EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______CHAPTER 3.7 NATURAL ENVIRONMENT

I. Background

A. Best Available Science (BAS) and Special Consideration for Anadromous Fisheries.

The Growth Management Act requires that the review and evaluation for the 10-year Comprehensive Plan update also include consideration of critical area ordinances. The plans and ordinances must consider the Best Available Science (BAS) requirements described in WAC 365-195-900 to 365-195-925, and must include “special consideration” to conservation or protection measures necessary to preserve or enhance anadromous fisheries. In 2003, the City hired consultants to review and evaluate the City’s policies, designations and requirements for geologically hazardous areas, and non-shoreline stream mapping, classification and buffers considering BAS. The City also considered documents and recommendations prepared in response to listing of Chinook salmon and bull trout as threatened and coho as a species of concern under the Endangered Species Act for Snohomish Watershed Resource Inventory Area (WRIA) 7 and the Lake Washington/Cedar/Sammamish WRIA 8. Reports addressing Best Available Science published by Snohomish, King and Pierce Counties and State agencies were also reviewed.

For the current update, the City reviewed the following documents related to BAS:  Update on Wetland Buffers: The State of the Science (Ecology Publication #13-06-011, October 2013) https://fortress.wa.gov/ecy/publications/SummaryPages/1306011.html.  Washington State Wetland Rating System for Western Washington, 2014 Update (Ecology Publication #14-06-029). (https://fortress.wa.gov/ecy/publications/SummaryPages/1406029.html.  A January 28, 2015 memo from the Department of Ecology with updated guidance for wetlands and frequently flooded areas.  Ecology also provided specific recommendations for amending Everett’s wetland buffers.  Snohomish County published a Draft Summary Snohomish County 2015 Best Available Science Review for Critical Area Regulations Update in March 2015. This is an Addendum to their 2006 Best Available Science Summary, and includes an analysis by Surface Water Management staff of new materials produced after 2006. The portion related to wetlands and fish and wildlife habitat conservation areas is most applicable to Everett. Everett’s regulations do not address Critical Aquifer Protection Areas, as our water source is from the Spada and Chaplain reservoirs. http://snohomishcountywa.gov/2183/Critical-Areas-Regulations-Update  City of Everett Hazard Inventory and Vulnerability Analysis. July 2011. https://everettwa.gov/documentcenter/view/275 These documents are available for review upon request. Staff also reviewed recent court cases (MRSC web site) and hearings board cases related to critical areas and BAS.

The proposed amendments will also be circulated to agencies with expertise for review.

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-1 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______II. Proposed Amendments to the Comprehensive Plan Text and Regulations Relating to the Natural Environment

Proposed amendments are primarily in response to Ecology guidance on BAS and potential impacts of climate change.

Proposed amendments to the text in the Comprehensive Plan Land Use Section Critical Area section include references to Planning Director interpretations regarding requirements to prepare biological assessments / habitat management plans.

Climate change has the potential to adversely impact critical areas and the natural environment. The new Climate Change and Sustainability Element includes policies to reduce greenhouse gas emissions and to adapt to the impacts of climate change, including ecosystem response to climate change. The Capital Facilities and Utilities Element and the Housing Element also include policies related to reducing greenhouse gas emissions, and monitoring the impacts of climate change, such as on increasing flows in streams.

Policies in the Land Use Element and Capital facilities and Utilities Element related to stormwater and water quality also address climate change and the natural environment. For example, “Policy 6.5.5 Affirm and expand the use of green stormwater infrastructure, such as rain gardens and pervious pavements, as the preferred stormwater management approach to reduce flows and support, enhance and restore natural habitats.”

The Urban Design Element added policies related to protecting, enhancing, and managing trees and other landscaping.

Proposed amendments to the critical area regulations address:  Ecology’s new wetland rating system and buffers based on the new system  new Ecology method to determine wetland mitigation ratios  Ecology guidance on using a watershed approach when selecting wetland mitigation sites  the option to use an in-lieu fee for wetland mitigation consistent with federal rules  references to Planning Director interpretations on when biological assessments and habitat management plans are required for projects that may impact listed species

Department of Ecology guidance on frequently flooded areas (100-year floodplains) recommends that 2010 floodplain maps that were issued, but not adopted by Federal Emergency Management Agency (FEMA), be used in regulating development in the floodplains. Jurisdictions are required to use the 2005 adopted maps, but may also regulate using the most restrictive of the 2005 and 2010 maps. This SEIS analyzes whether or not the City should regulate floodplains using 2010 floodplain maps that have not been formally adopted by FEMA. As part of the update process, the City will meet with property owners affected by the new maps and take public comments into consideration when making a decision.

Policies and regulations for areas in shoreline jurisdiction are not being reviewed and revised at this time, but will be updated as part of the next comprehensive update to Everett’s Shoreline Master Program.

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-2 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______III. General Description of Everett’s Landform

Figures 3.7.1 - 3.7.6 depict in general, the natural features in Everett. Everett is built on a plateau peninsula, bounded by the Snohomish River to the north and east, and Port Gardner Bay to the west. Portions of Smith and North Spencer Islands in the estuary to the north are within the city limits/Planning Area. The Snohomish River Valley, a floodplain belt of agricultural lands, and the Cascade mountain range lie to the east.

Puget Sound landforms have been shaped by past glacial periods. Rivers of ice up to one mile thick pushed into the region from the north and retreated, creating the topography found in the region today. The planning area is essentially a glacial drift plain underlain by soils deposited by advancing and retreating glacial ice. Successive ice ages deposited additional layers of glacial till soil and subjected the underlying soil stratas to immense shearing and compacting forces. Stream runoff eroded the drift plateau and formed a series of ravines by removing the till and exposing underlying stratas.

The landform in the north Everett plateau has been highly modified by grading and filling of streams and most wetlands. The western and eastern portion of the Planning area include numerous ridges, separated by ravines with associated steep slopes, streams and wetlands with drainage flowing to Port Gardner Bay and the Snohomish River. These streams are erosional features that are naturally unstable. The streams are in the process of downcutting through the till plateau. The streams in the Port Gardner Bay drainages flow through steep-walled gorges as they rapidly drop 500 feet from the plateau to the sound. Early development modified these streams heavily. They were used to skid logs during harvest operations. Railroads, roads, powder mills, communities, and sawmills were constructed in the creeks and associated ravines. The portion of Everett approximately south of SR 526 is a fairly flat plateau with drainages flowing to the south towards Lake Washington.

Most of the City is urbanized. Much of the undeveloped area is in a second or third state of growth regeneration following logging operations which occurred during the past 100 years. Most of the islands in the Snohomish estuary and the Snohomish River’s edge in Everett have been highly modified by diking, fill and stabilization with rip rap, etc. The Port Gardner Bay shoreline has been highly modified by the railroad, and industrial activities along the Port area.

The City is in the Western Hemlock Zone described by Franklin and Dryness (1984). The upland forested areas are dominated by second- or third-growth mixed or deciduous forest communities. Deciduous forests are dominated by red alder with occasional big leaf maple and black cottonwood. The limited areas of conifer forest are dominated by western hemlock and Douglas fir. Western red cedar occurs primarily along stream courses. Common understory shrubs include salal, Oregon grape, sword fern, and salmonberry. Poorly drained areas support bogs as well as forested, scrub-shrub, and emergent wetlands. In some of these wet areas there are pockets of shore pine and western white pine. Estuarine wetlands are located along the Snohomish River and associated sloughs.

Landscaped areas associated with development contain a wide variety of vegetation. Commercial and industrial areas primarily have landscaping in strips along property lines, along buildings, around stormwater ponds, and in parking lots. Some residential areas have larger

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-3 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______

Figure 3.7.1: Topography

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-4 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______

Figure 3.7.2: Slope Analysis

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-5 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______

Figure 3.7.3: Erosion Hazards

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-6 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______

Figure 3.7.4: Landslide and Seismic Hazards

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-7 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______

Figure 3.7.5: Drainage Basins

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-8 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______

Figure 3.7.6: Wetlands and 100-Year Flood Hazard Areas

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-9 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______areas of native vegetation remaining, though most are developed so densely that little native vegetation remains.

IV. Critical Areas

A. Existing Conditions.

1. Geologically Hazardous Areas Geologically hazardous areas include areas susceptible to erosion, sliding, earthquake, or other geological events. They pose a threat to the health and safety of citizens when incompatible commercial, residential, or industrial development is sited in areas of significant hazard. Some geological hazards can be reduced or mitigated by engineering, design, or modified construction so that risks to health and safety are acceptable. Geologically hazardous areas in Everett include landslide hazards, seismic hazards, erosion hazards associated with another environmentally sensitive area, and slopes of 40% and greater. These areas are generally shown on Figures 3.7.2, 3.7.3 and 3.7.4.

Erosion Hazards. Erosion is likely to occur on steep slopes, especially in erosion prone soils types, soils disturbed by human activities, and in the presence of rainfall and stormwater runoff.

Landslide Hazards. Landslide hazard areas are potentially subject to mass earth movement based on a combination of geologic, topographic and hydrologic factors with a vertical height of 10 feet or more, including, but not limited to  areas of historic failures,  areas with slopes steeper than 15% plus springs or ground water seepage plus hillsides intersecting geologic contacts with a relatively permeable sediment overlying a relatively impermeable sediment or bedrock,  areas with slopes of forty percent or steeper and with a vertical relief of ten or more feet, except areas composed of consolidated rock. Gravity is the driving force for landslides.

Seismic Hazards. Seismic hazards in Everett consist of ground shaking and ground failure. Rupture along fault lines is not a known factor in Everett; though over the past several years, evidence of seismically induced offsets has been found throughout the Puget Sound basin, including the south end of Whidbey Island. WA Department of Natural Resources’ (DNRs) Interactive Map shows potential Whidbey Island fault extensions into southwest Everett and the unincorporated UGA.1 See Figure 3.7.7.

Liquefaction is a phenomenon in which strong earthquake shaking causes a soil to rapidly lose its strength and behave like quicksand. It typically occurs in artificial fills and in areas of loose sandy soils that are saturated with water, such as low-lying coastal areas, lakeshores, and river valleys. In September 2004, the Washington State Department of Natural Resources, with the Department of Homeland Security Federal Emergency Management Region 10, and the

1 Fault source citations are : U.S. Geological Survey, 2010, Quaternary fault and fold database for the United States, accessed November 10, 2010, from USGS web site: http://earthquake.usgs.gov/hazards/qfaults/.; Gower, H. D.; Yount, J. C.; Crosson, R. S., 1985, Seismotectonic map of the Puget Sound region, Washington: U.S. Geological Survey Miscellaneous Investigations Series Map I-1613, 15 p., 1 plate, scale 1:250,000.

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-10 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______Washington Military Department, Emergency Management Division published a Liquefaction Susceptibility Map of Snohomish County, Washington. This map is very similar to Everett’s Seismic Hazard Map except that:

Figure 3.7.7: Southern Whidbey Island Fault Zone

 It identifies Maulsby Marsh and the west side of Smith Island (west of the Weyerhaeuser lagoons) as “Peat deposit.” The map states that “Peat is not susceptible to liquefaction but may undergo permanent displacement or loss of strength as a result of earthquake shaking.”  Several areas in the south Everett plateau and the Planning Area are identified as having “Liquefaction susceptibility: Moderate to High.” These areas are located near Paine Field Airport, Kasch Park, and Murphy’s Corner. Everett’s maps will be further updated to reflect this new information during the public review process for the Critical Area Ordinance. In the interim, this map is available for review in the Planning and Community Development Department.

The City of Everett’s 2011 Hazard Identification and Vulnerability Analysis includes updated information about seismic risks and secondary hazards from earthquakes, such as landslides and tsunamis which could be produced by landslides in and around Puget Sound. Earthquakes were listed as the hazard of highest importance in Everett. The City’s 2011 Hazard Mitigation Plan identifies and prioritizes a wide variety of proposed projects and programs targeted at reducing risks from natural hazards and mitigating disaster impacts.

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-11 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______2. Surface Water Surface waters in Everett include Port Gardner Bay, streams, including the Snohomish River, lakes, wetlands, and springs. See Figures 3.7.5 and 3.7.6. Springs are primarily located along the ravines that drain to Port Gardner Bay and along the hillsides above Lowell and Lowell- Larimer Road.

North Everett has been modified so vastly that no streams remain. It is served by a combined storm and sanitary sewer system that normally carries the stormwater to the City’s water pollution control facility for treatment. However, during heavy rainstorms, the interceptors exceed their capacity and the excess overflows directly into Port Gardner Bay. In the remainder of the planning area, storm and sanitary sewers are separate, with storm water pipelines eventually discharging to stream systems. See Section 3.4. for additional discussion on the City’s stormwater system.

Even though Everett is highly urbanized, the south end streams and wetlands still provide many of the same functions that they provided in their natural state, though not to the same extent. These functions include stormwater detention and conveyance, fish and wildlife habitat, flood control, sediment and pollution control, groundwater recharge, open space and recreation. Stream and wetland buffers provide flood control, pollution filtering, sediment and erosion control, stabilization of slopes, habitat for wildlife, screening of light and glare, shading and temperature control, open space, and aesthetic benefits.

Water quality in Everett’s surface waters has been degraded by past development practices and on-going actions. Degradation includes sedimentation, pollutant loading and increased water temperatures. Urbanization has also modified hydrology. In streams this results in larger peak flows during storm events, increased duration of storm flows, and lower summer base flows.

Everett developed Drainage Basins Plans in the 1980s and 1990s that address stormwater issues in individual basins. The plans include policies for control of stormwater impacts (quantity and quality), proposals for system improvements such as regional detention ponds to improve stormwater control and water quality, and on-site detention and water quality treatment requirements. The City is in the process of developing a new Surface Water Comprehensive Plan that will replace the Drainage Basins Plans. It is expected to be adopted in 2015. The draft Comprehensive Plan includes goals and objectives for water quality improvement, water flow, and habitat. Objectives in the Plan include:  Implement pollutant reduction strategies to achieve an overall net reduction of pollutant discharged.  Provide 25-year flood protection using future land use and a factor of safety for increase in precipitation due to climate change.  Encourage infiltration within the City.  Preserve and possibly enhance: o Wetland habitat in drainage basins, with emphasis on riparian wetland habitat or wetland habitat that is hydrologically linked to the stream systems in the basin o Instream habitat structure and complexity (e.g., large woody debris o Enhance riparian vegetative community.  Evaluate and, if warranted, provide or enhance: o Stream habitat for aquatic biota (e.g., salmonid species, resident, non-salmonid fish, aquatic invertebrates, etc.)

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-12 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______o Stream habitat units as needed – particularly pool habitat units. The Plan also includes hydraulic and hydrologic modeling; inventories; analyses of habitat, water quality, and geomorphology; and concludes with recommended capital improvement programs for the basins. Recommendations include projects to address flooding, habitat, and water quality issues.

In 2002, Snohomish County developed Drainage Needs Reports that address stormwater issues in urbanizing basins of Snohomish County. Plans that cover drainages in Everett’s Planning Area include the North Creek, Swamp Creek and Marshland Tributaries Drainage Needs Reports. These reports include hydraulic and hydrologic modeling; inventories; analyses of habitat, water quality, and geomorphology; and conclude with recommended Capital Improvement Programs for the basins. Recommendations include projects to address flooding, habitat, and water quality issues. Recommendations also address additional studies, maintenance of existing surface water facilities, maintenance of parking lots and streets, catch basin cleaning programs, and coordination with other jurisdictions, including Everett.

Everett contains two lakes - Silver Lake and Beverly Lake. Hilton Lake and Ruggs Lake are in the Planning Area. Lakes serve as storage sites for the watershed. They moderate flood flows, exchange surface water and ground water, stabilize sediments, cycle nutrients, and provide habitat for fish and wildlife, provide recreational opportunities, and add to views and the feeling of open space.

3. Flooding Certain areas of the City are subject to periodic flooding of the Snohomish River. The Federal Emergency Management Agency (FEMA) oversees floodplain management nationwide and requires that local jurisdictions that participate in the National Flood Insurance Program (NFIP) have FEMA approved plans. The City and Snohomish County participate in the program and have approved plans.

Dikes and bank armoring have been constructed along the Snohomish River and associated sloughs to limit flooding. In 2005 FEMA adopted new floodplain maps and the City adopted amendments to the City’s floodplain regulations to implement the new maps and associated standards. In 2010 FEMA issued preliminary updated maps. These have not been adopted, but the proposal includes the option of regulating using the 2005 and 2010 maps, which ever are more protective. Figure 3.7.8 shows the 2005 100-year floodplains, as well as the additional 100-year floodplain areas shown on the 2010 maps.

4. Groundwater /Aquifer Recharge Areas The City did not identify critical aquifer recharge areas in the Planning Area, since potable water is supplied to residential, commercial and industrial development within the planning area by the City of Everett from Sultan basin water supplies. The Mukilteo, Silver Lake and Alderwood Water Districts also provide water within the planning area that they obtain wholesale from the City of Everett

.

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-13 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______

Figure 3.7.8: Wetlands and 100-Year Flood Hazard Areas (With 2010 Floodway and Floodplain Additions)

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-14 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______

Groundwater is used for irrigation in some parts of the Planning Area, and as cooling for at least one manufacturing process.

Groundwater recharge sites are not common in Everett area streams. However, there are a few natural groundwater recharge sites in the southwest Everett area. The City’s Stormwater Management Manual encourages development to infiltrate groundwater where feasible after treatment, and includes requirements that protect groundwater quality.

5. Fish and Wildlife Conservation Areas The Minimum Guidelines Classifying Critical Areas (Chapter 365-190 WAC) defines Fish and Wildlife Conservation Areas as:  areas with which endangered, threatened, and sensitive species have a primary association  habitats and species of local importance  commercial and recreational shellfish beds  kelp and eelgrass beds, herring and smelt spawning areas  naturally occurring ponds under 20 acres and their submerged aquatic beds that provide fish or wildlife habitat  waters of the state  lakes, ponds, streams, and rivers planted with game fish by a governmental or tribal entity  state natural area preserves  natural resource conservation areas.

EMC 19.37 defines Fish and Wildlife Conservation areas in Everett as an area of habitat that is necessary and suitable for maintaining individual species, species diversity, or biological diversity. These areas include:  Lakes and ponds less than twenty acres in size;  Streams/riparian corridors  Habitats of primary association  Continuous vegetative corridors linking watersheds and  Significant biological areas listed by the City: o plant associations of infrequent occurance o commercial and recreational shellfish areas o kelp and eelgrass beds o herring and smelt spawning areas o state natural area preserves and natural resource conservation areas  Significant biological areas of local importance o Maulsby Swamp o Kasch Park (Bomarc) Bog o Simpson site Category 1 wetlands o Narbeck Swamp o Jetty Island. Most of these features are also addressed by regulations for other critical areas, such as streams, and shoreline regulations.

The federal government listed the following species found locally as endangered under the Endangered Species Act: Bocaccio rockfish, southern resident orca.

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-15 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______The following species are listed as threatened: Bull trout, Puget Sound Chinook salmon, Puget Sound steelhead trout, Canary rockfish, yelloweye rockfish, marbled murrelet, Eulachon, and Green Sturgeon. Humpback whale and four species of sea turtles are also ESA-listed as threatened and have been documented in Puget Sound, but these species are rare and highly unlikely to be in the City.

The Washington Department of Fish and Wildlife publishes a list of Species of Special Concern. This list includes native Washington species considered endangered, threatened, sensitive, candidate and monitor. Endangered, threatened and sensitive species are legally established in Washington Administrative Codes. Candidate and Monitor species are established by WDFW policy. WDFW also publishes a Priority Habitats and Species (PHS) list. The PHS list is a catalog of habitats and species considered to be priorities for conservation and management. All Species of Concern are included as priority species. The PHS program maintains a database of priority habitats and species in Washington. Priority habitats identified in Everett and the unincorporated UGA include Terrestrial: Biodiversity Areas and Corridors (including Riparian areas); and Aquatic: Estuarine Intertidal, Freshwater Wetlands, and Eelgrass.

Areas of habitat for Washington’s priority wildlife species identified in Everett include overwintering waterfowl concentrations, shorebird concentrations, haulouts for California sea lions and harbor seals, geoduck concentration with densities of interest for commercial harvest, Dungeness crab breeding areas and regular concentrations, Pandalid shrimp concentrations, hard shell clams, surf smelt spawning areas, and Pacific sand lance spawning areas.

Priority species occurrence identified / mapped in Everett include bald eagle nests and buffers, purple martin, peregrine falcon, California sea lion, harbor seal, bull trout, Chinook salmon, Chum Salmon, Cutthroat trout, Coho, pink salmon, , steelhead, Sockeye salmon. In addition WDFW monitors and maps osprey and arctic tern occurrences. See Figures 3.7.9 – 3.7.18 for mapped occurrences of these species. Figure 3.7.12 shows the extent of all Salmonids combined as identified in WDFWs Salmonid Stock Inventory database. Individual maps for each species are available for review in the Planning and Community Development Department. Additional unmapped occurrences of the species identified above and other priority and monitored species are likely to occur in Everett.

Plant communities form the basis of wildlife communities; they provide the primary productivity upon which animals depend, along with nesting and denning sites, escape cover, and protection from adverse weather. In general, more complex plant communities with more structural diversity and more plant species provide higher value wildlife habitat than less complex vegetation communities.

Wildlife corridors are generally narrow areas that link large habitat blocks. These areas can provide habitat in themselves, connect larger blocks of habitat, and allow for relatively free movement of animals among larger blocks of habitat that would otherwise be isolated. The Southwest Everett Subarea Plan EIS identified wildlife corridors in that area, including the railroad corridor along Puget Sound that provides connections between ravines, and two designated corridors on Boeing property. Other areas that could act as corridors include City- owned open space properties and buffers located between the industrial area to the south and the residential area to the north. Wildlife corridors have not been specifically identified in other parts of the Planning Area.

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-16 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______Figure 3.7.9: Biodiversity Areas and Corridors

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-17 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______Figure 3.7.10: National Wetland Inventory

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-18 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______Figure 3.7.11: PHS Wetlands

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-19 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______Figure 3.7.12: Salmonid Distribution and Forage Fish Spawning Areas

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-20 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______Figure 3.7.13: Priority and Monitored Species

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-21 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______Figure 3.7.14: Winter Waterfowl Concentrations

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-22 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______Figure 3.7.15: Shorebird Concentrations

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-23 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______Figure 3.7.16: Harbor Seal and California Sea Lion Haulouts

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-24 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______Figure 3.7.17: Shellfish

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-25 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______Figure 3.7.18: Eelgrass Meadows

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-26 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______

B. Regulatory Framework

1. Snohomish County. The portion of the Planning Area outside the City limits is subject to Snohomish County’s Critical Area Ordinance (SCC Section 30.62) until annexation to Everett. Snohomish County is also in the process of updating their Critical Area Ordinance to comply with GMA requirements. Their current critical area regulations were established in 2007. They do not anticipate significant policy or program updates in the update.

2. City of Everett. Everett updated critical area regulations in Everett Municipal Code (EMC) 19.37 in 2006. These regulations apply to properties that are not in shoreline jurisdiction.2

Geologically Hazardous Areas. Development proposed on or within 200 feet of geologically hazardous areas must complete geotechnical assessments. Setback buffers are based upon information contained in the assessment or the International Building Code. Generally the code requires that these areas be protected and that buffers be provided from the top, toe and sides of such areas. Modifications to geologically hazardous areas are permitted only when a geotechnical report is submitted which shows that, among other things, the proposed development will not create a hazard to the subject property or surrounding property, the proposed method of construction will reduce erosion potential, landslide and seismic hazard potential; the proposal uses construction techniques which minimize disruption of existing topography and natural vegetation; and the improvements are certified as safe as designed and under anticipated conditions by a geologist.

Geologically hazardous areas are also regulated through Building Codes, City of Everett Public Works Design and Construction Standards and Specifications, City of Everett Stormwater Management Manual, and the City’s Land Division Ordinance.

Surface Water. Surface waters in Everett regulated by EMC 19.37 include streams, wetlands, and lakes. The regulations generally require that streams and wetlands be preserved and that buffers be provided adjacent to those areas. A system to categorize streams and wetlands is included, and the required buffer width relates to the category of the wetland. Alterations to streams, wetlands, and their buffers are permitted in some situations when mitigation of the impacts is provided. The City’s objective is no net loss of the functions and values of streams and wetlands in the City.

Proposed updates to EMC 19.37 to comply with Best Available Science requirements address  Use of the federal wetland delineation manual and applicable regional supplements to delineate wetlands, versus the State delineation manual, which was repealed.  Use of a new Ecology wetland rating system and establishing buffers related to the new scores in that system. The system is documented in Washington State Department of

2 The Snohomish River and Port Gardner Bay are regulated by the City’s shoreline master program.

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-27 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______Ecology Washington State Wetland Rating System for Western Washington 2014 Update (Ecology Publication No. 06-029).  Allowing a new method to calculate ratios for wetland mitigation versus the standard ratios are set forth in the code. The method is documented in Calculating Credits and Debits for Compensatory Mitigation in Wetlands of Western Washington: Final Report, March 2012.  Allowing contributions to an approved In-lieu fee (ILF) program as an acceptable way to mitigate for impacts to wetlands consistent with Ecology’s Guidance on In-Lieu Fee Mitigation. December 2012. Publication no. 12-06-012.

EMC 14.28 adopted the Ecology Minimum Criteria for stormwater management on new development and redevelopment, and utilizes the 2010 Everett Stormwater Management Manual to provide the methodology to meet flow control and water quality requirements under the Phase II National Pollutant Discharge Elimination System (NPDES) stormwater permit. The City must adopt new minimum standards as required in the 2013-2018 NPDES permit, and plans to utilize the 2012 Ecology Stormwater Management Manual for Western Washington to meet those requirements. The biggest change in those requirements will be the use of Low Impact Development (LID) as the preferred option for development starting January 1, 2017. Prior to that time, the City must ensure that current ordinances are reviewed and altered as needed to allow LID to be utilized in the City. We have already begun this effort, when, in 2013, zoning code standards for landscaping and parking lots were modified to encourage the use of low impact development stormwater management facilities. The City also has an inspection program for private stormwater systems to ensure that they function properly and therefore do not cause flow or water quality problems to the City’s municipal separate storm sewer system (MS4) or waterbodies.

The City’s Surface Water System Ordinance (EMC 14.56) prohibits the discharge of polluting matter into the surface water system and natural water bodies. Violations can result in fines and require corrective actions.

The City monitors water quality in most streams and in lakes in the City as a component of the Surface Water Management Program, which is funded through a surface water assessment on utility bills. Ambient testing gives a long term view of water body health, while testing required by the NPDES permit for Water Cleanup Plans (aka TMDLs) and Illicit Discharge Detection and Elimination programs attempt to detect the source of the problem and address the behavior that is causing the concern. The City also samples benthic macroinvertebrates in streams.

Flooding. Floodplains are regulated by EMC 19.30, most recently updated in 2005. The City has three floodplain overlay districts: the Floodway overlay zoning district, the Urban Flood Fringe overlay district, and the Rural Flood Fringe overlay district. The Rural Flood Fringe district is located south of Lowell in the Marshland Area. Development in this area is highly restricted. The City of Everett’s Water Pollution Control Facility, including lagoons are in the Rural Flood Fringe District. The rest of Everett’s floodplains are in the Urban Flood Fringe District (UFFD). Development is allowed in the UFFD when it is consistent with the Shoreline Master Program and zoning code. Developments in these areas are required to elevate structures and outdoor storage areas two feet above the regulatory flood protection level.

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-28 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______The intent of the regulations in EMC 19.30 is to restrict or prevent development from obstructing flood flows and causing additional flooding outside the normal floodway, to require that uses vulnerable to floods shall be protected against food damage at the time of initial construction, to ensure that those who occupy special flood hazard areas assume responsibility for their actions, to ensure that potential buyers are notified that property is in a hazard area, and to meet the requirements of the federal flood insurance program.

A 2004 lawsuit held that FEMA had a responsibility to consult with the National Marine Fisheries Service (NMFS) about impacts of the NFIP on listed species under Section 7 of the Endangered Species Act (ESA). The plaintiffs (the National Wildlife Federation) believed that the operation of the NFIP resulted in impacts on several species listed under the ESA and their critical habitats within Puget Sound. A consultation is the mechanism used to review federal programs or permitting activities and determine what is needed to address any impacts. Consultations are handled either by the National Marine Fisheries Service (NMFS) or the United States Fish and Wildlife Service (USFWS).

The result of that consultation was the issuance in September 2008 by NMFS of a Biological Opinion (BiOp) under the ESA. The BiOp prepared for the NFIP found that some elements "jeopardized" several ESA-listed species in the Puget Sound, including Chinook salmon and Orca whales. These elements included FEMA floodplain mapping, the community rating system and the minimum development standards. The BiOp identified seven actions for FEMA that would bring the NFIP into compliance with the ESA, the third of which called for FEMA to modify its implementation of the NFIP minimum criteria to prevent and/or minimize the degradation of channel and floodplain habitat. NMFS set a deadline of September 22, 2011 for work by FEMA and 122 communities in Puget Sound to implement this action.

In July 2011, Everett submitted information to FEMA describing how Everett planned to comply with the BiOp through implementation of our existing regulations. The submittal included a Planning Director Interpretation (PDI) No. 2011-1 that described how the City would implement the critical area regulations requirements for preparation of biological assessments in areas addressed in the BiOp. PDI No. 2011-1 is in addition to PDI No. 2000-2 that also addressed requirements for biological assessments and habitat management plans for listed species. The biggest difference between past development practices and new development under PDI No. 2011-1 is that new development must replace fish habitat lost by fill, and also provide compensatory storage for fill in the floodplain that replaces storage of water during a 100-year flooding event. Note that floodplains adjacent to Silver Lake are not subject to the PDI since they do not provide habitat for endangered species.

After minor revisions to Everett’s submittal, in January 2014, FEMA approved Everett’s submittal, stating that we comply with the Biological Opinion through our ordinances, regulations and written policies. Proposed amendments to the Critical Area Regulations include reference to PDI No. 2011-1 to ensure that all staff and other parties are aware of these procedures required to comply with the BiOp.

Groundwater/Aquifer Recharge Areas The City’s Stormwater Management Manual requires infiltration and low impact development techniques where appropriate after treatment. It also includes standards to protect groundwater quality when infiltration occurs.

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-29 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______

Fish and Wildlife Conservation Areas. EMC 19.37 requires preparation of habitat management plans when a development is proposed on or within a distance that could impact fish and wildlife conservation areas. The plan must be based upon sound habitat management practices and designed to achieve specific habitat objectives. These plans are circulated to appropriate resource agencies for review and comment. Two Planning Director Interpretations (PDIs) have been issued that provide more detail about how the requirements for preparation of biological assessments and habitat management plans are implemented. The proposal adds references to these PDIs in the code.

3. State and Federal Regulations Applicable in City Limits and UGA Endangered Species Act. This federal act restricts activities that would significantly affect listed species and their habitats.

Clean Water Act and State Water Pollution Control Act. The Department of Ecology is responsible for issuing Federal National Pollution Discharge Elimination System (NPDES) permits for non-federal projects. The permit is for any project which disturbs five acres or more of total land during construction, and/or which will discharge stormwater to surface water or to a storm sewer. The regulations require stormwater prevention plans, including water quantity and water quality controls.

Under Section 404 of the Clean Water Act, the US Army Corps of Engineers regulate excavation and discharge of fill materials into wetlands and other waters of the state. The program includes Nationwide Permits to expedite authorization of projects considered by the Corps to have minimal impacts on the environment. Other projects are required to get individual permits, which require alternatives analysis. The Washington Department of Ecology also reviews the Corp’s Nationwide Permits issued under Section 404 of the Clean Water Act and either approves the permits, denies water quality certification for permits that have the potential to cause more than minimal harm, or certifies the permits with additional State conditions. Individual Water Quality Certifications are required for projects that fall under nationwide permits that were denied, projects that cannot meet State conditions for nationwide permits, and projects that must obtain individual Corps permits.

The Clean Water Act 401 Water Quality certification program requires states to certify that projects will not adversely affect water quality or violate state aquatic protection laws. The Department of Ecology coordinates the comments of all state natural resource agencies for required permits.

Water Quality Standards for Surface Waters of the State of Washington. The Department of Ecology is responsible for implementation and enforcement of water quality standards. The regulations require that waste discharge permits, including NPDES permits, are conditioned so the discharges authorized will meet the water quality standards. The regulations recognize four general beneficial uses for surface water sources. Aquatic Life, Contact Recreation, Water Supply and Other Uses, such as boating and aesthetics. All water bodies in the state are expected to provide all of these designated uses: When waters do not meet their established standards they are identified as impaired under Section 303(d) of the Clean Water Act. Ecology regularly publishes the list of 303(d) waters. Ecology then develops a pollutant management plan where total maximum daily loads (TMDLs) are established to restore water quality.

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-30 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______

Hydraulic Project Approvals. A Hydraulic Project Approval (HPA) from the Washington Department of Fish and Wildlife (WDFW) is required for work within the ordinary high water line of state waters. Work occurring in wetlands that are located adjacent to marine bodies, streams or lakes typically require an HPA. State standards require that fish be able to migrate through culvert structures unimpeded.

C. Impacts

1. All Alternatives

The Buildable Lands analysis used as the basis for Alternative 3 removed critical areas and their buffers, to the extent known, from the calculations for determining residential and employment capacity in Everett’s Planning Area. Those assumptions were carried forward to Alternative 1 and 2 capacity analyses. In addition, capacities were reduced to account for unmapped critical areas.

In all alternatives, urbanization will increase significantly over the 2025 development levels anticipated in the existing Comprehensive Plan. Development will be required to comply with regulations protecting the environment, including the City’s critical area, floodplain, clearing, grading, and stormwater regulations.

Because much of Everett’s land has already been developed, a large portion of future development will be expansions on partially used parcels and redevelopment. This will reduce impacts over what would occur from developing entirely vacant parcels in more rural areas. Figure 3.1.12 in DEIS Chapter 3.1 shows how the County’s Buildable Lands analysis categorized future development sites as of 2011 conditions. Alternatives 2 and 3 used the Buildable Lands assumptions for parcel status. Many of the sites that are shown as vacant are sites that have been developed in the past. For example, the Port’s Riverside Industrial Park along the Snohomish River is classified as vacant, but was previously developed with Weyerhaeuser mills. Significant environmental clean-ups have taken place on the properties and utilities and roads have been constructed in get the property ready for new development. Alternative 1 assumes that more parcels are redevelopable in the downtown core areas, and in the Evergreen Way E-1 MUO and the Broadway Mixed Use zones. See Figure 3.1.13 in DEIS Chapter 3.1. Note that not all of the parcels shown are expected to be developed by 2035. When calculating future development capacity, Buildable Lands takes out portions of these areas to account for unknowns, such as uncertainty, and property owners that are not willing to develop their properties for a variety of reasons.

Under all alternatives development has the potential to result in the following impacts:

Vegetative cover will be disturbed as sites are developed, particularly on vacant and partially used sites. Clearing and grading results in changes to topography; removal of topsoil from sites; increased soil erosion and resulting sedimentation of stream, lakes, and wetlands; soil compaction; possible slope failures; modifications to drainage and stormwater flows; degradation of water quality; and degradation of wildlife habitat. The degree of potential hazard depends on a large variety of factors, including the soil type, slope, drainage characteristics of the site, the

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-31 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______amount of rainfall during construction, the construction methods used, the extent of grading proposed, distance from critical areas, and the width and quality of buffers around critical areas.

Compacted soils and soils covered by impervious surfaces allow for less infiltration of stormwater, resulting in increased surface water runoff that can cause downstream flooding. The increased runoff also increases peak flows and the duration of flows in streams, resulting in increased erosion and degradation of aquatic habitats. Eroded material may settle into the stream channels or wetlands, or may be carried to receiving waters, such as Port Gardner Bay. Increased turbidity is harmful to fish. Sedimentation of stream channels can reduce gravel spawning beds necessary for fish habitat and can reduce the water storage and conveyance capacity of the system.

Erosion and sedimentation impacts are most likely to occur during site preparation and construction when soils are exposed. Soils can be eroded from the site by water and wind, or carried out on the wheels of construction vehicles. The eroded soil can impact air quality, and degrade surface waters and fisheries resources.

More significant impacts may result from work on geologically hazardous areas. Erosion is most likely to occur on steep slopes. Since many of Everett’s surface waters are adjacent to steep slopes, work adjacent to steep slopes is most likely to impact these surface waters. Structures in landslide hazard areas will be susceptible to the impacts of landslide/seismic hazards such as mudslides and falling debris. Landslides may disrupt sewer, water and gas lines; electrical facilities; detention ponds and other water quality features. These types of impacts are most likely to occur from on-going impacts from development constructed prior to adoption of the City’s critical area ordinance and less likely to occur with development constructed in accordance with current standards.

Alteration of slopes and urbanization can also affect views of natural areas.

Altered hydrology from impervious surfaces and changes to soils and vegetation can result in declining summer base flows in streams and streams becoming intermittent, since water is not stored in groundwater and released gradually to the streams. Low summer base flows can allow vegetation to encroach into the channel and resulting loss of flood-carrying capacity. These impacts are less likely to occur on projects built under new stormwater regulations that require the use of low impact development when feasible.

Urban land uses can degrade water quality in streams, wetlands, lakes and groundwater. Deterioration can occur when pollutants, such as sediments, fertilizers, pesticides, organic materials, petroleum products, toxic materials, and pet wastes are discharged into surface runoff. Contaminants from streets and parking areas are carried into the storm drainage system by rainfall. Polluted waters can cause health problems, kill fish, reduce wildlife habitat value, and detract from aesthetic qualities of water features. Improper disposal of toxic contaminants into storm drains by residents and businesses can also cause significant pollution of streams, wetlands and lakes.

Vegetation in buffers adjacent to surface waters can remove pollutants from stormwater before they reach the surface water. Removal of vegetation during urbanization degrades water quality

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-32 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______by eliminating that filtering, and also be changing microclimate, resulting in increased temperatures in the surface waters, particularly during the summer.

Modification of hydrology from urbanization can result in downstream flooding.

Increasing sedimentation and pollutants to lakes and wetlands can reduce storage volumes and modify chemistry. Excessive nutrients can accelerate eutrophication, increasing algal blooms and reducing oxygen in the water, impacting aquatic plants and wildlife.

As culverts are replaced over time, fish access will be increased due to state regulations for culverts. This increase could be moderated by sedimentation and lack of culvert maintenance that can block culverts.

As vegetation is removed and properties developed, isolation and fragmentation of wildlife habitat will increase, reducing wildlife present. Species adaptable to urban settings will increase. Species that may be particularly sensitive to reduction and fragmentation of forested areas include neotropical birds. Species that are more adaptable include jays, house wrens, robins, starlings, blackbirds and towhees.

Alteration of hydrology can result in a reduction in plant species diversity and vegetation structure in wetlands, and can adversely affect amphibians.

Urbanization favors the introduction and spread of exotic invasive species, such as Scot’s broom, English ivy, and Japanese knotweed. This decreases native plant diversity through competition and reduces available forage for deer and smaller herbivores, and foraging sites for shrubs and understory birds. Wildlife species such as opossum, raccoon and gray squirrels can increase with urbanization.

Research in the Lake Washington watershed found that fish species diversity declined with increasing levels of urban development. As urban development increased, cutthroat trout began to predominate over coho salmon and other salmonid species in small streams.

Lighting and noise associated with urbanization affect wildlife use of adjacent open spaces. Night time lighting into stream corridors may allow greater predation of fish by raccoons and other wildlife.

Increased disturbance by humans and domestic animals can affect how wildlife use remaining habitat.

Ground nesting birds decline with increasing urbanization.

Fences constructed around developments, including the BNSF rail line limits movement of wildlife.

As traffic increases on roadways, connections between wildlife areas will further decrease as wildlife is unable to cross.

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-33 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______Outside of the major ravines, few wildlife corridors will remain that are as wide as 300 feet, resulting in the disruption of movement of larger mammals such as deer. Deer may use landscaped corridors and roadways more frequently, resulting in more frequent conflicts for animals and humans.

The already low proportion of upland conifer forest will decrease further as development proceeds in the uplands. This will decrease the diversity of available habitats, and further limit conifer recruitment into mixed forest areas. Programs such as the Parks Department / Forterra Green Everett Partnership 20-Year Forest Management Plan can mitigate these impacts to some extent. This is a restoration and stewardship program for Everett’s parklands to control invasive species, plant native species to achieve a long-lived forest canopy with conifers, maintenance and monitoring.

Removal of large areas of forest adjacent to remaining critical areas and their buffers can result in damage to trees in the critical areas and buffers. Damage can result from compaction around roots, cutting roots, and blowdown from subjecting the remaining trees to greater wind forces.

Williams Map Amendments This proposal adjacent to the current downtown would allow more intense development of the site. The site is currently developed with structures containing 18 dwelling units. Site landscaping is typical of residential parcels, including lawns, trees and shrubs that will likely all be removed with redevelopment. The proposed zoning would not require building setbacks, so redevelopment would result in landscaping on the site. Street trees will be required as part of the redevelopment. The site is in the combined sewer area and there are no critical areas on or near the site. No significant impacts to the natural environment are anticipated as a result of this proposal. Providing additional development capacity on this site may result in less pressure to develop in more rural areas.

Everett Station Area Amendments This area has historically been developed with commercial and industrial development. Similar to the Williams property, the area is in the combined sewer area and there are no critical areas on or near the site. No significant impacts to the natural environment are anticipated as a result of this proposal. Providing additional development capacity on this site may result in less pressure to develop in more rural areas.

Marine Port Element The intent of this element is to ensure that local land use decisions are made in consideration of the economic contribution of Everett’s international container port, related industrial lands. The existing Port properties are already developed. The main impact to critical areas addressed in the element is the potential expansion of the Port’s South Terminal to accommodate larger cargo vessels and increasing cargo volume. The proposed expansion area was identified in the Port’s 2008 Marine Terminal Master Plan. The expansion area is located within the harbor lines where in-water development can occur under existing regulations. The element requires that the Port mitigate the impacts of redevelopment and expansion consistent with the City’s Shoreline Master Program, and other local, state, and federal regulations.

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-34 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______Amendments to EMC 19.37 Critical Area Regulations The proposed amendments are being made to address updated Best Available Science. No significant adverse impacts will result from the changes. Ecology analyzed use of the new wetland rating system for Western Washington for a set of wetlands in Western Washington and found that the ratings for 60 sites remain unchanged, while 30 sites had a lower category, and 21 sites had a higher category. Individual wetland ratings may change, and thus the buffers that apply may be affected.

Amendments to EMC 19.30 Floodplains Regulations The proposal includes an option to apply floodplain development regulations to areas on preliminary 2010 flood insurance rate maps (FIRMS) that are not shown in the floodplain on the adopted 2005 maps. Ecology guidance for frequently flooded areas states that the 2010 maps are best available science. The 2010 maps are digital, used a more accurate vertical datum and more accurate contour data, and use aerial photographs as the base map which make them easier to use. See Figure 3.7.8 for the location of these areas added to the 100-year floodplain on the 2010 maps. The alternative option is to continue to use the 2005 adopted maps only, and the additional areas added in the 2010 maps would not be regulated until the maps are adopted. The time frame for FEMA adoption of the maps is not known.

The City plans to meet with affected property owners prior to the comment period for this DEIS to discuss the potential regulations. This will provide notice to property owners that they will be in the floodplain when the new maps are adopted, and will be subject to floodplain regulations and different flood insurance standards. The City will also place an alert on the affected parcels in the City’s TRAKiT project and permit tracking system. This would notify property owners or potential purchasers in case they came to the permitting counter to ask questions before purchasing a property.

If the City decides not to regulate these areas until the maps are adopted the City could only encourage property owners to elevate structures. If a property owner decides to not elevate, that owner or future property owners would be subject to regulations and higher flood insurance rates when the maps are adopted. If property owners want to fill or otherwise develop their properties prior to adoption of the new maps, they could fill without providing the compensatory storage required under PDI No. 11-1 that responded to the BiOp issued by NMFS (see pages 28-29 for a description of the PDI). In addition, some of the parcels are more than 200 - 250 feet from the Snohomish River and a biological assessment would not be required for development on the site to assess impacts to habitat under the City’s existing regulations.

If the City does regulate these areas, it would ensure that new development is protected from flooding and property owners would get lower flood insurance rates. Property owners will have to meet the PDI requirements for compensatory storage and habitat function replacement. Providing compensatory storage that provides fish habitat during flooding events may be difficult on some of the parcels, especially those that do not front on the Snohomish River and have development between them and the River.

2. Alternative Comparison. The type of impacts that will occur under all Alternatives are similar.

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-35 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______Alternatives 1 and 2 assume higher density housing primarily in North Everett in and around the downtown and Everett Station area, near WSU/Everett Community College, and along portions of Broadway Ave. These areas are within the City’s combined stormwater system, and have been developed in the past. The redevelopment in these areas will not impact critical areas. Alternatives 1 and 2 also assume that densities will increase in the Evergreen Way mixed use overlay (E-1 MUO) zones. The E-1 MUO zones located south of approximately Highway Place are outside of the combined sewer area and have the potential to impact streams and wetlands. However developments that comply with all applicable regulations are not expected to result in significant impacts to streams or wetlands. Only two small landslide hazard areas are located in the vicinity of E-1 MUO zones.

To the extent that higher residential densities, and more population and employment are accommodated in Everett, the less that will potentially occur in the rural areas of Snohomish County, and the lower the impacts to critical areas in those rural areas.

D. Potential Mitigation Measures

 The proposed Comprehensive Plan policy amendments include a variety of measures to protect and restore Everett’s natural environment. Examples include: o Continue to implement programs such as the Green Everett Partnership 20-year Forest Management Plan to control invasive species, plant native species, and develop a long-lived coniferous forest canopy in Everett’s parklands. o Encourage the protection and restoration of private forested areas, such as at the Forgotten Creek ravine, and other steep slopes, and stream and wetland buffers. o Encourage the use of native plants to provide habitat for native species that are in decline. o Encourage the reduction in lawn areas since lawns use a disproportionate amount of water in summer when it is scarce, is a monoculture not supportive of native species, and is the source of much of the fertilizer and pesticide run-off from residential and recreation areas.

 The City’s Office of Emergency Management’s Hazards Inventory and Vulnerability Assessment (HIVA) and Hazard Mitigation Plan provide strategies that Everett can use to increase its hazard resilience. Examples which would help protect critical areas and general environmental health include: o Landslides: Increase education on the consequences of cutting even a few trees, and disseminate in television and radio formats, as well as through flyers or presentations in neighborhoods in which landslides are a higher-risk event. o Identify brownfield sites and plan their clean up and reuse. o Work with Snohomish County to develop a plan for Low Impact Development and increased storage in the Snohomish River watershed, and to coordinate development of regulations on the river.

 The City could consider, in part, the needs of salmonids and other wildlife when purchasing lands for public use, such as parks and recreation.

 Develop a city-wide wildlife corridor plan using landscape analysis and connectivity as a basis.

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-36 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______

 Consider policies that encourage dedication of critical areas to the City or Land Trusts as development occurs on adjacent areas to ensure the critical areas are protected over the long term.

 Increasing public access to and/or visibility of critical areas can lead to long-term public scrutiny of maintenance and protection of the critical areas, and potentially lead to less illegal dumping in these areas.

 Encourage the provision of understructure parking to reduce the amount of impervious surface and the pollutants in stormwater runoff.

 Encourage sustainable development.

 Increase public education regarding protecting and restoring critical areas.

 Aggressive inspection and enforcement of activities in or adjacent to critical areas.

 The provision of sewer service in unincorporated areas, either after or prior to annexation, will reduce the impacts of failing septic systems on surface water quality.

 Retrofit existing detention facilities to increase storage capacity and improve water quality treatment.

E. Unavoidable Adverse Impacts

Decreased forest land and native vegetative cover and increases in impervious surfaces, resulting in accelerated runoff and erosion processes, modifications to hydrologic regime in streams and wetlands, and loss of wildlife habitat. Compliance with new storm water regulations will reduce these impacts over that which occurred under past development practices.

Loss of vegetated cover providing shade, resulting in elevated water temperatures impacting aquatic life.

Increase in pollutants impacting soils and surface waters.

Alteration of wetlands and streams will occur as development of the urban area continues.

Plant and animal species will change with urbanization, including introduction of exotic species and increases in populations more adaptable to urban environments and disturbance.

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-37 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______V. Air Quality and Odor3

A. Existing Conditions: Regulatory Background

1. Standards for Criteria Pollutants Three agencies have jurisdiction over air quality in the Puget Sound area: the US Environmental Protection Agency (EPA), the Washington State Department of Ecology (DOE), and the Puget Sound Clean Air Agency (PSCAA). These agencies have established regulations that govern both the allowable concentrations of pollutants in the outdoor air and the allowable contaminant emissions from air pollution sources.

Based upon the National Clean Air Act (CAA) requirements, last amended in 1990, the U. S. Environmental Protection Agency (EPA) established national ambient air quality standards (NAAQS) for air pollutants considered harmful to public health and the environment. The standards are designed primarily to protect the general public, but also include specific sensitive populations such as asthmatics, children and the elderly. They are also intended to protect public welfare by reducing effects such as decreased visibility and damage to animals, crops, vegetation and buildings. The EPA has established standards for six common pollutants: carbon monoxide (CO), particulate matter [below 10 micrometers (PM10) and below 2.5 micrometers (PM2.5)], ozone, lead, sulfur dioxide, and nitrogen dioxide. The standards are updated approximately every 6 years.

The Washington State Department of Ecology (Ecology) and the Puget Sound Clean Air Agency (PSCAA)4 administer the provisions of the Clean Air Act and operate monitoring stations to evaluate conformance with Act. Ecology established standards for the criteria pollutants listed above that are at least as stringent as the national standards. Table 3.7.1 shows the ambient air quality standards established by the EPA and Ecology.

PSCAA has not adopted more stringent standards. However in 1999 they adopted an Air Quality health goal for all four of their counties to reduce PM 2.5 pollution to less than 25 g/m3 each day.

Areas that meet the NAAQS are attainment areas and areas that do not meet the standard for a pollutant are nonattainment areas for that pollutant. The Clean Air Act requires that attainment plans be prepared for nonattainment areas to show how the area will meet and maintain the standard. Once the nonattainment area meets the standard for a period of time, it is redesignated a maintenance area and is required to prepare a maintenance plan to show how the standard will continue to be met in the future.

3 Much of the information in this section was taken from the PSCAA web site, documents, and personal communication. 4 The PSCAA’s jurisdiction covers Snohomish, King, Pierce and Kitsap Counties.

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-38 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______Table 3.7.1: Ambient Air Quality Standards

National (EPA) WA State Pollutant Primary Secondary (DOE) Remarks Carbon Monoxide (CO) (EPA revised August 31, 2011) 8-hour average 9 ppm no standard 9 ppm Not to be exceeded more than once 1-hour average 35 ppm no standard 35 ppm per year Particulate Matter (PM10) 24-hour average 150 g/m3 150 g/m3 150 g/m3 Not to be exceeded more than once per year averaged over 3 years Particulate Matter (PM2.5) (EPA revised 12/14/2012) Annual average 12 g/m3 15 g/m3 12 g/m3 Annual mean, averaged over 3 years 24-hour average 35 g/m3 35 g/m3 35 g/m3 98th Percentile, averaged over 3 years Lead (Pb) (EPA revised 11/12/2008) Quarterly average .15 g/m3 .15 g/m3 .15 g/m3 Not to be exceeded Sulfur Dioxide (SO2) (EPA revised 6/22/2010) Annual average no standard no standard 0.02 ppmv Not to be exceeded in a calendar year 24-hour average no standard no standard 0.14 ppmv Not to be exceeded more than once per year 3-hour average no standard 0.50 ppm 0.5 ppmv Not to be exceeded more than once per year 1-hour average 75 ppb no standard 75 ppbv 99th percentile of 1-hour daily maximum concentrations averaged over 3 years Ozone (O3) (EPA revised 3/27/2008) 8-hour average 0.075 ppm 0.075 ppm 0.075 ppmv Annual 4th highest daily maximum 8-hr concentration, averaged over 3 years Nitrogen Dioxide (NO2) (EPA revised 6/22/2010) Annual average 53 ppb 53 ppb 1-hour average 100 ppb no standard 100 ppbv 98th percentile of 1-hour daily maximum concentration, averaged over 3 years Sources: WA State DOE regulations Chapter 173-476 WAC, effective 12/22/2013; http://www.epa.gov/air/criteria.html

Notes: PM10 = particles 10 microns or less in size PM2.5 = particles 2.5 microns or less in size ppb = parts per billion ppbv = parts per billion by volume ppm = parts per million ppmv = parts per million by volume g/m3 = micrograms per cubic meter

Particulate Matter (PM 10 and PM 2.5) Particulate matter (PM) includes both solid matter and liquid droplets suspended in the air. Particles smaller than 2.5 micrometers in diameter are called “fine” particle, or PM 2.5. Particles between 2.5 and 10 micrometers are called “course” particles. PM 10 includes both fine and course particles. Course particles typically come from crushing or grinding operations and dust

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-39 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______from roads. PM 10 can aggravate respiratory conditions such as asthma. People with respiratory conditions should avoid outdoor exertion if PM 10 levels are high.

PM 2.5 generally comes from wood burning and industrial sources, as well as vehicle exhaust including cars, diesel trucks, and buses. It can also be formed in the atmosphere by chemical reactions of pollutant gases. Exposure to particle pollution is linked to a variety of significant health problems, such as increased hospital admissions and emergency department visits for cardiovascular and respiratory problems, including non-fatal heart attacks and premature death. Older adults, children, pregnant women, and those with pre-existing health conditions are more at risk from exposure to particle pollution. Particle pollution also contributes to haze in cities and national parks.5

Carbon Monoxide (CO) Carbon Monoxide (CO) is an odorless, colorless gas that can enter the bloodstream through the lungs and reduce the amount of oxygen that reaches organs and tissues. CO forms when the carbon in fuels doesn’t burn completely. The majority of CO comes from vehicle exhaust. Higher levels of CO generally occur in areas with heavy traffic congestion. In cities, 85-95% of all CO comes from motor vehicle exhaust. The highest levels of CO in the outside air typically occur during the colder months of the year when temperature inversions are more frequent. People with cardiovascular or respiratory problems might experience chest pain and increased cardiovascular symptoms, particularly while exercising or exerting themselves during periods when CO levels are high. High levels of CO can affect alertness and vision even in healthy individuals. If CO levels are high; people should limit exertion and avoid sources of CO such as heavy traffic.

Sulfur Dioxide (SO2) Sulfur Dioxide is a colorless, reactive gas produced by burning fuels containing sulfur, such as coal and oil, and by industrial processes. Historically the greatest sources of SO2 were industrial facilities that derived their products from raw materials like metallic ore, coal, and crude oil, or that burned coal or oil to produce heat (petroleum refineries, cement manufacturing and metal processing facilities). Today on-road vehicles, marine craft and diesel construction equipment are the main contributors to SO2 emissions.

People with asthma who are active outdoors may experience bronchial-constriction, where symptoms include wheezing, shortness of breath and tightening of the chest. People should limit outdoor exertion if SO2 levels are high. SO2 can also form sulfates in the atmosphere, a component of fine particulate matter.

Ozone (O3) Ozone (O3) in the upper atmosphere protects us by absorbing harmful ultraviolet radiation from the sun. However, high concentrations of ground-level ozone can cause respiratory distress in humans and are associated with decreased yield of agricultural crops and forests. The damage ozone causes to the lungs heals within a few days, but repeated or prolonged exposure may cause permanent damage. Ozone has also been linked to immune system impairment. People with respiratory conditions should limit outdoor activity if ozone levels are high. Even healthy individuals may experience respiratory symptoms on a high ozone day.

5 Puget Sound Clean Air Agency 2013 Air Quality Data Summary. August 2014.

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-40 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______

Ozone is a summertime air pollution problem, and it is not directly emitted by pollutant sources. It forms when photochemical pollutants from vehicles, industrial sources, commercial solvents and woodburning react with sunlight. Ozone levels are usually highest in the afternoon because of the intense sunlight. The months of May through September are of concern for high ozone levels in the Pacific Northwest.

The photochemical formation of ozone takes several hours, and the reactions occur best on warm, sunny days when light winds are from the north. While the precursor chemicals that react with sunlight to produce the ozone are generated in the large urban areas, most monitoring stations measuring ozone are located in the rural areas of Puget Sound, downwind from these metropolitan centers. Ozone has typically been transported 10 to 30 miles downwind from the original sources by the time the highest concentrations have formed in the afternoon and early evening. The highest ozone concentrations occur at the Enumclaw monitor southeast of the urban area.

Lead (Pb) Lead is a highly toxic metal that was used for years in household products, automobile fuel and industrial chemicals. Locally, airborne lead was primarily associated with automobile exhaust and lead smelters. The large reductions in lead emissions from motor vehicles have changed the nature of the lead air quality problem in the US. Industrial processes (lead smelters and battery manufacturers) are now responsible for most of the lead emissions. Lead from aviation gasoline used in small aircraft is also of concern nationally. Since the phase-out of lead in fuel and the closure of the Harbor Island lead smelter, levels of lead in ambient air have decreased substantially in the Puget Sound area.

People, animals and fish are mainly exposed to lead by breathing or ingesting it in food, water, soil or dust. Lead accumulates in the blood, bones, muscles and fat. Infants and young children are especially sensitive to even low levels of lead. Lead can have health effects ranging from behavioral problems and learning disabilities to seizures and death.

Nitrogen Dioxide (NO2) Nitrogen dioxide (NO2) is a reddish brown, highly reactive gas that forms from the reaction of nitrogen oxide (NO) and oxygen in the atmosphere. The term nitrogen oxides (NOx) which frequently appears, refers to both nitrogen oxide (NO) and nitrogen dioxide (NO2). NO2 will react with VOCs and can result in the formation of ozone. On-road vehicles like trucks and automobiles are the major source of NOx. Home heaters and gas stoves can also produce NO. NO2 pollution is greatest during cold weather.

NO2 can cause respiratory symptoms such as coughing, wheezing and shortness of breath in people with respiratory diseases such as asthma. Long-term exposure can lead to respiratory infections.

2. Impaired Air Quality Periods (Burn Bans) The Washington Clean Air Act and DOE implementing regulations require PSCAA to declare an “impaired air quality” condition when levels of particulate matter (PM 10) or carbon monoxide exceed specific standards. The declaration results in a “burn ban” where outdoor fires and most

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-41 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______indoor burning is banned. Outdoor burning has been banned in the urban areas of Snohomish, Pierce and King Counties since 1992.

The Puget Sound Clean Air Agency has been issuing wintertime air quality burn bans during episodes of poor air quality since the late 1980s. During these burn bans, the Clean Air Agency has prohibited the use of primarily uncertified wood stoves and fireplaces in order to reduce pollution and lessen the impact on public health. Typically weather conditions allow for good air quality in our region, but during colder months, weather inversions and calm winds are more common. Without strong winds, the air becomes stagnant and weather inversions trap the air closer to the ground. These conditions combined with an increase in wood burning make air quality burn bans necessary.

The burn ban program has evolved over the years to reflect updates in health information and mandated air quality standards. More restrictive burn ban requirements began in the 2008-2009 heating season, prompted by a more protective law enacted by the 2008 Washington State Legislature to align with stricter air quality health standards adopted in late 2006 by the U.S. Environmental Protection Agency (EPA).

3. Non-Criteria Pollutants-Air Toxics Sources In addition to criteria air pollutants, PSCAA is increasingly focusing efforts on reducing air toxics. Air toxics are a group of over 400 pollutants known or suspected to cause a number of health problems, including cancer and birth defects, as well as damage to lungs, and immune and nervous systems. In our region, health risk from air toxics comes primarily from fine particles in diesel exhaust.

4. Permits – New and Modified Sources of Air Pollution PSCAA and Ecology are responsible for permitting all new or modified sources of air pollution in Everett. All new air emission sources must submit a notice of construction and application for approval, called a NOC Application. All new or modified sources within the region and state must apply best available control technology (BACT), as defined by the EPA, to reduce emissions. Also they must conduct computer modeling to demonstrate that the facility’s emissions will not cause ambient concentrations to exceed the NAAQS limits, and to minimize the impacts of odors and toxic air pollutants. In addition, new air emission sources must not violate any federally established new source performance standard (NSPS), or national emission standard for hazardous air pollutants (NESHAP). Beyond the EPA regulations and standards, the PSCAA regulations address specific sources such as volatile organic compound (VOC) emission sources and air toxics sources. Odors are also regulated.

New “major sources” (facilities that emit more than 100 tons per year of any single air pollutant, more than 10 tons per year of any hazardous air pollutant, or more than 25 tons per year of a combination of hazardous air pollutants) are also required to obtain a Prevention of Significant Deterioration (PSD) and an Air Operating Permit. The requirements are more stringent than for a NOC. Facilities with a PSD permit must comply with lower ambient air quality limits, and must demonstrate they will not cause visibility or acid deposition problems at national parks and wilderness areas in the region.

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-42 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______5. Inspections All major air contaminating operations and equipment, other than motor vehicles, are registered with and regularly inspected by PSCAA. Major air contaminating sources are defined as those sources that emit ten tons or more of volatile organic compounds (VOC) or toxic air contaminants (TAC) per annum; and sources emitting 25 tons or more of particulate matter, oxides of sulfur, oxides of nitrogen or carbon monoxide per annum.

6. Conformity Analyses – State and Federal-Funded Transportation Projects Cars and trucks on public roads are the largest single source of pollutants in Everett, Snohomish County and the Puget Sound region. EPA and the state enacted regulations requiring federal or state funded highway projects to evaluate their local and regional impacts (40 CFR Part 93 and WAC 173-420). Transportation projects proposed for construction within non-attainment or maintenance areas are subject to the Transportation Conformity regulations specified under federal and state regulations. The permitting agency must demonstrate conformity by the following steps:  Confirm that the project is in the regional Transportation Improvement Plan (TIP).  Confirm that the regional emissions (including the proposed project) described in the TIP are within the allowable emission budget specified by DOE.  Use an EPA-approved air quality dispersion model to assess CO concentrations at the most heavily congested intersections.

B. Existing Conditions

1. The Puget Sound Region’s Compliance with NAAQS PSCAA’s four-county jurisdiction is currently in attainment for carbon monoxide, ozone, lead, sulfur dioxide, and PM10. However, in 2009 a large portion of Pierce County was designated a nonattainment area for PM 2.5. In 2013 PSCAA’s 1999 goal for PM 2.5 was met in Kitsap County for the first time. It has not been met in the 3 other counties. The western portion of Snohomish County is currently a maintenance area for CO.

PSCAA’s 2013 Air Quality Data Summary states Over the last two decades, many pollutant levels have declined and air quality has improved. While air quality is improving, we face new challenges. The Environmental Protection Agency (EPA) regularly revises national ambient air quality standards as directed by the Clean Air Act to protect public health.

Elevated fine particle levels pose the greatest air quality challenge in our jurisdiction. While fine particle levels met EPA’s health-based standard of 35 micrograms per cubic meter in 2013, sites in three of four counties (King, Pierce and Snohomish) continued to exceed the Agency’s more stringent local PM 2.5 heath goal of 25 micrograms per cubic meter. In 2013, our Kitsap County monitor met the Agency’s local PM 2.5 health goal.

Ozone levels remain a concern in our region. Over the last decade, ozone concentrations have not decreased as significantly as other pollutants. The Enumclaw Mud Mountain monitor has the highest regional ozone concentrations. EPA is expected to propose a more protective health-based standard in 2014.

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-43 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______Air toxics were present in our air at levels that posed adverse health effects. These health effects include, but are not limited to, increased cancer risk and respiratory effects.

2. Air Quality Index in Snohomish County PSCAA uses the national Air Quality Index (AQI) to report daily air quality conditions. The index is based on calculations for five major air pollutants: ground level ozone, particulate matter, carbon monoxide, sulfur dioxide and nitrogen dioxide. A descriptive term is used for the index value. Any pollutant measurement exceeding the short-term national primary standard causes the index value to be in the Unhealthy for Sensitive Groups or Unhealthy Category. A Moderate value is acceptable; however, for some pollutants there may be a moderate health concern for a very small number of people.

Air quality monitoring stations in Snohomish County are located in Marysville, Lynnwood and Darrington. In 2013 in Snohomish County 74% of the year rated Good in the AQI, 25% of the year rated Moderate, and 1% of the year rated Unhealthful for Sensitive Groups. Figure 3.7.19 shows Air Quality Index results for Snohomish County from 2000 to 2013.6

Figure 3.7.19: Air Quality Index for Snohomish County 2000-2013

Air Quality Index for Snohomish County 350 324 321 301 294 304 290 288 282 290 288 288 300 269 271 253

250

200

150 92 Days Days ofthe Year 100 79 84 73 69 80 74 72 57 70 72 41 53 43 50 12 5 2 8 3 2 5 7 6 0 0 8 1 2 0 1 1 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 Year

Good Moderate Unhealthy for Sensitive Groups Unhealthy

3. Existing Conditions: Odors Nuisance odors may result from residential activities, such as cooking, fireplaces, composting; business and commercial uses, for example, gas stations, dry cleaners and restaurants; and industrial and manufacturing uses, including coffee roasters, large scale composting, food smoking, factories; and other land uses such as sewage treatment plants. Odors may or may not

6 Puget Sound Clean Air Agency. 2013 Air Quality Data Summary. August 2014

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-44 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______indicate the presence of hazardous substances, and may be objectionable to some people and not others. Odors may occur even when industries use the best available control technology (BACT).

4. Greenhouse Gas Emissions and Climate Change Climate change refers to the alteration of the global atmosphere attributed to human activity compared to natural climate variability. Climate change effects are not limited to global warming (increases in surface temperatures), but also include sea-level rise, ocean and ice sheet dynamics, ocean acidification, changes in precipitation and runoff patterns, and extreme weather events. Climate change results from the increase in greenhouse gas emissions. These gases absorb heat emitted from the earth’s surface, and increases in the atmospheric concentration of these gases causes Earth to warm by trapping more of this heat. These gases include hydrofluorocarbons, CO2, methane, nitrous oxide and ozone.  The major sources of carbon dioxide are from burning fossil fuels (coal, natural gas, and oil), solid waste, trees and wood products, and as a result of certain chemical reactions (e.g., manufacture of cement).  Methane is emitted during the production and transport of coal, natural gas, and oil. Methane emissions also result from livestock and other agricultural practices and by the decay of organic waste in landfills.  Nitrous oxide is emitted during agricultural and industrial activities, as well as during combustion of fossil fuels and solid waste.  Hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride are synthetic, powerful greenhouse gases that are emitted from a variety of industrial processes. Fluorinated gases are sometimes used as substitutes for stratospheric ozone-depleting substances. These gases are typically emitted in smaller quantities, but because they are potent, their release into the air is also important.

In our region, nearly 50% of our greenhouse gas pollution comes from transportation – cars, trucks, trains, ships, etc.

Everett has completed two inventories of greenhouse gases for municipal operations7, but not a community-wide inventory.

In 2008 Snohomish County completed an assessment of emissions for the year 2000, included an emissions calculation for an interim year (2005) to identify recent trends in the county’s emissions, and forecasted emissions for the year 2020 under a “business as usual” approach.8 Key findings of the assessment were:  Inventory: In 2000, Snohomish County emitted approximately 5.5 million metric tons of greenhouse gases.  2005 Status: Countywide emissions are dropping, largely due to cleaner electricity fuel sources from the Snohomish County Public Utility District. Snohomish County emitted approximately 4.8 million metric tons of greenhouse gases in 2005.

7 See the City of Everett Comprehensive Plan Climate Change & Sustainability Element Background Report, January 2015 for more information. 8 Snohomish County Sustainable Climate & Energy Initiative. Greenhouse Gas Emissions Inventory and Forecast. April 28, 2008

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-45 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______ Forecast: Applying project growth rates in population, employment, and number of households to 2005 emissions provides a forecasted “business as usual: growth scenario showing 2020 countywide emissions at 6.4 million metric tons.

5. Indoor Air Quality

Indoor air quality (IAQ) refers to the quality of the air in a home, school, office, or other building environment. The quality of indoor air is important not only for peoples' comfort but also for their health. Immediate health effects that have been associated poor IAQ has been tied to symptoms like headaches, dizziness, fatigue, trouble concentrating, and irritation of the eyes, nose, throat and lungs. Such immediate effects are usually short-term and treatable. Symptoms of some diseases, including asthma, hypersensitivity pneumonitis, and humidifier fever may also show up soon after exposure to some indoor air pollutants. Some specific diseases have been linked to specific air contaminants or indoor environments, like asthma with damp indoor environments. In addition, some exposures, such as asbestos and radon, do not cause immediate symptoms but can create long term health effects and lead to respiratory diseases, heart disease and cancer after many years.

Most pollutants affecting indoor air quality come from sources inside buildings, although some originate outdoors. Typical pollutants of concern include combustion products such as carbon monoxide, particulate matter, and environmental tobacco smoke; substances of natural origin such as radon; biological agents such as molds; pesticides; lead; asbestos; ozone (from some air cleaners); and various volatile organic compounds from a variety of products and materials. Indoor concentrations of some pollutants have increased in recent decades due to such factors as energy-efficient building construction and increased use of synthetic building materials, furnishings, personal care products, pesticides, and household cleaners.

The potential impact of indoor air quality on human health nationally is considerable, for several reasons. Americans, on average, spend approximately 90 percent of their time indoors9 where the concentrations of some pollutants are often 2 to 5 times higher than typical outdoor concentrations.10 Moreover, people who are often most susceptible to the adverse effects of pollution (e.g., the very young, older adults, people with cardiovascular or respiratory disease) tend to spend even more time indoors.11

Indoor air pollutants originate from many sources. These sources can be classified into two general categories:

 Indoor sources (sources within buildings themselves). Combustion sources in indoor settings, including tobacco, heating and cooking appliances, and fireplaces, can release harmful combustion byproducts such as carbon monoxide and particulate matter directly into the indoor environment. Cleaning supplies, paints, insecticides, and other commonly used products introduce many different chemicals, including volatile organic compounds,

9 U.S. Environmental Protection Agency. 1989. Report to Congress on indoor air quality: Volume 2. EPA/400/1-89/001C. Washington, DC. 10 U.S. Environmental Protection Agency. 1987. The total exposure assessment methodology (TEAM) study: summary and analysis. EPA/600/6-87/002a. Washington, DC. 11 U.S. Environmental Protection Agency. 1997. Exposure factors handbook: volume 3—activity factors. EPA/600/P-95/002Fa. Washington, DC.

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-46 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______directly into the indoor air. Building materials are also potential sources, whether through degrading materials (e.g., asbestos fibers released from building insulation) or from new materials (e.g., chemical off-gassing from pressed wood products). Some materials such as carpeting will act like a sponge to newly introduced volatile organic compounds and other chemical gasses, and then slowly release low levels over many years. Other substances in indoor air are of natural origin, such as mold and pet dander.

 Outdoor sources. Outdoor air pollutants can enter buildings through open doors, open windows, ventilation systems, and cracks in structures. Some pollutants come indoors through building foundations. For instance, radon forms in the ground as naturally occurring uranium in rocks and soils decays. The radon can then enter buildings through cracks or gaps in structures. In areas with contaminated ground water or soils, volatile chemicals can enter buildings through this same process. Volatile chemicals in water supplies can also enter indoor air when building occupants use the water (e.g., during showering, cooking). Finally, when people enter buildings, they can inadvertently bring in soils and dusts on their shoes and clothing from the outdoors, along with pollutants that adhere to those particles.

Many factors affect IAQ. These factors include poor ventilation, lack of fresh outdoor air or contaminated air being brought into the building, poor maintenance of ventilation, heating and cooling systems, problems controlling temperature, high or low humidity, recent remodeling, and other activities in or near a building that can affect the fresh air coming into the building. The air exchange rate with the outdoors is an important factor in determining indoor air pollutant concentrations. The air exchange rate is affected by the design, construction, and operating parameters of buildings and is ultimately a function of infiltration (air that flows into structures through openings, joints, and cracks in walls, floors, and ceilings and around windows and doors), natural ventilation (air that flows through opened windows and doors), and mechanical ventilation (air that is forced indoors or vented outdoors by ventilation devices, such as fans or air handling systems). Outdoor climate and weather conditions combined with occupant behavior can also affect indoor air quality. Weather conditions influence whether building occupants keep windows open or closed and whether they operate air conditioners, humidifiers, or heaters, all of which can impact indoor air quality. Weather also has a large effect on infiltration. Certain climatic conditions can increase the potential for indoor moisture and mold growth if not controlled by adequate ventilation or air conditioning.

The link between some common indoor air pollutants and health effects is very well established. Radon is a known human carcinogen and is the second leading cause of lung cancer.12,13 Carbon monoxide is toxic, and short-term exposure to elevated carbon monoxide levels in indoor settings can be lethal.14 Episodes of Legionnaires’ disease, a form of pneumonia caused by exposure to the Legionella bacterium, have been associated with buildings with poorly

12 U.S. Environmental Protection Agency. 2003. EPA assessment of risks from radon in homes. EPA/402/R-03/003. Washington, DC. 13 National Research Council. 1999. Health effects of exposure to indoor radon: biological effects of ionizing radiation (BEIR), report VI. Washington, DC: National Academy Press. http://www.epa.gov/iaq/radon/beirvi.html 14 Raub, J.A., M. Mathieu-Nolf, N.B. Hampson, S.R. Thom. 2000. Carbon monoxide poisoning—a public health perspective. Toxicology 145:1-14.

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-47 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______maintained air conditioning or heating systems.15,16 In addition, numerous indoor air pollutants—dust mites, mold, pet dander, environmental tobacco smoke, cockroach allergens, and others can cause some asthmatics to experience asthma attacks following exposure.17

While these and other adverse health effects have been attributed to specific pollutants, the scientific understanding of some indoor air quality issues continues to evolve. One example is “sick building syndrome,” which occurs when building occupants experience similar symptoms after entering a particular building, with symptoms diminishing or disappearing after they leave the building; these symptoms are increasingly being attributed to a variety of building indoor air attributes.

Researchers also have been investigating the relationship between indoor air quality and important issues not necessarily related to health, such as student performance in the classroom and productivity in occupational settings.18 Another evolving area is research in “green building” design, construction, operation, and maintenance that achieves energy efficiency and enhances indoor air quality.

Many of the regulations affecting IAQ are incomplete, fragmented, and overlapping, but the federal government and states are working on new draft regulations. No single U.S. federal agency has authority over IAQ in nonindustrial buildings, however. There are five major groups that address the IAQ issue and their standards and guidelines. They are: OSHA (the Occupational Safety and Health Administration), the EPA (Environmental Protection Agency), ASHRAE (the American Society of Heating, Refrigerating, and Air-Conditioning Engineers, Inc.), the ACGIH (American Conference of Governmental Industrial Hygienists), and individual states.

OSHA will investigate building IAQ complaints from workers and has established guidelines for IAQ investigations. While OSHA does not explicitly regulate IAQ, it does influence IAQ through other existing standards. These include standards about: asbestos, hazard communication, record keeping, emergency response, respiratory protection, fire prevention, various chemicals that affect IAQ and IAQ management programs.

The EPA and its Office of Air and Radiation, Office of Atmospheric Programs, and Indoor Air Quality Division have no regulatory authority over IAQ or environmental tobacco smoke. The EPA provides policy, recommendations, guidelines, and coordination on the issue, however. The EPA's strategy is to minimize reasonable exposure to all IAQ contaminants.

The EPA's actions on air pollution (the CAA [Clean Air Act of 1990] and Amendments) outline ambient air quality standards called the NAAQS (National Ambient Air Quality Standards). These standards address a limited number of contaminants that can affect IAQ. HVAC design professionals use these standards to categorize outdoor air quality in local regions.

15 Allan, T., et al. 2001. Outbreak of Legionnaires’ disease among automotive plant workers—Ohio, 2001. MMWR 50(18):357- 359. 16 Fields, B.S., R.F. Benson, and R.E. Besser. 2002. Legionella and Legionnaires’ disease: 25 years of investigation. Clin. Microbiol. Rev. 15(3):506-526. 17 Institute of Medicine. 2000. Clearing the air: Asthma and indoor air exposures. Washington, DC: National Academy Press. 18 U.S. Environmental Protection Agency. 2003. Indoor air quality and student performance. EPA/402/K-03/006. Washington, DC.

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-48 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______ASHRAE provides non-mandatory standards and guidelines to help professionals design ventilation systems properly for buildings.

The ACGIH deals with the administrative and technical aspects of occupational and environmental health and has contributed substantially to developing and improving worker health protection. The ACGIH publishes several books and pamphlets that explain the threshold limit values for inhalation exposure and biological exposure indices, reference values derived from measurements of biological exposure when a worker is exposed.

Most states have regulations governing environmental tobacco smoke in the public sector, and many states are currently drafting legislation to address broader IAQ issues. In Washington, state law requires the Department of Labor and Industries to develop policies for evaluating IAQ in state owned/leased buildings, for strengthening IAQ regulations in the workplace, improving IAQ in public buildings, and to recommend to the legislature measures for improving IAQ in public buildings. They also require the Department to review IAQ programs in public schools, provide state agencies with educational and informational pamphlets on IAQ standards, and authorize the Superintendent of Public Instruction to implement a model IAQ program.

State Building Code Council is directed to bring ventilation and filtration standards into conformity with industry standards, and state agencies are encouraged to maintain and operate mechanical ventilation and filtration systems in a manner consistent with ASHRAE standards.

The state Board of Health was required to adopt rules controlling public health related to environmental conditions in public facilities, including schools. In August 2009 the Board of Health adopted a revised rule that requires annual inspections by local health boards, and established a more detailed set of facility standards to include addressing numerous IAQ issues such as moisture, ventilation, and others. The state, however, enacted budget legislation in 2009 that prohibited implementation of the revised rule until the legislature appropriates funding for implementation, and the Board delayed the effective date of the revised rules until July 2015.

A low-income weatherization program was established by state law, and defined weatherization services to include indoor air quality improvements and other health and safety improvements. One purpose of the program specifically established the identification and correction, to the extent practical, of health and safety problems for residents of low-income households, including asbestos, lead, and mold hazards.

State law also requires landlords to provide tenants with written or posted information approved by the Department of Health about the health hazards of indoor mold and how to control mold growth to minimize health risks, and requires sellers of improved and unimproved residential real property, as well as commercial real estate, to provide buyers with a disclosure statement providing information about carbon monoxide alarms and indicating knowledge of substances of environmental concern on the property, including radon gas, formaldehyde, asbestos, and lead- based paint.

C. Impacts:

The impacts to air quality generated within the Everett Planning Area will affect an area larger that the land area for which Everett is planning, and growth outside of the Everett Planning Area

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-49 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______will impact air quality in Everett. Alternatives with lower densities and less economic growth will allow for greater dispersion of air pollution throughout the county but will also likely result in greater emissions overall. For example, residents in lower density areas are more likely to use wood as a primary or major source of heat, and will also likely drive greater distances to work, also increasing emissions. Impacts to air quality are not expected to be significantly different between the three alternatives.

1. Vehicular Emissions. Increased population and employment growth will generate vehicle emissions, which under all alternatives will continue to be the single largest air pollutant source in the Everett Planning Area. (See the Transportation Section of this DEIS for an analysis of the impacts that result from Everett’s proposed transportation system.) In 2014, the Puget Sound Regional Council updated their Regional Air Quality Conformity Analysis for Transportation 204019. The conformity analysis must show that the total regional emissions produced by projects in Transportation 2040, plus activity on the existing travel network, do not exceed the motor vehicle emissions budget identified in the maintenance plan for each criteria pollutant. The emissions budget is a ceiling of total emissions that cannot be exceeded. Modeling included emissions of CO, PM 2.5, and nitrogen oxide. The analysis showed that emissions for the three criteria pollutants are below the emissions budgets through 2040. A large decrease in emissions from motor vehicles is expected between current conditions and 2030, due to new regulations and technologies taking effect, as well as the gradual replacement of older, more polluting vehicles. After 2030, emissions from motor vehicles will continue to decrease but at a less dramatic rate; coupled with the growth in vehicle miles traveled during this time period, overall emissions may gradually increase, as demonstrated by the slight increase in CO emissions between 2030 and 2040.

Table 3.7.2: PSRC Modeled Criteria Pollutants Through 2040

Under any of the alternatives localized impacts could occur at major intersections that experience greater traffic congestion. New roadway projects will be required to conduct computer modeling of future CO emissions to ensure they will not result in exceedances to air quality standards.

2. Commercial and Industrial Impacts PSCAA’s 2014-2020 Strategic Plan states that industrial and business activities produce a declining, but still significant, amount of air pollution in our region each year. The region has had success reducing commercial air toxics pollution. An example is dry cleaners: they’ve replaced old-technology machines with new equipment that emit almost no air toxics.

19 Puget Sound Regional Council. Transportation 2040 Update. Appendix E: Regional Air Quality Conformity Analysis. May 29, 2014.

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-50 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______

It is possible that air quality will be adversely impacted under all alternatives since commercial, manufacturing and industrial businesses are expected to increase under all alternatives, and many of these businesses will generate air pollutant emissions. All of the alternatives have similar levels of employment (140,000 to 145,000 in 2035). We cannot predict the types and amounts of pollutants that will be generated since we do not know the types of industries that will locate here. We expect that future advances in technology and modifications to industrial processes to control some pollutants will occur. These changes may reduce the level of air pollution emissions from commercial and industrial-related sources.

Because PSCAA and DOE require all new stationary sources to use best available control technology (BACT) and demonstrate that their emissions will not cause ambient concentrations near the source to exceed the allowable NAAQS limits, we anticipate that under all alternatives, permitted emission levels will not result in additional non-compliance with any air quality standards.

Future residential development in Everett will be primarily multiple family and located in commercial and business mixed-use areas. Mixed-use developments have the potential to result in more complaints regarding odors since more residents are exposed to odors from restaurants and other commercial uses.

3. Residential Impacts All three alternatives will result in population growth, new residential development and adverse impacts on air quality. Alternatives 1 and 2, which have more dense population growth in Everett will likely result in the installation of fewer fireplaces and wood stoves and therefore less emissions. New multiple family developments in urban areas are far less likely to include wood burning fireplaces than single family developments in more rural areas. Everett’s building official stated that he could not remember the last time someone proposed a masonry wood burning fire place in Everett, and that when fireplaces are proposed they are gas. Space heating with natural gas also generates air pollution, but emissions are much lower than wood.

4. Construction Impacts During construction, fugitive dust from excavation, grading or demolition and construction activities will contribute to temporary increases in ambient concentrations of particulate matter. Construction will require the use of heavy construction equipment, large diesel-powered trucks, and smaller equipment such as portable electrical generators. Tailpipe emissions from these engines will temporarily degrade air quality near the construction sites, but their regional impacts will typically be far outweighed by emissions from cars and trucks in the neighborhoods surrounding the construction site.

PSCAA regulations require construction contractors to take all reasonable steps to minimize fugitive dust emissions during construction. These required mitigation measures are designed to reduce localized impacts affecting homes and businesses adjacent to construction sites.

Some phases of construction, for example painting, paving, or roofing, will cause temporary odors detectible to some people close to a construction site.

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-51 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______5. Odor Increases in population and employment growth will create the potential for additional odors under all of the alternatives. Alternatives 1 and 2, which include the most mixed-use developments, will likely increase the potential for nuisance odor complaints. For example, restaurants or other businesses on ground floors of mixed-use buildings will expose the residents above to more odors, which some people may find objectionable.

Alternative 3 has the most dispersed work and residential populations and will therefore result in more dispersion of odors with less people exposed to any specific odor.

6. Greenhouse Gases and Climate Change Continued emissions of greenhouse gases by human activity will cause further warming and changes of the climate system, and most aspects of climate change will persist for many centuries even if emissions of carbon dioxide are stopped20. These emissions will result in an increase in average annual temperature of 3.3oF to 9.7oF projected by 2070 to 2099 (compared to the period 1970 to 1999). This will have a variety of impacts, such as  changing ecological conditions may alter the ranges, types and abundances of marine and terrestrial plants and animals  warmer summers and related heat stress, including increasing demand for energy usage for cooling in summer months, further increasing emissions  warmer summers increasing ozone pollution and exacerbating lung and heart disease  changes in precipitation patterns and timing of stream flows, resulting in more severe storm events, smaller snow pack, earlier snowmelt, less water for irrigation and domestic use, heightened drought and wildfire danger. Additional impacts include sea level rise and ocean acidification.

See the City of Everett Comprehensive Plan Climate Change and Sustainability Element Background Report for more detail on impacts of GHG emissions, and some of the strategies being taken locally, regionally and at the state and federal levels to address emissions of GHGs and climate change. The impacts of climate change will be less the more aggressively the public and all levels of government implement actions to reduce emissions.

Transportation 2040 states that a compact development pattern is a foundation of the region’s greenhouse gas reduction strategy; and that the increased shift to a more compact and concentrated growth pattern, and a better jobs/housing balance within the region’s four counties will reduce GHG emissions by about 6 percent from the trend.

Transportation 2040 also makes assumptions about the market penetration of alternative fuel vehicles, less carbon-intensive fuels, and improved fuel efficiency in vehicle fleets. A likely scenario resulted in an additional 25% reduction in GHG emissions, and the aggressive scenario resulted in an additional 43 percent reduction in emissions.

20 IPCC, 2013. Summary for Policy Makers. IPCC, 2013: Summary for Policymakers. In: Climate Change 2013: The Physical Science Basis. Contribution of Working Group I to the Fifth IPCC, 2013: Summary for Policymakers. In: Climate Change 2013: The Physical Science Basis. Contribution of Working Group I to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change [Stocker, T.F., D. Quin, G.K. Plattner, M. Tignor, S.S. Allen, J. Boschung, A Nauels, Y Xia, V. Bex and P.M. Midgley (eds.)]. Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA. http://www.climatechange2013.org/images/report/WG1AR5_SPM_FINAL.pdf

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-52 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______

Transportation 2040 pricing strategies that result in reduced vehicle miles traveled, supported by the plan’s increase in local transit service, the extension of regional light rail, and investments in walking and biking facilities result in a 9% reduction in GHG emissions from the trend.

D. Mitigation Measures Incorporated into the Proposal

Everett’s strategies to direct growth to centers and encourage higher density mixed-use pedestrian- and transit-oriented developments, along with the multi-modal focus of the Transportation Element will result in reduced vehicular trips and resultant air emissions over that which would otherwise occur.

The update includes a number of goals, objectives, policies and potential implementation measures specifically directed at reducing emissions to the air:  Land Use Element – New Air Quality goal, and policies (Goal 2.16.1, and Policies 2.16.1 through 2.16.9).  A new Climate Change and Sustainability Element that includes goals and policies for reducing GHG emissions, including adopting GHG emission reduction goals for both municipal and community-wide emissions.  Capital Facilities and Utilities Element o New goals, objectives, policies and implementation measures (starting with goal 6.5). o Includes description of some of the actions the City is taking to reduce GHG emissions. o Policies that encourage conservation of resources.  Housing Element – Residential Energy Efficiency Objective and Policies (Objective 4.11 and Policies 4.11.1 and 4.11.2)

E. Mitigation Actions Taken by Others

EPA, Ecology, and PSCAA regulate allowable ambient air quality and emissions to the air from stationary sources. They each have a variety of programs to prevent or reduce emissions and improve or maintain air quality.

The PSCAA’s 2014-2020 Strategic Plan includes a number of strategies to reduce future air emissions. Examples of their past / ongoing work to reduce air toxics emissions that also reduce criteria air pollutant emissions (most notably fine particulate and ozone precursors) include:  Diesel Solutions®. Since 2000, the Agency has worked with public and private partners to reduce diesel emissions with new technologies, use cleaner fuels, and promote reduced idling.  Northwest Ports Clean Air Strategy. In 2007, the Agency combined with other local officials and the Ports of Tacoma, Seattle, and Vancouver to set targets to reduce diesel emissions in the future.  Less wood smoke. The Agency reduces pollution from wood burning through education, wood stove replacement programs, burn bans, and enforcement.  Cleaner cars. The Agency and partners encouraged adoption of the stricter Washington vehicle standards that will reduce mobile source air toxics emissions.

CHAPTER 3.7: NATURAL ENVIRONMENTAL 3.7-53 EVERETT COMPREHENSIVE PLAN 10-YEAR UPDATE DEIS ______ Cleaner fuels. The Agency works with local fuel suppliers to provide gasoline that releases fewer toxics into the air. The Agency also adopted new gas station rules to reduce gas station emissions. The Agency encourages the use of biofuels that also emit fewer air toxics.  Cleaner Business and Industry. The region has had success reducing commercial air toxics pollution. An example is dry cleaners: they’ve replaced old-technology machines with new equipment that emit almost no air toxics.

I. Unavoidable Impacts

Local levels of suspended particulates (dust) will increase during demolition, grading and excavation.

Exposure to odors, which some people will consider nuisance odors, will increase as population and employment becomes denser in mixed-use areas.

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