CITY OF OLYMPIA AND NISQUALLY INDIAN TRIBE

Photograph Courtesy of Nisqually Land Trust

CITY OF OLYMPIA AND NISQUALLY INDIAN TRIBE

McAllister Wellfield Mitigation Plan

Nisqually Indian Tribe

DECEMBER 2010

(Updated and resubmitted from September 2008)

City of Olympia and Nisqually Indian Tribe

McAllister Wellfield Mitigation Plan

December 2010 (Updated and resubmitted from September 2008)

For more information, contact:

Rich Hoey, P.E. Director of Water Resources

City of Olympia, Public Works Department (360) 753-8495

Fax (360) 753-8087 E-mail: [email protected]

Joe Cushman Planning Director

Nisqually Indian Tribe (360) 456-5221

Fax (360) 456-4838 E-mail: [email protected]

To request this Plan in an alternate format, please call 360.753.8769 or 360.753.8270 (TTY) during normal office hours to arrange for a reasonable accommodation, or mail a written request to

Heather Reed, City of Olympia, P.O. Box 1967, Olympia, WA 98507-1967

The City of Olympia is committed to the non-discriminatory treatment of all persons in employment and the delivery of goods and services.

McAllister Wellfield Mitigation Plan i City of Olympia and Nisqually Indian Tribe

Table of Contents 1.0 Introduction

1.1 Olympia’s Existing Source – McAllister Springs ......................................................... 8 1.2 Nisqually Indian Tribe’s Existing Source ..................................................................... 9 1.3 McAllister Wellfield – Background .............................................................................. 9 1.4 City of Olympia Water Right Change Applications ................................................... 12 1.5 Planned Wellfield Facilities and Operations ............................................................... 13

1.5.1 Phase I of Well Development Schedule ......................................................... 14 1.5.2 Phase II of Well Development Schedule ........................................................ 14 1.5.3 Phase III of Well Development Schedule ...................................................... 14

2.0 Predicted Water Resource Impacts

2.1 Water Bodies of Interest ............................................................................................. 15 2.2 Numerical Model of Groundwater System ................................................................. 16

2.2.1 Model Accuracy for Predicting Small Depletions .......................................... 19 2.3 Model Results – McAllister Wellfield ........................................................................ 19

2.3.1 Predicted Impacts on Modeled Surface Water Bodies ................................... 20 2.3.2 Cumulative Model Results ............................................................................. 22 2.3.3 Potential Impacts on Nearby Wells ................................................................ 23

3.0 Mitigation Alternatives, Phasing and Approach

3.1 Mitigation Alternatives Screening Process ................................................................. 27 3.2 Olympia and Nisqually Tribe Shared Mitigation Approach ....................................... 29 3.3 Phasing of Mitigation Program ................................................................................... 29 3.4 Stewardship ................................................................................................................. 30

4.0 Nisqually Indian Tribe’s Mitigation Program

4.1 Tacoma Power Element .............................................................................................. 31 4.2 Groundwater Protection Zone Element ....................................................................... 32

4.2.1 Groundwater Protection Zone Ordinance ....................................................... 32 4.2.2 Hydrogeology and Expected Benefits ............................................................ 33 4.2.3 Groundwater Model Results ........................................................................... 34 4.2.4 Expected Benefits from the Groundwater Protection Zone ............................ 34

4.3 Habitat Restoration Element ....................................................................................... 35 4.3.1 Ohop Creek Restoration ................................................................................. 36 4.3.2 Muck Creek Restoration ................................................................................. 37 4.3.3 Other Restoration Projects in the Nisqually Watershed ................................. 37

5.0 City of Olympia’s Mitigation Program

5.1 McAllister Creek ......................................................................................................... 40 5.2 Lake Saint Clair .......................................................................................................... 41 5.3 Woodland Creek Basin ............................................................................................... 43

5.3.1 Olympia's Predicted Depletions ..................................................................... 43

McAllister Wellfield Mitigation Plan ii City of Olympia and Nisqually Indian Tribe

5.3.2 Predicted Depletions and Mitigation Quantities for Regional Mitigation in Woodland Creek Basin ............................................................................... 43

5.3.3 Regional Flow Mitigation for the Woodland Creek Basin: Reclaimed Water Infiltration ............................................................................................ 45

5.3.4 Regional Non-flow Mitigation for Woodland Creek: Riparian Land Protection ........................................................................................................ 50

5.4 Deschutes River Basin ................................................................................................ 52 5.4.1 Olympia's Predicted Depletions ..................................................................... 52 5.4.2 Predicted Depletions for Olympia, Lacey and Yelm in the Deschutes

River Basin ..................................................................................................... 52 5.4.3 Flow Mitigation Using Water Rights Acquisitions ........................................ 53 5.4.4 Non-Flow Land Acquisition and Habitat Restoration .................................... 59 5.4.5 City of Olympia Share of Non-Flow Mitigation ............................................ 65

5.5 Groundwater Drawdown Effects ................................................................................ 65

6.0 Conclusion .............................................................................................................................. 67

References

Tables

Table 1-1 McAllister Springs and Abbott Springs Water Rights Quantities ..................................... 12 Table 1-2 McAllister Wellfield Monthly Pump Rates at Full Production ......................................... 13 Table 1-3 Preliminary Schedule of Well Development ..................................................................... 14 Table 2-1 Regulatory Status of Key Water Bodies in WRIAs 11 and 13 ......................................... 15 Table 2-2 Annual and Summer Depletions Predicted for Surface Water Bodies .............................. 21

Table 3-1 Anticipated Implementation of Mitigation Actions .......................................................... 30 Table 4-1 Predicted Depletions at 3 MGD Allotment ....................................................................... 35 Table 5-1 Regional Mitigation Program: Model-Predicted Depletions for Woodland Creek

Basin .................................................................................................................................. 44 Table 5-2 Regional Mitigation Program: Calculated Mitigation Quantities for Woodland Creek Basin

........................................................................................................................................... 44 Table 5-3 Maximum Estimated Changes to Lake Levels .................................................................. 45 Table 5-4 Regional Mitigation for Woodland Creek: Mitigation with Reclaimed Water ................. 48 Table 5-5 Regional Mitigation Program: Model-Predicted Depletions for Deschutes River

Basin ............................................................................................................................53 Table 5-6 Regional Package of Deschutes River Water Right Acquisitions ..................................... 54 Table 5-7 Deschutes Flow Mitigation by Reach for Closure Period – McAllister Wellfield Predicted

Depletions ......................................................................................................................... 55 Table 5-8 Winter Flow Depletion Impact Calculation for Cities of Olympia, Lacey and Yelm ....... 60 Table 5-9 Deschutes Property Acquisition and Habitat Restoration: Schedule for Completing

Actions .............................................................................................................................. 65

McAllister Wellfield Mitigation Plan iii City of Olympia and Nisqually Indian Tribe

Table 6-1 Summary of Partnered Mitigation Strategies .................................................................... 68 Table 6-2 Proposed Implementation of Closure Period Flow Mitigation for Modeled Water Bodies

by Phase (AFY) ................................................................................................................. 69 Table 6-3 Proposed Implementation of Non-Flow Mitigation for Modeled Water Bodies by

Phase ................................................................................................................................. 69 Figures

Figure 1-1 Location of McAllister Springs, McAllister Wellfield, and Other Key Features ............... 8 Figure 1-2 Map of McAllister Wellfield and Vicinity ........................................................................ 10 Figure 1-3 Major Features of McAllister Groundwater Model .......................................................... 11 Figure 2-1 Locations of McAllister Wellfield Model Water Budget Analysis Reaches .................... 18 Figure 2-2 Predicted Groundwater Drawdown in the Shallow Aquifer (Model Layer 3) in the Vicinity

of McAllister Wellfield ..................................................................................................... 24 Figure 2-3 Predicted Groundwater Drawdown in Model Layer 6 in the Vicinity of McAllister

Wellfield ............................................................................................................................ 25 Figure 2-4 Predicted Groundwater Drawdown in Model Layer 7 in the Vicinity of McAllister

Wellfield ............................................................................................................................ 26 Figure 4-1 Nisqually Reservation Groundwater Protection Zone ...................................................... 33 Figure 4-2 Lower Ohop Valley Restoration Project ........................................................................... 37

Figure 5-1 Groundwater Flow Dynamics – Transition from Springs to Wellfield ............................. 41 Figure 5-2 Location of Surface Water Right 4436 (Schoepfer) .......................................................... 42 Figure 5-3 Baseflow Effects – Current Condition Before Reclaimed Water Infiltration .............. 46 Figure 5-4 Baseflow Effects – Future Condition with Reclaimed Water Infiltration .................... 47 Figure 5-5 Riparian Protection Property on Fox Creek .................................................................51

Figure 5-6 Deschutes River Flow Mitigation ..................................................................................... 57 Figure 5-7 Proposed Restoration Actions at Smith Ranch (from Anchor QEA 2010) ....................... 63

Appendices A. Memorandum of Agreement between the City of Olympia, Washington and the Nisqually

Indian Tribe. B. Washington State Department of Health letters dated January 31, 2000 and November 10, 2004

regarding City of Olympia, ID #634506, Thurston County, Public Health Priority for Water Rights Processing and Public Health Concern Regarding Application for Ground Water Rights.

C. S. S. Papadopulos & Associates, Inc., Technical Memorandum

Technical Memorandum dated August 18, 2008. McAllister Wellfield Hydrologic Impacts Analysis.

D. Woodland Creek/Tri-Lakes Mitigation Actions Interlocal Agreement between the City of Lacey and the City of Olympia for Water Rights

Mitigation.

McAllister Wellfield Mitigation Plan iv City of Olympia and Nisqually Indian Tribe

Woodland Creek Reclaimed Water Infiltration Facility Analysis, consulting report from Pacific Groundwater Group, July 2010.

LOTT Reclaimed Water Distribution Agreement No. 1 with the City of Olympia. Nisqually Planning Unit Letter of Support. Fromuth Property: Statutory Warranty Deed, aerial photo, letter from Ecology, Letter from

Lacey. E. Deschutes River Mitigation Actions

Interlocal Agreements between the Cities of Olympia, Lacey, and Yelm for a Water Rights Acquisition Strategy – Phases I, II and Amendment No. 1 to Phase II.

Water Rights Acquisition o Smith Beneficial Use Analysis (BUA) and Purchase and Sale Agreement for Water

Rights and Amended Purchase and Sale Agreement. o Jensen BUA and Option Agreement for Water Rights Purchase.

Property Acquisition and Habitat Restoration o Initial Acquisition and Restoration Assessment of the Smith Ranch (Consultant

report produced by Anchor Environmental, September 2010). F. Olympia Water Right Change Applications

McAllister Water Right Certificate 8030 McAllister Water Right Certificate S2-01105C Abbott Water Right Permit 10191

G. Design Evaluation for the Planned McAllister Wellfield, Golder Associates, Inc. Technical

Memorandum dated September 10, 2007. H. Nisqually River Mitigation Actions

Regulatory Status of the Nisqually River o Letters Regarding Tacoma Power Element o Habitat Restoration Element Details o Groundwater Protection Zone Ordinance o Groundwater Modeling Memos

I. Lake Saint Clair Water Right Documents

Water Right Summary and Proof of Beneficial Use Report for whispering Firs Farm, consulting report by WestWater Inc, July, 2008.

Hydrologic Assessment , SSPA Statutory Warranty Deed and Certificate of Water Right Trust Water Right Letter from City of Olympia to Washington State Department

of Ecology (July 10, 2008) Trust Water Right Letter from Washington State Department of Ecology to City of

Olympia (July 29, 2008) Extension Request Letter from City of Olympia to Washington State Department of

Ecology (September 3, 2009) Extension Approval Letter from Washington State Department of Ecology to City of

Olympia (February 18, 2010)

McAllister Wellfield Mitigation Plan v City of Olympia and Nisqually Indian Tribe

Second Extension Request Letter from City of Olympia to Washington State (September 16, 2010)

Second Extension Approval Letter from Washington Department of Ecology to City of Olympia (November 15, 2010)

Abbreviations and Acronyms

AFY acre-feet per year BUA Beneficial Use Analysis BNSF Burlington Northern Santa Fe Railroad CDM Camp Dresser and McKee cfs cubic feet per second City City of Olympia DOH Washington State Department of Health Ecology Washington State Department of Ecology FERC Federal Energy Regulatory Commission gpm gallons per minute MGD Million gallons per day MOA Memorandum of Agreement NRCC Nisqually River Coordinating Committee RM River Mile SEPA State Environmental Policy Act SPSSEG South Puget Sound Salmon Enhancement Group SSPA S.S. Papadopulos & Associates Tribe Nisqually Indian Tribe USGS U.S. Geological Survey WAC Washington Administrative Code WRIA Water Resources Inventory Area

McAllister Wellfield Mitigation Plan vi City of Olympia and Nisqually Indian Tribe

McAllister Wellfield Mitigation Plan 7 City of Olympia and Nisqually Indian Tribe

Section 1 Introduction

The City of Olympia (City) and Nisqually Indian Tribe (Tribe) have jointly developed this McAllister Wellfield Mitigation Plan in support of the City’s applications for change of its McAllister Springs and Abbott Springs water rights. On October 16, 1995, the City applied for a change of its water rights with the objective of creating a new McAllister Wellfield upgradient of the existing Springs.

Under a Memorandum of Agreement (MOA) signed on May 14, 2008, the City and Tribe now intend to jointly develop the McAllister Wellfield as a more protected and productive water source for both communities. The agreement also establishes a commitment from both parties to form a stewardship coalition aimed at protecting water resources in the Nisqually Watershed, as well as a commitment to ensure permanent protection of the McAllister and Abbott Springs properties.

This Mitigation Plan has been developed consistent with the MOA. The MOA is included in Appendix A.


1.1 Olympia’s Existing Source – McAllister Springs

The City's primary source of water is McAllister Springs, located at the headwaters of McAllister Creek in northeastern Thurston County (Figure 1-1).

Figure 1-1. Location of McAllister Springs, McAllister Wellfield, and Other Key Features

McAllister Springs has served the City effectively since the 1940s. Water emerging at the Springs is of high quality for drinking water purposes. However, the Springs location is vulnerable to potential contamination from:


The Burlington Northern Santa Fe (BNSF) rail line, which is immediately upgradient of the Springs. In the event of a fuel or hazardous chemicals spill, the aquifer that supports the Springs would likely be compromised.

The configuration of the Springs and adjacent pond make the water susceptible to microbial contamination at certain times of year. This vulnerability can be addressed, but would require construction of costly new treatment facilities.

Sea water intrusion, as sea levels rise in the coming century.

Also, the City has a reduced ability during the dry summer months to take advantage of its full water right without affecting water quality. The Washington State Department of Health (DOH) has long encouraged the City to develop a reliable alternate source that is more protected from potential water quality problems. This is documented in correspondence from DOH to the Washington State Department of Ecology (Ecology) requesting expedited processing of the City’s water rights change applications (see Appendix B). The City also views this project as a high priority for protection of public health in its water service area.

1.2 Nisqually Indian Tribe’s Existing Source

The Tribe currently relies on shallow, low-producing wells in three main wellfields (Cuyamaca, Leschi, and Nisqually) on the Nisqually Reservation (Figure 1-1). All of the wellfields are in fairly close proximity to the Nisqually River. The Tribe’s wells withdraw water from an unconfined groundwater system, characterized by layers of glacial till and outwash. These geologic materials are not consistently saturated and do not provide a reliable source of water. The first consistent water-bearing unit below the reservation is the Kitsap Formation, which is in contact with the Nisqually River in some areas. In other areas, this formation is in contact with the valley wall and forms springs such as Kalama Spring. The wells are low-producing and susceptible to contamination from land activities and nearby surface water.

Over the past several years, the Tribe has similarly evaluated options to secure a more sustainable and protected water source for its growing community. The Tribe has also sought options to reduce impacts of Tribal pumping on the Nisqually River.

1.3 McAllister Wellfield – Background

After considering numerous options to address water quality issues, in the mid-1990s the City determined that the best solution was to move the water production site from McAllister Springs to groundwater wells at an upgradient location, named the McAllister Wellfield. The new wellfield is approximately 0.8 miles southeast of McAllister Springs (Figure 1-2).


Figure 1-2. Map of McAllister Wellfield and Vicinity The McAllister Wellfield is also close to the Nisqually Reservation, lying approximately 1 mile to the west. The McAllister Wellfield, which taps a large aquifer with very high quality water, would also provide a more reliable source of water for the growing Tribal community. Current and future pumping from reservation wells, which are closer to the Nisqually River than the McAllister Wellfield wells, result in a higher relative impact on the Nisqually River. Pumping farther from the river, such as at the McAllister Wellfield, would spread the stress of pumping over a larger area and reduce the impact to the river.

Over the past decade, the City has evaluated the effects of shifting withdrawal of water from a spring source to a groundwater source by studying the predicted impacts on surface water bodies and other wells in the McAllister Wellfield area. The City has spent over ten years and more than $1 million to develop a complex and sophisticated numerical groundwater model to characterize the hydrogeologic dynamics of the area, including interactions with surface water bodies (Camp Dresser and McKee – CDM 2002a, 2002b). The modeling analyses indicate differing magnitudes of hydraulic interaction between the McAllister Gravel aquifer and surface water bodies in both Water Resource Inventory Areas (WRIA) 11-Nisqually and 13-Deschutes. The analysis also included simulated predictions of the impacts of pumping at the McAllister Wellfield on these surface water bodies. Section 2 of this plan provides a more detailed discussion of these predictions. The City has conducted several different runs of the model in recent years, refining and updating it, to fully understand the degree of predicted impacts. The most current model results (Appendix C) – summarized in Section 2 of this plan – show that reducing or eliminating production at McAllister Springs will significantly benefit McAllister Creek instream flows. Flows in this impaired stream are predicted to increase, especially during July, which is typically the driest month.


Groundwater pumping at the McAllister Wellfield is also predicted to cause differing magnitudes of small depletions of flow in other surface water bodies in the Nisqually River and Deschutes River watersheds. The most significant impacts are predicted to occur in the Nisqually River. Flow depletions in other water bodies are generally small enough to fall at or below the accuracy limit of the model. Water bodies evaluated include:

The Nisqually River Lake Saint Clair Hicks, Long, and Pattison Lakes and associated wetlands (the Tri-Lakes Complex) Woodland Creek The Deschutes River

The WRIA boundaries and other major features of the McAllister groundwater model are shown in Figure 1-3.

Figure 1-3. Major Features of McAllister Groundwater Model

This mitigation plan presents the City’s and Tribe’s strategies to address predicted impacts to these surface water bodies and groundwater in the Nisqually River and Deschutes River watersheds. It identifies mitigation actions the City and Tribe will carry out as a required condition of the water right change applications described in Section 1.4 below.

Middle

Deschutes


This plan promotes sustainable management of water resource impacts while supporting the public health objective of moving to the more protected groundwater wellfield. Given that the predicted impacts of pumping at the McAllister Wellfield cross jurisdictional boundaries, the City has also joined with the City of Lacey and the City of Yelm to expand its multiparty approach to manage and mitigate water resources within WRIA 11 and WRIA 13. The Cities of Olympia, Lacey, and Yelm have entered into several formal agreements that define how mitigation responsibilities will be shared. These shared mitigation responsibilities are explained in Section 5. The City’s Interlocal Agreements with Lacey and Yelm are provided in Appendices D and E.

1.4 City of Olympia Water Right Change Applications

Since the 1940s, the City has produced water at McAllister Springs under two water rights.

Certificate No. 8030, which allows withdrawal of up to 25 cfs (January 10, 1941). Certificate No. S2-001105C, which allows withdrawal of up to 5.33 cfs (January 10, 1949).

The City also holds a water right permit for Abbott Springs, a large natural spring located north of McAllister Springs and part of the McAllister Creek complex (Figure 1-1).

Permit No. 10191, which allows withdrawal of up to 10 cfs (June 8, 1955).

Equivalent quantities of water allowed by these water rights are provided in Table 1-1.

Table 1-1 McAllister Springs and Abbott Springs Water Rights Quantities

Water Right Cubic feet per

second (cfs) Million gallons per day (MGD)

Gallons per minute (gpm)

Acre-feet per Year (AFY)

McAllister Springs 8030 25 16.16 11,220 18,0991

McAllister Springs

S2-001105C 5.33 3.44 2,392

782 (primary)

3,088 (supplemental)

Abbott Springs 10191 10 6.46 4,488 72402

TOTAL 26.06 1 The McAllister Springs Water Right Certificate 8030 does not specify Qa. The AFY shown are based on 25 cfs x 24 hrs/day x 365 days.

2 The Abbott Springs Water Right Permit 10191 does not specify Qa. The AFY shown are based on 10 cfs x 24 hrs/day x 365 days.

In 1995, the City submitted to Ecology a water rights change application to transfer its existing water rights from McAllister Springs and Abbott Springs (totaling 26.06 MGD) to the Wellfield. The change applications are for a new point of withdrawal under each of the three water rights. Appendix F contains the water right change applications for the McAllister Springs and Abbott Springs water rights. In discussions with Ecology’s Southwest Regional office, both Ecology and City staff agreed to the concept that the change application for an additional point of withdrawal is appropriate because the groundwater model demonstrates that the McAllister Wellfield will draw water from the same aquifer system that feeds McAllister Springs and Abbott Springs.

In April 1998, the City purchased the 20-acre McAllister Wellfield site and development rights to an additional adjacent 100 acres. Consultants installed two test wells and conducted aquifer pumping tests which verified that the wellfield location is capable of producing the full 26.06 MGD with relatively minimal drawdown (Appendix G, Section 5.0).


The MOA between the City and Tribe (Appendix A) calls for the Tribe to receive a portion of the transferred Abbott Springs water right, to be conveyed by the City either in the form of a lease or deed. The MOA also calls for the City to grant an exclusive, perpetual easement of up to two acres to the Tribe for construction and operation of waterworks facilities. The agreement also outlines responsibilities for required mitigation associated with the applications. These mitigation responsibilities are discussed further in Sections 4 and 5.

This mitigation plan applies only to the use of the McAllister Springs water right certificates and the Abbott Springs water right permit, and does not involve other water rights held by the City. Given the large scope of the McAllister Wellfield project, the City will be conducting a State Environmental Policy Act (SEPA) review of the project over the next several months.

1.5 Planned Wellfield Facilities and Operations

As shown in Figure 1-1, the planned McAllister Wellfield is located approximately 0.8 mile southeast of McAllister Springs, within Township 18 North, Range 1 East Section 29. The waterworks will be comprised of approximately six wells with necessary pumping facilities and conveyance infrastructure. The wells will draw groundwater from the McAllister Gravel Aquifer with most of the intake occurring near the lower end of the screened interval, anticipated to be approximately 180 to 280 feet below ground surface.

The anticipated pumping schedule at McAllister Wellfield full build-out production levels is shown in Table 1-2.

Table 1-2 McAllister Wellfield Monthly Pump Rates at Full Production

Month PW-25, 26, 27,281 TW-22 PW-24 Total January 1,927 1,349 1,790 10,849 February 1,790 1,253 1,662 10,075 March 1,740 1,218 1,616 9,791 April 1,747 1,223 1,623 9,836 May 1,445 1,012 1,342 8,135 June 2,099 1,469 1,949 11,813 July 3,109 2,177 2,888 17,501

August 2,357 1,650 2,189 13,265 September 1,657 1,160 1,539 9,325

October 1,799 1,259 1,670 10,124 November 1,918 1,343 1,782 10,797 December 1,906 1,334 1,770 10,729

1 Pump rate per well in gpm. Source: Technical Memorandum: McAllister Wellfield Hydrologic Impacts Analysis. S.S. Papadopulos

& Associates, Inc., August 18, 2008 (Appendix C). The City and Tribe intend to develop the Wellfield in three phases. Table 1-3 shows the expected schedule for developing the wellfield and the corresponding production needs at each phase.


Table 1-3 Preliminary Schedule of Well Development

Phase

Expected Completion Date

(approximate) Maximum Production

(MGD) Cumulative Proportion of

Build-out

Phase I 2011-2014 17 65%

Phase II 2014-2030 20.1 (19.6 for Olympia

and 0.5 Tribe)

77%

Phase III 2030-2050 26.06 (23.06 for Olympia and

3.0 for Tribe)

100%

1.5.1 Phase I of Well Development Schedule

Phase I production is targeted for no later than October 2014, when the City plans to have completely transitioned its pumping from McAllister Springs to the McAllister Wellfield. Under the federal Safe Drinking Water Act Long Term 2 Enhanced Surface Water Treatment Rule, the City must install costly additional disinfection treatment at McAllister Springs by October 2014 (assuming a 2-year extension is granted by DOH) or develop a new source of supply. During Phase I, only 65 percent of the full build-out production volume is anticipated to be needed (to support the City’s approximate current demand) and will be supported by the McAllister Springs water right only. None of the Abbott Springs water right will be utilized during Phase I.

Following the transfer of production to the McAllister Wellfield at the end of Phase I, McAllister Springs will be taken out of service. The City and Tribe will enter into good faith negotiations on the future use of the McAllister Springs and Abbott Springs properties with intent to ensure a perpetual state of conservation for those properties. The Tribe has strong cultural and spiritual connections to the springs, known to the Tribe as “Medicine Springs.”

1.5.2 Phase II of Well Development Schedule

Phase II production is anticipated some time during 2014-2030, when the Tribe will begin producing from their well or wells located at the McAllister Wellfield. Production will also be increased as necessary to meet an anticipated additional demand by the City. Production is estimated at 19.6 MGD for Olympia (the full quantity of the McAllister Springs water rights) and 0.5 MGD for the Tribe (partial quantity of the Abbott Springs water permit), which amounts to about 77 percent of the full build-out production rate.

1.5.3 Phase III of Well Development Schedule

Phase III production reflects the long-term development under the full Abbott Springs water right to meet the City and Tribe’s 50-year planning horizon and would be completed some time during 2030-2050. By about 2058, the City and Tribe expect their service areas to have grown, along with a gradual increase in production to the full authorized amount of 26.06 MGD, supported by both McAllister Springs and Abbott Springs full water rights. Maximum production at full build-out will be 23.06 MGD for Olympia and 3 MGD for the Tribe.


Section 2 Predicted Water Resource Impacts This section describes the method used to identify water resources predicted to be impacted by pumping at the McAllister Wellfield. The regulatory appropriation status of each water body is provided, as are the predicted surface water impacts relative to the accuracy of the groundwater model applied.

2.1 Water Bodies of Interest

Groundwater modeling identified potentially impacted surface water bodies, which are listed in Table 2-1, along with the regulatory status of each under the State Water Code.

Table 2-1 Regulatory Status of Key Water Bodies in WRIAs 11 and 13

Water Body Regulatory Status (Chapters 173-511 and 173-513 WAC)

WRIA 11 (Nisqually River Watershed) Lower Nisqually River1 (RM2 4.3 to RM 12.6) Control Station: “New gage” at RM 4.3

Open year round. New appropriations subject to instream flows of 600-900 cfs varying seasonally.

Bypass Reach of Nisqually River (between RM 12.6 – RM 26.2) Control Station: 12-0895-00 at RM 21.8

Closed to new appropriations June 1 – October 31 (370-500 cfs varying seasonally). New appropriations subject to instream flows of 600 cfs in remaining months.

Middle Nisqually River (from RM 26.2 – approximately RM 39.9) Control Station: 12-0884-00 at RM 32.6

Closed to new appropriations June 1 – October 31 (600-800 cfs varying seasonally). New appropriations subject to instream flows of 700-900 cfs in remaining months.

Upper Nisqually River (from approximately RM 39.9 to headwaters including all tributaries) Control Station: 12-0825-00 at RM 57.8

New appropriations subject to instream flows of 300-650 cfs varying seasonally.

McAllister Creek Closed to new appropriations (year round). Lake Saint Clair Closed to new appropriations (year round). Yelm Creek Closed to new appropriations (year round). WRIA 13 (Deschutes River Watershed) Deschutes River (from confluence with Capitol Lake upstream to RM 41)

Closed to new appropriations April 15 – November 1. New appropriations subject to instream flows in remaining months (150-400 cfs, varying seasonally).

Woodland Creek and all tributaries Closed to new appropriations (year round). Long Lake Closed to new appropriations (year round). Patterson Lake (a.k.a. Pattison Lake) Closed to new appropriations (year round). Hicks Lake Closed to new appropriations (year round).

1 The Lower Nisqually River includes modeled reaches 1, 2, and 3 as discussed in this section.

2 River Mile.

To analyze the effects of groundwater pumping on the flow of the largest rivers, the Nisqually River and Deschutes River were subdivided into specific reaches. Modeled reaches defined for the Nisqually River begin at River Mile 4.3 (RM 4.3) and include Reaches 1, 2 and 3, as well as the Upper Nisqually. Modeled reaches defined for the Deschutes River include the Upper Deschutes, the Middle Deschutes and the Lower Deschutes (Figure 2-1). An earlier version of the groundwater


model did not include the Middle Deschutes Reach due to the believed presence of a geologic boundary to the east of the river in the form of a basalt intrusion (Drost et. al, 1999). After consultation with the Squaxin Island Indian Tribe, the groundwater model was modified to incorporate the results of additional hydrogeologic information available in this area. As a result, the groundwater model indicates McAllister Wellfield may impact the Middle Deschutes Reach.

In addition to the water bodies listed in Table 2-1, other water resources that are of interest for this plan include aquifers tapped by wells in the vicinity of the McAllister Wellfield, the Tribe's community water system wells, the Kalama Creek Springs (located near the west bank of the Nisqually River, which are used to supply the Tribe's Kalama Creek Hatchery), and Silver Springs. State law related to appropriations of new water rights does not identify these resources for any specific restrictions such as those listed in Table 2-1. However, the groundwater model was used to assess potential impacts.

2.2 Numerical Model of Groundwater System

Impacts to water resources identified in Section 2.1 were investigated using a numerical groundwater model designed to simulate the response of the surface water and groundwater system to pumping at the new McAllister Wellfield site. The model was originally developed for the City by Camp Dresser and McKee (CDM, 2002a and 2002b) to evaluate potential hydrologic impacts to surface water bodies in the vicinity of the proposed Wellfield. The model is based on a pre-existing numerical model originally developed by the U.S. Geological Survey (USGS) (Drost et al., 1999). However, the model was significantly refined by CDM and more recently by Golder Associates and SSPA. Model refinements include:

Updating the hydrogeologic interpretation based on new boring logs; Representing the actual elevation of hydrogeologic units in the model; Modeling the aquifers for both saturated and unsaturated conditions (variable saturation); Refining the model grid for more accuracy in model results particularly in the area of

pumping wells; Updating pumping rates for the Cities of Olympia, Lacey and Yelm; Representing the Middle Reach of the Deschutes River as in contact with the regional

aquifer; Adding hydrologic features not included in the USGS model including Kalama Spring,

Silver Springs, Silver Creek, and Yelm Creek; and Calibration of the model to steady-state and transient data.

These changes were made in cooperation with the Cities of Olympia, Lacey and Yelm, and through consultation with the Nisqually and Squaxin Island Tribes. The changes result in a more realistic and reliable model for making estimates of the impact of pumping on surface water bodies.

The computer model simulates the hydrologic cycle in the McAllister study area. It is the most up-to-date and scientifically sound method of predicting impacts that could result from groundwater withdrawals. The scientists who have built, and run this model orient towards a “conservative” approach to modeling. This means that results tend more toward over-prediction of surface water depletions. In the case of this specific model, there are features that result in over-prediction of surface water depletions due to model construction.


For purposes of this mitigation plan, hydrologic impacts are defined as either reduced groundwater inflow to a surface water body, or increased loss from a surface water body following full development of the McAllister Wellfield. Either of these conditions constitutes potential surface water depletion. Surface water depletion is analyzed by simulating a set of hydrologic conditions and conducting a water budget analysis on the results of the simulation. The difference between the water budgets of surface water bodies between a base condition and a future condition constitutes the predicted surface water depletion.

Figure 2-1 identifies specific reaches of the Nisqually and Deschutes Rivers, and other surface water bodies for which depletions were predicted in the modeled analysis. The model covers an area approximately 15 miles (north-south) by 8 miles (east-west) in extent. It extends from the Deschutes River on the west to the Nisqually River on the east, and from McAllister Springs upstream to a point above McKenna on the Nisqually River and to approximately Lake Lawrence in the Deschutes River watershed. Within this area, the model grid ranges from 100-foot spacing in the vicinity of the wellfield to 1,000-foot spacing in other areas. The model has nine distinct geologic layers including aquifers and aquitards. It simulates flow through the aquifers, interactions between aquifers, flow gradients, and recharge and discharge to streams and springs. The rivers in this model, Nisqually and Deschutes, are modeled as no-flow boundaries for the purposes of model development. This feature of the model does not accurately reflect “real” conditions on the ground, where water would flow across river boundaries. This is one area where the model design can lead to over-predictions of depletions along river boundaries. Ecology’s Southwest Regional Office hydrogeology staff has been consulted on the content and development of the model.


Figure 2-1. Locations of McAllister Wellfield Model Water Budget Analysis Reaches

The City retained S.S. Papadopulos & Associates (SSPA) for groundwater modeling services associated with this project. The version of the model used by SSPA for this project is based on the original CDM model. As highlighted above, as a result of discussions over the past three years with the Cities of Olympia, Lacey and Yelm, the Tribe, and the Squaxin Island Indian Tribe, SSPA worked with Golder Associates to refine and update the model based on new data. Each time a


modification was determined necessary, the Cities coordinated closely to ensure any subsequent runs of the model accommodated the new data and associated discussions. For more information on the refinement of the model and its application, see SSPA’s August 18, 2008 Technical Memorandum on the McAllister Wellfield in Appendix C.

2.2.1 Model Accuracy for Predicting Small Depletions

At this time the McAllister Numerical Ground Water model represents the best available science for analyzing the effects of groundwater pumping and making water rights decisions for large water right requests within the model’s boundaries. However, for many of the water bodies evaluated the predicted effects are very small relative to measured stream flows and/or the groundwater inflow to each water body. Furthermore, the conservative construction of the McAllister model potentially leads to over-prediction of depletions along the model boundaries, which includes the Deschutes River and Nisqually River (see Figure 2). For example, the McAllister model boundary at the Deschutes River has “constant head” cells only in the shallow (Qva) aquifer and “no flow” cells in the middle (Qc) and deep (TQu) aquifers. In other words, no water enters the middle and deep aquifers from the area outside of the model boundary although in reality water will flow under the river and enter the basin. In the model, this will force new pumping from deeper aquifers to draw water from other boundaries, including the shallow Deschutes River boundary, and potentially result in over-estimating impacts to the river. The modelers contracted by the cities (SSPA and Golder Associates) felt it was important to define a margin of error or accuracy limit for the model. If values fall below this limit, it is not clear whether that there will be actual surface water depletions. In discussing the relative accuracy of modeling results, both modelers reported that the model has a high degree of precision, but the accuracy of the model for predicting small flow depletions in areas with large groundwater flow rates is questionable. Regarding the accuracy of the model,

“As a rule of thumb, it is advised that reaches with predicted depletions that are 1 percent or less of the total groundwater flow rate in the reach should be considered as beyond the accuracy limits of the model.” (Riley 2008)

The City and the Tribe considered the relative accuracy of the modeling results in the development of mitigation strategies proposed in this plan. Predicted depletions that are above the model accuracy limit are considered to pose greater potential for risk to the resource, and consequently more mitigation is proposed in order to provide a margin of safety. In contrast, predicted impacts that are below the accuracy limit are less accurate and less likely to actually occur.

2.3 Model Results – McAllister Wellfield

Table 2-2 lists the annual and summer depletions predicted for surface water bodies in the study area. Depletions that are at or below the model accuracy limit are denoted by an underlined value. The predicted impacts of pumping at the McAllister Wellfield are detailed in the August 18, 2008 SSPA Technical Memorandum provided in Appendix C. The Technical Memorandum evaluates potential hydrologic impacts on the surface water bodies listed in Table 2-2 due to groundwater pumping at the McAllister Wellfield. The body of this plan focuses on potential impacts to surface water bodies resulting from pumping at the McAllister Wellfield by the City and Tribe only. The Tribe’s portion of pumping at the Wellfield is included in the City’s modeled conditions.


Under the MOA (Appendix A), the City and Tribe agreed to jointly develop the McAllister Wellfield. The City’s and Tribe’s combined pump rates represent the full transfer of the McAllister Springs and Abbott Springs water rights to the McAllister Wellfield. The pump rates applied in the model to simulate potential surface water impacts after full build-out of the Wellfield reflect the maximum peak month average daily pumping rate of 25.2 MGD in the month of July. (Peak day use may be up to 26.06 MGD.) This pumping condition reflects termination of withdrawing water from the McAllister Springs and full withdrawal from the McAllister Wellfield, using the full water rights for both McAllister Springs and Abbott Springs. The rest of this Section 2 presents the results of pumping the City’s and Tribe’s wells under full build out of the McAllister Wellfield. These results reflect maximum pumping rates, at full wellfield development for the month when the greatest impacts are predicted (July).

2.3.1 Predicted Impacts on Modeled Surface Water Bodies

The predicted impacts of pumping the McAllister Wellfield wells under full build out for those water bodies included as features of the model are summarized in Table 2-2.

The locations of water bodies referred to by number in Table 2-2 are shown on Figure 2-2.

McAllister Valley

As shown in Table 2-2, moving full production from McAllister Springs to the Wellfield will result in a substantial increase in flow in McAllister Springs and McAllister Creek. The creek is an impaired surface water body and will benefit at the confluence with Medicine Creek from the predicted increase in flow of between 6.72 cfs to 18.72 cfs during the spring (May) through fall (September) months.

Lake Saint Clair is expected to realize a slight depletion of 0.12 cfs that is below the model’s accuracy limit.

Nisqually Valley

Table 2-2 shows depletions in the Nisqually Valley occurring primarily in the Lower Nisqually reach (Figure 2-2) during the month of July. Depletions of the Middle and Upper Reaches and other surface water features upstream of RM 4.3 are each below the model’s accuracy limit, contributing a total of 0.24 cfs additional depletion.

The largest flow depletion predicted by the model would occur at the downstream end of the Nisqually River, near RM 4.3. The maximum depletion predicted for the sum of the modeled reaches of the Lower Nisqually reach is 6.97 cfs. This flow rate equates to 1.2 percent of the regulatory minimum stream flow, which is 600 cfs in the lowest flow month. Data reported by Ecology in 2001 and confirmed by Tacoma Power staff suggest that it is extremely rare for flows in the Nisqually River to drop to or below 600 cfs, and are ordinarily far higher (Appendix H).


Table 2-2 Annual and Summer Depletions Predicted for Surface Water Bodies

Basin/Feature (Number denotes model

reach as shown on Figure 2-2)

Maximum Annual

Depletion (cfs)

% of Groundwater

Flow Month

Maximum Summer Depletion

(cfs)

% of Groundwater

Flow Month

McAllister Valley1

McAllister Springs (15) -13.15 - May -14.71 - Sep -30.17 - Jul -30.17 - Jul

McAllister Creek at Medicine Creek (1,15,3,5)

-6.72 - May -6.78 - Sep -18.72 - Jul -18.72 - Jul

Lake St Clair (2) 0.122 0.8% Jul-Aug 0.12 0.8% Jul-Aug

Predicted average impacts (AFY): - (7,260)

Nisqually Valley

L. Nisqually reach (20,21,22) 6.97 14.8% Jul 6.97 14.8% Jul M. Nisqually reach (9) 0.12 0.4% Jul-Aug 0.12 0.4% Jul-Aug

U. Nisqually reach (33)

00.5 0.2% All Year 0.05 0.2% All

Summer

Kalama Springs (31) 0.04 1.0% Jan-Jun,

Dec 0.03 0.8% Jun

Yelm Creek (32,34) 0.03 1.0% Jan-Jun,

Dec 0.03 0.8% Jun

Total for Nisqually Valley: Nisqually River at RM 4.3

(23,4,35,14,11) 7.21 6.4% Jul 7.21 6.4% Jul

Predicted average impacts (AFY): 3,859 Deschutes Valley

L. Deschutes reach (11,14) 0.21 0.4% Feb 0.13 0.5% Jun

M. Deschutes reach (4) 0.04 1.0% All Year 0.04 1.0% All

Summer

Silver Springs (35) 0.01 0.3% Feb, Mar 0.01 0.7% All

Summer

U. Deschutes reach (23) 0.11 0.3% Feb, Mar 0.06 0.3% All

Summer Total for Deschutes Valley:

Deschutes River at Tumwater (23,4,35,14,11)

0.37 0.3% Feb 0.24 0.5% Sep

Predicted average impacts (AFY): 195 Woodland Creek Basin

Woodland Creek (26) 0.03 0.3% Jan-Mar,

Dec 0.01 0.3%

All Summer

Tri-lakes/wetlands combined (16,17,18,19,24)

0.20 1.5% Mar 0.19 5.1% Aug-Sep

Total for Woodland Creek Basin:

Woodland Creek at Henderson

(16,17,18,19,24,26)

0.23 1.0% Mar 0.21 2.7% Sep

Predicted average impacts (AFY): 145 1 Negative depletion indicates increase in flow to the surface water body reported as maximum and minimum flow increase over the

year. Average impacts reflect increase in flow to McAllister Creek at McAllister Springs, and do not include Lake St. Clair. 2 Underlined values indicate depletions of 1% or less of baseline groundwater flow in a reach, which is considered below model

accuracy. Baseline is taken from run “20d” by Golder Associates.


As noted earlier, construction of the model tends to conservatively over-predict depletions near the rivers, which are set as non-flow model boundaries. In the Technical Memorandum presenting modeling results (Appendix C), SSPA noted that depletions in the Lower Nisqually Reach may be conservatively over-predicted due to the following two assumptions in the construction of the model:

The model assumes the McAllister Gravel Aquifer extends to and underlies the Nisqually River. It is more likely that a relatively thick layer of fine estuarine silt and sand separates the base of the river from the gravel aquifer. This fine-grained layer would tend to diminish the impact of pumping.

The Nisqually and Deschutes Rivers are located on the eastern and southwestern boundaries of the model, respectively. Both rivers are treated as a “no-flow” model boundary. In actuality, groundwater can flow under a river without discharging to the river. This is especially true for groundwater in deeper aquifers. Where the model imposes a no-flow boundary under each river, the results likely over-state surface water depletions. Some of the “depletion” may in fact be made up by increased discharge to the river from that part of the groundwater system lying beyond the model boundary, as the aquifer system adjusts to pumping.

Deschutes Valley

Predicted depletions in this basin vary seasonally, with maximums occurring in winter months. As shown in Table 2-2, the greatest predicted depletion in the Deschutes Valley (Figure 2-2) occurs in the lower reach (0.21 cfs), at a rate that is less than the model’s accuracy limit. The middle reach appears to realize the largest relative depletion (0.04 cfs) which is equal to the model accuracy limit. The maximum cumulative predicted depletion of all water bodies on the Deschutes River is 0.37 cfs, which is also below the model’s accuracy limit. As noted above with the Nisqually River, depletions on the Deschutes River will also tend towards over-prediction of depletions due to the no-flow boundary conditions set in the model for the rivers.

Woodland Basin

Predicted depletions in this basin also vary seasonally, with maximums occurring in winter months for all water bodies. The predicted depletions in Woodland Creek are 0.03 cfs, which is below the model’s accuracy limit, and the cumulative total for Woodland Creek and the Tri-Lakes is 0.23 cfs, which is at the accuracy limit of the model. The model predicts a maximum annual depletion of 0.20 cfs in the Tri-Lakes Complex (including Hicks, Pattison and Long Lakes, and associated wetlands). This depletion is greater than the model’s accuracy limit.

In summary, relatively small depletions – less than the accuracy limit of the model – occur in the majority of surface water bodies. The largest depletions are predicted to occur in the Lower Nisqually Reach. In the Tri-Lakes Complex, depletions fall above the accuracy limit in the lakes and below in Woodland Creek.

2.3.2 Cumulative Model Results

The City of Lacey and City of Yelm are also seeking to develop additional water sources to provide for projected population growth in their jurisdictions. Additional water is being sought via existing wells and development of new wells. The close proximity of proposed future points of withdrawal (by virtue of the jurisdictions’ adjacent locations) has resulted in predicted impacts to some of the same surface water bodies by each of the three Cities.


In 2008, the cities conducted an evaluation of the cumulative predicted impacts from the cities of Olympia, Lacey and Yelm applications. The cumulative run evaluated projected pumping (these pumping projections are now out-of-date) by all three cities and the Nisqually Tribe on surface water bodies in the Nisqually River and Deschutes River watersheds. The most critical thing learned from this cumulative run was that the predicted depletions from each city’s project were generally additive, and that they actually declined a bit as a result of the cumulative model run. The cumulative model run results also show that certain water bodies are expected to realize a net increase in flow as a result of the water rights applications being proposed by the three Cities, most notably McAllister Creek.

Olympia and the Nisqually Tribe also request that the application for our change be considered Ecology’s first priority – or at a minimum, be processed at the same time as the new applications from the cities of Lacey and Yelm. This is important for two reasons, 1) flow benefits to McAllister Creek and McAllister Springs are critical components of collaborative mitigation approaches being pursued with the cities of Lacey and Yelm, and 2) Ecology has made a commitment to processing changes and transfers first, over new applications. The Cities have agreed to work together on mitigation in both the Woodland Creek and Deschutes River basins. Section 5, Olympia’s Mitigation Plan, includes a discussion of the collaborative mitigation and the interlocal agreements that guide them.

2.3.3 Potential Impacts on Nearby Wells

Production at the McAllister Wellfield will cause a slight decline in groundwater levels (drawdown) near the producing wells. Drawdown was simulated under conditions of full wellfield pumping. Three separate geologic units were analyzed.

Model Layer 3, representing the bottom of the shallow aquifer in the vicinity of the wellfield.

Model Layer 6, the deeper of the two layers in which most of the City of Lacey wells are screened.

Model Layer 7, where most of the McAllister Wellfield pumping will occur, and therefore where the greatest impact is predicted to occur.

Figures 2-2, 2-3, and 2-4 display the predicted drawdown in the different aquifer units (model layers). The model indicates that declines in groundwater levels due to pumping the McAllister Wellfield will generally be less than five feet, except in the immediate vicinity of the wellfield. Potential impacts would be unique for each affected well depending on how a given well is constructed and the amount of water available above the pump. Therefore, the City cannot predict which wells might experience problems from this amount of drawdown. However, we believe a typical well with a normally screened interval is unlikely to incur problems from the predicted amount of drawdown.

The Tribe operates a hatchery near the Nisqually River at the Kalama Creek Spring Complex (Figure 2-1 (#31) and Figure 2-2). Although it is difficult to accurately predict the impacts of wellfield pumping directly on spring flows, the model provides an estimate of drawdown, which could impact the wells at the hatchery, and potentially the springs. The predicted drawdown is seasonally uniform at just under 0.1 foot (Figure 2-2). The City will continue to evaluate potential impacts to Kalama Creek Springs Complex in consultation with the Tribe.


Figure 2-2. Predicted Groundwater Drawdown in the Shallow Aquifer (Model Layer 3)

in the Vicinity of McAllister Wellfield


Figure 2-3. Predicted Groundwater Drawdown in Model Layer 6 in the Vicinity of McAllister Wellfield


Figure 2-4. Predicted Groundwater Drawdown in Model Layer 7 in the Vicinity of McAllister Wellfield


Section 3 Mitigation Alternatives, Phasing and Approach This section generally describes the initial screening process the City and Tribe applied to identify and evaluate a range of mitigation alternatives based on the predicted impacts. This Section considers whether the project will cause significant adverse impacts as defined under the SEPA. Also described is the phased approach the City and Tribe will implement to accomplish full mitigation in time with achieving full production at the McAllister Wellfield.

3.1 Mitigation Alternatives Screening Process

As presented in Section 2, computer modeling for the McAllister Wellfield project identifies a wide range of predicted impacts to surface water bodies in the vicinity of the planned wellfield. In screening and proposing mitigation alternatives, the significance of these impacts, both adverse and beneficial were considered. SEPA rules under WAC 197-11-794 define “significant” as, “a reasonable likelihood of more than a moderate adverse impact on environmental quality.” There are three key reasons why the City and Tribe propose that impacts to environmental quality as a result of this project will be minimal:

Computer modeling predicts widespread, small depletions, many of which fall below the model’s ability to accurately predict. This calls into question whether predicted depletions will even occur as a result of the McAllister Wellfield development in some areas.

Design of the computer model along river boundaries is such that over-prediction of impacts in the river areas is highly likely.

Proportion of predicted depletions to overall ground and surface water flow is extremely low. Impacts to these water bodies are not measurable in the field, and would therefore be classified as minimal.

Even though predicted impacts are not significant, the City and Tribe are proposing a conservative mitigation package that provides a “margin of safety” and clearly meets the requirements under the SEPA for appropriate mitigation. In the City’s Critical Areas provisions (Chapter 18.32), the code states that “Mitigation shall be undertaken in the following order of preference”:

1. Avoiding the impact altogether by not taking a certain action or parts of an action; 2. Minimizing impacts by limiting the degree or magnitude of the action and its implementation,

by using appropriate technology, or by taking affirmative steps to avoid or reduce impacts; 3. Rectifying the impact by repairing, rehabilitating or restoring the affected environment; 4. Reducing or eliminating the impact over time by preservation and maintenance operations

during the life of the action; 5. Compensating for the impact by replacing, enhancing or providing substitute resources or

environments; 6. Monitoring the impact and taking appropriate corrective measures.


Our approach to the overall mitigation package includes: Targeting flow augmentation through water rights acquisition and reclaimed water infiltration as

far upstream as possible. This approach maximizes the environmental benefits of flow mitigation.

For predicted depletions falling above the accuracy limit we would provide a minimum of 1.5:1 flow replacement to offset predicted depletions during periods where these waters are closed to further appropriations. We would supplement with habitat restoration projects as needed to bolster environmental benefits.

For predicted depletions falling at or below the accuracy limit we would provide a minimum of 1:1 flow replacement during summer closure periods; and land acquisition and habitat restoration projects during winter closures.

The City and Nisqually Tribe considered several reports to prepare this Mitigation Plan.

Mitigation Measures Used in Water Right Permitting, published by Ecology in April 2003. This report summarizes mitigation measures approved by Ecology in conjunction with various applications for new water rights or changes to existing water rights.

The Nisqually Watershed Management Plan issued by the Nisqually Watershed Planning Unit on October 31, 2003. This plan includes mitigation strategies to consider for the Nisqually Watershed, as well as comments on mitigation for the McAllister Sub-basin.

The Phase IV Nisqually Implementation Plan for Watershed Management in WRIA 11 issued by the Nisqually Watershed Planning Unit on February 14, 2007. This plan outlines implementation actions associated with the 2003 Nisqually Watershed Management Plan.

The Nisqually Chinook Recovery Plan identifies and prioritizes habitat areas in the Nisqually Basin for protection and enhancement related to salmon recovery efforts. It identifies a number of specific action items. Related information was also obtained from the Nisqually Wildlife Refuge Conservation Plan.

The Salmonid Habitat Limiting Factors: Water Resources Inventory Areas 13. Final Report. 1999. This report evaluates stream flow, ground water and water quality conditions, and water rights and fish status.

The Final Deschutes River Watershed Recovery Plan: Effects of Watershed Habitat Conditions on Coho Salmon Production. Prepared for the Squaxin Island Tribe by Anchor Environmental in 2008, this plan identifies specific reaches and projects within the basin for Coho salmon habitat enhancement and restoration.

The City and Nisqually Tribe met on a regular basis with the McAllister-Yelm Sub-basin Technical Subcommittee of the Nisqually Watershed Planning Unit specifically to discuss the proposed water right changes and associated mitigation issues. Members of this subcommittee include the Tribe, the Cities of Lacey, Yelm and Olympia, Thurston County, and Ecology. The City and Tribe also met with Ecology Southwest Regional Office, the Washington State Department of Fish and Wildlife, and the Nisqually River Council.


The Cities of Olympia, Lacey, and Yelm also met with the Squaxin Island Indian Tribe on several occasions to discuss regional water management efforts, modeled impacts within the Deschutes and Woodland Creek watersheds, and specific mitigation strategies.

Based on the level of impact to the environment, mitigation sequencing priorities, information gathered, and ideas shared - a set of mitigation alternatives was defined for each surface water body potentially impacted by the McAllister Wellfield. Seven (7) criteria were defined to determine those mitigation alternatives with the greatest merit.

Direct versus indirect offset of depletion Technical feasibility Permitting feasibility Programmatic feasibility Certainty of desired results Cost effectiveness Listed in watershed plan, or other significant planning document

Following the initial screening process, and after meeting with stakeholders, the resulting list of potential mitigation actions was further refined and developed. Sections 4 and 5 of this Mitigation Plan describe the specific mitigation actions selected for each surface water body predicted to be impacted by the McAllister Wellfield.

3.2 Olympia and Nisqually Tribe Shared Mitigation Approach

The City and Tribe propose to carry out the actions described in Sections 4 and 5 as a condition of the water right changes requested for the McAllister Springs certificate and Abbott Springs permit. Under the MOA, the City and Tribe agreed on responsibilities for mitigating potentially impacted water bodies.

Under the agreement, the Tribe is responsible for mitigating predicted impacts of full (City and Tribe) Wellfield pumping on the Nisqually River as addressed in Section 4.

The City is responsible for mitigating predicted impacts on Lake Saint Clair, Woodland Creek, the Tri-Lakes Complex, and the Deschutes River as addressed in Section 5. These mitigation actions are being coordinated with the cities of Lacey and Yelm as part of a collaborative mitigation strategy.

3.3 Phasing of Mitigation Program

The City and the Tribe are committed to matching the appropriate mitigation strategy to the timing and volume of phased production to best mitigate predicted impacts to surface water bodies in the Nisqually River, Woodland Creek and Deschutes River watersheds. The package proposed in this mitigation plan is complete mitigation for all three of the City’s water right applications. The City and Tribe request Ecology link formal deadlines for mitigation requirements to the three phasing milestones so that the timing of mitigation actions will precede or match the corresponding impact.

As outlined in Table 3-1 below, the City and Tribe will phase mitigation for the predicted impacts of full Wellfield pumping. The mitigation actions described in this plan will be performed over time as the City and Tribe develop the McAllister Wellfield. Additional details on phased production and


related mitigation are provided in Section 6. The corresponding mitigation actions strategies are described in Sections 4 and 5.

Table 3-1 shows how the proportion of total mitigation would be phased, if wellfield development is carried out as expected. The key principle here is that each time new capacity is installed, a proportionate quantity of mitigation must be achieved before the City and Tribe put that capacity to use. The proportionate implementation of mitigation actions is especially pertinent to water rights acquisitions carried out for mitigation purposes.

Based on its Comprehensive Plan, the City has outlined in its 2009-2014 Water System Plan a 50-year demand forecast and supply plan. The Tribe is similarly looking out 50 years as part of its planning for growth. Although demand and supply estimates are based on projected population growth, actual wellfield development may vary depending on growth in demand and other factors.

As noted earlier in Section 1, Phase I is targeted to be fully transitioned from McAllister Springs by October 2014 (the regulatory deadline for treatment at the McAllister Springs). Phase II reflects the Tribe’s transition from its reservation wells to the Wellfield, plus expected growth in demand for the City. Phase III reflects the long-term development under the Abbott Springs water right to meet the City’s and Nisqually Tribe’s 50-year planning horizon.

Table 3-1 Anticipated Implementation of Mitigation Actions

Phase

Expected Completion Date

(approximate)

Proportion of Total Capacity Installed at

Wellfield

Proportion of Total Mitigation Required for Each Water

Body Phase I 2011-2014 65% 65% Phase II 2014-2030 77% 77% Phase III 2030-2050 100% 100%

3.4 Stewardship

In addition, under the MOA, the City and Tribe have agreed to form a Stewardship Coalition aimed at protecting water resources in the Nisqually Watershed. The creation of a Stewardship Coalition was initially conceived as part of the 2004 Nisqually Watershed Management Plan in WRIA 11 and is intended to be an open organization and include the other major regional water purveyors, including the Cities of Yelm and Lacey. Activities of the proposed Stewardship Coalition include water conservation commitments, joint aquifer protection, sharing of water use and quality data, coordination of joint mitigation actions, and funding for staffing and stewardship related projects. Stewardship and maintenance of the groundwater model based on best available data will be important roles of this Stewardship Coalition.

The Cities of Lacey, Olympia and Yelm would also establish and support a stewardship group for projects within the Deschutes and Woodland Creek basins. Actions that could be taken by this group would include model refinements, coordinating monitoring and data collection within the basin, and coordinating joint mitigation within the basins. The cities would work with Ecology and the Squaxin Island Tribe to determine the membership and structure of this group.


Section 4 Nisqually Indian Tribe’s Mitigation Program Under the MOA with the City, the Tribe is responsible for mitigating predicted impacts to the Nisqually River under full (City and Tribe) pumping conditions at the McAllister Wellfield. This section outlines the Tribe’s proposed mitigation actions for the Nisqually River. Three elements are included: coordination with Tacoma Power on dam controls; habitat restoration; and establishment of a Groundwater Protection Zone. The two major elements are coordination with Tacoma Power on dam flow controls and establishment of a Groundwater Protection Zone on the Nisqually Indian Reservation. In addition, the Tribe is leading a substantial habit restoration effort in the Nisqually Watershed that is expected to provide significant flow and habitat benefits.

4.1 Tacoma Power Element

The Nisqually River drains the 720 square mile area of WRIA 11. Chapter 173-511 WAC established an Instream Resources Protection Program (IRPP) for the Nisqually Basin. The WAC divides the river into four reaches – the Lower, Bypass, Middle and Upper – and establishes minimum instream flow requirements or partial-year closures for each reach (Table 2-1).

As discussed in Appendix H, flows in the Nisqually River are heavily influenced by operation of the Alder and La Grande dams, as well as the river diversion through the Centralia City Light power project. These projects and their water rights were established prior to Chapter 173-511 WAC and are not subject to that regulation’s minimum flow requirements. However, these projects are regulated by the Federal Energy Regulatory Commission (FERC) and are required to be operated in such a manner as to ensure instream flows are sufficient to preserve reservoir storage and maintain adequate flows for fish.

Nisqually River mitigation actions associated with pumping at the McAllister Wellfield focus on the farthest downstream reach defined by RM 4.3. Potential depletions estimated by modeling wellfield pumping at full build-out may be realized, but will not be measurable in the Nisqually River at RM 4.3. Tacoma Power’s downstream flow obligations are greater than the minimum flows established by Ecology at RM 4.3. Excursions below the Ecology minimum flows at RM 4.3 are extremely rare, and are most likely to occur during the winter months when the minimum flow is set at its highest level (900 cfs). This is also the time when Tacoma Power is operating under an adjusted minimum flow regime (below minimum flows set under FERC) to preserve reservoir storage and assure flows for fish are maintained throughout a drought period. No observed excursions below minimum instream flows were documented in the late summer and early fall months in a drought year, during a study conducted by Ecology at RM 4.6 (Appendix H).

The only time that Tacoma Power’s obligations are diminished is during extreme hydrologic circumstances of low snow pack, delayed fall and winter rain, or both. When these conditions occur, Tacoma Power is required to petition the Nisqually River Coordinating Committee (NRCC) for a modification to their FERC minimum flow requirements. The petition is based on analysis of the impacts of minimum-flow releases at La Grande Dam powerhouse on reservoir levels at Alder Lake. Petitions made in the fall are typically to delay an increase in the minimum instream flow or to modify the minimum flow. The Tribe is a member of the NRCC and flow modifications cannot occur without the Tribe’s agreement.


As part of the mitigation for the Nisqually River, the Tribe has committed to require the discharge of an additional 10 cfs as a condition for its approval of any petition by Tacoma Power to the NRCC for a reduction in the minimum flow requirement. The 10 cfs quantity is twice the estimated impact of winter pumping on the Nisqually River for an additional factor of safety, and is considered highly conservative. A commitment letter from the Tribe is included in Appendix H. A letter from Tacoma Power is also included as an attachment to the Tribe’s letter. The additional release of 10 cfs during periods when Tacoma Power is operating under an adjusted minimum flow regime (under FERC) serves as mitigation for impacts of pumping the McAllister Wellfield under full build-out. It is likely that Ecology minimum flows are not violated during these times; however, in the rare instance that they could be, the addition of 10 cfs in the controlled river system will ensure that there is no adverse effect of McAllister Wellfield pumping.

4.2 Groundwater Protection Zone Element

The second element of the Tribe’s mitigation related to withdrawals from the McAllister Wellfield is the establishment of a Groundwater Protection Zone on the Nisqually Reservation. The Groundwater Protection Zone concept involves prohibiting additional future groundwater withdrawals near the Nisqually River as future Tribal water use is replaced by water withdrawn at the McAllister Wellfield.

The Tribe intends to grow into their allotted amount of water at the McAllister Wellfield (3 MGD). Once the Tribe transitions to the Wellfield, their intention is not to rely on the existing reservation wells for future supply on a regular basis (with the exception of hatchery uses). However, the Tribe may rely on these existing wells on an interim basis for flexibility and future emergency use. The benefits of transferring current water use provided by the Tribe’s existing wells is relatively modest (0.1 cfs cumulative depletion in summer months). The benefits of transferring the full 3 MGD allotment from the reservation to the Wellfield are significant.

The Groundwater Protection Zone element discussion includes:

A map of the land area where future groundwater withdrawals will be prohibited. A Nisqually Tribal Code provision to be adopted to implement the Groundwater Protection

Zone. Groundwater modeling results describing the flow benefits to the Nisqually River resulting

from transfer of potential future groundwater withdrawals to the McAllister Wellfield.

4.2.1 Groundwater Protection Zone Ordinance

The Tribe has completed a Groundwater Protection Zone regulation as an amendment to Section 14.06 of the Nisqually Tribal Code. This amendment (new section 14.06.10 Groundwater Access) prohibits accessing groundwater from more than twenty-five (25) feet below the ground surface from bluff-line to bluff-line. The Groundwater Protection Zone is shown in Figure 4-2. New wells will not be allowed in the lowland area next to the Nisqually River where groundwater is in direct hydraulic continuity with the river. Water supply for hatchery use is exempted. Emergency wells will be permitted within the Groundwater Protection Zone based on determinations made by the Tribal Council, but may only be used for a maximum of six months. Violation of these regulations will result in permanent termination of the groundwater withdrawal, at the violator’s expense. The full code amendment and final resolution adopting the code is included in Appendix H.


4.2.2 Hydrogeology and Expected Benefits

The Nisqually Reservation is underlain by a shallow, unconfined groundwater system, characterized by layers of glacial till and outwash which are not consistently saturated and do not provide a reliable source of water. The first consistent water-bearing unit below the reservation is the Kitsap Formation (Qc aquifer), which is in contact with the Nisqually River in some areas. In other areas, the Qc aquifer is in contact with the valley wall, and forms springs such as Kalama Spring. A conceptual hydrogeologic cross section and additional hydrogeologic characterization are provided in Appendix H.

The hydrogeology and subsequent impacts of pumping on flows in the Nisqually River in the vicinity of the Tribe’s reservation and the Groundwater Protection Zone are somewhat different than in the McAllister Wellfield. Current wells and potential future wells on the reservation are in closer proximity to the Nisqually River than are the wells at the McAllister Wellfield. Therefore, pumping the Nisqually Reservation wells has a higher relative impact on the Nisqually River than pumping at the McAllister Wellfield. Pumping farther from the river, such as at the McAllister Wellfield, spreads the stress of pumping over a larger area, reducing the impact to a surface water body.

In addition, the McAllister Wellfield is planned to be completed in the McAllister Gravel deposit. This highly transmissive aquifer draws water from the south and west, and discharges much of the flow to McAllister Springs, at the lower end of the Nisqually River (including the tidally influenced reach below RM 4.3), and Puget Sound. The large areal extent of the aquifer from which the McAllister Wellfield draws water serves to reduce the impact of wellfield pumping on the Nisqually River, compared to wells located on the reservation.

Figure 4-1. Nisqually Reservation Groundwater Protection Zone


4.2.3 Groundwater Model Results

The McAllister Wellfield groundwater model estimated changes in impacts to the Nisqually River resulting from the relocation of future pumping away from the Groundwater Protection Zone on the Nisqually Reservation. Appendix H provides memoranda detailing the groundwater modeling effort.

The model predicts flow depletions to the Nisqually River and other surface water bodies, computed as the change in groundwater flow to the river, for two future pumping scenarios on the Nisqually Reservation. A flow budget analysis is conducted to compute the changes in groundwater flow to the river resulting from moving potential future water use from the reservation to the McAllister Wellfield. Depletions do not represent direct removal of water from the river, but rather a reduction in the groundwater discharge rate to the river.

Model results are reported by river reach. In the model, the Nisqually River is divided into five reaches starting from RM 4.3, approximately at the BNSF railroad bridge over the river (Figure 2-2). The first three reaches (reach #20, 21, and 22 on Figure 2-2) are combined in this analysis and are called the Lower Nisqually Reach, extending from the BNSF railroad bridge to approximately midway through the Nisqually Reservation. The middle reach of the Nisqually River (reach #9) extends through the remainder of the reservation to Thompson Creek just downstream of Yelm. The upper reach (reach #33) extends to the model boundary.

In addition to the reaches of the Nisqually River, the model also analyzes water budgets for Yelm Creek (reach #32 and 34 on Figure 2-2) and for Kalama Creek Spring (reach #31), which contribute flow to the Nisqually River.

4.2.4 Expected Benefits from the Groundwater Protection Zone

The Tribe has evaluated the hydrologic benefits of moving the full Tribal allocation of 3 MGD from the Nisqually Reservation to the McAllister Wellfield. The model was used to assess the depletions to the Nisqually River caused by pumping the full allotment on the reservation, and therefore identified the benefits of moving withdrawal to the McAllister Wellfield. This transfer would be facilitated by the Groundwater Protection Zone ordinance. The groundwater model was used to simulate a specific possible pumping scenario. Under this future scenario, the full 3 MGD that are set aside at the McAllister Wellfield for the Tribe (based on the MOA) are withdrawn from the Groundwater Protection Zone (Figure 4-2). The 3 MGD pumping condition was distributed among existing and hypothetical additional future wells. The present pump rates at the Leschi and Nisqually wellfields were applied directly, as these wellfields currently operate at near capacity. The pump rate at the Cuyamaca wellfield was assumed to have doubled, based on development plans for the northern part of the reservation. Additional pumping was also modeled at two future wells, as well as six more hypothetical wells, located in relatively high hydraulic conductivity zones along the northern and southern ends of the reservation where sufficient groundwater flow is present to supply the wells.

The modeled impacts of simulating withdrawal of 3 MGD from the Groundwater Protection Zone are shown in Table 4-1. Relocating points of withdrawal from existing and future tribal wells located in the Groundwater Protection Zone to the McAllister Wellfield would result in a gain to the Lower Reach of the Nisqually River of approximately 3.7 cfs during peak usage in July and August (Appendix H). This gain of 3.7 cfs is approximately half of the total depletion resulting from full production at the McAllister Wellfield (25.2 MGD peak month use).


Table 4-1 Predicted Depletions at 3 MGD Allotment

Month Nisqually River Reach (cfs)

Kalama Spring (cfs)

Yelm Creek (cfs)

Total (cfs)

January 1.02 0.88 0.02 0.29 0.01 2.21 February 1.02 0.86 0.02 0.28 0.01 2.19

March 1.01 0.87 0.02 0.29 0.01 2.20 April 1.09 0.92 0.02 0.31 0.01 2.34 May 1.21 1.00 0.02 0.34 0.01 2.57 June 1.55 1.26 0.02 0.44 0.01 3.28 July 1.76 1.42 0.02 0.50 0.01 3.70

August 1.78 1.44 0.02 0.50 0.01 3.76 September 1.69 1.38 0.02 0.48 0.01 3.58

October 1.44 1.19 0.02 0.41 0.01 3.07 November 1.19 1.01 0.02 0.34 0.01 2.56 December 1.06 0.91 0.02 0.30 0.01 2.31

The predicted annual depletion to the Nisqually River from the modeled impacts of future pump scenarios (3.7 cfs) is over 80 percent of the total annual pump rate eventually to be realized at the reservation (3 MGD). By contrast, the predicted depletion to the Nisqually River from the McAllister Wellfield (7.2 cfs) is only about 20 percent of the total pump rate at the McAllister Wellfield (25.2 MGD). The higher relative impact from pumping future Nisqually wells is due to their close proximity to the Nisqually River. Pumping farther from the river, such as at the McAllister Wellfield, spreads the stress of pumping over a larger area of the aquifer, thereby reducing the impact to any one surface water body.

In addition, the McAllister Wellfield is planned to be completed in the McAllister Gravel deposit. This highly transmissive aquifer draws water from the south and west, and discharges much of the flow to McAllister Springs, at the lower end of the Nisqually River including the reach below RM 4.3, and Puget Sound. The large areal extent of the aquifer from which the McAllister Wellfield draws water serves to reduce the impact of the McAllister Wellfield on the Nisqually River compared to reservation wellfields located near the river.

4.3 Habitat Restoration Element

The Nisqually Tribe and partner organizations are actively involved in conducting restoration projects throughout the Nisqually watershed. These projects are not explicitly mitigation, but they do provide net benefits for stream flows and substantial habitat benefits, and they also provide a larger context for the Tribe’s mitigation actions described in Sections 4.1 and 4.2. These projects include wetland and riparian restoration, removal of bank armoring, invasive species control, and acquisition of wetlands and riparian areas along the Nisqually and its tributaries. This plan section highlights activities on Ohop Creek and Muck Creek. Appendix H contains additional discussion in support of the Tribe’s habitat restoration element.


4.3.1 Ohop Creek Restoration

A major priority of the Tribe, which provides significant benefit to the Nisqually River flows, is to restore wetlands and improve channel connectivity on Ohop Creek. While not specifically providing a quantified drop-for-drop benefit, this restoration will return the hydrologic system of the Ohop sub-basin to a more natural state, improving base flows in Ohop Creek and the Nisqually River. This project strengthens the overall restoration and habitat enhancement effort in the Nisqually system, and compliments the Tribe’s mitigation program (Appendix H).

The Tribe, in partnership with the South Puget Sound Salmon Enhancement Group (SPSSEG), has initiated channel reconstruction and wetland restoration work on Ohop Creek. The Ohop Valley is characterized by numerous springs and seeps, and is dominated by wetlands. Historically, the Ohop Valley was channelized, ditched, and drained to improve conditions for agriculture, physically disconnecting the creek from the floodplain and adjacent wetlands. Restoration is expected to reconnect the creek to the natural floodplain and adjacent wetlands, improve the connectivity between surface water and groundwater, and increase recharge from wetland water storage, thereby contributing to both Ohop Creek and Nisqually River base flow. Further detail regarding research on benefits to base flow resulting from restoration is provided in Appendix H.

The project will elevate and reconstruct Lower Ohop Creek to create a more natural meander pattern which is hydrologically connected to the adjacent floodplain and wetland areas (see Figure 4-1).

Restoration work will also involve revegetating the entire floodplain, including riparian and wetland areas. The first phase of this restoration, along one mile of the creek, is planned to begin in 2009 and be completed by 2010. Two additional restoration phases are projected to be complete within ten years, contingent on funding.

The Tribe and partners will monitor the hydrologic effects of this restoration work, beginning in the fall of 2008 by collecting groundwater data from several transects of piezometers located upstream, within, and downstream of the initial restoration area. By collecting these data before, during, and after restoration, the Tribe will be able to track changes in groundwater saturation. Groundwater monitoring activities by the Tribe are discussed in more detail in Appendix H.


4.3.2 Muck Creek Restoration

Restoration work is also ongoing on Muck Creek (Appendix H). Due to the hydrogeologic nature of that creek, base flow benefits resulting from restoration to both Muck Creek and the Nisqually River cannot be predicted. Although benefits will be positive, they are not anticipated to be significant.

4.3.3 Other Restoration Projects in the Nisqually Watershed

The Tribe is solidly committed to fulfilling a stewardship role in the Nisqually River system. As the lead entity for salmon recovery planning and coordination in the Nisqually watershed, the Tribe has undertaken and planned a wide range of restoration projects. These projects are largely focused on helping to restore and protect high quality, functioning salmon habitat, which necessarily includes adequate stream flows. Highlights of this restoration work include a large-scale estuary restoration project; wetland and riparian restoration on the Mashel River, Tanwax Creek, and along the Nisqually mainstream; and the Ohop Creek restoration project (Section 4.2.1).

Appendix H includes additional information on the Tribe’s restoration work along with the benefits of these activities on the overall health of the hydrologic system in the Nisqually watershed.

Figure 4-2. Lower Ohop Valley Restoration Project



Section 5 City of Olympia’s Mitigation Program The City proposes to carry out the mitigation actions listed in this section as a condition of the changes requested for the McAllister Springs and Abbott Springs water rights. This mitigation program is a complete mitigation package for all three phases of the McAllister Wellfield development (three applications pending). Under the MOA with the Tribe, the City is responsible for mitigating predicted impacts on Lake Saint Clair, Woodland Creek, the Tri-Lakes Complex, and the Deschutes River. As discussed in Section 3, our proposed mitigation program assumes that no significant adverse impacts to these water bodies will result from the development of the McAllister Wellfield. Therefore, we are proposing a conservative approach to mitigation, which provides an appropriate “margin of safety” for water bodies that include Lake St. Clair, Tri-Lakes/Woodland Creek and the Deschutes River.

The Cities of Yelm, Olympia, and Lacey (Cities) each have water right applications pending before Ecology. To address mitigation of predicted cumulative effects on common water bodies, the Cities have entered into formal agreements to share and coordinate mitigation efforts. In contrast to the MOA with the Tribe – which resulted in the shared development of a water source and separate mitigation efforts to water resources, the Cities of Olympia, Lacey, and Yelm will develop separate water sources, yet will share mitigation efforts where feasible and appropriate. Significant and innovative elements are jointly proposed by the cities of Lacey, Olympia, and Yelm for the Woodland Creek, Deschutes River, and McAllister Creek basins.

Numerical modeling of the Cities’ water right applications indicates that all three Cities will potentially impact surface water in the Deschutes River and the Tri-Lakes/Woodland Creek basin. McAllister Springs and McAllister Creek are predicted to benefit significantly as a result of Olympia’s move to the McAllister Wellfield. In addition, McAllister Springs and McAllister Creek are predicted to be impacted by the City of Lacey and Yelm’s applications. Mitigation will be provided for McAllister Creek (City of Lacey and Yelm applications) by the City, when the City moves its primary source of supply from McAllister Springs to the McAllister wellfield. The City and the Tribe request Ecology recognize net regional benefits of mitigation and changes in points of withdrawal, including where a net improvement in flow is predicted.

Olympia is coordinating with Lacey and Yelm on regional mitigation strategies. Interlocal agreements are in place that detail roles and responsibilities for all parties related to these mitigation strategies (Appendices D and E). By working together as mitigation partners, the cities developed large mitigation projects that will have more overall benefit to these basins than would have been possible through individual efforts. Regional actions for Woodland Creek and the Deschutes River consist of both flow (also referred to as in-kind) and non-flow (also referred to as out-of-kind) actions that will mitigate predicted impacts from water rights actions individually requested by the each of the Cities. These collaborative mitigation actions are described within each of the basin discussions below.


5.1 McAllister Creek

As a result of shifting production from McAllister Springs to the McAllister Wellfield, the City’s longstanding diversion of flow from the Springs will be eliminated by October 2014, at the end of Phase I of McAllister Wellfield development. At the same time, pumping from the Wellfield will reduce the natural outflow of groundwater at McAllister Springs and Abbott Springs, both of which contribute flow to McAllister Creek. Thus, pumping at the McAllister Wellfield will affect flow in the McAllister Springs/Creek system in two ways: flow will increase due to eliminating the diversion; and flow will decrease due to reducing the outflow of groundwater (see Figure 5-1). However, the gain realized through eliminating diversion is predicted to be greater than the loss due to reduced outflow by a considerable margin, resulting in a significant increase in flow to McAllister Creek (Table 2-2), which is a closed water body. The City and Tribe request Ecology recognize this net increase in flow to McAllister Springs/Creek system and consider this benefit in the context of the full mitigation proposal.


Figure 5-1. Groundwater Flow Dynamics – Transition from Springs to Wellfield

5.2 Lake Saint Clair

Full production pumping at the McAllister Wellfield is predicted to deplete Lake Saint Clair by 0.12 cfs, a quantity that is below the accuracy limit of the model (Table 2-2). As a result, the City worked towards a goal of acquiring water rights at a one-to-one mitigation ratio, as described in Section 3.2. A surface water right (certificate 4436) from the Schoepfer Whispering Firs Farms located upgradient of Lake Saint Clair was acquired by the City (Appendix I). The Schoepfer water right has a priority date of April 17, 1951, and authorizes irrigation of 20 acres and a withdrawal rate of 0.20 cfs. Therefore, this acquisition adequately mitigates predicted depletions during summer irrigation months, when lake levels are lowest. The diversion point is an unnamed pond that ultimately discharges to Lake Saint Clair via Raymond Ditch and Eaton Creek. The location of the pond is shown in Figure 5-2.


On July 10, 2008, the City applied to Ecology for temporary placement of water right 4436 into the Washington State Trust Water Right Program to benefit Lake Saint Clair water levels. This application was accepted by Ecology on July 29, 2008. The temporary trust donation is for 0.20 cfs and 28.2 AFY, was extended in 2009 and 2010, and is now secured until October 1, 2011. This water right (0.20 cfs) provides appropriate mitigation of predicted impacts to Lake Saint Clair (0.12 cfs) associated with full production at the McAllister Wellfield for the City and Tribe. If approved as mitigation, the City intends to make a permanent donation to the Washington State Trust Water Right Program or permanently retire the water right for the benefit of Lake Saint Clair water levels.

A copy of the water right certificate, BUA, hydrologic assessment, deed, certificate, and other documents related to the temporary trust water right application are included in Appendix I.

Figure 5-2. Location of Surface Water Right 4436 (Schoepfer)


5.3 Woodland Creek Basin

Impacts in the Woodland Creek basin will be mitigated using a combination of in-kind and out-of-kind mitigation actions. All of the flow mitigation, and some of the non-flow mitigation, will be implemented as part of a mitigation package that is jointly proposed by the cities of Lacey and Olympia. This section presents the mitigation program for the Woodland Creek basin which would serve to mitigate predicted depletions in this basin from development of phases 1-3 of the McAllister Wellfield. Although impacts are predicted for the tri-lakes, associated wetlands and Woodland Creek, the overall approach to mitigation is to focus on upper Woodland Creek. The creek experiences low flows and has more potential for fish production than the upstream lakes area, and it is expected that there will be more overall benefit to the system by concentrating mitigation effort on the creek as opposed to the individual lakes. Predicted changes to the lakes are very small and will not impair the use of water rights from the lakes. 5.3.1 Olympia’s Predicted Depletions Table 2.2, on page 21, summarizes predicted depletions for the Woodland Creek Basin. At full production of the McAllister Wellfield, the groundwater model predicts an annual maximum depletion of 0.23 cfs for the Woodland Creek basin (Table 2-2). During the summer months, the maximum predicted depletion is lower at 0.21 cfs. Predicted total maximum annual depletions for the Woodland Creek Basin at (including the Tri-Lakes and associated wetlands) from the McAllister Wellfield are at the model accuracy limit, and predicted total maximum summer depletions for the basin are above the model accuracy limits.

Given this, the City in partnership with the City of Lacey proposes a combination of both flow and non-flow mitigation, to achieve a conservative “margin of safety” for mitigation purposes.

The Cities of Olympia and Lacey will jointly mitigate predicted impacts of respective pumping within the Woodland Creek basin. See Appendix D for the detailed interlocal agreement on this collaborative mitigation. The agreement involves two main mitigation elements: flow mitigation through the infiltration of Class A reclaimed water; and non-flow mitigation through property acquisition resulting in habitat preservation. Under the agreement, the City of Lacey takes the lead on implementing mitigation strategies, and the City pays a 21.7% share of the costs. This percentage is based on Olympia’s fraction of the predicted depletions within the basin.

5.3.2 Predicted Depletions and Mitigation Quantities for Regional Mitigation in Woodland Creek Basin

Model-predicted depletions to be addressed collaboratively by the Cities of Olympia and Lacey are shown in Table 5-1. These depletions are the cumulative impacts to the individual lakes, associated wetlands, and Woodland Creek from water rights requested by Lacey and Olympia, and represent flow depletion predicted for the mouth of Woodland Creek at Henderson Inlet. All predicted impacts reported in Table 5-1 are above the accuracy limit of the model, except for Olympia’s maximum annual/winter depletion, which is at the accuracy limit. Yelm’s impacts are not included in this section, although Yelm may be included in regional mitigation at a later date if final modeling results indicate this is warranted.


As noted earlier, Olympia’s approach to mitigation is to provide an additional margin of safety for predicted impacts that exceed the model accuracy limit by providing mitigation at a 1.5:1 ratio. The City of Lacey’s mitigation plan takes the same approach to mitigating predicted impacts that are above the model accuracy limit. For planning mitigation actions a ratio of 1.5:1 was applied to all depletions that were at or above the model accuracy limit and were used to determine the “mitigation quantities” that are shown in Table 5-2.

Table 5-1 Regional Mitigation Program:

Model-Predicted Depletions for Woodland Creek Basin

Application Phase Max Summer Depletion

(cfs)

Max Annual Depletion (cfs) Annual Depletion (AFY)

Lacey Phase 1 Lacey Phase 2 Lacey Phase 3 Subtotal Lacey Olympia Phase 1 Olympia Phase 2 Olympia Phase 3 Subtotal Olympia

0.09 0.22 0.35 0.66

0.14 0.02 0.05 0.21

0.12 0.27 0.44 0.83

0.15 0.03 0.05 0.23

69 160 257 486

94.3 17.4 33.3 145

TOTAL: 0.87 cfs 1.06 cfs 631 AFY Sources: City of Olympia and Nisqually Indian Tribe McAllister Wellfield Mitigation Plan (2008); Riley (2008); Sources for Lacey’s depletions are cited in Table 10.


Calculated Mitigation Quantities for Woodland Creek Basin

Application Phase Summer Mitigation Quantity* (cfs) Winter Mitigation Quantity* (cfs)


0.14 0.33 0.52 0.99

0.21 0.03 0.08 0.32

0.18 0.40 0.66 1.24

0.22 0.04 0.08 0.34

TOTAL: 1.31 cfs 1.58 cfs

*A mitigation ratio of 1.5:1 was applied to predicted impacts from Table 5-2 that are at or above the accuracy limit of the model.

Predicted depletions from the tri-lakes are included in cumulative impacts shown in Table 5-1, and are reported as the depletion of groundwater inflow in CFS. However, predicted impacts to lakes are more easily visualized as changes in lake levels, which are summarized in Table 5-3. These lake level changes are very small compared to seasonal changes in lake levels which vary annually by 2-4


feet at Hicks Lake, 0.5-1.5 feet at Pattison Lake, and 1.5- 2.0 feet at Long Lake. Because these predicted changes are very small and will not impair the use of water rights from the lakes, regional mitigation is not focusing on direct mitigation to the individual lakes. The mitigation quantity for the Woodland Creek basin includes the predicted impacts to the lakes and in-kind mitigation will focus on upper Woodland Creek. However, some lake impacts may be addressed through in-kind mitigation. This is discussed further in the next section.

Table 5-3 Maximum Estimated Changes to Lake Levels

Application Hicks (in.) Pattison (in.) Long (in.)


0.05 0.10 0.20 0.35

0.09 0.02 0.03 0.14

0.11 0.28 0.41 0.80

0.21 0.04 0.07 0.32

0.10 0.26 0.41 0.77

0.19 0.04 0.07 0.30

TOTAL: 0.5 in. 1.1 in. 1.1 in. Source: Lacey and Olympia’s impacts are from “Analysis of Lake Level Deficit”, electronic communication from Peter Brooks to Tom Loranger, Phillip Crane, and Mike Gallagher , January 23, 2009. 5.3.3 Regional Flow Mitigation for the Woodland Creek Basin: Reclaimed

Water Infiltration The cities propose to focus the full mitigation quantity for the entire basin on upper Woodland Creek. Flow-related mitigation for all predicted impacts in the Woodland Creek basin will be provided by a regional reclaimed water infiltration facility to be located near the headwaters of Woodland Creek in Lacey. The facility will infiltrate reclaimed water year-round, with the purpose of recharging groundwater that provides base flows to Woodland Creek. Whereas infiltration of reclaimed water was also proposed in the cities’ original mitigation plans submitted in 2008, the original proposal was for seasonal infiltration. This proposal to provide year-round infiltration will provide more flow mitigation than originally proposed by the cities, and is based on a study conducted from 2009 – 2010. Infiltration capacity of the site was evaluated from both field tests and groundwater modeling using a localized model that was developed from the McAllister Numerical Groundwater Model (PGG, 2010; see Appendix D). Modeling results indicate that the site has the capacity to infiltrate large quantities of water without flooding the site. The site also has the capacity to infiltrate water year-round, although infiltration rates will have to be adjusted seasonally. Modeling indicates that the site capacity for infiltration is 1.3 MGD during dry (summer) months, and 0.3 MGD during wet (winter) months. These rates are predicted to increase Woodland Creek flow by 66% of the summer infiltration rate, and 85% of the winter infiltration rate. The locations where reclaimed water will discharge to Woodland Creek will depend on the infiltration rate that will be allowed for this facility, which in turn will be defined by water quality permit parameters. The facility will need to be approved for coverage under the LOTT (Lacey, Olympia, Tumwater, and Thurston County) Clean Water Alliance’s (LOTT) reclaimed water permit


for reclaimed water produced at the Martin Way Reclaimed Water Plant, although it is anticipated that the water quality permit requirements will allow for the construction of a facility that infiltrates between 0.8 MGD and 1.3 MGD in the summer. LOTT produces Class A Reclaimed Water through regional wastewater treatment facilities. At the lower rate, 0.8 MGD, reclaimed water is predicted to discharge in the mid- and lower areas of the creek north of Martin Way. At higher rates, reclaimed water is predicted to enter the creek in the upper reach and could even discharge into the creek in the immediate vicinity of the infiltration pond. In addition to augmenting groundwater, infiltrated reclaimed water will increase base flows in Woodland Creek because the hydraulic gradient of the native groundwater will be affected by the reclaimed water mound that will form in the vicinity of the infiltration site. Downstream of the infiltration site, the mound of reclaimed water will force more native groundwater into the creek in gaining reaches and springs (Figures 5.3 and 5.4). Upstream of the mound, the lakes and the creek will lose less native groundwater to the aquifer. The end result is that even at the lower-end summer infiltration rate of 0.8 MGD, the proposed infiltration facility will increase flows in Woodland Creek although not all of the increased flow in the creek will be discharged reclaimed water. The infiltration facility may also reduce some of the predicted impacts on the tri-lakes from additional pumping.

Figure 5-3. Baseflow Effects – Current Condition before Reclaimed Water Infiltration


Figure 5-4. Baseflow Effects – Future Condition with Reclaimed Water Infiltration The modeled relationships between infiltration rate and streamflow increases at the mouth of Woodland Creek were used to calculate the amount of infiltration that will be needed for each phase of water rights (Table 5-4). Based on these relationships the facility will need to infiltrate up to 0.84 MGD to mitigate summer impacts the cities’ Phase 1 and Phase 2 water rights, and up to 1.3 MGD to mitigate Phases 1, 2, and 3. Winter infiltration capacity is sufficient for mitigating Phase 1 only. To address the balance of winter impacts, the cities are proposing out-of-kind mitigation to supplement the in-kind mitigation. Non-flow mitigation is discussed in the next section.


Table 5-4 Regional Mitigation for Woodland Creek:

Mitigation with Reclaimed Water

Application

Summer Flow Mitigation Winter Flow Mitigation

Mitigation Quantity

(cfs)1

Infiltration rate needed for 0.8 MGD facility2

(MGD)

Infiltration rate needed for 1.3 MGD facility3

(MGD)

Mitigation Quantity (cfs)1

Infiltration Needed for 0.3 MGD winter

capacity4 (MGD)

Phase 1 Lacey Olympia subtotal Phase 2 Lacey Olympia subtotal Phase 3 Lacey Olympia subtotal

0.14 0.21 0.35

0.33 0.03 0.36

0.52 0.08

0.60

0.16 0.23 0.39

0.37 0.03 0.40

--5

--5

--5

0.14 0.20 0.34

0.32 0.03 0.35

0.51 0.08 0.59

0.18 0.22 0.40

0.40 0.04 0.44

0.66 0.08 0.74

0.14 0.17

0.31

--5

--5

--5

--5

--5

--5

TOTAL:

1.31 cfs 0.79 MGD 1.28 MGD 1.58 cfs 0.31 MGD

1 See Table 5-2; this includes the mitigation ratio of 1.5:1 2 At 0.8 MGD, the model predicts flow to Woodland Creek will increase by 58% of summer infiltration rate 3 At 1.3 MGD, the model predicts flow to Woodland Creek will increase by 66% of summer infiltration rate 4 Regardless of the summer infiltration rate, the site’s winter infiltration capacity is predicted to be 0.3 MGD. The predicted

increase to flow in Woodland Creek is 85% of winter infiltration rate 5 Infiltration amount would be beyond what model predicts for site infiltration and facility size.

It is important to recognize that modeling was based on a conservative conceptual design for the infiltration facility. As noted in the infiltration analysis report, optimizing the design of the facility may increase the actual infiltration capacity at the site. It will be necessary to confirm the actual site capacity for infiltration by monitoring the facility when it is in operation. Consequently, the cities are proposing to take an adaptive management approach for mitigation for phasing in mitigation for Phases 1 and 2, and then Phase 3. Data collected during implementation of Phases 1 and 2 of mitigation will be used to further optimize design of the facility by the time Phase 3 water rights will be exercised. Based on timelines for phasing in use of new water rights, Phase 3 mitigation will not need to be operational earlier than 2030 for Olympia and the Tribe. This is based on modeling for both the water rights impacts analysis and the infiltration facility analysis. For impacts analysis, pumping achieved steady-state after six years, whereas for the infiltration facility, travel time to Woodland Creek was up to four years for the 0.8 MGD summer infiltration rate. Consequently, flow mitigation for each water right phase should start when the water rights start to be exercised. This phasing of flow mitigation is described in more detail in Section 6.


To evaluate how much streamflow will be replaced by infiltration in terms of AFY, we need to use the streamflow/infiltration rate relationships used in Table 5-4. The infiltration analysis report concluded that on an annual basis the site can infiltrate 550 AFY using the conservative conceptual design of infiltrating 0.8 MGD in summer and 0.3 MGD in winter, but did not quantify streamflow increase in acre-feet. However, using the streamflow/infiltration rate relationships, a facility that infiltrates 550 AFY should replace 319 – 468 AFY of streamflow. Given that the annual impacts from Phases 1 and 2 are predicted to total 341 AFY, a 0.8 MGD infiltration facility should completely replace the volume of water depleted on an annual basis from Phases 1 and 2, while mitigating summer flow impacts in cfs at 1.5:1. If a 1.0 – 1.3 MGD facility is permitted through LOTT’s reclaimed water permit, the amount of water replaced on an annual basis will be at a higher percentage, and should be sufficient for mitigating Phase 3 impacts. Because shallow groundwater levels will be affected by precipitation, it is important to plan for meeting mitigation goals during years of extreme precipitation patterns. The cities propose to maximize infiltration at the site on a seasonal basis to ensure that the 5-year average of maximum infiltration rates is at least the summer infiltration rate needed for mitigation as shown in Table 5-4. This will mean that during unusually dry years more water can be infiltrated, which will provide more benefit to stream flows during those years when it is needed. It will also compensate for unusually wet years when infiltration will have to be reduced to avoid local discharge at the site. As noted above, monitoring the site during the first 6 years of implementation will provide a baseline for determining how much additional capacity is available at the site for providing this operational flexibility, and for mitigating Phase 3 water rights. The Regional reclaimed water infiltration facility will be operational in 2012, to coincide with first phase of use of water rights. Significant work and coordination for implementing this mitigation project has already been completed, all of which demonstrate the project’s feasibility and the Cities’ commitment to completing this project as scheduled. The following are key points about the facility:

The facility will infiltrate Class A reclaimed water, which is currently produced at LOTT’s Martin Way Reclaimed Water Plant.

The design capacity of LOTT’s Martin Way Reclaimed Water Plant is 2 MGD. An interlocal agreement between LOTT, Thurston County, and the cities of Lacey, Olympia, and Tumwater distributes allotments of reclaimed water from this plant to LOTT (0.25 MGD), Olympia (0.3 MGD) and Lacey (1.45 MGD). The Reclaimed Water Distribution Agreement No. 1 is included in Appendix D. The quantities allotted to Lacey and Olympia are sufficient for water rights mitigation proposed in this plan.

The WRIA 11 Nisqually Watershed Planning Unit provided a letter of support for securing grant funding for this reclaimed water infiltration project (Appendix D). Lacey was awarded an EPA grant for a portion of the construction costs of the infiltration facility. Construction of the facility will be scheduled for 2011 - 2012.

Infiltration of reclaimed water for groundwater recharge purposes is an approved use on LOTT’s reclaimed water permit for the Martin Way reclaimed water plant. The Woodland Creek infiltration facility will also be regulated under LOTT’s permit, although an amendment will be required for this infiltration location. LOTT has been participating in discussions with Lacey, Olympia, Ecology’s Water Quality Program, and DOH regarding permitting issues for the proposed facility.

A mounding study, which is required for reclaimed water permitting, has already been completed and is part of the facility infiltration analysis report that is in Appendix D.


The facility will be owned and operated by the Cities of Lacey and Olympia. An interlocal agreement for cost sharing the design and construction of the facility is attached in Appendix D.

5.3.4 Regional Non-Flow Mitigation for Woodland Creek: Riparian Land Protection

Regional non-flow mitigation will complete mitigation for Olympia Phases 1, 2, and 3; Lacey’s Phases 1 and 2. Yelm may also elect to participate in regional out-of-kind mitigation, pending updated modeling results. Whereas infiltration of reclaimed water in the upper Woodland Creek basin will both replace and enhance flows during summer, and replace the annual amount of water depleted from the basin year-round, the site infiltration capacity in winter months is not sufficient for completely replacing depletions predicted for winter months. The site’s winter infiltration capacity is predicted to be 0.3 MGD, which is considerably lower than the infiltration rates that would be needed for using the infiltration facility to mitigate all predicted winter depletions (Table 5-4). In addition to flow mitigation for the Regional Mitigation package for Woodland Creek, Lacey and Olympia propose to jointly pursue the purchase of property or conservation easements along Woodland Creek to increase the amount of undeveloped protected land along the creek. This will augment 498 acres of existing buffers, parks, and protected open space in the basin. For mitigating water rights, Washington State Department of Fish and Wildlife (WDFW) recommends combining stream flow augmentation with riparian land reserves (Beecher 1998). Riparian land protection will supplement the available in-kind mitigation for winter months, and since the benefits will be year-round, this will further increase summer mitigation. As stated by WDFW:

“The purpose of riparian land reserves is to maintain structural integrity of the stream channel and protect groundwater-stream interactions. Maintaining vegetation and trees will provide a source of large woody debris (LWD), which is important in dissipating energy of flood waters, thereby reducing erosion and stream widening. LWD also increases depth and provides cover, as well as substrate for benthic insect production. Vegetation protects soil from rills during high rainfall, thus reducing fine sediment input. The reserves serve as groundwater recharge areas.”

In addition to being a viable mitigation option, riparian land acquisition in the Woodland Creek basin was highly recommended in the City of Lacey: Woodland Creek Riparian Habitat Assessment for protecting forested stream buffer (Agua Tierra Environmental Consulting 2003). Riparian land reserves will also complement recommendations in the water quality improvement reports for the Henderson Inlet Watershed TMDL, which recommend preserving mature trees (“site-potential shade”) for ensuring the continued compliance with state water quality standards for stream temperature and dissolved oxygen in the mid- and lower reaches of Woodland Creek (Ecology 2006; 2008). The Cities are proposing to purchase approximately 30 acres of undeveloped property in the basin that includes creek frontage. To meet this goal of purchasing 30 acres, the Cities of Lacey and Olympia have already purchased 10.5 acres of undeveloped property that includes frontage along both Woodland Creek and Fox Creek (Figure 5-5). This property is within Lacey’s Urban Growth Area and includes approximately 650 feet of Fox Creek frontage, and 1,000 feet of Woodland Creek


frontage. An added benefit of this property is that the other side of Woodland Creek is owned by the City of Lacey, so now both sides of the creek are protected. Although this property was acquired prior to approval of Lacey and Olympia’s water rights, Ecology provided written acknowledgement that this property was purchased for mitigation purposes. The letter from Ecology is provided in Appendix D. The three cities are currently pursuing the acquisition of approximately 20 additional acres of undeveloped property. In addition to providing creekside protection, there will be hydraulic benefits from removing developable creekside property from development. A final consideration is that 30 acres of undeveloped property will keep 126 acre-feet of infiltrated precipitation from being altered from the natural hydrologic regime. Further, long-term stewardship of jointly acquired properties will be assured by zoning, conservation easements, or other legal constraints against development, timber harvest, or vegetation removal. The cities will also manage the properties to control noxious weeds and vehicular access. These constraints on land use will not restrict opportunities for habitat restoration projects on these properties, and the cities intend to make these properties available for enhancement projects.

Figure 5-5. Riparian Protection Property on Fox Creek


5.4 Deschutes River Basin

This section presents the mitigation program for the Deschutes River basin which would serve to mitigate predicted depletions in this basin from development of phases 1-3 of the McAllister Wellfield. The City and Tribe, in collaboration with the cities of Lacey and Yelm, are proposing the following mitigation proposal for the Deschutes Basin:

Flow mitigation for the closure period through acquisition and retirement of irrigation water rights, and;

Land acquisition and habitat restoration for predicted non-closure period impacts.

To date, the three Cities have signed two Interlocal Agreements, including one amendment to formalize this collaborative effort, as outlined below. Copies of the Interlocal Agreements and Amendment are provided in Appendix E. Work on these interlocal agreements have included a variety of specific actions, including:

Updating groundwater model features to better reflect features within the Deschutes River Basin;

Research into consumptive water rights available within the Deschutes River Basin; Negotiations with water rights holders for acquisition of priority water rights; Two option agreements for the purchase of water rights finalized and the third in negotiation; Negotiations and finalization of an option agreement to purchase the Smith Ranch for non-

flow mitigation; Research, field work, and a habitat restoration feasibility assessment report produced on the

Smith Ranch; and Discussions with the Squaxin Island Tribe regarding priorities for water rights acquisitions

and habitat restoration.

5.4.1 Olympia’s Predicted Depletions

The maximum predicted depletion to the Deschutes River at full Wellfield pumping is 0.37 cfs during the month of February (Table 2.2). This peak impact occurs in the winter due to the distance of the river from the Wellfield and the long lag-time of pumping impacts. The maximum predicted summer impact is 0.23 cfs, in the months of June through August. Both the maximum annual and summer predicted impacts are small - at or below the model accuracy limit. For the Deschutes River, as with other water bodies where modeling results fall below the accuracy limit, modeling results are inconclusive as to whether the McAllister Wellfield, at full pumping, will or will not impact surface water in the Deschutes River. Another compounding factor is that the model conservatively over-predicts depletions at river boundaries. Given the sensitive nature of this basin, and the potential for an impact, the City and Tribe are proposing a conservative mitigation package as a “margin of safety” under these circumstances.

5.4.2 Predicted Depletions for Olympia, Lacey and Yelm in the Deschutes River Basin

Model-predicted depletions to be addressed collaboratively by the Cities of Olympia, Lacey and Yelm are shown in Table 5-5. These depletions represent potential impacts to the upper, middle, and


lower reaches of the basin, and are quantified as the flow depletion predicted near the mouth of the Deschutes River in Tumwater.

The volume of depletions in acre-feet was split out between the closure period and the non-closure period because the regional flow mitigation program will focus flow replacement during the closure period.


Model-Predicted Depletions for Deschutes River Basin

Application Phase Closure Period Winter Period

Max Summer Depletion (cfs)

Closure period Depletion (AF)

Max Winter Depletion (cfs)

Winter period Depletion (AF)

Lacey Phase 1 Lacey Phase 2 Lacey Phase 3 Subtotal Lacey Olympia Phase 1 Olympia Phase 2 Olympia Phase 3 Subtotal Olympia Yelm Southwest 1A Subtotal Yelm1

0.03 0.09 0.12 0.24

0.16 0.02 0.06 0.24

0.19 0.19

11.13 32.21 44.77 88.11

60.49 11.17 21.40 93.10

65.8 65.8

0.03 0.13 0.18 0.34

0.24 0.04 0.09 0.37

0.24 0.24

2.80 36.26 51.68 90.75

66.68 12.31 23.59

102.58

64.9 64.9

TOTAL: 0.67 cfs 247.01 AF 0.95 cfs 258.23 AF 1 Updated flow depletion modeling results from Golder Associates Technical Memo, November 14, 2010, 2010 Modeling Results:

Yelm Well SW1A Hydrologic Impact Assessment.

5.4.3 Flow Mitigation Using Water Rights Acquisitions

In accordance with Chapter 173-513 WAC, the Deschutes River is closed to further appropriation from April 15 to November 1. For the regional mitigation program, the cities of Lacey, Olympia, and Yelm propose to provide in-kind mitigation during the closure period through the acquisition and retirement of water rights. During months outside of the closure period, any mitigation requirement is dependent on instream flows. The cities have been collaboratively pursuing the acquisition of consumptive irrigation water rights that will mitigate predicted impacts by returning actual water to the river during the critical low-flow closure period. The cities propose to provide mitigation for the closure period by purchasing irrigation water rights and placing those water rights into the trust program or relinquishing them. Table 5-6 presents the regional package of water right acquisitions in the Deschutes River currently proposed by the cities of Olympia, Lacey and Yelm. The cities have the Smith and Jensen water rights under contract for purchase. The third water right is in the process of negotiation for purchase. The cities would propose to acquire an equivalent amount of water for the third water right if acquisition of this right is unsuccessful. The cities are confident that these water right acquisitions will be completed during Phase 1, even though in the implementation and phasing proposal described in Section 6, full mitigation for the McAllister Wellfield would not be required until later.


On paper, the water rights total 330 AFY. With a one third split – as outlined in the current Interlocal Agreement - that would provide up to 110 AFY available for the City’s use to offset predicted depletions for Phase 1, 2 and 3 of the McAllister Wellfield. Final water rights credit and phasing of the acquisition requirements would be determined after review by Ecology. Olympia is proposing that these acquisitions would be finalized on the phasing schedule and at the percentages described in Section 6, (see Table 6-2 on page 68) – at the latest. Actual water would thereby be returned to the river during the critical low-flow closure period in time to mitigate the predicted impacts of McAllister Wellfield withdrawals.

1 As defined in the McAllister Groundwater Model. See figure 1.3 on page 11.

2 In negotiation for acquisition at this time. May include acquisition of surrounding land.

The cities also gave higher priority to the acquisition of surface water rights in the upper and middle reaches of the Deschutes River, to ensure that mitigation was in the same reach as, or upstream of, predicted impacts. For Olympia, this approach provides a considerable amount of additional benefit to the upper and middle reaches of the river, since the majority of Olympia’s predicted impacts are in the lower reach. Table 5-7 quantifies how the specific location of these water rights corresponds to predicted depletions by reach of the Deschutes River. This is important, because the reach containing the point of diversion will get a direct benefit from retirement of these rights, as well as all downstream reaches. Mitigation ratios, which estimate the quantity of these benefits, also change for different reaches. Using ratios as a method of comparison, both the upper and middle reaches of the Deschutes River will receive a significant amount of flow benefit relative to Olympia’s predicted impacts, for both annual quantity and instantaneous flow.

Table 5-6 Regional Package of Deschutes River Water Rights Acquisitions

Water Right Certificate Modeled River

Reach1 Qa Qi

S2-00972CWRIS Dillard and Juanita Jensen

Upper 100 AFY 0.50 cfs

G2-26862GWRIS Ron Smith Farms

Upper 170 AFY 300 gpm (0.67 cfs)

Irrigation Water Right 2

Middle 60 AFY 0.37 cfs

Totals

330 AFY 1.54 cfs

Total potential water available to each city

110 AFY 0.51 cfs


Table 5-7 Deschutes Flow Mitigation By Reach for Closure Period

McAllister Wellfield Predicted Depletions Cumulative Impact Mitigation

Quantities Paper Right

Mitigation Ratio Predicted Depletions

AF1 cfs AF cfs AF cfs

Upper Reach

24.21 AF (0.06 cfs)

24.21 0.06 90 0.39 3.72:1 6.5:1

Middle2

16.27 AF (0.05 cfs)

40.48 0.11 110 0.51 2.72:1 4.6:1

Lower

52.62 AF (0.13 cfs)

93.10 0.24 110 0.51 1.18:1 2.1:1

1 Acre feet amounts for each reach calculated based on a relative percentage of CFS impact in order to match total depletion amount in Table 5-5.

2 In negotiation for acquisition at this time. May include acquisition of surrounding land.

Based on the quantities listed in the water rights, this package of water rights acquisitions achieves mitigation goals in all reaches of the river. Again, actual mitigation ratios will depend on Ecology evaluation of beneficial use history and other factors. A significant amount of work and coordination for implementing in-kind mitigation has already been completed, all of which demonstrate the feasibility of this mitigation approach and the Cities’ commitment to providing in-kind mitigation. Under contract with WestWater LLC, the Cities have negotiated two option agreements for purchase of irrigation water rights, and are in negotiations for acquisition of a third irrigation water right in the middle reach of the Deschutes River. Figure 5-6 shows these acquisitions on a map of the Deschutes River.

Appendix E provides a more detailed review of the Jensen and Smith water right acquisitions, and copies of the Purchase and Sale and Option Agreements for the Smith and Jensen rights. Appendix E also includes copies of the Beneficial Use Analyses (BUA) for the Ron Smith water right (G2-26862GWRIS) and the Jensen water right (S2-00972CWRIS). Beneficial use information on the third irrigation water right in the middle reach will be forthcoming when acquisition terms are finalized.

Olympia is also committed to pursue the use of Class A reclaimed water for flow augmentation in the Deschutes Basin in future years. The City’s 2009-2014 Water System Plan, which was recently approved by WDOH and adopted by the City Council, outlines a strategy to advance the use of reclaimed water as defined in Council-adopted policies. One of the nine activities identified in the plan is to “partner with the Squaxin Island Tribe, the LOTT Alliance and others to pursue opportunities for use of reclaimed water for stream restoration purposes.” These activities, although outside the scope of this mitigation plan, have the potential to provide future benefits to the lower reach of the Deschutes River.



Figure 5.6. Deschutes River Flow Mitigation



5.4.4 Non-Flow Land Acquisition and Habitat Restoration

During the non-closure period, which is regulated by established in-stream flows, the Cities propose to provide substantial “non-flow” mitigation which would benefit salmonid habitat year-round and not exacerbate winter high-flow conditions. Our review of the Deschutes River USGS stream flow data at the Tumwater gage indicates the river meets or exceeds the established in-stream flow more than 70% of the time during the non-closure (or “winter”) period. Water is theoretically available for appropriation during these periods when in-stream flows are met. Conversely, this same historical data suggests the river fails to meet minimum in-stream flows approximately 30 percent of the non-closure period. These periods of winter low flows suggest, therefore, that mitigation is warranted to offset predicted winter impacts. The Cities evaluated options for providing flow mitigation during winter low flow periods, and found two principal challenges: 1) the lack of active water rights with winter time use that can be purchased and retired, and 2) the inability to predict low flows and time mitigation actions so as to address low flows and not exacerbate high flows/flooding. The Cities propose land acquisition and habitat restoration as the most appropriate strategy for “winter” impacts. These actions can have greater biological benefits during the winter than flow mitigation. For example, in the Deschutes, one of the primary limiting factors for fish in the winter is the availability of off channel rearing habitat and/or large woody debris that provide protection from high main stream flows. In addition, these restoration actions will have year-round (high flow and low flow) benefits. A significant amount of work and coordination for implementing out-of-kind mitigation has already been completed, all of which demonstrate the feasibility of this mitigation approach and the Cities’ commitment to providing this mitigation. The Cities have signed an Option Agreement to jointly purchase over 200 acres of the Ron Smith Farm, which is located in the upper reach of the Deschutes River. This Option Agreement is included in Appendix E. This property is currently a sheep ranch and has been altered considerably from a natural condition. The property includes Deschutes River frontage, most of the frontage of the outlet channel from Lake Lawrence, and springs and seeps that flow via the outlet channel to the Deschutes River. This is our proposed acquisition and habitat restoration site for mitigation in the Deschutes River for non-closure periods. To evaluate the Smith Ranch’s potential for water rights mitigation, the cities contracted with Anchor QEA to conduct an acquisition and restoration assessment of the site. This site is uniquely situated to provide habitat restoration benefits, as noted in the Anchor QEA report,

“The Smith Ranch property is an appropriate site to acquire in order to meet desired outcomes for mitigation associated with the Cities’ proposed water rights applications. The Smith Ranch is an ideal location to provide mitigation for predicted flow depletions to all the downstream segments of the river. In this way, the benefits derived from property acquisition, cessation of intensive agricultural land practices, and recommended restoration actions will benefit the full extent of the watershed that is predicted to be impacted by the water withdrawals.”

Anchor QEA identified a number of restoration options for the site, and then utilized a point system for quantifying habitat depletion points based on predicted impacts, and mitigation “credit” points for


each property protection and restoration action. This point system was adapted from the methodology used in the Salmon/Washougal Basin for quantifying habitat mitigation. We recognize that use of this credit/debit system in the Deschutes Basin is subjective and relies heavily on professional judgment, but it does provide a method of quantifying the mitigation value of the projects that are included in this mitigation plan. The Anchor QEA report, Initial Acquisition and Restoration Assessment of the Smith Ranch, is included in Appendix E. Table 5-8 is reproduced from the Anchor QEA report and summarizes the habitat depletion points that were calculated based on the cities’ cumulative predicted impacts that were available at the time the report was completed. The predicted depletions and the depletion points are reduced as a result of Yelm’s revised modeling scenario for Yelm Well SW1A. This information will be updated when Yelm submits its Mitigation Plan.

1 Flow depletion sources: Golder 2008; Thomas 2008a, 2008b, and 2008c; Riley 2008; and City of Olympia and Nisqually Indian Tribe

2008. The depletions listed in the table are the cumulative predicted depletions for the following water right applications: City of Lacey – New water right applications G2-29165 (Madrona Wellfield), G2-29304 (Evergreen Estates), G2-30248 (Hawks

Prairie #2), G2-30249 (Betti Well), G2-30250 (Meridian Campus), and G2-30251 (Marvin Road) City of Olympia and Nisqually Indian Tribe – Water right change applications for Certificate Nos. 8030 and S2-001105C

(McAllister Springs) and Permit No. 10191 (Abbott Springs) City of Yelm – Phases I and II of new water right applications G2-29084, G2-29085, and G2-29086 (SW Yelm Wellfield)

2 The numbers in Table 5-8 represent the worst-case impact scenario, and do not include updated flow depletion modeling results from

Golder Associates Technical Memo, November 14, 2010, 2010 Modeling Results: Yelm Well SW1A Hydrologic Impact Assessment. Modeling results show that Yelm’s impacts are reduced with their new pumping proposal.

The Cities propose a package of actions that will total 4,327 mitigation points, 2,447 points more than is required using the point scoring system. This results in a ratio of 2.3:1 for non-flow mitigation actions. An aerial photograph, showing the approximate locations of the proposed habitat restoration actions is included in Figure 5-7. These actions include:

Acquire the Smith Ranch and cease farming activities by 2012. Reshape existing channel from Main Spring (2A) Re-establish the wetland around smaller springs on the ranch (2D) Construct a small live cribwall to address erosion along the Deschutes River (3A) Replant high density 50-foot riparian buffer and install buffer fence along the river (4A) Replant low density 50 to 200 feet riparian buffer along the Deschutes River (4B)

Table 5-8 Winter Flow Depletion Impact Calculation for Cities of

Olympia, Lacey and Yelm

River Reach Reach Length

Predicted Maximum Winter Impacts Flow Depletion1, 2

Scoring System for Depletion

Points per 0.1 cfs-mile

Depletion Points

Incremental Depletion in Reach

Cumulative Depletion

Upper Deschutes

8.8 miles 0.39 cfs 0.39 cfs 343

Middle Deschutes

7.0 miles 0.14 cfs 0.53 cfs 10 371

Lower Deschutes

11.0 miles 0.53 cfs 1.06 cfs 1,166

Total to Mitigate for Winter Flow Depletions 1,880


The benefits of these specific actions were summarized by Anchor QEA (2010):

“These recommended actions were selected because each action make significant contributions to address the habitat limiting factors, immediately address some of the most impactful alterations resulting from the intensive agricultural practices, and set the stage for future restoration. The benefits of these actions would extend far beyond the boundaries of the property, thereby significantly contributing the restoration of the Deschutes River watershed.



Figure 5.7. Proposed Restoration Actions at Smith Ranch (from Anchor QEA 2010)



A timeframe of proposed actions and how they correspond with the phases of the McAllister Wellfield development is included below in Table 5-9. All non-flow mitigation actions are proposed to be completed by the end of 2018, during Phase II development of the McAllister Wellfield.

Table 5-9 Deschutes Property Acquisition and Habitat Restoration:

Schedule for Completing Actions

Action Timeframe1 McAllister Wellfield

Phases

Complete property acquisition 2011 Phase I

4A (partial) – Install Buffer Fence 200 feet from Deschutes River and along mouth of Lake Lawrence outlet

2011 Phase I

4A (partial) – Replant 50-foot Riparian Buffer 2012-2013 Phase I

3A – Construct Live Cribwall Along Eroding Reach of Deschutes River 2013-2015

Phase I and II

2A –Reshape Existing Channel from Main Spring

2013-2015 Phase I and II

2D – Re-establish Wetland Around Smaller Springs 2013-2015 Phase I and II

4B – Replant Riparian Buffer 50 to 200 feet from the Deschutes River.

2014-2016 Phase I and II

Note: Timeframe assumes water rights decisions are made by March 2011.

5.4.5 City of Olympia Share of Non-Flow Mitigation

The Cities are committed to fully implement this package of non-flow mitigation actions. Land acquisition and habitat restoration activities are being jointly pursued by the Cities, and the three cities will be working collaboratively to successfully implement the entire package of acquisition and restoration actions. To mitigate predicted McAllister Wellfield depletions, the City would fund a portion of the non-flow package. This would include acquisition of the Smith Property and completion of the specific habitat restoration actions outlined in the Anchor QEA report. The Cities will update the Deschutes Interlocal Agreement to define proportional cost shares, outline responsibilities and accountabilities for implementation of habitat restoration work, and identify funding mechanisms.

5.5 Groundwater Drawdown Effects

The City cannot anticipate which existing wells will experience problems due to drawdown effects from the McAllister Wellfield (Section 2.3.2). However, it is possible that some wells could be affected. Figures 2-3, 2-4 and 2-5 show the predicted groundwater drawdown in the area of the McAllister Wellfield during full production pumping. Given the high transmissivity of the McAllister Gravel Aquifer, the predicted drawdown of five feet in the immediate vicinity of the wellfield is relatively small.


For cases where a landowner believes that a well has become unproductive due to pumping at the McAllister Wellfield, the City will work with the landowner to determine whether the problem is due to pumping at the Wellfield. Where a claim is validated, the City will carry out one of the following mitigation actions:

Provide financial assistance to the landowner to re-drill an existing well. Install a replacement well, or arrange for a replacement source of water supply.


Section 6 Conclusion Development of the McAllister Wellfield is a critical public works project that will provide a more protected and productive source of drinking water for the City and the Tribe. The Wellfield will allow the City to transition off the vulnerable McAllister Springs water source – a goal of the City for more than a decade, and similarly allow the Tribe to transition off its shallow, low-producing wells near the Nisqually River.

The City applied a complex numerical groundwater model to predict impacts to surface water bodies in the Nisqually River and Deschutes River Basins. Impacts are predicted for when the McAllister Wellfield is pumping at full production capacity to provide the City and Tribe with up to 25.2 MGD (peak day 26.06 MGD).

This mitigation plan, presents a responsible program to offset the predicted effects of the McAllister Wellfield on water resources in the Nisqually River and Deschutes River watersheds. This plan is in keeping with both the City’s and Tribe’s sustainability philosophy and stewardship ethic. It recognizes the benefits to McAllister Creek by shifting production from McAllister Springs to the McAllister Wellfield site. Following transfer to the McAllister Wellfield, the City and Tribe have formally agreed to keep the McAllister Springs and Abbott Springs area in a natural, protected state.

The mitigation plan has been developed in a regional context, consistent with the Nisqually Watershed Management Plan. The Nisqually Tribe and the Cities of Olympia, Lacey and Yelm have gone to great lengths to coordinate efforts on water supply development and water resource mitigation. The City and Nisqually Tribe believe these efforts will result in a better outcome for regional water resources. Coordinated mitigation efforts are summarized in Table 6-1.


Table 6-1 Summary of Partnered Mitigation Strategies

Water Body Mitigation Strategy Mitigating Partners Partnering Mechanism

McAllister Creek Olympia’s Transition off McAllister Springs

City of Olympia Nisqually Indian Tribe City of Lacey City of Yelm

Mitigation Plans and Interlocal Agreements

Nisqually River 1. Dam Releases by Tacoma Power

City of Olympia Nisqually Indian Tribe

Memorandum of Agreement signed May 14, 2008

2. Groundwater Protection Zone

3. Ohop Creek Restoration

Lake Saint Clair Water Rights Acquisition

City of Olympia Nisqually Indian Tribe

Memorandum of Agreement signed May 14, 2008

Deschutes River 1. Water Rights Acquisition

City of Olympia City of Lacey City of Yelm

Interlocal Agreements and Amendments effective November 2007, August 2008, and January 2010

2. Land Acquisition for Habitat Protection

3. Habitat Restoration

Tri-Lakes Complex at Woodland Creek

1. Reclaimed Water Infiltration Facility

City of Olympia City of Lacey

Interlocal Agreement effective October 10, 2008

2. Land Acquisition/Conservation Easements for Habitat Protection

Recognizing that predicted impacts are not limited to the Nisqually Watershed and extend to the Deschutes Basin, the Cities have also met on several occasions with the Squaxin Island Tribe. The Cities have appreciated the input of the Squaxin Tribe, and have incorporated requested changes to the groundwater modeling to better reflect existing hydrogeology, as well as refinements to mitigation proposals.

The City and Tribe request Ecology link formal deadlines for mitigation requirements to the three phasing milestones shown in Tables 6-2 and 6-3 so that the timing of flow and non-flow mitigation actions will precede or match the corresponding impact. At this time, the City and the Tribe have made significant progress on these mitigation actions, and anticipate that most of them will be completed before the phasing milestones shown below.


Table 6-2 Proposed Implementation of Closure Period Flow Mitigation for

Modeled Water Bodies by Phase (AFY) Proportion of mitigation proposed

McAllister Valley1

Nisqually River

Woodland Creek Basin2

Deschutes Valley3

Phase I – 65% -7,260 3,859 94 60.5

Phase II – 77% 0 0 18 11.2

Phase III – 100% 0 0 33 21.4

Total predicted average impacts (AFY)

-7,260 3,859 145 93.1 1 This includes predicted maximum annual depletions of .12 cfs at Lake St. Clair and flow increases at McAllister Springs and

McAllister Creek. 2

This includes year-round predicted maximum depletions at Pattison, Long and Hicks Lakes and associated wetlands. Flow mitigation occurs via reclaimed water infiltration. During winter, mitigation is being accomplished through both flow and non-flow actions.

3 This includes flow mitigation during closure period, not non-flow related mitigation proposed for the Deschutes Valley. Table shows total predicted depletions from the McAllister Wellfield development phases 1, 2 and 3.

Table 6-3 Proposed Implementation of Non-Flow Mitigation for

Modeled Water Bodies by Phase

Proportion of mitigation proposed

Woodland Creek Basin (acres of habitat

acquired and protected)1

Deschutes Valley (habitat mitigation points)2

Phase I – 65% 4.23 65 percent of Olympia’s portion

Phase II – 77% .78 77 percent of Olympia’s portion

Phase III – 100% 1.5 100 percent of Olympia’s portion

Total required acres/points 6.51 Olympia’s portion of 4327 1 Habitat acquisition and protection requirement is 21.7% of 30 acres based on Olympia’s portion of the predicted impacts to the

Woodland Creek basin. 2 Olympia’s cost share and proportion of points will be determined through an interlocal agreement with the cities of Lacey and Yelm

regarding Deschutes River mitigation.

The City and Tribe also request that Ecology view the Cities of Olympia, Lacey and Yelm’s individual water rights applications in a regional context and, accordingly, that Ecology recognize net regional benefits of mitigation and changes in points of withdrawal, including where a net improvement in flow will result. This includes recognition of the net increase in flow to the McAllister Springs/Creek system and consideration of this benefit in the context of the full mitigation proposal.

The City and Tribe request that Ecology approve this Mitigation Plan and process the water rights change applications necessary to permit the City and Tribe to proceed with development of Phases I, II and III of the McAllister Wellfield.



References CDM, 2002a, Interim Report, Model Construction and Steady-State Calibration, McAllister

Wellfield Numerical Model. April 2002.

CDM, 2002b, Final Report – Draft (Sections 5-8), McAllister Wellfield Numerical Model. July 2002.

Drost, B.W.; D.M. Ely and W.E. Lum, II, 1999, Conceptual Model and Numerical Simulation of the Ground-Water Flow System in the Unconsolidated Sediments of Thurston County, Washington, U.S. Geological Survey Water Resources Investigations Report 99-4165.

Golder Associates, Inc., 2006, Report on Groundwater Modeling of Water Right Applications and Transfers, prepared for City of Lacey Water Resources Division, February 16, 2006. S.S. Papadopulos and Associates (SSPA), 2008, McAllister Wellfield Hydrologic Impacts Analysis

(Technical Memorandum August 18, 2008).

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