 407 -7263
If contamination is suspected, discovered, or occurs during the proposed SEPA action,
testing of the potentially contaminated media must be conducted. If contamination of soil or
groundwater is readily apparent, or is revealed by testing, Ecology must be notified. Contact
the Environmental Report Tracking System Coordinator in the Southwest Regional Office
(SWRO) at (360) 407 -6300. For assistance and information about subsequent cleanup and to
identify the type of testing that will be required, contact Thomas Middleton with the SWRO,
Toxic Cleanup Program at the phone number given above.
Ecology's comments are based upon information provided by the lead agency. As such, they
may not constitute an exhaustive list of the various authorizations that must be obtained or legal
requirements that must be fulfilled in order to carry out the proposed action.
If you have any questions or would like to respond to these comments, please contact the
appropriate reviewing staff listed above.
Department of Ecology
Southwest Regional Office
(SM:15 -0086)
cc: Thomas Middleton, TCP
Gail Sandlin, AQP
Washington State Olympic Region
To Department of Transportation 5720 Capitol Boulevard, Tumwater
P.O. Box 47440
Olympia WA 98504 -7440
Lynn Peterson 360- 357 -2600 J FAX: 360- 357 -2601
Secretary of Transportation TTY: 1- 800. 833 -6388
www.wsdot.wa.gov
February 5, 2015
City of Yelm
Attn: Tami Merriman
Yelm Community Development Department
105 Yelm Avenue West
Yelm, WA 98597
RE: Yelm East Gateway Planned Action Draft Environmental Impact Statement
(DEIS)
Dear Ms. Merriman:
Thank you for the opportunity to comment on the city's Yelm East Gateway Planned
Action Draft Environmental Impact Statement (DEIS) and Traffic Impact Analysis
(TIA). We offer the following comments as the city finalizes its planned action and
develops the associated implementation measures.
WSDOT interests and concerns revolve around the impacts and mitigation measures
identified in the planned action DEIS; how those measures relate to the state facilities
and how they will be implemented. WSDOT interest is that whatever mitigation and
implementation strategy the city takes; it adequately addresses impacts to the state
transportation system. WSDOT generally evaluates impacts on a case -by -case basis
to assess and mitigate reasonable and proportionate impacts on the state highway that
result from proposed development. Our concern is that the planned action DEIS
include sufficient details for the state facility to assess mitigation requirements which
adequately substitute for the case -by -case evaluation typically done under SEPA.
Page 14, Yelm Avenue (SR 507) /Grove Road, 2nd paragraph: WSDOT is advocating
for a roundabout-and not a signal at Grove Road. This should be made explicitly
clear. Page 30 (Section 6.4.13) of the TIA, the second paragraph of this section is
more explicit in its wording about the roundabout and should be mimicked in DEIS.
Pages 42, Figure 8 Existing PM Peak Hour Traffic Volumes and Page 47, Figure 11
Projected 2020 PMpeak hour traffic volumes preferred alternative: The turning
movement numbers on these pages are too small to read (Pixelated). Recommend
that these figures include a reference to the applicable page number in Appendix A,
Traffic Impact Analysis where the volumes can be read.
Is there a reason the most easterly approach is only right out? Why not right in and
right out? If possible, joint access with adjacent property owners at the common lot
line should be considered.
February 5, 2015
Ms. Tami Merriman
Page - 2
Appendix A, Traffic Impact Analysis (TIA), Page 21 (Section 5.2.1 2020 Horizon):
What is the source of the growth rates; this should be clarified in the document.
Appendix A, Traffic Impact Analysis (TIA): Traffic mitigation seems to be vague. It
is clear when no mitigation is required (section 6.5), but other sections should be
clarified that the proposed solutions are traffic mitigation measures. WSDOT
discussed the potential of a roundabout at Walmart Boulevard, the discussion is
lacking in the text.
Why wasn't a four -lane divided highway with multilane roundabouts at both Grove
Road Intersection and Wal -Mart Blvd considered? Both Figure 12 and Figure 13
(Year 2020 and Year 3035 Channelization Plans) of the TIA essentially depict a four -
lane divided facility between the two intersections. Converting the Wal -Mart Blvd
from Signal Control to an Urban Multilane Roundabout would reduce all fatal and
injury collisions by 66% per WSDOT.Crash Modification Factor (CMF) "Short
List ", Revised October 10, 2014. WSDOT is beginning to use Highway Safety
Manual excel software to perform no build and build alternative safety analysis in
Interchange Justification Reports, but the tool could be helpful in comparing safety
impacts within the Gateway's study limits (Between Yelm Creek and Wal -Mart's
second access). In planning studies, WSDOT typically compares signal with
channelization alternatives against roundabout alternatives in order to determine
mobility and safety performance.
WSDOT is interested in how mitigation measures will be implemented, particularly
implementing improvements to address potential impacts to state facilities. It is our
understanding that under this process, the city's adoption of the planned action would
exempt future Gateway developments from individual review, substituting the case -
by -case evaluation that WSDOT would normally do under State Environmental
Policy Act. We are interested in how mitigation measures for state facilities will be
addressed.
The planned action mitigation threshold and measures seem unclear on how they will
effectively implement the discussed improvements. The DEIS on page 51 identifies
a cumulative traffic threshold within the Yelm East Gateway area to be 2,000 new
PM peak hour trips. While in the TIA portion of the DEIS (Section 8.4 Phasing of
On -Site and Off -Site Traffic Mitigation Improvements) identifies a threshold of 25
PM peak hour trips of development traffic (new -to- network and pass -by) using
various legs of the intersection and/or the fourth developer to trigger construction of
a roundabout. Are these thresholds mutually exclusive? What is the threshold for
triggering the right turn only accommodations for the right in channelization, which
is not discussed? How will WSDOT be kept informed as the area is developed? How
the mitigation is to be implemented should be clearly spelled out since this plan will
be taking the place of any individual development SEPA reviews.
February 5, 2015
Ms. Tami Merriman
Page - 3
Will there be provisions to revisit the plan's recommendations at some future
threshold or timeline? The concern is that, when development does occur, it could
take the form of something very different than what the DEIS and preferred
alternative assumes. If so, this would require a new look at mitigation described in
the EIS.
Thank you again for the opportunity to comment on the Yelm East Gateway Planned
Action Draft DEIS. WSDOT is supportive of the city's proactive approach and look
forward to working with the city on this matter. If you have any questions related to
this letter, please contact Dale Severson of my staff at 357 -2736 or
seversd@wsdot.wa.gov.
Sincerely,
Denms Engel,
Planning Manager
cc: Dale Severson, WSDOT Olympic Region Development Services