SEPA ENVIRONMENTAL CHECKLIST

SEPA Environmental checklist (WAC 197-11-960) July 2016 Page 1 of 51

SEPA ENVIRONMENTAL CHECKLIST

Purpose of checklist: Governmental agencies use this checklist to help determine whether the environmental impacts of your proposal are significant. This information is also helpful to determine if available avoidance, minimization or compensatory mitigation measures will address the probable significant impacts or if an environmental impact statement will be prepared to further analyze the proposal.

Instructions for applicants: This environmental checklist asks you to describe some basic information about your proposal. Please answer each question accurately and carefully, to the best of your knowledge. You may need to consult with an agency specialist or private consultant for some questions. You may use “not applicable” or "does not apply" only when you can explain why it does not apply and not when the answer is unknown. You may also attach or incorporate by reference additional studies reports. Complete and accurate answers to these questions often avoid delays with the SEPA process as well as later in the decision-making process. The checklist questions apply to all parts of your proposal, even if you plan to do them over a period of time or on different parcels of land. Attach any additional information that will help describe your proposal or its environmental effects. The agency to which you submit this checklist may ask you to explain your answers or provide additional information reasonably related to determining if there may be significant adverse impact.

Instructions for Lead Agencies: Please adjust the format of this template as needed. Additional information may be necessary to evaluate the existing environment, all interrelated aspects of the proposal and an analysis of adverse impacts. The checklist is considered the first but not necessarily the only source of information needed to make an adequate threshold determination. Once a threshold determination is made, the lead agency is responsible for the completeness and accuracy of the checklist and other supporting documents. Use of checklist for nonproject proposals: For nonproject proposals (such as ordinances, regulations, plans and programs), complete the applicable parts of sections A and B plus the SUPPLEMENTAL SHEET FOR NONPROJECT ACTIONS (part D). Please completely answer all questions that apply and note that the words "project," "applicant," and "property or site" should be read as "proposal," "proponent," and "affected geographic area," respectively. The lead agency may exclude (for non-projects) questions in Part B - Environmental Elements –that do not contribute meaningfully to the analysis of the proposal.

A. Background [HELP]

1. Name of proposed project, if applicable:

White River Restoration Project (hereinafter WRRP or Project), Appendix A Figures 1 and 2


2. Name of applicant: Doug Beagle, Development Services Director City of Sumner

3. Address and phone number of applicant and contact person:

1104 Maple Street Sumner, WA 98390

4. Date checklist prepared:

August 10, 2021 5. Agency requesting checklist:

City of Sumner Community Development 6. Proposed timing or schedule (including phasing, if applicable):

May 2022, through December 31, 2026. Construction is scheduled to begin in May 2022 and is expected to occur over an estimated five construction seasons. External factors such as stipulations tied to grant funding may require an extension of the construction period beyond five years. Typical daytime construction hours are anticipated. There will be construction elements, such as dewatering pumps, that will run for 24 hours a day when needed. In-water work, except for the removal of containment and isolation systems, will occur during a work window approved by the WDFW and the USACE: July 1-August 31.

7. Do you have any plans for future additions, expansion, or further activity related to or connected with this proposal? If yes, explain.

Concurrent with and related to the WRRP, the BNSF Railway (BNSF) has proposed to install ten new staging tracks on 40 acres west of the existing tracks (the BNSF Sumner Staging Tracks Project, Appendix A Figures 1 and 2). The longest track would run for approximately 9,200 feet and the shortest would be 7,700 feet. The longest track would terminate just north of Lake Tapps Parkway E, at the northern end, and just north of the Sumner Distribution Center, at the southern end. Pursuant to the Interstate Commerce Commission Termination Act, the Sumner Staging Track Project is not subject to state and local permitting requirements and consequently is not subject to review under SEPA. See also, City of Auburn v. U.S. Gov't, 154 F.3d 1025, 1031 (9th Cir. 1998), as amended (Oct. 20, 1998). BNSF is obtaining all required federal authorizations for the BNSF


Sumner Staging Track Project (e.g. Clean Water Act Section 404, Clean Water Act Section 401, National Pollutant Discharge Elimination System Construction Permit, Section 7 Consultation under the Endangered Species Act, Coastal Zone Management Certification, and National Historic Preservation Act Consultation). There are no plans for future additions or expansions of the WRRP. Initial staging and construction of the WRRP will utilize portions of the former Sumner Meadows Golf Course property. As staging and construction is completed, the portion of the Sumner Meadows Golf Course that is not permanently utilized for the WRRP or the BNSF Sumner Staging Track Project will be redeveloped consistent with applicable zoning and consistent with the environmental analysis set forth in the Sumner Meadows Draft Environmental Impact Statement (EIS) prepared in May 2014, with a Final Revised Mitigated Determination of Non-significance (MDNS) issued December 23, 2014 by the City of Sumner(PLN-2014-0064, Sumner Meadows Industrial Park). The City is considering other restoration projects along the White River, including immediately the reach of stream between the WRRP north to Stewart Avenue. These projects are in conceptual stage at this time, and will require property acquisition before a final design or permitting process would begin, so there is no timeline for these projects at this time. In the future, the WRRP may require maintenance of restoration plantings and in-channel habitat structures. All federal, state, and local permits will be obtained as required prior to performing maintenance work. The City may pursue similar ecosystem restoration work on other City-owned properties along the White River separate from the WRRP. The City is in the process of modifying water rights to support the City’s water supply, including meeting future demand projections in its service area. It is likely that the City will need to provide mitigation to support the issuance of new or changed water rights. To the extent necessary, the City intends to use a subsection of the WRRP to provide a portion of the mitigation required for approval of the City’s water right applications. A portion of the WRRP may be delineated as full or partial mitigation for these water rights modifications.


8. List any environmental information you know about that has been prepared, or will be

prepared, directly related to this proposal.

Anderson, S. and K. Jaeger. 2019. Coarse Sediment Dynamics in the White River Watershed. Prepared by the USGS Washington Water Science Center for King County Water and Land Resources Division.

Berk Consulting.et.al. 2014. Sumner Meadows Docket, Draft Supplemental Environmental Impact Assessment. Prepared for the City of Sumner Comprehensive Plan Annual Amendments.

Jacobs Engineering Group. 2020. Avoidance and Minimization Measures - Technical Memorandum: for The White River Restoration Project and Sumner Staging Tracks Project. Prepared for BNSF and The City of Sumner.

Jacobs Engineering Group. 2020. Cumulative Impacts Analysis: White River Restoration Project and Sumner Staging Tracks Project. Prepared for BNSF.

Natural Systems Design (NSD). 2019. Lower White River Restoration Project 60% Basis of Design Report. Preliminary Review Draft. Prepared for City of Sumner.

NSD. 2020. Bank Stabilization Discussion and Alternatives Analysis – Lower White Restoration Project. Prepared for the City of Sumner.

NSD. 2020. Proposed Permanent Stormwater Management Approach: White River Restoration Project (Review Draft). Prepared for City of Sumner.

NSD. 2020. Regulatory Floodplain Context – White River Restoration Project. Prepared for the City of Sumner.

NSD and Jacobs Engineering Group. 2020. Clean Water Act 404(b)(1) Alternatives Analysis: White River Restoration Project and Sumner Staging Tracks Project. Prepared for BNSF and The City of Sumner.

Widener and Associates. 2020. Biological Evaluation: White River Restoration Project and Sumner Staging Tracks Project.

Widener and Associates. 2020. Wetland Investigation and Delineation Report: White River Restoration Project and Sumner Staging Tracks Project. Prepared for BNSF and The City of Sumner.


All of these materials, with the exception of the Regulatory Floodplain Context memo (NSD 2020), also present actions undertaken by BNSF as part of the Sumner Staging Track Project which are not a part of the WRRP action being evaluated in this SEPA checklist.

9. Do you know whether applications are pending for governmental approvals of other proposals directly affecting the property covered by your proposal? If yes, explain.

Concurrent with and related to the White River Restoration Project (WRRP), BNSF is seeking federal permits for the Sumner Staging Tracks Project on a 40-acre site adjacent to their existing main line. (This is a joint application by BNSF and the City including both the Sumner Staging Tracks Project and the White River Restoration Project.) As noted above, the Sumner Staging Tracks Project is not subject to state or local permitting and consequently is not subject to SEPA review. All other portions of the WRRP, specifically river and floodplain restoration and associated required relocating of utilities are included in this application for SEPA determination, Appendix A Figures 1 and 2. The City of Sumner’s water right applications, identified in Section 3.b, are pending with the Washington State Department of Ecology. The mitigation being proposed by the City for its water right applications will likely include portions of the WRRP in order to provide net ecological benefits to fish and related aquatic resources in the Lower White River and Puyallup River below the confluence. The City anticipates undertaking a separate SEPA review of the water rights application, including use of the WRRP as a portion of the mitigation for that application, when appropriate (WAC 197-11-050(2)).

10. List any government approvals or permits that will be needed for your proposal, if known.

White River Restoration Project:

Federal permits and authorizations including approvals from:

o United States Army Corps of Engineers under:

Clean Water Act, Section 404


Rivers and Safe Harbors Act, Section 10

Section 106 of the National Historic Preservation Act

o National Marine Fisheries Service and US Fish and Wildlife Service under Endangered Species Act, Section 7

o National Marine Fisheries Service under the Magnuson-Stevens Fisheries Conservation and Management Act, Section 305(b)(4).

o Washington Department of Ecology – federally delegated authority for implementation of Clean Water Act Section 401 Water Quality Certification

State and local permits including approvals from:

o Washington Department of Ecology Construction Stormwater General Permit (CSWGP)

o Washington State Department of Fish and Wildlife – Hydraulic Project Approval

Relocation of utilities and floodplain restoration are being pursued as separate Hydraulic Project Approvals from Washington State Department of Fish and Wildlife.

o City of Sumner local approvals under:

State Environmental Policy Act

Sumner Critical Areas Ordinances, specifically Resource, Wildlife, and Hazard Area (RWHA) approval

State Shoreline Management Act Exemption for the WRRP

Shoreline Conditional Use Permit and Shoreline Substantial Development Permit for the Utilities Relocation

Floodplain Development Permit

Cut and Grade Permit

Demolition Permit

Civil, and Building Permits for Utilities Relocation


The City is also pursuing a Washington State Department of Ecology Groundwater Application Approval and Groundwater Change Application Approvals under RCW 90.03.290 (see Section 3.b). Portions of the WRRP may be used as mitigation for the ground water application.

11. Give brief, complete description of your proposal, including the proposed uses and the size of the project and site. There are several questions later in this checklist that ask you to describe certain aspects of your proposal. You do not need to repeat those answers on this page. (Lead agencies may modify this form to include additional specific information on project description.)

Project Purpose: The White River Restoration Project (WRRP) will improve aquatic habitat and water quality and reduce flood risk by reconnecting the White River with its floodplain. The project will expand flood storage and reestablish geomorphic processes in this channelized reach of the White River over approximately 203 acres. The project will enable frequent activation of the floodplain, reestablish habitat-forming processes, and maintain those habitats over time, even with continued channel aggradation and climate change. The WRRP will restore native vegetation, including forested wetland, mixed coniferous and deciduous upland forest, and scrub-shrub plant communities. The proposed stream and floodplain restoration will improve rearing opportunities for salmonids by providing slower water habitats, increased channel complexity, increased number and depths of pools, and more frequently engaged floodplain food webs. The new channel network will be able to adjust to current and future sediment loads. A related project purpose is to provide habitat (or “out-of-kind”) mitigation for the City’s pending water right applications under the Foster Pilot Project authority at RCW 90.94.090(9)(c) to the extent determined necessary to establish net ecological benefits to fish and related aquatic resources in the Lower White River and Puyallup River below the confluence. Sumner is one of five legislatively-authorized pilot projects designed to demonstrate alternative mitigation sequencing, and the WRRP is the City’s principal out-of-kind compensatory mitigation for its water right applications to the extent such mitigation is determined to be necessary for the applications. See Section 3.b.


Project Actions: The WRRP will lower the existing floodplain via grading to restore a more natural channel and floodplain configuration and allow for significant expansion of aquatic habitats. The new floodplain configuration will allow for dynamic channel processes to occur while maintaining stable boundaries to protect adjacent developments. New, more natural, channels will be installed for the Dieringer Tailrace and #9 Ditch. Twenty-one Engineered Log Jams (ELJs) will be installed in the White River channel and new side channels. Approximately 163 acres will be planted to restore native floodplain and riparian plant communities. The existing Sumner Link Trail will be rerouted along the east perimeter of the restoration site. Portions of the trail on the west side of the river will be relocated to be further away from the active channel. A new 16-foot-wide trail will be paved on the forested bench at the eastern end of the floodplain grading area. The trail will cross the Dieringer Tailrace on a single-span pedestrian bridge with pedestrian railings. The relocated Sumner Link Trail will connect to the existing trail, maintaining the north and south connection points. In-water work will be necessary to complete the project. In-water work will include rerouting of the Dieringer Tailrace and #9 Ditch to natural flow paths, isolation of off-channel connection points with the existing White River channel, placement of ELJs, and installation of complex wood revetments on the White River. All in-water work will occur within the designated in-water work window (July 1-August 31) with the exception of isolation cofferdam removal, which may occur until November 1. As part of the project, the at-grade railroad crossing at 24th Street E will be closed permanently. The bridge at 148th Avenue E that crosses the Dieringer Tailrace will be removed. An existing utility corridor with above and below ground lines occurs along 24th Street E with lines attached to the existing pedestrian bridge that are buried on the east side of the river. These lines will be modified and/or relocated to allow for greater floodplain reconnection without increasing risk to infrastructure. These relocations will generally occur during the first phases of the project. Utility relocations include:


Existing Puget Sound Energy (PSE) overhead power lines will remain in their current corridor, but poles will be moved to maximize floodplain area, as some existing poles would interfere with project elements.

PSE gas lines will be installed in new conduit that will be directionally drilled below the White River and floodplain. The Horizontal Directional Drill (HDD) will be approximately 24.5 feet below the thalweg (lowest point) in the White River.

Water, sewer, and communication lines will be bored below the eastern floodplain from the east side of the 24th Street pedestrian bridge to locations east of the BNSF tracks.

As part of the sewer line relocation, an existing sewer pump station will be relocated to a location east of the BNSF tracks. It will be drilled at a deep enough depth as to not intersect or impact the White River.

All underground utilities will be drilled deeper than their existing depths. Utility corridors will be planted with native shrubs that can be cleared if access is needed to the corridors. See Appendix A, Figures 1 and 2 for utility corridor locations. See Appendix B, Attachment 1, Sheets U-1 and U-2 of the Permit Drawings. See also Appendix B, Attachment 5, City of Sumner Public Works, 24th St. E. Utility Relocation Plan Set and Appendix B, Attachment 6, Proposed HDD Plan and Profile Sheet.

12. Location of the proposal. Give sufficient information for a person to understand the precise location of your proposed project, including a street address, if any, and section, township, and range, if known. If a proposal would occur over a range of area, provide the range or boundaries of the site(s). Provide a legal description, site plan, vicinity map, and topographic map, if reasonably available. While you should submit any plans required by the agency, you are not required to duplicate maps or detailed plans submitted with any permit applications related to this checklist.

The WRRP will occur on a 203-acre portion of the former Sumner Meadows Golf Links golf course, as well as agricultural land south of the golf course, river banks west of the White River between 16th and 24th Streets, and utility corridor work west of the river along 24th Street East (Appendix A, Figure 1). Restoration will include increased flood storage capacity and instream habitat improvements along both banks of the lower White River. The


restoration is proposed to improve habitat and water quality ecosystem functioning through development of a more resilient river channel and floodplain corridor that is connected with a diversity of restored native riparian forest, side channels, and wetlands. The proposed restoration will reduce flood risk by providing increased floodplain capacity.


Figure 1. Project Overview Map


B. Environmental Elements [HELP] 1. Earth [help] a. General description of the site: (circle one): Flat, rolling, hilly, steep slopes, mountainous, other _____________

The project area is in the relatively flat alluvial floodplain of the Lower White River; the floodplain has a gradual rise in elevation of approximately 4’ from the south to the north. The channel banks of the White River can be steep at 50% or steeper in places.

b. What is the steepest slope on the site (approximate percent slope)?

The site generally is flat; however, portions of the White River channel banks are classified by the City of Sumner as 20-40% steep slopes.

c. What general types of soils are found on the site (for example, clay, sand, gravel, peat,

muck)? If you know the classification of agricultural soils, specify them and note any agricultural land of long-term commercial significance and whether the proposal results in removing any of these soils.

Soils are typical for an alluvial floodplain in this region. Soil types within the project area include silty clay loam (~32.6% of the project area), fine sandy loam (~27.8%), muck (~21.2%, primarily located immediately south of the Dieringer Tailrace), loam (~12%), fine sand (~4.3%) silt loam and silt clay loam (combined are ~1.5%) and riverwash (~0.6%). Approximately 29.2% of the site is composed of soils whose primary component is classified as prime agricultural land. Another ~70.1% is classified prime agricultural land if drained or if drained and either protected from flooding or not frequently flooded during the growing season.

d. Are there surface indications or history of unstable soils in the immediate vicinity? If so,

describe.

No indications of unstable soils are known to exist within or immediately adjacent to the project area. Several areas associated with the BNSF railway and the banks of the White River within the project site are mapped as steep slopes between 20% and 40% gradient (City


of Sumner GIS). Steeper slopes (mapped by Sumner GIS as between 40% and 100%) exist outside of the project area, near the southeast extent of the project boundary.

e. Describe the purpose, type, total area, and approximate quantities and total affected area of

any filling, excavation, and grading proposed. Indicate source of fill. Staging and Stockpiling Area The northern section of the Project area is owned by the City and will be graded for access to the site during all construction phases and for use as a staging and stockpiling area. Stabilized construction access points will be established and maintained for access to and from local roadways. All constructed landscape water features (i.e., golf course ponds) and drainage ditches in the staging and stockpiling area will be filled, totaling approximately 10.5 acres of constructed landscape water features and approximately 1,350 linear feet of drainage ditch. Construction equipment, materials such as streambed gravel, excess excavated material, temporary storage of unsuitable material and/or obstructions, plant materials and large wood will be stored in the staging and stockpiling area. The primary access locations will be from Stewart Road, 24th Street E on the east side of the river until the 24th Street E crossing is removed, 24th Street E on the west side of the river, 16th Street, and the right-of-way east of an existing building at the south end of the site. At the completion of construction, the staging area will be redeveloped consistent with applicable zoning and the Sumner Meadows Draft Environmental Impact Statement (EIS) prepared in May 2014. Floodplain Excavation and Grading The project would involve both filling and grading. Approximately 760,000 cubic yards (CY) of material excavated for the floodplain improvements will be utilized as fill for the staging tracks embankment as part of the Sumner Staging Tracks Project. While floodplain excavation and grading will occur throughout the duration of the project, most of the work would be completed in the first two years. Excavation will begin with excavators, scrapers, off-road trucks, and dozers. In the first two years, approximately 760,000 CY of excavated material will be loaded in trucks or


scrapers and brought to the staging tracks location to be used to build the staging tracks embankment as part of the Sumner Staging Tracks Project. After the material for the staging tracks and floodplain capacity has been removed, floodplain fine grading for the WRRP will complete side channels, wetland, and habitat features occurring over multiple seasons. The final grading will add approximately 700,000 cubic yards of net floodplain storage in the White River between River Mile 2.5 and River Mile 4.2. A forested berm along the northern and eastern edge of the floodplain grading area will be constructed and reinforced with an integrated subsurface rock revetment. The forested berm will provide an enduring native forest perimeter around the north, east, and south sides of the restoration site, and reduce the chance of lateral channel migration against rock on the BNSF fill embankment. During the floodplain grading, existing depressions within the floodplain will be retained to encourage wetland development but will be graded to connect flowing side channels to prevent fish stranding following high-water events. Grading around the new side channels will occur to create habitat diversity including lower floodplain wetlands and higher upland forested riparian habitats. As noted above, the portion of the grading activities described herein that are part of BNSF’s Sumner Staging Tracks Project are exempt from local and state permitting, and thus are not part of the action evaluated in this checklist. Information regarding BNSF’s Sumner Staging Tracks Project is provided for context only. Side Channel Excavation Approximately 13 acres of new open-water side channels will be created. The majority of the side channel grading work will occur in uplands adjacent to the existing White River, the Dieringer Tailrace, and the #9 Ditch. The channel will be constructed prior to connections at the up and downstream ends to minimize impacts to the White River. Erosion control best management practices (BMPs) will be put in place prior to water diversion to reduce the risk of sedimentation and turbidity within the White River.


Excavators, dozers, and graders will be used to excavate side channels, and haul trucks will deliver the excavated material the staging tracks and/or storage at the staging area. Each channel will have the bottom lined with either native streambed material or imported streambed materials that are sized appropriately for the hydraulic conditions anticipated in the new channels. Side channel excavation will occur concurrently with the rest of the floodplain excavation and grading. However, filling of the existing Dieringer Tailrace and the #9 Ditch channels will not occur until water has been diverted to their proposed side channels. Approximately 0.51 acre of the #9 Ditch and approximately 1.45 acres of the Dieringer Tailrace will be filled.

Floodplain ELJ’s Two types of ELJ’s will be installed in the floodplain grading area:

Four Type 2 ELJs will be installed in the graded floodplain area.

Five Type 3 ELJs will be placed along the constructed side channels before flow is diverted.

ELJs placed along the proposed channels will include inclined key member logs that are buried into the channel bank at the back end and are dropped into the channel along the edge of the channel. Each ELJ will also have an excavated pool associated with it to provide additional habitat complexity. The key member logs and racking material will be woven between buried wooden piles to prevent significant lateral movement. The key member logs and piles will be lashed together with cable and steel clamps to ballast the key member log posts against buoyant forces. Galvanized 5/8-inch-diameter steel cables will be tensioned to a minimum of 1,000 pounds and at least four steel clamps will be used to secure each cable. A total of 8, 23-inch-diameter timber piles will be driven to secure each Type 2 ELJ in place. A total of 6, 18-inch-diameter timber piles will be driven for each Type 3 ELJ. Timber piles will be driven to a depth of 30 to 50 feet below the ground surface. A vibratory pile driver will be used to drive these timber piles wherever feasible, but some piles may need to be impact driven for part or most of the depth. (See permit drawings Page 5


through 9.)

Complex Wood Revetments Complex wood revetments installed in the floodplain grading area will be constructed in a similar manner and specification to those installed in water (see Water section below) with the exception of the need to isolate the work area from the flow of the White River. Isolation and dewatering may be necessary and will be completed in a manner that utilizes infiltration and/or on-site treatment prior to any off-site discharge, in compliance with the Water Quality Monitoring and Protection Plan (WQMPP). The revetments that cut through the existing Dieringer Tailrace will be installed after the Tailrace has been diverted to its proposed channel, so that work will occur in the dry.

Sumner Link Trail Realignment A new 12-foot-wide trail will be graded and paved on the forested bench at the eastern end of the floodplain grading area. The trail will cross the Dieringer Tailrace west of the proposed staging tracks, either on the culverts or on a single-span bridge supported by steel pipe piles located outside of the existing OHWM. The bridge at 148th Avenue E that crosses the Dieringer Tailrace will be removed while the filling of the Tailrace is occurring. Debris from this demolition activity will be hauled to the staging and stockpiling area for material salvage and/or approved off-site upland disposal.

f. Could erosion occur as a result of clearing, construction, or use? If so, generally describe.

Floodplain clearing and grading will produce exposed soils. Exposed soils will be stabilized during construction in accordance with the temporary erosion and sediment control plan. Long term soil stability will be accomplished through establishment of native plants. Temporary erosion control systems will be maintained until plantings are established consistent with the planting plan shown in Appendix B, Attachment 1, Sheets R-13 to R-18 of the Permit Drawings.

g. About what percent of the site will be covered with impervious surfaces after project

construction (for example, asphalt or buildings)? Approximately 2.2% of the site, or 4.56 acres will consist of impervious surface as follows:


1. The re-located Sumner Link trail. The Sumner Link

trail will be re-located to the outer perimeter along the east side of the site onto a forested berm that will surround the restoration site. The forested berm will be between 50 and 100 feet wide and will be planted with native vegetation. The trail surface will be paved to support year-round use and ADA accessibility.

2. The proposed stabilized PSE access road. Access to a PSE tower on the east side of the 24th Street Bridge will require a stabilized access road. The City proposes to install an articulate concrete block access road with porous substrate.

Neither installation is considered to be pollutant generating. Both the trail and access road will have motor vehicle access but at a very low frequency (e.g., 1-3 trips per month).

Table 1 below summarizes the proposed changes in impervious surface included in the White River Restoration project.

Table 1. Summary of impervious surface area changes proposed as part of the White River Restoration

Impervious Area

Quantity Removed (Acres)

Quantity Installed (Acres)

Net Change In

Impervious Surface (Acres)

Notes

24th Street 1.0 None -1.0 Only the traveled portion from the proposed City boundary to the north end of the tailrace bridge is included.

Sumner Link Trail

2.2 3.6 +1.4 Both widths assumed to be 12 feet wide

PSE Access Road

None 0.96 +0.96 20 feet wide

Total -3.2 +4.56 +1.36

h. Proposed measures to reduce or control erosion, or other impacts to the earth, if any:

The northern section of the project area is owned by the City and will be graded for access to the site during all construction phases and for use as a staging and stockpiling area. Stabilized construction access points will be established and maintained for access to and from local roadways.


Temporary erosion control measures will be installed in conjunction with clearing and grubbing activities. Clearing and grubbing will be sequenced for the access and phased work that is planned for each of the five construction seasons. Areas to be accessed in subsequent construction seasons will be left undisturbed with existing vegetation to limit site disturbance to only what is necessary to complete each construction phase. Temporary erosion control measures will be implemented to stabilize the site from erosion due to precipitation, local drainage, and/or river flooding. Erosion control measures are anticipated to include, temporary seeding, erosion control blanket, mulching, slope roughening, check dams, and fine grading to slow drainage, consistent with the Project’s anticipated NPDES permit.

2. Air [help] a. What types of emissions to the air would result from the proposal during construction,

operation, and maintenance when the project is completed? If any, generally describe and give approximate quantities if known.

No emissions to the air would result from the completed floodplain restoration and utility relocation components of the project. Emissions associated with construction (e.g., equipment exhaust from construction equipment, and dust from grading) will occur.

b. Are there any off-site sources of emissions or odor that may affect your proposal? If so, generally describe.

Emissions from the adjacent BNSF rail lines will continue but would not negatively affect the WRRP.

c. Proposed measures to reduce or control emissions or other impacts to air, if any:

All state-required emission and dust prevention planning and TESC measures will occur, and BMP’s will be used and inspected regularly.

3. Water [help] a. Surface Water: [help]

1) Is there any surface water body on or in the immediate vicinity of the site (including year-round and seasonal streams, saltwater, lakes, ponds, wetlands)? If yes, describe type and provide names. If appropriate, state what stream or river it flows into.


The lower White River flows through the project area between River Mile (RM) 2.6 and 4.3. From the project area, the lower White River continues in a southwest direction before joining the Puyallup River at Puyallup RM 10.0. The project area intersects the Cascade Water Alliance Dieringer Tailrace that outlets into the lower White River at RM 3.6, as well as the #9 Ditch, which originates east of the railroad and flows into a multibranched ditch network west of the railroad. The project is within Water Resource Inventory Area (WRIA) 10: Puyallup/White, Hydraulic Unit Code (HUC) 171100140204.

Within restoration project footprint, there are approximately 5.0 acres of constructed landscape water features, (i.e., constructed ponds from the former Sumner Meadows Golf Links golf course), and approximately 2,290 linear feet of drainage ditches.

2) Will the project require any work over, in, or adjacent to (within 200 feet) the described

waters? If yes, please describe and attach available plans.

Yes. Elements of the utility relocations will cross the White River, generally along the 24th Street corridor. Large wood installations including Engineered Log Jams (ELJs) and complex wood revetments will occur within the White River. All in-water ELJ and complex wood revetment installations will begin during the in-water work window of construction season 1 or 2 and will continue during in-work windows until completed. Utility Relocations

An existing PSE gas line will be directionally drilled below the White River. Existing utilities that cross the White River on the 24th Street pedestrian bridge will be modified to add necessary pressure relief valves. For the utilities that will be drilled east of the river temporary work including HDPE pipe fusing and layout and related construction will occur in uplands adjacent to the White River. Engineered Log Jams Installed in Water Twelve Type 1 ELJs will be placed within the White River. Dewatering around each jam location will be required unless flows have dropped below the installation location. Before dewatering, fish


exclusion will be conducted. Each ELJ will include inclined key member logs that are buried into the channel bank at the back end and are dropped into the channel along the edge of the river. Each ELJ will also have an excavated pool to provide additional habitat complexity. The key member logs and racking material will be woven between embedded wooden piles to prevent significant lateral movement. The key member logs and piles will be lashed together with cable and steel clamps to ballast the key member log posts against buoyant forces. A total of 23, 23-inch-diameter timber piles will be driven to secure each Type 1 ELJ in place. Piles will be driven to a depth of 30 to 50 feet below the substrate. A vibratory pile driver will be used to drive these piles as deep as possible, but some piles may need to be impact driven for part or most of the depth. A total of 656, 23-inch timber piles will be driven for ELJs, with 491 of them below the existing OHWM. All timber piles installed below the existing OHWM will be driven in completely isolated and/or dry conditions. Suitable material excavated for the construction of the ELJs will be reused to fill interstitial spaces within the ELJ or on the downstream side to aid in the sediment retention process that these structures are designed to attain. Unsuitable material will be hauled to the staging and stockpiling area for reuse and/or eventual disposal in an approved location off-site. See Appendix B, Attachment 1, Sheets R-1 through R-6 and detail Sheets R-7 through R-11 of the Permit Drawings. Also See Appendix B, Attachment 3, In-Water Impacts Figure 6 in BE. Complex Wood Revetments Installed in Water In-water complex wood revetments installed below the existing OHWM will require fish exclusion and isolation. Before dewatering, fish exclusion will be conducted as described above. Some revetment isolation areas will be continuous with ELJ and/or channel connection isolation areas. Gravel supersacks will be placed using a crane or excavator. Sheetpile will be installed with a vibratory hammer.

Revetments will be constructed with 22- to 26-inch-diameter base logs, 21- to 23-inch-diameter timber


piles, dolosse, 6- to 12-inch-diameter racking logs, and thread lashing. Revetment placement areas will be excavated to place the base and racking logs along the bank. Dolosse will be placed and timber piles will be used to secure the revetments in place. A maximum of 480 dolosse will be placed. Revetments will be secured with 18-inch-diameter timber piles driven using the same method as the ELJ piles. All-thread bolting will be used to attach wood to the timber piles. A total of 5 base logs, 5 timber piles, 5 dolosse, and 100 racking logs will be used for every 40-foot section of revetment. A crane, an excavator, an impact hammer, and a vibratory hammer will be used to construct the revetments. A total of 2,388, 18-inch-diameter timber piles will be driven for revetments, with 290 of them below the existing OHWM. See Appendix B, Attachment 1, Sheets R-1 through R-6 and detail Sheets R-8 through R-11 of the Permit Drawings. Rock Roughness Features A total of 10 rock roughness features will be placed below the OHWM of the White River. Each feature will be composed of several large rocks that will sit on approximately 135 square feet of substrate and encompass approximately 10 cubic yards. Rocks will be placed from the bank with an excavator. The rocks will be placed as gently as possible to minimize turbidity. In total, approximately 100 cubic yards of rock roughness features will be placed in the White River covering approximately 0.03 acre. See Appendix B, Attachment 1, Sheets R-1 through R-6 and detail Sheet R-12 of the Permit Drawings. Fill of abandoned reaches of Dieringer Tailrace and the #9 Ditch New channel excavation will occur concurrently with the rest of the floodplain excavation and grading (described in the Earth elements section above). Filling of the abandoned reaches of the Dieringer Tailrace and the #9 Ditch will not occur until water has been diverted to their proposed side channels. Approximately 0.3 acre of the existing #9 Ditch and approximately 1.9 acres of the existing Dieringer Tailrace will be filled. See Appendix B, Attachment 1, Sheets R-1 through R-5


of the Permit Drawings.

Fill of Constructed Landscape Features Approximately 6 acres of constructed landscape water features, (i.e., constructed open water golf course ponds), and approximately 2,290 linear feet of drainage ditches are located within the restoration project area and will be modified via excavation or filling during the floodplain excavation and grading. Portions of these features will be integrated into proposed side channels and overbank flow paths on the floodplain. Portions of some ponds will be left as depressions within the floodplain to encourage wetland development. They will be graded to connect to flowing side channels to prevent fish stranding following high-water events. See Appendix B, Attachment 1, pages Sheets R-1 through R-5 of the Permit Drawings.

3) Estimate the amount of fill and dredge material that would be placed in or removed

from surface water or wetlands and indicate the area of the site that would be affected. Indicate the source of fill material.

All fill to be placed below the OHWM of any waters of the U.S., including wetlands, will be native material excavated to create the increased floodplain capacity or material excavated for the placement of ELJs and woody revetments. All fill, except for temporary gravel supersacks, will be placed in isolated dewatered areas. Fish, if present, will be excluded from aquatic areas prior to dewatering. See Appendix B, Attachment 3, Figure 6 In-Water Impacts of BE.

All of the existing constructed landscape features on the former Sumner Meadows Golf Links will be filled using excavated material from the floodplain grading.

The Dieringer Tailrace from the mouth to the proposed side channel connection just downstream of the staging tracks crossing will be filled using approximately 22,000 cubic yards of excavated material from the floodplain grading. In addition, approximately 2,100 cubic yards of temporary gravel supersacks will be placed during the isolation of the work area.


The #9 Ditch from the mouth to the proposed side channel connection just downstream of the staging tracks crossing will be filled using approximately 2,600 cubic yards of excavated material from the floodplain grading. In addition, approximately 160 cubic yards of temporary gravel supersacks will be placed during the isolation of the work area.

Construction within the White River for ELJs and revetments will result in the placement of approximately 18,500 cubic yards of salvaged streambed gravel. Work areas will be isolated using 15,400 cubic yards of gravel supersacks and/or 1,100 linear feet of sheetpile. Total dredging within the White River for ELJ and revetment placement and new channel connections will be approximately 19,900 cubic yards.

Included in ELJ and revetment installation are timber piles to secure these habitat features in place. Timber piles will be driven to depths of 30 to 50 feet below the channel. Timber piles will be vibrated in as far as possible and finished off with an impact hammer. Piles will be driven in work areas isolated from flowing water.

A total of 491, 22-inch-diameter and 290, 16- to 18-inch-diameter timber piles will be driven within the existing OHWM of the White River.

Dredging for channel connections and ELJs will be conducted in dewatered, isolated areas. Fish exclusion will be conducted prior to dewatering. Excavators will be used to dredge the material, and trucks will remove the material. Some native substrate may be utilized in the proposed channels. Material that is not reused will be hauled to the staging and stockpiling areas and/or disposed of off-site in accordance with city, state, and federal regulations. See Appendix B, Attachment 1, Sheets R-1 through R-12 of the Permit Drawings for typical plans and cross sections.

4) Will the proposal require surface water withdrawals or diversions? Give general

description, purpose, and approximate quantities if known.

No surface water withdrawals will occur. Work area


isolation to divert water around construction activities will occur. A total of approximately 8 acres of the White River will be temporarily isolated for revetment and ELJ installation, though these isolation areas will not all be in place at the same time. An approximate 35-foot radius will be isolated around each in-water ELJ and revetment with additional areas of temporary fill needed for engineered bridge crossings required for construction access. It will take approximately 2 days to isolate each ELJ work area. Access and containment structures will be limited to the total acreage below the OHWM presented in this application; however, the specific locations will be adjusted during construction to further minimize in-water impacts.

5) Does the proposal lie within a 100-year floodplain? If so, note location on the site plan. Yes, the majority of the project lies within the 100-year floodplain. The City intends to meet applicable NFIP standards as adopted in the City’s Municipal Code for the project.

6) Does the proposal involve any discharges of waste materials to surface waters? If so, describe the type of waste and anticipated volume of discharge.

No. Waste material will not be discharged into surface waters. Applicable TESC measures and construction BMPs will be utilized to control potential sources of temporary erosion during construction.

b. Ground Water: [help]

1) Will groundwater be withdrawn from a well for drinking water or other purposes? If so, give a general description of the well, proposed uses and approximate quantities withdrawn from the well. Will water be discharged to groundwater? Give general description, purpose, and approximate quantities if known.

No consumptive use of groundwater will occur for the construction of the WRRP. It may be necessary to use temporary groundwater wells to draw groundwater levels down below construction activities. Any temporary dewatering will return clean groundwater to the shallow aquifer or directly to the White River.

2) Describe waste material that will be discharged into the ground from septic tanks or

other sources, if any (for example: Domestic sewage; industrial, containing the following chemicals. . . ; agricultural; etc.). Describe the general size of the system, the number of such systems, the number of houses to be served (if applicable), or the number of animals or humans the system(s) are expected to serve.


Waste materials will not be generated or discharged to groundwater as part of the proposed condition.

c. Water runoff (including stormwater):

1) Describe the source of runoff (including storm water) and method of collection and disposal, if any (include quantities, if known). Where will this water flow? Will this water flow into other waters? If so, describe.

The majority of the restoration site will either be channel or native vegetation in the proposed condition and so will not generate elevated stormwater runoff and thus does not trigger permanent stormwater BMPs.

Proposed impervious surfaces as part of the restoration include:

1. The re-located Sumner Link trail. The Sumner Link trail will be re-located to the outer perimeter along the east side of the site onto a forested berm that will surround the restoration site. The forested berm will be between 50 and 100 feet wide and will be planted with native vegetation.

2. The proposed stabilized PSE access road. Access to a PSE tower on the east side of the 24th Street Bridge will require a stabilized access road. The City proposes to install an articulate concrete block access road with porous substrate.

Neither installation is pollutant generating. Both the trail and access road will have motor vehicle access but at a very low frequency (e.g., 1-3 trips per month).

The City’s Stormwater Management Regulations (Sumner Municipal Code Chapter 13.48) requires the use of the 2012 Department of Ecology Stormwater Management Manual, which was used as the project’s design standard. The White River is on Ecology’s list of Flow Exempt Waters, which influences the appropriate on-site stormwater management method.

For both the trail and access road, the City will implement Sheet Flow Dispersion of stormwater (T5.12)


to meet Minimum Requirement #5 – On-site Stormwater Management.

The White River project meets Sheet Flow Dispersion based on:

1. The trail and access road will be less than 20 feet wide and will provide flow paths greater than 10 feet wide.

2. The trail and access road will provide a 2-foot-wide transition zone to avoid focused runoff from the trail

3. The trail and access roads are installed in locations with shallow slopes less than 15%.

2) Could waste materials enter ground or surface waters? If so, generally describe.

There is the potential for waste materials from construction machinery to enter ground or surface waters during construction. TESC Measures and construction BMPs, as described in the section below, will be taken to reduce the likelihood of any leaked or spilled waste material entering ground or surface waters.

3) Does the proposal alter or otherwise affect drainage patterns in the vicinity of the site? If

so, describe. No. The WRRP will only alter drainage patterns within the project site through floodplain reengagement and side channel connection.

d. Proposed measures to reduce or control surface, ground, and runoff water, and drainage

pattern impacts, if any: The restoration project is designed to enhance and uplift environmental conditions through establishing and restoring floodplain functions, instream habitat, and side channel connections and wetland, riparian, and forested habitat along the lower White River. The following measures will be taken to reduce or control surface, ground and runoff water impacts and related impacts to biological resources:


All in-water work will occur within the proposed in-water work window of July 1 to August 31, which has been determined through consultations with Washington Department of Fish and Wildlife (WDFW) and the Puyallup Tribal Fisheries.

Work within the floodplain will occur over multiple years, so temporary stabilization will be required between each potential flood season.

To ensure compliance with state water quality standards, qualified personnel will be onsite during in-water work to monitor turbidity.

Sheetpile will be vibrated in and out, as opposed to impact driven, to reduce harmful Sound Pressure Levels (SPLs).

All timber piles driven waterward of the OHWM will be driven in isolation from flowing water. The piles will be driven with a vibratory pile driver as deep as possible, but some may need to be impact driven for most of the depth.

All waste materials will be fully contained and disposed of offsite in accordance with federal, state, and local laws.

A spill prevention control, and countermeasures (SPCC) plan will be implemented and will prevent the movement of fuels, lubricants, and other hazardous materials from entering the White River, the Dieringer Tailrace, and adjacent wetlands.

To prevent turbid runoff from entering the White River, erosion control BMPs including but not limited to silt fencing, straw (certified weed free), and catch basin sediment traps will be utilized and maintained throughout construction, including during work outside of the in-water work window. These BMPs will be incorporated into the final temporary erosion and sediment control (TESC) plan and stormwater pollution prevention plan (SWPPP).

Regular inspections of project BMPs will be conducted by a Certified Erosion and Sediment Control Lead (CESCL) in accordance with the National Pollution Discharge Elimination System


(NPDES). A Construction Stormwater General Permit (CSWGP) issued by the Washington State Department of Ecology (WSDOE) will be obtained.

To reduce turbidity outside of the isolated in-water work area, cofferdams, gravity bypasses, silt booms, and screened dewatering pumps will be utilized and maintained throughout construction. These BMPs will be incorporated into the final TESC plan and SWPPP.

A Section 401 Water Quality Monitoring and Protection Plan (WQMPP) will also be approved by the WSDOE prior to construction. This plan will be designed to reduce turbidity impacts to the maximum extent possible. As part of this WQMPP, turbidity monitoring will be conducted at least twice a day during in-water work.

Turbidity monitoring will be conducted using a calibrated turbidimeter.

All equipment will be checked daily for leaks and any necessary repairs will be made prior to the commencement of work.

Any equipment operating below the ordinary OHWM of the White River or the Dieringer Tailrace will use vegetable-based hydraulic fluids. Refueling operations will not occur, and fuel will not be stored, within 100 feet of any waterbody.

Access points will be designed to limit as much in-water work as possible.

4. Plants [help] a. Check the types of vegetation found on the site:

_x___deciduous tree: alder, maple, aspen, other

__x__evergreen tree: fir, cedar, pine, other __x__shrubs

__x__grass

____pasture

____crop or grain

____ Orchards, vineyards or other permanent crops. __x__ wet soil plants: cattail, buttercup, bullrush, skunk cabbage, other

____water plants: water lily, eelgrass, milfoil, other

____other types of vegetation


With the exception of a buffer along the White River, native vegetation communities have been cleared from the majority of the study area for agricultural use or the development of the Sumner Golf Links course.

b. What kind and amount of vegetation will be removed or altered?

The project will impact the existing riparian buffer on both banks of the White River, as well as existing vegetation on the former Sumner Meadows Golf Links and vegetation adjacent to the existing BNSF railroad tracks. A maximum of 345 trees will be removed, however, these will be replaced at a minimum 1:1 replacement ratio in accordance with the proposed planting plan. Approximately 10.4 acres of riparian vegetation will be impacted for the floodplain grading, ELJ installation, and revetment installation. Once work is completed in a given area, and in accordance with the NPDES CSWGP, all disturbed areas will be seeded with a native erosion control grass mix. Vegetation removal will consist of existing plant communities associated with the former agricultural areas and former golf course operations. Species are primarily non-native and weedy species (e.g., Himalayan blackberry, reed canarygrass). Pockets of native species exist at various places across the site. Trees in the weed control and conifer underplanting treatment will be preserved as this area will not be graded (see below).

c. List threatened and endangered species known to be on or near the site.

The Washington Department of Natural Resources Natural Heritage Inventory program rare plant database was consulted (May 2021) and indicated no listed plant species are documented within the lower White River Valley, inclusive of the site and all adjacent areas.

d. Proposed landscaping, use of native plants, or other measures to preserve or enhance

vegetation on the site, if any:

Riparian Forest, Wetland Restoration, and Planting More than 162 acres of revegetation of native tree, shrub, and ground cover species will be conducted as part


of the Project. The planting plan is designed as eight different plant communities:

1. Revetment plant community (approximately 7 acres)

2. Wet forest community (approximately 47 acres)

3. Transitional forest community (approximately 56 acres)

4. Conifer forest community (approximately 5 acres)

5. Upland forest plant community (approximately 18 acres)

6. Scrub-shrub/emergent plant community (approximately 3 acres)

7. Forested berm slope treatment (approximately 14 acres)

8. Weed control and conifer underplanting treatment (approximately 13 acres)

Plantings will enhance habitat and provide stabilization and weed control. Trees in the weed control and conifer underplanting treatment will be preserved as this area will not be graded. Preservation of these trees will enable continued large woody material recruitment within the Project reach of the White River while new trees establish in the areas cleared for floodplain grading and other habitat features. Additional plantings will improve the habitat and reduce the area for any invasive species to colonize. See Appendix B, Attachment 1, Sheets R-13 through R-18. Utility corridors for overhead power and underground utilities will be planted with native shrubs and herbaceous species that can be reestablished should utility crews need to perform maintenance in the future. Prior to construction activities clearing limits for vegetation removal would be staked and/or flagged. BMPs such as silt fencing, erosion control blankets, mulching, matting, seeding, and minimizing the amount of excavation at any given time would be used to control erosion. During construction, these areas would be stabilized to prevent soil erosion. The City will prepare a Habitat Management Plan (HMP)


which will include details regarding planting and soil specifications, success standards, contingency plans, and an invasive species control plan. The final HMP will detail the goals and objectives of the WRRP actions and the related evaluation of effectiveness of the proposed restoration measures and provisions for 10 years of annual monitoring (or duration as determined to be necessary by the City or other regulatory agencies).

e. List all noxious weeds and invasive species known to be on or near the site. The WRRP area is known to support knapweed (Centaurea spp.) many species of which are Class B noxious weeds, as well as Himalayan and cutleaf blackberry (Rubus armeniacus; R. laciniatus), common tansy (Tanacetum vulgare), Canada thistle (Cirsium arvense) and reed canarygrass (Phalaris arundinacea) which are Class C noxious weeds.

5. Animals [help] a. List any birds and other animals which have been observed on or near the site or are known

to be on or near the site.

Hawks, great blue heron, bald eagle, songbirds, crows and jays, gulls, various ducks, Canada geese, squirrel, Pacific salmon and trout.

Examples include:

birds: hawk, heron, eagle, songbirds, other: mammals: deer, bear, elk, beaver, other: fish: bass, salmon, trout, herring, shellfish, other ________ b. List any threatened and endangered species known to be on or near the site.

(Note: The following descriptions of threatened or endangered fish presence at or near the site are excerpted from and referenced in the Biological Evaluation prepared for the combination of the WRRP and Sumner Staging Tracks Project, Appendix B, Attachment 3.) Bull trout – potential presence assumed. Within the White River Basin, bull trout are known to utilize the headwaters of the White River as spawning and rearing habitat. There is no documented spawning within the lower White River. The lower White River is likely only utilized by anadromous bull trout when migrating and by fluvial bull trout as foraging and overwintering habitat. Bull trout numbers are especially low in the lower White River in the summer, when both temperature


and turbidity are above levels preferred by bull trout. Spring and Fall-run chinook – present. There are two distinct stocks of Chinook salmon present in the White River Basin: a spring and fall run. The White River spring-run population is one of six spring-run Chinook populations remaining in Puget Sound. While the majority of Chinook within the White River are spring-run salmon, there are a significant number of Puyallup River fall-run Chinook that stray into the White River. The average number of Chinook, including natural and hatchery-origin fish, trapped at the Buckley Trap between 2004 and 2016 was 1,837 fish. All of these fish pass through the aquatic action area of the project to reach the Buckley Trap. White River spring-run Chinook migrate through the project area to spawn in Boise Creek and the upper reaches of the White River. Spring Chinook may enter freshwater as early as May and will stay in the White River until spawning commences in mid-August. There are no documented occurrences of spawning in the lower White River, but spring Chinook may utilize areas within the project reach for rearing. Juvenile Chinook migrate to saltwater between February and August with the peak occurring at the end of May. As such, there is a potential for both adult and juvenile Chinook salmon to be present within the project reach of the White River. Steelhead trout- present. Puget Sound steelhead migrate through the lower White River to spawn in the upper White River and its tributaries. There is no documented spawning or rearing of steelhead within the aquatic action area of this project. Winter steelhead enter the Puyallup River as early as early as November and continue to migrate upstream to Puyallup and White River tributaries through June. Peak spawning in the upper White River tributaries occurs between late April and early May. Juvenile steelhead rear for 1 to 4 years before outmigrating to the marine environment between March and June. Despite their being no suitable spawning or rearing habitat within the project area, there is still a potential for both adult and juvenile steelhead trout to be present within the project area.

See Appendix B, Attachment 3, BE, Section 4, for additional discussion of threatened and endangered species presence, presence of critical habitat, and references.


c. Is the site part of a migration route? If so, explain.

As described in 5.b. above, this reach of the Lower White River is used a migration route for several salmonid species including bull trout, chinook, and steelhead, as well as coho, chum, sockeye, and odd-year pink. The surrounding wetlands and uplands are also be used by migrating bird species along the Pacific Flyway.

d. Proposed measures to preserve or enhance wildlife, if any:

More than 162 acres of revegetation of native tree, shrub, and ground cover species will be conducted as part of the Project, as described above in section 4d Plants. Upon completion, there will be approximately 30.7 acres of riparian forested area within the project area. This new riparian area will be an improvement over the existing riparian area, which has limited habitat value due to the development of the area for agriculture, the golf course, roadways, etc. Over the long-term it is anticipated that planted trees will provide increased shade and LWD recruitment which will in turn provide both food for aquatic organisms and cover from predators within the White River. Upon completion of the WRRP, the new side channels will provide approximately 13 acres of higher-quality habitat for listed salmonids. ELJs with excavated pools as well as woody revetments will improve the complexity of the main channel as well as the proposed channels improving salmonid habitat. The proposed natural flow paths for the Dieringer Tailrace and the #9 Ditch will also be a habitat improvement. The approximately 162 acres of proposed vegetation will provide terrestrial habitat and additional filtration of runoff into the White River improving river habitat. The 21 ELJs, approximately 6,100 linear feet of complex wood revetments, approximately 13 acres of side channel habitat, approximately 162 acres of native plant communities, and approximately 700,000 CY of floodplain storage that includes floodplain connectivity grading will all improve the habitat within the project reach for listed salmonids. LWD recruitment will increase with the abundance of vegetation and snags created by revetments and ELSs. ELJs will increase holding pools for juvenile salmonids. Both the ELJs and revetments will provide


complex cover for salmonids to utilize as protection from predators. Water quality will be improved with the increased vegetation separating the White River from major developments. Prey abundance will go up starting with the lowest trophic levels. Insect abundance will increase with the increased vegetation, which will be foraged on by juvenile salmonids and small fish, starting a cascade up the food chain. Salmon runs across Washington State have suffered from increased developments adjacent to rivers. This project looks to undo some of the damage caused on the White River.

General Fish Exclusion Measures Impacts to fish during construction will be avoided and minimized. Fish will be excluded from the in-water work area prior to in-water work and site isolation structures will be constructed that will isolate the work areas from the remainder of the aquatic environment. Turbid water in isolated in-water work areas will be pumped to upland areas for infiltration prior to removing the site isolation structures; sediment will escape these structures into the water column. Qualified personnel will be onsite during any in-water work to measure turbidity levels daily using a calibrated turbidimeter. If turbidity levels exceed WSDOE standards, in-water work will be paused and construction procedures will be altered, if necessary, to maintain compliance.

e. List any invasive animal species known to be on or near the site.

None are known or confirmed. Based on the habitats present within the WRRP area, there is limited potential for most invasive animal species considered priorities by the Washington Invasive Species Council and WDFW to be present within the WRRP area. The constructed landscape features on the former golf course and the associated interior site ditches may support bull frogs (Rana catesbeiana) and potentially New Zealand mudsnails (Potamopyrgus antipodarum). Bull frogs are found in areas of permanently ponded water throughout the lowlands of Washington; New Zealand mudsnails can be spread by waterfowl and have been documented in tributaries to Lake Washington, in the lake itself, and in the Snohomish River estuary among other fresh and estuarine waters in Washingotn state. It is possible that nutria (Myocastor coypus) may inhabit the banks of the lower White River as the species has been recorded in western Washington, including in Lake


Washington.

6. Energy and Natural Resources [help] a. What kinds of energy (electric, natural gas, oil, wood stove, solar) will be used to meet

the completed project's energy needs? Describe whether it will be used for heating, manufacturing, etc.

The completed restoration aspects of the WRRP will not require outside energy resources.

b. Would your project affect the potential use of solar energy by adjacent properties?

If so, generally describe.

The potential use of solar energy by adjacent properties

would not be affected by trees on the project site; the

proposed sewer pump station will similarly not inhibit the

potential use of solar energy by adjacent properties.

c. What kinds of energy conservation features are included in the plans of this proposal?

List other proposed measures to reduce or control energy impacts, if any:

The new sewer pump station will be at least as efficient as the existing equipment in the existing pump station.

7. Environmental Health [help] a. Are there any environmental health hazards, including exposure to toxic chemicals, risk

of fire and explosion, spill, or hazardous waste, that could occur as a result of this proposal? If so, describe.

No toxic or hazardous materials will be used or generated by the completed WRRP. During construction, hazardous materials (e.g., fuels, oils, grease) will be used in the construction equipment. All work will be done in accordance with local, state, and federal standards with regards to materials, training, inspections, precautions, and responses.

1) Describe any known or possible contamination at the site from present or past uses. None known. The northern portion of the site was used as a public golf course and the southern portion has been farmed. Given these land uses, pesticides and herbicides may have been stored and used. However, the Washington State Department of Ecology Cleanup and Tank search list of sites in Sumner undergoing cleanup or awaiting further investigation of contamination does not indicate any such sites within the project area.


2) Describe existing hazardous chemicals/conditions that might affect project development

and design. This includes underground hazardous liquid and gas transmission pipelines located within the project area and in the vicinity. The project includes horizontal directional drilling for relocation of the existing PSE gas line out of the floodplain. The gas line will be directionally drilled below the White River to the east side of the BNSF tracks, ultimately installed approximately 24.5 feet below the thalweg of the White River. City sewer and water lines will be buried further underground from the east side of the 24th Street pedestrian bridge to the east side of the BNSF tracks. The sewer pump station will be relocated out of the floodplain to the east side of the BNSF tracks. Fiber-optic cables will be installed in new conduit that will be directionally drilled below the project area along what is currently 24th Street East.

3) Describe any toxic or hazardous chemicals that might be stored, used, or produced during the project's development or construction, or at any time during the operating life of the project. No toxic or hazardous chemicals will be stored, used, or produced by the completed project. During construction, fuels, lubricants, and related hazardous fluids will be used in construction equipment; fuel may be stored on site during construction.

See Appendix B, Attachment 3, BE, Section 2.5 Minimization Measures, for additional details regarding commitments to avoid, minimize, and/or mitigate project impacts on listed species by managing construction equipment.

4) Describe special emergency services that might be required.

Emergency service requirements would be those typically required for large construction projects. No special emergency services would be required during construction or as a result of the completed project.

5) Proposed measures to reduce or control environmental health hazards, if any:

Crews will be trained in hazardous spill response and have spill kits on hand. A spill prevention control, and countermeasures


(SPCC) plan will be implemented and will prevent the movement of fuels, lubricants, and other hazardous materials from entering the White River, the Dieringer Tailrace, and adjacent wetlands. All waste materials will be fully contained and disposed of offsite in accordance with federal, state, and local laws. Daily safety meetings will be conducted led by contractors in consultation with the City of Sumner and Site Engineer and will address the use, storage, and management of environmental health hazards during construction.

b. Noise

1) What types of noise exist in the area which may affect your project (for example: traffic, equipment, operation, other)?

None of the typical noise in the surrounding area will affect the proposed project. Lake Tapps Parkway East/8th Street E marks the northern boundary of the project area and is the main source of noise for the area. E Valley Highway East also runs adjacent to sections of the eastern project boundary. Traffic is typical of this area consisting primarily of family cars and large trucks transporting goods in and out of warehouses within the project vicinity. A section of 24th Street E and 148th Avenue E run through the project area but are only used for access to the adjacent agricultural field and therefore have a limited noise impact. Background noise from the area is not anticipated to impact construction or the completed restoration project. The existing BNSF tracks include train traffic that will continue into the future. The Sumner Staging Tracks Project is not anticipated to significantly increase noise from existing levels.

2) What types and levels of noise would be created by or associated with the project on a short-term or a long-term basis (for example: traffic, construction, operation, other)? Indi- cate what hours noise would come from the site.

The maximum in-air Sound Pressure Level (SPL) that will be produced during construction within the bridge replacement project area is 111 dBA, estimated based on decibel addition of the three loudest pieces of construction equipment that may be operating at any one time (WSDOT 2020). A new 16-foot-wide trail at the eastern end of the floodplain grading area will cross the Dieringer Tailrace west of the proposed staging tracks on a single-span bridge. This noise will become indistinguishable from the estimated ambient level of approximately 70 dBA,


defined by the recorded traffic noise on Stewart Road, at a maximum distance of approximately 2,183 feet or approximately 0.41 miles from the project limits. This estimate assumes that the noise is traveling over a soft site with no barriers or other background noise sources. A total of 426 sheetpiles may be driven below the OHWM. Vibratory driving sheetpile produces underwater noise at sound levels of 165 root mean square decibels (dBRMS) (WSDOT 2020). The practical spreading loss model was used to determine where underwater SPLs created from vibratory pile driving construction become indistinguishable from estimated ambient levels of 160 dB peak or 140 dBRMS (WSDOT 2020). Sound pressure levels from vibratory sheetpile driving will become indistinguishable from assumed background levels at approximately 0.29 mile or approximately 1,523 feet from the proposed isolation areas. However, as land masses are known to hinder the forward movement of elevated SPLs within water, only those areas within line of sight of the proposed pile driving will experience elevated SPLs. Therefore, due to the sinuosity of the White River, impact and vibratory pile driving will become indistinguishable approximately 0.18 mile or approximately 955 feet upstream of the furthest upstream sheetpile isolation area, approximately 0.23 mile or approximately 1,191 feet downstream of the furthest downstream sheetpile isolation area, and in an approximately 0.07- mile or approximately 372-foot section of the White River absent of any in-water features. Each containment structure will take 2 days to place with vibratory pile driving potentially occurring on both days. Seven containment structures will be installed each of the two in-water work windows.

3) Proposed measures to reduce or control noise impacts, if any:

Qualified professional staff will monitor for underwater noise during in-water work consistent with the project permits and Endangered Species Act consultation documents.


8. Land and Shoreline Use [help] a. What is the current use of the site and adjacent properties? Will the proposal affect current

land uses on nearby or adjacent properties? If so, describe.

The Dieringer Tailrace carries flow from Lake Tapps west to the White River within the Project area. Areas north of the tailrace are a closed golf course. Portions of the golf course are currently used by City of Sumner Public Works for equipment storage. Areas to the south are agricultural fields. The east side of the Project area includes BNSF Railway Company’s existing tracks. The Sumner Link Trail crosses into the Project area and connects to existing pedestrian bridges within the golf course and at 24th Street E. The Project area just south of 24th Street East has a forested riparian corridor along the White River that is wider than the functioning riparian habitat through the remaining Project area. Adjacent property uses are primarily industrial and commercial, with some residential areas west of the White River. Recreational trail corridors connect to the Project area and some vacant land exists near the existing BNSF rail corridor, which borders the Project area to the east. Cascade Water Alliance’s Lake Tapps discharge and powerhouse are outside the Project area. The WRRP will not affect land uses on nearby or adjacent properties. Existing industrial, commercial, and residential uses will not be altered or affected by the WRRP’s restoration of the floodplain and riparian zone along the White River. Recreational trail access will be maintained with the relocated Sumner Link Trail and pedestrian bridge over the Dieringer Tailrace.

b. Has the project site been used as working farmlands or working forest lands? If so, describe.

How much agricultural or forest land of long-term commercial significance will be converted to other uses as a result of the proposal, if any? If resource lands have not been designated, how many acres in farmland or forest land tax status will be converted to nonfarm or nonforest use?

Yes, approximately 79 acres of floodplain south of the Dieringer Tailrace owned by the City of Sumner are leased for use as agricultural fields. These parcels have been zoned Resource Protection District, which includes agriculture and also wildlife conservation projects, so no change in zoning is proposed. All 79-acres would be converted to nonfarm use as part of the restored floodplain.


1) Will the proposal affect or be affected by surrounding working farm or forest land normal

business operations, such as oversize equipment access, the application of pesticides, tilling, and harvesting? If so, how:

No. The WRRP will not affect or be affected by working farm

or forest land operations or practices.

c. Describe any structures on the site.

Structures within the Project limits include paved pathways for walking and golf carts, former golf course parking lot, paved and unpaved roads, a vehicular bridge over the Dieringer tailrace, staging and stockpiling of public works materials, two storage buildings, a utility shed, utility boxes, overhead electrical power, overhead communications, radio towers, utilities belowground (fiber optic, sewer, and water), and the existing BNSF railroad bridges and tracks.

d. Will any structures be demolished? If so, what?

A portion of the Sumner Link Trail will be demolished and re-routed as part of the project.

Radio towers north of 24th Street and West of the BNSF tracks.

The bridge at 148th Avenue E that crosses the Dieringer Tailrace will be removed in its entirety (including its abutments). Debris from this will be hauled off site for material salvage and/or disposal. See Appendix B, Attachment 3, BE Figure 3 for the bridge removal location.

Two storage buildings just north of the Dieringer Tailrace (on the former golf course property), will be demolished and disposed of in their entirety, including foundation/slab.

A pump station located along 24th Street East will be removed from the Project area. A new pump station will be installed east of the BNSF tracks.

A paved portion of 24th Street west of the BNSF tracks, and east of the White River, will be removed.

e. What is the current zoning classification of the site?


Light Manufacturing (M-1) and Resource Protection District (RES).

f. What is the current comprehensive plan designation of the site?

Under the current comprehensive plan, most of the site is designated Light Industrial. Much of the eastern bank of the White River, and an area extending eastward towards the BNSF tracks is designated Public-Private Utilities and Facilities.

g. If applicable, what is the current shoreline master program designation of the site?

Much of the site is designated as Urban Conservancy under the Sumner Shoreline Master Program. This designation varies in width within the project area, extending eastward from the channel centerline into the project area a minimum of 220 feet, in the northern part of the project, to a maximum of 1,490 feet eastward of the channel centerline, near 24thth Street East.

h. Has any part of the site been classified as a critical area by the city or county? If so, specify.

The project area is wholly within an identified aquifer recharge area and large portions of the project area are identified as flood hazard area. Flood hazard area designations within the project area include: AE, A, and 0.2 PCT Annual Chance Flood. In addition, the site is wholly within the seismic hazard area (‘high’ designation), and Category C – volcanic hazard. Portions of the BNSF railway embankment adjacent to the project area, as well as portions of the White River channel banks are classified as 20-40% steep slopes.

Wetlands are mapped by the City of Sumner’s 2007 wetland inventory adjacent to the eastern portion of the utilities relocation elements of the project.

i. Approximately how many people would reside or work in the completed project?

None.

j. Approximately how many people would the completed project displace?

None.

k. Proposed measures to avoid or reduce displacement impacts, if any:

None.


L. Proposed measures to ensure the proposal is compatible with existing and projected land uses and plans, if any:

The White River Restoration Project has been developed to be consistent with City agreements for public access and Shoreline management. The project will maintain north-south regional trail connections while setting the trail back from the active channel where possible. Riparian restoration will occur to expand the riparian area along the main channel to preserve and enhance Shoreline functions within the Urban Conservancy zone.

m. Proposed measures to reduce or control impacts to agricultural and forest lands of long-term

commercial significance, if any:

The 79 acres of land currently utilized as agricultural

fields have not been designated as of ‘long-term

commercial significance’ by the City.

9. Housing [help] a. Approximately how many units would be provided, if any? Indicate whether high, mid-

dle, or low-income housing. None.

b. Approximately how many units, if any, would be eliminated? Indicate whether high,

middle, or low-income housing. None.

c. Proposed measures to reduce or control housing impacts, if any:

Not Applicable.

10. Aesthetics [help] a. What is the tallest height of any proposed structure(s), not including antennas; what is

the principal exterior building material(s) proposed?

The relocated PSE towers will be the same as the existing towers at approximately 180 feet tall.

b. What views in the immediate vicinity would be altered or obstructed?

Views of the river and riparian zone from the surrounding hillsides will be altered by the restoration of native vegetation with trees and side channels on the project site.


b. Proposed measures to reduce or control aesthetic impacts, if any:

The project has been designed to be aesthetically pleasing by restoring natural riparian forested conditions and aquatic habitats as green space.

11. Light and Glare [help] a. What type of light or glare will the proposal produce? What time of day would it mainly

occur?

The complete project will not produce light or glare. During the construction phase, typical daytime construction hours are anticipated, thus the use of artificial construction lighting is not anticipated.

b. Could light or glare from the finished project be a safety hazard or interfere with views?

The restoration project will not produce light or glare.

c. What existing off-site sources of light or glare may affect your proposal?

Off-site sources of light will continue to impact wildlife onsite, but project success will not be jeopardized by light or glare.

d. Proposed measures to reduce or control light and glare impacts, if any:

Restoration of a native forested riparian zone will reduce impacts of light and glare on wildlife over time.

12. Recreation [help] a. What designated and informal recreational opportunities are in the immediate vicinity?

A section of the Sumner Link Trail runs adjacent to the west side of the lower White River for most of the project area. Since closing in 2013, portions of the former Golf Course site have been informally used as an informal dog park and by a model airplane club, but this use has been terminated by the City.

b. Would the proposed project displace any existing recreational uses? If so, describe.


The Sumner Link Trail on the west side of the lower White River would be temporarily closed during construction. Temporary trail detours will be provided during construction. The Sumner Meadows Golf Course has been closed for use since 2013 and will not be displaced by the Project. Informal recreational use of the former Golf Course site was previously terminated by the City.

c. Proposed measures to reduce or control impacts on recreation, including recreation

opportunities to be provided by the project or applicant, if any:

The existing trail system connection will be preserved at the completion of this project. A new 16-foot trail corridor will be installed on the forested bench at the eastern end of the floodplain grading area.

13. Historic and cultural preservation [help] a. Are there any buildings, structures, or sites, located on or near the site that are over 45 years

old listed in or eligible for listing in national, state, or local preservation registers ? If so, specifically describe.

In 2020, Drayton Archaeology conducted a cultural resource investigation of the project area in accordance with Section 106 of the National Historic Preservation Act of 1966, as amended, and Washington State Historic Preservation Office (SHPO) along with the Department of Archaeology and Historic Preservation (DAHP). That investigation identified the Dieringer Tailrace, which is an element of the White River Hydroelectric Project (WRHP), in the project area. The WRHP consists of the approximately 14-mile-long system that diverts water from the White River near Buckley, sends that water through a canal to Lake Tapps where water is stored, and returns water to the river through the Dieringer Power Plant and tailrace system. The Dieringer Tailrace is an excavated open channel that flows from east to west. The tailrace flows into the project under the BNSF tracks. The WHRP has been identified as a potentially eligible National Register of Historic Places (NRHP) resource(Drayton 2021).

b. Are there any landmarks, features, or other evidence of Indian or historic use or occupation?

This may include human burials or old cemeteries. Are there any material evidence, artifacts, or areas of cultural importance on or near the site? Please list any professional studies conducted at the site to identify such resources.


The 2020 Drayton Archaeology cultural resources investigation and summary report was conducted to identify any cultural resources within the WRRP area. See response to 13.a above.

c. Describe the methods used to assess the potential impacts to cultural and historic resources

on or near the project site. Examples include consultation with tribes and the department of archeology and historic preservation, archaeological surveys, historic maps, GIS data, etc.

The 2020 Drayton Archeology cultural resources investigation and summary report used standard methods to identify any cultural or historic resources within the WRRP and Sumner Staging Tracks project area. The investigation utilized the procedures required under Section 106 of the National Historic Preservation Act to identify the Area of Potential Effect (APE), inventory any historic properties located within the APE, and determine if any identified historic properties are listed or would be eligible for listing in the National Register of Historic Places (NRHP). A review and analysis of previous cultural resources studies, records on file with DAHP, and local historic records was completed. Field sampling was employed to investigate the project area for buried resources.

d. Proposed measures to avoid, minimize, or compensate for loss, changes to, and disturbance

to resources. Please include plans for the above and any permits that may be required.

An Inadvertent Discovery Plan has been developed consistent with protocols identified in Drayton 2020 to identify and protect any cultural resources encountered during construction. The IDP is a component of project review and authorization being completed by DAHP and the U. S. Army Corps of Engineers under the Section 106 of the NHPA.

14. Transportation [help] a. Identify public streets and highways serving the site or affected geographic area and

describe proposed access to the existing street system. Show on site plans, if any.

Public access to the site is primarily non-motorized access via the Sumner Link Trail. Access in the north would remain in its current location, from Stewart Rd SE/8th St E. Access from the south would be relocated to


150th Ave E. No changes are proposed to roads to the west of the White River.

b. Is the site or affected geographic area currently served by public transit? If so, generally

describe. If not, what is the approximate distance to the nearest transit stop?

No. The nearest bus stop is located at the Sunset Hills Park and Ride, approximately 1.6 miles from the north end of the project site.

c. How many additional parking spaces would the completed project or non-project proposal

have? How many would the project or proposal eliminate?

The completed WRRP would not require or provide parking spaces. Informal roadside parking along Stewart Road SE/8th Street E and the access road to the former Sumner Links golf course, as well as informal roadside parking along 24th St. East would be eliminated during construction. Vehicle access and informal roadside parking along 24th Street East between the river and the BNSF tracks will be eliminated.

d. Will the proposal require any new or improvements to existing roads, streets, pedestrian,

bicycle or state transportation facilities, not including driveways? If so, generally describe (indicate whether public or private).

No. e. Will the project or proposal use (or occur in the immediate vicinity of) water, rail, or air

transportation? If so, generally describe.

The project will occur adjacent to BNSF rail line along its eastern boundary.

f. How many vehicular trips per day would be generated by the completed project or proposal?

If known, indicate when peak volumes would occur and what percentage of the volume would be trucks (such as commercial and nonpassenger vehicles). What data or transportation models were used to make these estimates?

Monitoring and long-term maintenance will continue after the WRRP is completed to ensure the success of the habitat restoration. The following City of Sumner maintenance and monitoring activities will occur after the WRRP complete:

Perimeter flood and scour protection

Weed control and adaptive replacement plantings of vegetative communities


Channel capacity review in light of ongoing aggradation of the White River

Vegetation management to avoid potential conflict with overhead power

Utility owner access to service power, sewer, water, communication, and gas facilities

Vehicular trips associated with site monitoring and maintenance activities would be expected to occur several times per week in the 3 years post completion for monitoring and maintenance as the project transitions through its establishment phase. Trips per week would decrease in number through the anticipated 10 years of post construction monitoring of vegetation establishment as the project ages. It is likely that vehicular trip volume would average less than one visit per day throughout any given year.

g. Will the proposal interfere with, affect or be affected by the movement of agricultural and

forest products on roads or streets in the area? If so, generally describe.

No. The WRRP will not generate traffic and will not interfere with the movement of agricultural and forest products on roads or streets in the area.

h. Proposed measures to reduce or control transportation impacts, if any:

During construction, use of the staging area will reduce the need for multiple trips into and out of the site for materials transport. Delivery of some project materials will occur by rail to avoid surface street trips.

15. Public Services [help] a. Would the project result in an increased need for public services (for example: fire protection,

police protection, public transit, health care, schools, other)? If so, generally describe.

No. The WRRP will not require public service. It will be a passive habitat restoration project. The Project includes relocation of a portion of the Sumner Link Trail where passive recreational use will continue.

b. Proposed measures to reduce or control direct impacts on public services, if any.

Given the absence of direct impacts on public services, no measures are proposed.


16. Utilities [help] a. Circle utilities currently available at the site:

electricity, natural gas, water, refuse service, telephone, sanitary sewer, septic system, other ___________

Current utilities available on site include power, gas, water, sewer and other. A sewer pump station is currently located onsite. Other than utilities used to operate the pump station, utility usage onsite is minimal, as the site is currently occupied by cropland, an abandoned golf course, and the recreational trail.

b. Describe the utilities that are proposed for the project, the utility providing the service,

and the general construction activities on the site or in the immediate vicinity which might be needed.

No utility use is proposed as part of the Project. However, the site will continue to accommodate transmission lines in service of adjacent areas. As described above, utility lines will be relocated to maintain their function (Appendix B, Attachment 1, Sheets U-1 and U-2 of the Permit Drawings). A few of the existing poles supporting PSE's overhead powerlines interfere with the WRRP and will be relocated within the existing transmission corridor. City sewer and water lines will be buried further underground from the east side of the 24th Street pedestrian bridge to the east side of the BNSF tracks. The sewer pump station will be relocated out of the floodplain to the east side of the BNSF tracks. Fiber-optic cables will be installed in new conduit that will be directionally drilled below the project area along what is currently 24th Street East. In preparation for horizontal directional drilling (HDD) along 24th St E, pipe will be laid down within the project area north of 24th St E in an approximately 1,600’ arc.

A HDD pipe lay-down plan has been developed. Silt fence will be installed on both sides of the laydown path. PSE gas lines will be directionally drilled below the White River to the east side of the BNSF tracks. The gas line will be installed approximately 24.5 feet below the thalweg of the river.


Utility corridors will be planted with native shrubs and herbaceous species that can be cleared if access is needed to the corridors. See Appendix A, Figure 2 for utility corridor locations. Also see Appendix B, Attachment 1, Sheets U-1 and U-2 of the Permit Drawings. See also Appendix B, Attachment 5, City of Sumner Public Works, 24th St. E. Utility Relocation Plan Set and Appendix B, Attachment 6, Proposed HDD Plan and Profile Sheet.

C. Signature [HELP] The above answers are true and complete to the best of my knowledge. I understand that the lead agency is relying on them to make its decision. Signature: ___________________________________________________

Name of signee __________________________________________________

Position and Agency/Organization ____________________________________

Date Submitted: _____________


D. Supplemental sheet for nonproject actions [HELP] (IT IS NOT NECESSARY to use this sheet for project actions) Because these questions are very general, it may be helpful to read them in conjunction

with the list of the elements of the environment. When answering these questions, be aware of the extent the proposal, or the types of

activities likely to result from the proposal, would affect the item at a greater intensity or at a faster rate than if the proposal were not implemented. Respond briefly and in general terms.

1. How would the proposal be likely to increase discharge to water; emissions to air; pro-

duction, storage, or release of toxic or hazardous substances; or production of noise?

Proposed measures to avoid or reduce such increases are:

2. How would the proposal be likely to affect plants, animals, fish, or marine life?

Proposed measures to protect or conserve plants, animals, fish, or marine life are:

3. How would the proposal be likely to deplete energy or natural resources?

Proposed measures to protect or conserve energy and natural resources are:

4. How would the proposal be likely to use or affect environmentally sensitive areas or

areas designated (or eligible or under study) for governmental protection; such as parks, wilderness, wild and scenic rivers, threatened or endangered species habitat, historic or cultural sites, wetlands, floodplains, or prime farmlands?

Proposed measures to protect such resources or to avoid or reduce impacts are:


5. How would the proposal be likely to affect land and shoreline use, including whether it

would allow or encourage land or shoreline uses incompatible with existing plans?

Proposed measures to avoid or reduce shoreline and land use impacts are:

6. How would the proposal be likely to increase demands on transportation or public

services and utilities?

Proposed measures to reduce or respond to such demand(s) are:

7. Identify, if possible, whether the proposal may conflict with local, state, or federal laws or

requirements for the protection of the environment.

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