Jay & Marianne Wilkins
mariannew@msn.com
425-391-4284
City of
Emily Arteche
Subject:
Comments to the Notice of Application - File #SED003013
There are so many issues that I have regarding
1.
Alternatives to the preferred park master
plan not considered:
Everything I read tells me that the least intrusive option to
the environment should be implemented when building. Areas of wetlands and buffers should be
respected, without mitigation or variance.
If I were to build a home in the area, I would be required to avoid the
wetlands and buffers. I
expect no less from the City.
SCC 21A.24.010 states “The purpose of this chapter is to
implement the goals and policies of the Washington State Environmental Policy
Act, RCW 43.21C, and the City of Sammamish Interim Comprehensive Plan which call
for protection of the natural environment and the public health and safety
by:”
“A. Establishing development standards to protect defined sensitive areas.”
“C. Protecting unique, fragile and valuable elements of the environment including, but not limited to, wildlife and its habitat;”
“E. Preventing cumulative adverse environmental impacts on water availability, water quality, ground water, wetlands and streams;”
SCC 21A.24.020 B “The city shall not approve any permit or otherwise issue any authorization to alter the condition of any land, water, or vegetation or to construct or alter any structure or improvement without first assuring compliance with the requirements of this chapter.”
“D. When any provision of any other chapter of the Sammamish City Code conflicts with this chapter or when the provision of this chapter are in conflict, that provision which provides more protection to environmentally sensitive areas shall apply unless specifically provided otherwise in this chapter or unless such provision conflicts with federal or state laws or regulations.”
RCW 43.21.030(2)(c) states that alternatives to the proposed action shall be considered. It states in the 1990 King County Sensitive Areas Ordinance (KCSAO), that mitigation for wetland impacts must follow a sequence that begins with #1 “Avoiding the impact all together by not taking a certain action or parts of an action”, followed by #2 minimizing the impact by limiting the degree or magnitude of the action.
SCC21A.24.070 states “Exceptions. A. If the application of this chapter would prohibit a development proposal by a public agency and utility, the agency or utility may apply for an exception pursuant to this subsection:
1. The public agency or utility shall apply to the Department and shall make available to the Department other related project documents such as permit application to other agencies, special studies and SEPA documents.
2. The Department shall review the application based on the following criteria:
a. There is no other practical alternative to the proposed development with less impact on the sensitive area: and
b. The proposal minimizes the impact on sensitive areas.”
Construction of
If the City of Sammamish wants Little
League ball fields, they have a
wonderful alternative location at the Commons site, which they own. The site has no creek or salmon, few
trees, no possible flooding problems, no immediate neighbors, is flat, has
adequate wetland buffers and has been measured to be more than adequate in
size. It is on the northwest edge
of the property, so it will not affect the
“Friends of
He states that “The Commons site does not appear to be near
any sensitive areas and is buffered by an expanse of vegetation that will be
useful in infiltrating and filtering runoff.” He also states in that letter “A 90-foot buffer between adjacent
properties and the ball fields is possible at the Commons site (including
land within the park, surrounding right-of-way, unbuildable parcels, and
building set backs). Additionally there is a significant grade
separation that will provide a visual and acoustic separation between the
activity areas and the adjacent properties at the Commons.”
Instead of trying to mitigate the wetland
and buffer encroachment at
2.
Cumulative
Traffic Impacts cause problems
Less than 1 mile away, a new development called The Crossing is being implemented. That development adds 132 homes to the area. All of those homes will be using 212th SE to enter and exit the development. An additional (132X10) 1320 more car trips per day will be added on that stretch of road. The Ebright SEPA indicates the proposed park would add another 300 trips per day to the road. That is is total of 1620 additional road trips per day. Weekends could add another 300 trips per day. The result will be dangerous conditions when anyone tries to enter or exit 212th SE. The Crossings occupants, the park patrons as well as the neighbors that live in the area will be adversely impacted. The park should be scaled down to reduce the number of road trip on 212th. One over development (The Crossings) is enough.
3.
Upper drain
field will add 1500 gallons of water per day
The proposed park will add 3 new drain fields to handle the additional water runoff and sewage created by the park. The restrooms waste will be pumped via a lift station, across the wetlands, to a drain field by the upper picnic area. The septic system will add about 1500 gallon of water per day to the Septic drain field. The parking lot will also have a drain field setup. Both of these will drain into the wetlands. The wetlands drain across the Ramerman’s property and eventually back to Ebright Creek. Increased water flow to the wetlands can create downstream problems to the neighbors and Ebright Creek where the water eventually flows. The park should be scaled back to a smaller parking lot, and no ball fields. The ball fields result in peak water usage to the sewer system.
4.
Lower Drain
Field creates excessive phosphates into Ebright Creek
The multipurpose ball field is a under drained sports field turf. A multipurpose field requires a high level of maintenance over a longer period of time. It must also be constructed so it it will drain rapidly so that the surface will be dry to play on. It is fertilized heavily so the grass will grow and be maintained. The fertilizers and additional watering system is added to the drain field. The cutting of 54 large fir trees in this area will also add to additional water runoff in the drain field. This drain field will be released next to EBright Creek. Now we have more water and pollutants entering Ebright Creek. .
Ebright Creek is the last viable
salmon creek in Sammamish. What
does this mean? At last count,
there was over 100 fish per day spawning in the creek during spawining
season. The last count for
Pine Lake Creek, which is close by, counted 2 fish per day during the spawning
season. Everything possible should be done to allow
for the continuation of this unique species of Kokanee salmon at Ebright
Creek.
High maintenance ball fields, with
excessive polluted runoff, should not be placed next to an environmentally
sensitive creek.
The King County Erosion Hazards
near Sensitive Water Bodies Special District Overlay, known in brief as the SO
190, applies to Ebright Creek.
Protections are in place for Ebright Creek. The city should be following
them.
5. Wetlands should support wetland plants,
not Douglas Fir Trees
Fifty four large trees will be destroyed so that a ball field may be created. The plan indicates that 2 trees will be planted for each one that is cut down. This is not an acceptable alternative. Trees that will be cut are 50-100 feet tall. The new trees will be 4-6 feet tall. Does one equate to the other? I also have concerns regarding where these trees will be planted. One location is on the north property line. Douglas Fir trees offer no privacy screening or noise control. Another location for these trees is in the wetland buffer zone. It is questionable if those trees would even live in that habitat. Wetlands should support wetland plants, not Douglas Fir trees. There simply is not room for that many trees to be planted in a suitable location on the property. Other park alternatives should be considered that does not result in destroying these 54 large trees.
It has been sad to see our area so drastically changed this last month with the destruction of all the trees for the 132 housing development down the street.. It makes it even more important that we save the trees that we have to enjoy.
6.
Cumulative Effects to Ebright
Creek
There will be much more water entering Ebright Creek. As discussed above, there will be the 1500 gallons of water per day added by the septic system. There will be the water run off from the parking lot. There will be 54 large fir trees cut down to create the ball fields. The tree canopy handled much of the rain water before it hit the ground and they also absorbed much of the ground water beneath them. This absorption system is gone. All of the rain water will go directly onto the ball fields with the loss of the forest canopy. The ball fields will be heavily fertilized and watered, which will add more gallons of water to be dispersed. All of this water is dispersed into the wetlands or ground water. Ebright Creek is fed by wetlands and groundwater.
The following is a summary of the
water quality and habitat for Ebright Creek from the City of
“Ebright
Creek (WRIA08-0149); Class 2
Problems
in the Ebright Creek subbasin include bed and
bank
erosion in the upper and middle reaches of Ebright
Creek,
resulting in sedimentation of lower reach salmonid
spawning
and rearing habitat and of culverts under East
quality
problems in this subbasin, although elevated
nutrient
and turbidity levels have been.
Under
future land-use conditions without mitigation, peak
flows in
Ebright Creek are predicted to increase by 100 to
150
percent, an absolute increase of between 20 and 40
cubic
feet per second. Such increases will exacerbate
existing
erosion and sedimentation problems. Future land
uses are
expected to produce water quality problems far
greater
than those previously observed. Increases in
turbidity,
nutrients, metals, and organic pollutants are
likely
with projected urban uses.
Summary
of Habitat
Ebright
Creek (WRIA 08-0149) is a Class 2 stream
with
salmonids downstream (west) of 212th
Avenue
SE. Species identified in this creek are
chinook
salmon, sockeye salmon, coho salmon,
kokanee
salmon (spawning only), cutthroat trout,
and
rainbow trout. Although the creek is of
minimal
size for chinook salmon, a few have been
sighted.
The creek is unclassified east of 212th
Avenue
SE where the wetlands begin.
Although
the City Stormwater Management Plan
indicates
there is an impassable fish barrier located
north of
SE,
field review by a consulting engineer indicates
there
are no complete manmade fish barriers and no
permanent
natural fish barriers. Of significance, the
stream
is predominantly groundwater fed and is
about 50
degrees in temperature. It supports one of
the best
runs of Kokanee. The stream is nicely
intact,
particularly the lower reach (personal
communication,
Geoff Clayton, RH2 Engineering,
The
increased water flow to Ebright Creek, as indicated above, would be very
damaging to the Creek and the Kokanee.
The park design should be scaled back and the ball fields
removed.
7.
Detail design work completed before any SEPA input
Things seem to
be out of whack with the SEPA process.
SEPA should be completed early in the process so that environmental
concerns may be taken into account
in the park design. See the attached letter dated
8. Preferred Master Plan Decision made before public meetings.
Three public
meetings were to be scheduled regarding the design content of Ebright park. One public meeting was held. The
9. Public not given any real alternatives
regarding options in the park.
All three public meetings completed by the parks department showed schematics with ball fields in different positions. Options without ball fields were not presented. The city had those options but choose to limit what information the public received.
10. Wildlife Habitat
Severely Impacted
Most of the trees (54) on the
park site will be destroyed to create the ball field. The noise from the ball games is not
conducive to the animal habitat.
The amount of people per day coming to this park also destroys the
sanctuary. Cumulative impacts are
created due to the recently demolished area called The Crossings where 132 homes
will be developed. The Crossings is less than a 1/2 mile from
11. As designed,
The whole length of the path around the soccer field (270
feet) is 10 feet from my property line. Most home owners, when building
allow for distance to the neighbors and build accordingly. King county always tries to allow for
30-40 feet between any active park usage and the neighboring property. What is wrong with Sammamish? This design concept destroys my privacy,
security, peace and quite, views,
quality of life, serenity of the neighborhood and property value. I have written to the city asking how
they propose to mitigate the noise to me and my neighbors. See attached letter
dated
The ball field positioning is the worse possible for noise control. The whole length of the soccer field is within 10 feet of my property line. There is no sloping to the land. All trees are removed from one fence line to the other. Home plate faces directly toward my property. This means all noise is projected directly toward my property with no buffer and no noise control.
Drainage problems will damage my property. The city plans to add 5600 cubic yards of fill for the fields. This will raise the land level creating a downward slope to my property. They are also cutting down 54 large fir trees that had been absorbing much of the moisture in the area. The net effect will be dumping water onto my property.
My view is destroyed. Instead of viewing 100 foot large fir trees and wild life in the area, I will be forced to see the ball fields. I have lived in my home for over 25 years. I thought the incorporation of the city was here to help protect residents from uncaring developers.
I have attended all of the public meetings. My first thought was, how nice to have a
park next door. My next thought
was, no , I really don’t want the ball fields there, but it may be good for the
community. The more I learned
about the process for park development, the alternatives for ball fields at
other locations, the design alternatives within the park that are not being
used, the impact to the wetlands and wetland buffer, the environmental concerns, the loss of
habitat by cutting 54 large trees, the effect on the last viable salmon creek in
Sammamish, the need for an environmental center, the more I am convinced that
this park is not the place for ball fields. It is not in the best interest of the
community to destroy
Greater concern to me has been the City’s lack of concern for the impacts it is having on its citizens. There is supposed to be a public process to give citizens a voice. This city limits that process in numerous ways: It limited the schematic alternatives at the public meetings so in essence, all views had ball fields. They led us to believe that alternatives without ball fields were not an acceptable. They agreed upon a preferred master plan before all of the public meetings had been held and without any SEPA process initiated.
It has been difficult to obtain public records on
Once the detailed design was completed, than the SEPA checklist was completed and given to the public. What kind of process is this? The city chose what they wanted, limited public input, and then created a SEPA document that would fit their plan. The city should be leaders in serving the public, not look for ways to circumvent their own processes. The SEPA process should be used to help design the park, not circumvent public safe guards to the environment.
The web site, at
one time showed the
12. Vision
I am attaching a copy of the City of
“Vision
The vision Statement and the Vision Ideals provided in the Introduction to this Comprehensive Plan reflect a strong emphasis on the value of and need to protect environmentally sensitive features:
This element furthers this vision by providing policy direction for the City’s active role in participating in regional environmental protection efforts, developing and applying local environmental regulations, promoting education, and other programs.”
Attached is a copy of Pg 29 and Pg 63 of the City of Sammamish Draft Parks, Recreation and Open space standards dated February 2003. Again the citizens rank trails and pathways, and passive/Leisure recreation categories above all others per page 29. On page 63 it states “It is clear that the people of Sammamish hold open space, greenways and natural resource lands in high regard. Every effort should be made to identify, preserve, enhance and manage such important assets.”
13. Recommendations
In the light of all
of the issues above, I would recommend the following:
Sincerely,
Jay & Marianne Wilkins
Attachments:
RCW 43.21C.030
Schematic Option #3
City Web Site as of July 12th.
Park Board Minutes dated
Letter dated April 4th from J Richard Aramburo
Letter dated
Council Minutes of
PAB Recommended Draft Comprehensive Plan dated
Letter dated
PAB Recommended