Chapter 5 Comments and Responses

5.1 Introduction This Chapter presents the letters of comment and public hearing testimony received during the 45-day comment period for the 10-Year Update Draft Environmental Impact Statement (EIS). The period to provide written comments extended from May 5 to 5:00 p.m. June 18, 2004. Three public hearings were held on June 1, 3, and 8, 2004. Comment letters and testimony were received from State, Regional, and Special District Agencies, as well as interest groups and local citizens. Responses in each subsection (e.g. 5.2 et seq.) precede the public comments that are associated with that subsection. The comment letters are divided by the following categories: • 5.2 Government Agencies • 5.3 Interest Groups • 5.4 Citizen Comments – Alternatives and Land Use Designations • 5.5 Citizen Comments – SEPA and Environmental Issues • 5.6 Public Hearing Comments Distinct comments are numbered in the margins with responses corresponding to the numbered comment. Comments that state an opinion or preference are acknowledged with a response that indicates the comment is noted and forwarded to the appropriate decision makers. Comments that ask questions, request clarifications or corrections, or are related to the DEIS analysis are provided a response which explains the EIS approach, or offers corrections, or provides other appropriate replies. Letters received after 5:00 p.m. June 18, 2004 are not included in the FEIS responses to comments. These letters were reviewed for any potential DEIS corrections. A list of late letters is provided in Appendix II-A of this FEIS.

Snohomish County Comprehensive Plan 5-1 December 13, 2005 10-Year Update FEIS

Snohomish County Comments and Responses

5.2 Government Agencies This section of Chapter 5 responds to comments made by State, Regional, Tribal, and Local Agency Governments regarding the DEIS.

5.2.1 State, Regional, Tribal Table 5.1-1 lists State, Regional, and Tribal Agencies that prepared comments addressing the DEIS. The agency letters appear following the responses to comments.

Table 5.1-1 State, Regional, and Tribal Agencies with Comments FEIS# Log # Commenter Date 1 111 Department of Community Trade and Economic Development (Dave 6/17/04 Andersen, AICP) 2 162 Department of Fish and Wildlife (Daniel E. Penttila) 6/17/04 3 112 Puget Sound Regional Council (Norman A. Abbott, AICP) 6/18/04 4 30 The Tulalip Tribes (Stanley G. Jones & Stokes Sr.) 5/7/04

5.2.1.1 FEIS Letter 1: Department of Community, Trade and Economic Development

Response to Comment 1: Deliberative and Comprehensive Review of Potential UGA Expansion Your comments are noted and forwarded to the appropriate decision makers. Please note that the County developed criteria to evaluate each potential Urban Growth Area (UGA) expansion and infill proposal as described in FEIS Chapter 2.

Response to Comment 2: Location and Sequencing of UGA Expansions Your comments are noted and forwarded to the appropriate decision makers. The Planning Commission Recommended Plan (“Recommended Plan”) focuses primarily on infill of UGAs at 6.6 square miles, and less upon expansion at 4.3 square miles. The County Council FEIS Map List (“Council Map List”) proposes 6.7 square miles of infill and 7.7 square miles of UGA expansion. The UGA expansion areas tend to be proposed in Rural/Urban Transition Areas (RUTAs). An analysis of the ability to provide infrastructure and services was part of the evaluation described in Response to Comment 1. Please also see FEIS Chapter 2.

Response to Comment 3: UGA Expansions into Resource Lands and Critical Areas DEIS section 3.1 Natural Environment addressed a range of critical area topics and included mitigation measures some of which advised limiting UGA boundaries to avoid high value critical areas such as Little Bear Creek basin, various floodplain, and geologic hazard areas. Similarly

Snohomish County Comprehensive Plan 5-3 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

DEIS Section 3.2.2 Relationship to Plans and Policies addressed issues related to natural resource land conversions. Please note that the County developed criteria to evaluate each potential Urban Growth Area (UGA) expansion and infill proposal as described in FEIS Chapter 2, including effect upon critical areas and natural resource lands. A table showing how the Recommended Plan and Council Map List incorporate DEIS mitigation measures, regarding avoidance of environmentally sensitive areas in UGA expansion areas, is provided in FEIS Chapter 2, Table 2.3-3. On the whole, the Recommended Plan and Council Map List have a lower growth level and UGA expansion level, and their effects upon critical areas would be less than Alternative 3, although there are individual locations that have greater or lesser impacts. The effects of the Recommended Plan and Council Map List on designated resource lands is found in the Land Use and Relationship to Plans and Policies sections of the FEIS. Both the Recommended Plan and Council Map List would reduce potential impacts to resource lands in comparison to DEIS Alternative 3. Alternative 3 proposed over 30 acres of reclassification of Riverway Commercial Farmland along the Arlington UGA near the Stillaguamish River. The Council Map List would convert about 11 acres, less than Alternative 3 and greater than the Recommended Plan (approx. 5 acres). The Recommended Plan would actually increase Riverway Commercial Farmland south of Snohomish and result in a net gain for this category. Both increase Urban Horticulture within the Arlington UGA, although this is not a resource land of long-term commercial significance. Based on mineral lands mapping available in 2003, the DEIS projected that Alternatives 2 and 3 could intrude, to differing degrees, into mapped mineral lands (bedrock and sand and gravel) near the Southwest, Sultan, and Stanwood UGAs. As of the 2003 timeline, the mineral lands mapping excluded cities, National Forests, Tribal Trust lands, lands in the 100-year flood plain, shorelines, Chinook/bull trout corridors, UGA boundaries, parks and trails, and agricultural lands. Between 2003 and April 2005, additional criteria for mapping included the elimination of (1) any land where rural residential densities are greater than 0.15 dwellings per acre (average 6.67 acre lots), and (2) the removal of all land with an R-5 zoning or land use designation, except where a landowner has specifically requested inclusion and the property otherwise meets all designation criteria. As a result, a new proposed Mineral Lands Resources Overlay map has been developed as part of the Recommended Plan. With the proposed overlay map, neither the Recommended Plan nor the Council Map List UGA boundaries extend into the proposed Mineral Lands Resources Overlay. This is also true for the DEIS Alternatives. The net result is that none of the studied alternatives would intrude into the proposed Mineral Lands Resources Overlay. None of the studied alternatives intrudes into designated forestlands.

Response to Comment 4: Use of Fiscal and Environmental Costs Please note that the County developed criteria to evaluate each potential Urban Growth Area (UGA) expansion and infill proposal as described in FEIS Chapter 2 including effect upon critical and natural resource lands and capital costs.

Snohomish County Comprehensive Plan 5-4 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 5: Infill and Intensification of Existing Urban Areas In general, a greater focus on infill would lead to more concentration of population and employment in current urban areas, less land consumption, and ability to more efficiently provide public services and capital facilities. Approaches that promote further growth inside current UGAs would take advantage of existing infrastructure, and reduce the need for additional roadways to serve areas within expanded UGAs. A greater focus on UGA expansion would tend to allow for greater land consumption, conversion of rural lands, and greater need to expand public services and capital facilities. The various approaches tested different levels of population growth and UGA infill and expansion levels. Forecast populations are within the range of State Office of Financial Management (OFM) forecasts. Opportunities for infill and intensification were studied in more detail in developing the Recommended Plan and Council Map List, which mix and match several concepts of the DEIS Alternatives. Under the Recommended Plan, total Urban Growth Area expansion (4.3 square miles) would be intermediate to expansions proposed under Alternatives 2 (2.4 square miles) and 3 (11.5 square miles). Under the Council Map List, total Urban Growth Area expansion (7.7 square miles) would be intermediate to expansions proposed under Alternatives 2 and 3, but closer to Alternative 3, and greater than under the Recommended Plan. Infill for both the Recommended Plan (6.6 square miles) and Council Map List (6.7 square miles) would be similar to but slightly greater than the Alternative 3 infill proposal (6 square miles). Infill is proposed principally in the Southwest UGA under Alternatives 2, 3, the Recommended Plan and the Council Map List, with some infill included in other selected UGAs (e.g. Stanwood, Marysville, etc.).

Response to Comment 6: Transportation and Capital Facilities Impacts As noted in your comment and the DEIS, all three alternatives in the DEIS have substantial projected revenue shortfalls with respect to transportation-facility needs. One of the challenges in developing a recommended plan is balancing projected revenues with the significant costs of accommodating projected population and employment growth, including the provision of adequate transportation facilities, while still maintaining desired level-of-service standards. The Recommended Plan includes recommended measures to balance revenues, costs, and land use, and have been considered by the County Council in its deliberations. Please see FEIS Chapters 2 and 3.

Response to Comment 7: Land Use Impacts on State Transportation Facilities GMA only requires an evaluation of the impacts on the State system. The DEIS estimated impacts to WSDOT facilities, for example in Tables 3.2-23 and 3.2-27. The transportation improvements, which the State anticipates completing within the planning period, have been included unless noted otherwise. Also note that the County made available more detailed analysis in the Technical Memorandum 3-18: Major Highway and Arterial Projects for Snohomish County at the time the DEIS was issued, and may be obtained from the Public Works Department.

Snohomish County Comprehensive Plan 5-5 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

In the FEIS, the County has evaluated the impacts, and to the extent practicable, the costs, to the state highway system and the arterial system in affected cities from the land-use assumptions for the Recommended Plan and Council Map List. See Chapter 3 of this FEIS.

Response to Comment 8: UGA Expansion Road Costs Please see Response to Comment 5 regarding the extent to which the FEIS alternatives focus on infill, greater than prior alternatives. This greater focus on infill, and less UGA expansion than Alternative 3, combined with likely State improvements and local costs and revenues have produced plans for less new arterial road miles. Please note that the County developed criteria to evaluate each potential Urban Growth Area (UGA) expansion and infill proposal as described in FEIS Chapter 2, including capital costs.

Response to Comment 9: Transportation Facility Policy Options Comment noted. Shifting financial resources from other transportation capital programs and maintenance and operations to fund capacity improvements could adversely impact the County’s ability to preserve the existing transportation system. Likewise, reallocating real estate excise taxes to road improvements could negatively affect those County programs that have historically used this revenue source. DEIS Table 3.2-32, Transportation Policy Mitigation Options, is intended to illustrate a full-range of policy options for decision makers to consider when balancing land use, level of service, and transportation finance under a selected alternative rather than recommend a particular course of action. The Recommended Plan includes recommended measures to balance revenues, costs, and land use, and have been considered by the County Council in its deliberations. Please see FEIS Chapters 2 and 3.

Response to Comment 10: Real Estate Excise Tax Reallocation See Response to Comment 9.

Response to Comment 11: Infill May Have Less Impact on Transportation Facilities Comment noted. Both Alternatives 2 and 3 identify opportunities for infill and intensification, including urban center development, within existing UGAs. Opportunities for infill and intensification were studied in more detail in developing the Recommended Plan and Council Map List. Please see Response to Comment 5 as well as FEIS Chapter 2.

Response to Comment 12: Impacts on Natural Features and the Environment The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 13: Surface Water Impacts Land use designations, with the exception of a downzone near Lund’s Gulch (Alternative 3 Recommended Plan, and Council Map List), and an Urban Industrial to ULDR change near Woodway in the Recommended Plan, and Council Map List would not change along the Snohomish County marine coastline as a result of any of the alternatives. However, there are buildable lands along the shoreline as shown in DEIS Sections 3.1.1 and 3.1.5, Surface Water

Snohomish County Comprehensive Plan 5-6 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses and Fisheries respectively. Therefore, in Chapter 4 of this FEIS, text describing nearshore and estuarine habitat impacts are added.

Response to Comment 14: Consistency with WRIA 7 and 8 Planning Recommendations See Response to Comment 3.

Response to Comment 15: Alternative 2 and WRIA 8, Little Bear Creek Subbasin Based on environmental, infrastructure, and other factors as described in FEIS Chapter 2, the Little Bear Creek basin is not shown for large UGA expansions in the Recommended Plan, and for lesser UGA expansions in the Council Map List than Alternative 3.

Response to Comment 16: Alternative 3 WRIA 7 Basin Sections of the DEIS mitigation measures address implementation of the WRIA plans to reduce impacts, such as Section 3.1.5 Fisheries. To recognize this is of high importance for wetlands, a mitigation measure addressing WRIA actions to minimize wetland impacts are added to the mitigation measures for DEIS Section 3.1.6. Please refer to Chapter 4 of this FEIS.

Response to Comment 17: Alternative 3 and WRIA 8, Little Bear Creek Subbasin See Response to Comment 15 above.

Response to Comment 18: Cottage Lake Subbasin The comments are noted and forwarded to the appropriate decision makers. The DEIS lists the implementation of WRIA plans under potential mitigation measures in several Natural Environment Sections (DEIS 3.1). The proposed UGA expansions in the Cottage Lake Subbasin (mapped as Bear Creek basin on County maps) total roughly 76 acres under the Recommended Plan and Council Map List. The lands appear to consist largely of rural residential, pasture, or cleared properties and are not forested in character. The EIS provides a qualitative area-wide analysis, supported by some selected quantitative information. The County did not conduct detailed hydrologic analysis to quantify the potential hydrologic changes that would occur due to these proposed UGA expansions for the DEIS. In general though, since the runoff from these proposed UGA expansion areas would pass through several existing lakes before reaching Cottage Lake Creek, it is not expected that the expansions would cause significant hydrologic changes in this creek.

Response to Comment 19: PSAT Environmental Recommendations Please see Response to Comment 3.The mitigation measures listed in the DEIS related to water quality and quantity, impervious surfaces, monitoring, and vegetation retention are carried forward in the FEIS to apply to the Recommended Plan and Council Map List. Regarding the recommendation to add low impact development to the list of potential mitigation measures, this was already included in the potential mitigation list on page 1-16 of the DEIS, which will be carried forward in the FEIS. Likewise, a potential mitigation measure related to adequate

Snohomish County Comprehensive Plan 5-7 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses setbacks from streams and rivers was already included in the DEIS in section 3.1.5 and will be carried forward in the FEIS. See FEIS Chapters 1 and 3.

Response to Comment 20: Appreciation for Opportunity to Comment and Future Cooperation The comments regarding the appreciation for the opportunity to comment and, the agency’s availability for future coordination are noted and forwarded to the appropriate decision makers. 5.2.1.2 FEIS Letter 2: Department of Fish and Wildlife

Response to Comment 1: Comprehensive Plans and Critical Areas Ordinance – Consideration of Fish and Wildlife The comments are noted and forwarded to the appropriate decision makers. The Comprehensive Plan is intended to define the land use plan, policies, associated supporting infrastructure, and service needs for the County. The Critical Areas Regulations Update is under preparation in a separate process as noted on pages 3-2 and 3-3 of the DEIS. The DEIS and FEIS assumed implementation of the current adopted CAR.

Response to Comment 2: DEIS Presentation of Detailed Information The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 3: Surface Water Quality/Quantity Table 3.1-6 outlines existing adopted not proposed stream buffer widths. The Critical Areas Regulations Update is under preparation in a separate process as noted on pages 3-2 and 3-3 of the DEIS. The DEIS and FEIS assumed implementation of the current adopted CAR. The DEIS Fisheries Section (3.1.5) cross-references Table 3.1-6 on page 3-116. The DEIS Wetlands Section (3.1.6) identifies wetland buffers on page 3-155 in Table 3.1-23. The DEIS Wildlife Section (3.1.7) described the County adopted regulations on page 3-166. A cross reference to Tables 3.1-7 and 3.1-8 is added on page 3-125 in the DEIS Fisheries Section. Please see Chapter 4 of this FEIS.

Response to Comment 4: Potential Surface Water Mitigation Measures A mitigation measure that identifies the improvement to water quality by increasing critical area buffers is added to DEIS Section 3.1.3 similar to mitigation measures in other DEIS Natural Resource Sections. Please see Chapter 4 of this FEIS.

Response to Comment 5: Surface Water Significant Unavoidable Adverse Impacts Direct impacts to protected critical areas including streams should be mitigated by City critical area regulations and requirements for no-net-loss of functions and values, particularly as these regulations are updated to address Best Available Science. The extent to which indirect and/or cumulative impacts (such as effects of runoff on water quality) could be reduced or offset will depend on the County’s implementation of revised critical area and shoreline regulations, stormwater regulations, restoration plans, and regional watershed plans.

Snohomish County Comprehensive Plan 5-8 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Because the Comprehensive Plan will tend to concentrate growth into the UGAs, the potential for development related impacts would also be concentrated in these areas. In this way, it is intended that impacts at the larger countywide scale will be reduced. In UGA areas not fully urbanized and better vegetated there could be localized impacts where mitigation is less than 100% effective because engineered surface water systems may not be 100% effective in replicating natural systems. However, by concentrating development within the UGAs, the quantity of habitat degraded will be minimized, and in general will be most prevalent in streams already affected by existing conditions. Where development can be accomplished using low impact development methods that reduce the sources of runoff and nonpoint pollution (rather than treating stormwater produced by conventional developments) the potential for development related impacts would be minimized. Given the scale of this analysis and the status of related plans and programs underway, it is not possible to determine specifically the quantity and location of impacts to streams. The level of significance of impacts would be more precisely determined through environmental reviews of regulation and plan updates underway and through project-specific environmental review. Mitigation measures are clarified in FEIS Chapter 4 to recognize no-net-loss goals and the Critical Area and Shoreline Master Program Update, as well as to clarify that the level of significance of impacts would be more precisely determined through environmental reviews of regulations and plans underway and through project-specific environmental review.

Response to Comment 6: Stream Buffer Widths Page 3-116 of the DEIS describes existing adopted buffer widths, not proposed stream buffer widths. It describes both CAR standards and the County’s Salmonid Habitat Management Plan. This latter plan currently requires wider buffers near salmon-bearing waters (150 feet) than standard CAR provisions. The Habitat Management Plan further limits increases in EIA within an additional 150-foot area (within 150 to 300 feet of the stream, beyond the 150 foot buffer). This is clarified in Chapter 4 of the FEIS. The Critical Areas Regulations Update is under preparation in a separate process as noted on pages 3-2 and 3-3 of the DEIS. The DEIS and FEIS assumed implementation of the current adopted CAR.

Response to Comment 7: Watershed and Salmonid Resources The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 8: Near Shore Marine Environments See Letter 1, Response to Comment 13.

Response to Comment 9: Marine Priority Habitats and Species The County’s current CAR includes a section on protection of fish and wildlife habitat as described on page 3-166. In addition to addressing habitats of federal endangered or threatened species, the CAR addresses protection of marine habitats including kelp and eelgrass beds, shellfish areas, and herring and smelt spawning areas. The information on page 3-166 is summarized on page 3-116 as amended in Chapter 4 of this FEIS. The Critical Areas Regulations Update is under preparation in a separate process as noted on pages 3-2 and 3-3 of the DEIS. The DEIS and FEIS assumed implementation of the current adopted CAR.

Snohomish County Comprehensive Plan 5-9 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Please also see Response to DCTED Comment 13.

Response to Comment 10: Marine Fish on Priority Species List Table 3.1-17 is amended to list Priority Marine Fish and Shellfish Species. Table 3.1-25 is amended to add Marine Mammals. See FEIS Chapter 4.

Response to Comment 11: Shellfish Species on Priority Species List Table 3.1-17 is amended to list Priority Marine Fish and Shellfish Species. Table 3.1-25 is amended to add Marine Mammals. See FEIS Chapter 4.

Response to Comment 12: Species of Local Importance The Critical Areas Regulations Update is under preparation in a separate process as noted on pages 3-2 and 3-3 of the DEIS. The comment to address “species of local importance” can be considered in that process. Your comments are forwarded to the appropriate decision makers.

Response to Comment 13: Specific Data on Species of Local Importance The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 14: Wetland Types Priority habitat information was a resource reviewed for the DEIS. However, more information regarding wetland types in the County, while valuable, is not available. The County does not have a current comprehensive inventory of its wetland resources. This level of detail, moreover, is outside of the scope for this nonproject programmatic EIS. The County may determine in the future that additional resources should be provided to prepare a County wetland inventory. Your comments are forwarded to the appropriate decision makers.

Response to Comment 15: Eel Grass/Kelp Bed/Turf Algae Habitat Page 3-156 has been revised to include mention of marine nearshore wetlands. See FEIS Chapter 4.

Response to Comment 16: Wetland Inventories The County uses the National Wetland Inventory as its source of reference data, along with site- specific wetland reports. The County’s CAR regulates wetlands based on criteria and wetlands found in the field, and uses reference maps as a guide. It is noted in the DEIS that not all wetlands or other critical areas are mapped. Impacts were noted to potentially affect mapped and unmapped resources. The County may determine in the future that additional resources should be provided to prepare a County wetland inventory. Your comments are forwarded to the appropriate decision makers.

Response to Comment 17: Impacts to Wetlands All wetlands are regulated under County critical areas regulations whether mapped or not. Critical area regulations allow for wetland alteration subject to criteria, which include mitigation sequencing where an applicant demonstrates that avoidance is not feasible and the impacts are

Snohomish County Comprehensive Plan 5-10 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses minimized. The paragraph is intending to indicate that despite wetland regulations that limit wetland alteration, when such wetlands are altered, the mitigation may not be fully successful if appropriate monitoring or corrective actions are not taken.

Response to Comment 18: Wetland Buffer Widths The Critical Areas Regulations Update is under preparation in a separate process as noted on pages 3-2 and 3-3 of the DEIS. The DEIS and FEIS assumed implementation of the current adopted CAR.

Response to Comment 19: Alternative Wetland Buffer Widths See Response to Comment 18 above.

Response to Comment 20: Designation of Priority Wildlife Species Information was added to this section to clarify that additional priority species occur in the County in areas not in or near a UGA and that it is likely that priority species that have not been documented also occur within the County. See Chapter 4 of this FEIS. Snohomish County is currently in the process of updating its Critical Area Regulations (CAR) as described on pages 3-2 and 3-3 of the DEIS. The DEIS and FEIS assumed implementation of the current adopted CAR. The EIS analysis focuses on species occurring in or near UGAs because this is where impacts associated with the Comprehensive Plan update would primarily occur. This has been clarified in Section 3.1.7.1. See Chapter 4 of this FEIS.

Response to Comment 21: Marine Mammal Species The marine mammal species noted on page 3-168 have been added to Table 3.1-25 and the text on page 168 has been edited to reflect this change. See Chapter 4 of this FEIS.

Response to Comment 22: Priority Habitats and Species Surveys Snohomish County is currently in the process of updating it’s Critical Area Regulations (CAR) as described on pages 3-2 and 3-3 of the DEIS. The DEIS and FEIS assumed implementation of the current adopted CAR. There are no plans to conduct countywide wildlife surveys at this time. The County may determine in the future that additional resources should be provided to prepare a County wildlife inventory. Your comments are forwarded to the appropriate decision makers.

Response to Comment 23: Presumed Impacts to Wildlife Habitat Section 3.1.7.2 has been edited to clarify that fish and wildlife habitat conservation areas would be protected as required under SCC 30.62, Critical Area Regulations, however there would be a loss of wildlife habitats not covered under this regulation (not defined as fish and wildlife habitat conservation areas) through time under all Alternatives. See FEIS Chapter 4.

Response to Comment 24: Fish and Wildlife Conservation Areas Term Fish and wildlife conservation areas are described in section 3.1.7, page 3-166.

Snohomish County Comprehensive Plan 5-11 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 25: Bald Eagle Habitat Impacts The bald eagle has been added to Table 3.1-25. By definition, a bald eagle nest territory would be considered a fish and wildlife habitat conservation area under SCC 30.62, Critical Area Regulations, and would receive the same protection whether located inside or outside of a UGA. Page 3-175 has been edited to describe protections to bald eagle habitat from SCC 30.62 and the WDFW Management Recommendations. See Chapter 4 of this FEIS. Snohomish County is currently in the process of updating it’s Critical Area Regulations (CAR) as described on pages 3-2 and 3-3 of the DEIS. The DEIS and FEIS assumed implementation of the current adopted CAR.

Response to Comment 26: Appreciation for Opportunity to Comment The comments are noted and forwarded to the appropriate decision makers. 5.2.1.3 FEIS Letter 3: Puget Sound Regional Council

Response to Comment 1: PSRC Responsibilities and Success The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 2: Density Transfers Density Transfers are a part of the Recommended Plan and Council Map List. These alternatives would implement the County’s Pilot Program and extend it. Density transfer and receiving areas (e.g. near Arlington) are identified. See Chapter 2 of this FEIS.

Response to Comment 3: Design Standards The Recommended Plan includes updated design standard policies. It updates design standard regulations for the Urban Centers. More areas are eligible to use the Urban Centers Demonstration Program. The Council has considered these policies in its deliberations. See Chapter 2 of this FEIS.

Response to Comment 4: Expand Discussion of Vision 2020/Destination 2030 The comment identifies a four-fold transportation policy emphasis of Vision 2020 and Destination 2030 and asks for a comparison of the three Draft EIS alternatives in their relative consistency with the policy emphasis. These policy directives and the relative consistency of the Draft EIS alternatives are provided below. In general, it should be noted that the alternatives considered in the Draft EIS were focused on alternative land use designations and transportation facilities to serve the land uses. Please refer to the Plans and Policies section of this Final EIS for additional discussion of the Recommended Plan and Council Map List as appropriate.

Optimizing and managing use of existing facilities and services Under all of the alternatives, the County’s approach to transportation planning is to fully utilize existing facilities prior to expanding or creating new alignments.

Snohomish County Comprehensive Plan 5-12 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

In general, land use alternatives that focus growth in urban areas with an established roadway network are likely to have the greatest potential to optimize use of existing facilities. Land use alternatives that provide for urban expansion in the rural areas with a less developed transportation network are more likely to require new roadway corridors and facilities. Under these assumptions, Draft EIS Alternative 1 is most likely to be able to optimize and manage use of existing facilities and Alternative 3 is least likely to fulfill this objective. Draft EIS Alternative 2 is in between the two, but more similar to Alternative 1 than Alternative 3.

Managing travel demand to address traffic congestion and environmental objectives Travel demand measures to reduce traffic congestion, improve air quality and reduce fuel consumption are identified in the Air Quality, Transportation, and Energy sections of the EIS. Measures that are described include the County’s Commute Trip Reduction Plan and Community Transit programs. Mitigation measures in the Transportation section also describe commute trip reduction and transportation demand management measures that could be implemented under any of the alternatives. These measures are intended to apply equally to all alternatives. Commute trip reduction and transit programs may be more likely to work successfully where there is a sufficient employment base and residential densities to support such programs. Draft EIS Alternatives 1 and 2 are the most focused within the existing UGA and may be most likely to achieve the development thresholds for such programs, relative to Alternative 3.

Coordinating transportation and land use planning to support transit and pedestrian-oriented land use patterns As described in the Transportation section of the Draft EIS, the transportation system associated with each land use alternative is tailored to reflect the alternative’s land use pattern. The needs of each alternative and related transportation improvements are described in the Draft EIS Transportation section. All of the alternatives provide for urban center and transit/pedestrian village designations, which emphasize transit access and pedestrian activity. These designations are located in established UGAs and near existing transportation corridors and facilities. Mitigation measures identified in the Transportation section of the Draft EIS identify land use measures that could help mitigate transportation impacts and encourage transit and pedestrian- oriented land use patterns. Selected measures include: limits to urban boundary expansion, intensification of existing UGAs and Urban Centers, land development phasing and proactive city annexation of growth areas.

Expanding transportation capacity to offer greater mobility options Modes of transportation addressed in the Draft EIS include automobiles, non-motorized (bicycle and pedestrian), transit, ferries, rail and airports. The relative impacts of the alternatives on these modes of transportation are qualitatively described in the Transportation section of the Draft EIS. For the non-motorized system, the analysis states that changes would be experienced in existing and expanded urban growth areas. Transit use would increase by 118% for Alternative 1, 128% for Alternative 2 and 142% for Alternative 3 (between 2000 and 2025). The Draft EIS states that ferries, rail and airports would all be impacted in varying degrees.

Snohomish County Comprehensive Plan 5-13 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

In addition, the County’s submittal of the subsequent certification documentation for the Update will address consistency with the GMA, Vision 2020 and Destination 2030.

Response to Comment 5: Specific Regional Policy Consistency The DEIS provided a review of policy consistency related to the three map alternatives. Since the Recommended Plan includes policy amendments, a more detailed review is provided. See FEIS Chapter 3 for the Relationship to Plans and Policies discussion.

Response to Comment 6: Reducing Share of Population in the Rural Area The County’s Urban/Rural Split policies in the adopted 1995 General Policy Plan (GPP) document are as follows: PE Policies 1.A.1 Snohomish County's portion of the urban growth areas shall receive the majority of the unincorporated county's projected population and employment growth. PE Policies 1.B.1 The rural population and employment growth targets of Appendix D and any future target amendments shall represent a reduction in the amount of rural growth presently occurring. These are carried forward in the Recommended Plan with minor amendments. As noted in the DEIS, the observed rural-urban split between 1990 and 2000 was 13% rural and 87% urban. The remaining growth with the adopted 1995 GMA Comprehensive Plan is estimated to be 18% rural and 82% urban. The Countywide Planning Policies promote an urban/rural split that reduces rural share in comparison to a PSRC trend analysis that showed a potential for 28% rural growth. The Recommended Plan provides a 15% /85% rural-urban split and the Council FEIS Map List a 14%/86% rural-urban split very similar to the adopted 1995 GMA Comprehensive Plan. Each would reduce the amount of rural lands to a different degree – 4.3 square miles versus 7.7 square miles for the Recommended Plan and Council Map List, respectively. The Council Map List would likely produce the greatest unincorporated UGA population of all the approaches.

Response to Comment 7: Intensification in Existing UGA Boundaries The No Action Alternative provides a significant amount of population growth within the current UGA boundaries by infill based on current Future Land Use Map designations, but this population is lower than the “most likely” OFM Forecast. DEIS Page 2-24 indicates that accommodating growth solely through intensification or solely through UGA expansion is low due to a variety of physical, local community vision, or GMA limitations. The text indicates that the feasibility of solely relying on intensification at higher population target levels is limited. The text is clarified to state that the feasibility of solely relying on UGA expansion at any population levels above the No Action is limited. Please see Chapter 4 of this FEIS. Opportunities for infill and intensification were studied in more detail in developing the Recommended Plan and Council Map List. Please see Letter 1, Response to Comment 5.

Snohomish County Comprehensive Plan 5-14 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 8: Reasonable Measures As noted in the Draft EIS discussion of reasonable measures, the Snohomish County Countywide Planning Policies Policy UG-14 (b) identifies reasonable measures to consider prior to expanding UGAs. The CPP lists reasonable measures in six different categories, including measures that: • Increase residential capacity • Increase employment capacity • Support increased densities • Mitigate the impacts of density; and • Other measures The Draft EIS identified the relevant measures and provided a preliminary discussion of applicability to each of the Draft EIS alternatives. The Relationship to Plans and Policies section of this Final EIS provides a more specific analysis of consistency of the Recommended Plan proposed land use designations and policy language with the reasonable measures guidance in the CPP and GMA. Please refer to FEIS Chapter 3. The Recommended Plan and Council Map List do include a provision for a Fully Contained Community. Siting criteria, process for designation and reservation of the total population allocation for the FCC are consistent with the policy guidance of the CPP and RCW 36.70A.350.

Response to Comment 9: Coordination of Municipal Planning Coordination with municipalities in the County has been ongoing through the growth allocation process at the Snohomish County Tomorrow Forum. Additionally, the County held joint municipal/ County Planning Commission discussions during November 2004 at four locations. This is summarized in Chapter 2 of this FEIS. Regarding land use plan compatibility related to the Recommended Plan and Council Map List, see the Land Use Patterns and Relationship to Plans and Policies analysis in Chapter 3 of this FEIS.

Response to Comment 10: County and City Transportation Facilities The FEIS and Transportation Element for the County’s Comprehensive Plan Update describe how adequate transportation facilities and services will be provided. Chapter 3 of this FEIS and the Comprehensive Plan Update documents under separate cover present the implications of financing recommended improvements, particularly as they relate to regional investment and finance principals.

Response to Comment 11: Urban Centers Term Urban Center terminology and the relationship to regional plans are addressed in the Relationship to Plans and Policies analysis in Chapter 3 of this FEIS. As part of the Recommended Plan, the GPP includes amendments to create a revised Centers hierarchy. Proposed amendments were made available as part of the hearing process in summer and fall 2005.

Snohomish County Comprehensive Plan 5-15 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 12: Growth in Vehicle Miles Traveled The traffic modeling the County performs is supplemental to, and based on, regional trip tables prepared by PSRC. Concepts of public transportation, ridesharing, and lower trip generation associated with land use strategies are already built into the technical analysis performed by the County. In addition, the Snohomish County Countywide Planning Policies and General Policy Plan have commitments to these concepts that intend to facilitate growth reductions in VMT and mobile pollutants. Alternative 3 has significant intensification of land uses that will reduce vehicle trip-making; however, this alternative also provides major expansion of the urban boundary which adds vehicle trip-making. The net result is very little net reduction in vehicle trip-making. For the Recommended Plan despite a greater population than Alternative 2, its VMT is similar in impact due to greater focus on infill relative to expansion and a smaller future road network than for Alternative 3. The Council Map List VMT is in the range of Alternatives 2 and 3 and greater than the Recommended Plan; this alternative’s near balance of infill and expansion and smaller future road network than Alternative 3, contribute to its relatively less VMT estimate than Alternative 3.

Response to Comment 13: SR-9 Highway Corridor Description Given that State Route 9 is within the jurisdiction of the Washington State Department of Transportation, Snohomish County will have a secondary role in dealing with highway impacts on rural and agricultural areas of the County. The County will continue to work with WSDOT to minimize impacts by limiting access where practical and maintaining rural zoning.

Response to Comment 14: Streetscape/Street Standards Snohomish County’s Countywide Planning Policies and General Policy Plan each address the multi-modal function of major highway and arterial corridors. The 10-Year Update of the County’s Transportation Element of the Comprehensive Plan identifies and provides policy guidance on public transportation, pedestrian/bicycle facilities and the movement of goods and services (The GPP and TE amendments are summarized in Chapter 2 and Chapter 3 of this FEIS since policy and program updates are part of the Recommended Plan). Specific project- level improvements are identified which support multi-modal travel as well as implementation measures that ensure compatible design and operations.

Response to Comment 15: Environmental Analysis of Densification Mitigation measures in DEIS Sections 3.1.3 to 3.1.7 address a variety of measures including low impact development techniques to minimize impervious surfaces, cluster development, and others. These are cross-referenced to the Earth Section 3.1.1 as amended in Chapter 4 of this FEIS. 5.2.1.4 FEIS Letter 4: The Tulalip Tribes

Response to Comment 1: UGA on Tulalip Reservation The Recommended Plan and Council Map List do not include UGA expansions west of Marysville. However, upon consultation with the tribe, these alternatives include a class recognizing the urbanized nature of some portions of the subject area by designating some properties as “Reservation Commercial.” Please refer to FEIS Chapter 2.

Snohomish County Comprehensive Plan 5-16 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

5.2.2 Cities, County Local government agencies submitted comments on the DEIS and are listed in Table 5.2-1. The letters appear following the responses to comments.

Table 5.2-1 City and County Agencies with Comments FEIS # Log # Commenter Date 5 80 City of Arlington Executive (Cliff Strong) 6/10/04 6 166 City of Arlington Development Services (Cliff Strong) 6/18/04 7 228 City of Arlington Utilities (Karen Latimer) 6/18/04 8 163 City of Bothell (William Wiselogle) 6/18/04 9 120 City of Everett Planning and Community Development (Allan 6/18/04 Giffen) 10 90 City of Gold Bar (Colleen Hawkins) 6/11/04 11 E360 City of Mill Creek (Bill Trimm, AICP) 6/18/04 12 E381 City of Monroe (Hiller West, AICP) 6/18/04 13 E67 City of Mountlake Terrace (Shane Hope, AICP) 6/18/04 14 149 City of Mukilteo (Heather McCartney, FAICP and Thomas 6/17/04 Hansen, PE) 15 48 City of Snohomish (Dwight Hartman) 6/8/04 16 97 Snohomish County Agricultural Advisory Board (Jackie 6/15/04 Macomber) 17 113 City of Sultan (Rick Cisar) 6/16/04 18 E270 City of Woodinville (Steve Munson) 6/18/04

5.2.2.1 FEIS Letter 5: City of Arlington Executive

Response to Comment 1: Properties Included and Excluded from 2004 Docket Your comments are noted and forwarded to the appropriate decision makers. These requests are included for study in both the Recommended Plan and the Council Map List except the Foster and Johston (Public Use portion is in Recommended Plan) property is included in the Council Map List only, and the Johnston request is partially included at the north for public uses in both the Recommended Plan and the Council Map List. Please see FEIS Appendix I-B for a review of each docket request.

Snohomish County Comprehensive Plan 5-17 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

5.2.2.2 FEIS Letter 6: City of Arlington Development Services

Response to Comment 1: Figures 3.2-5 and 3.2-6, East-West Arterial I- 5 to SR-9 The County found no need for an interchange on I-5 at 152nd Street NW nor for an east/west extension to SR 9 under the three alternative land use scenarios studied as part of the DEIS. Any land use permits associated with a race track proposal or other changes in use would be studied at a site or area specific level through the SEPA and permit review processes.

Response to Comment 2: Figures 3.2-5 and 3.2-6, SR-531 between I-5 and SR-9 To the County’s knowledge, SR-531 is correctly designated.

Response to Comment 3: Figures 3.2-5 and 3.2-6, 186th between SR-9 and Burn Road The County could eventually consider reclassifying 186th Street NE to an arterial, as development and traffic volumes would necessitate. However, at this time such a change is outside the scope of this planning effort.

Response to Comment 4: Figure 3.2-13 School District Map Requires Update The DEIS Figure 3.2-13 notes that the map conveys information as of 11/2000. The map has since been updated. Please see FEIS Chapter 4.

Response to Comment 5: Reference to County Council Thank you for your observation. “City Council” is corrected to “County Council” on page 3-3 as noted in FEIS Chapter 4.

Response to Comment 6: Norma Soils The text on DEIS page 3-5 states that the Norma-Lynnwood-Custer (as well as two other soil associations) exhibit a range of depth and drainage characteristics. The text has been revised to clarify that this range includes poorly drained Norma and Custer soils. Please see FEIS Chapter 4.

Response to Comment 7: Soil Processes This sentence has been revised to clarify that that it is the ability of soil to infiltrate stormwater that is particularly important in urban areas. The revised sentence reads: “The ability of soils to infiltrate stormwater is particularly important in urban and residential areas where greater impervious surface area results in greater volumes of runoff delivered to soils and streams.” Please also see corrections in FEIS Chapter 4.

Snohomish County Comprehensive Plan 5-18 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 8: Glacial Outwash Soils This paragraph has been edited to include mention of the seasonally high water table that is present in portions of the Quilceda watershed. Please see FEIS Chapter 4.

Response to Comment 9: Seismic Hazards The Seismic Hazards section has been revised to include mention of the Lake Cavenaugh fault. Please see FEIS Chapter 4.

Response to Comment 10: Volcanic Hazards Comment noted. The text of this section has been corrected in FEIS Chapter 4.

Response to Comment 11: Mine Hazards We assume the TMDL study referenced in the comment is the 2004 Stillaguamish watershed TMDL study for fecal coliform, dissolved oxygen, pH, mercury, and Arsenic (Ecology 2004). The TMDL study says the following about mercury and mines, “Although inactive and abandoned mines could be potential sources of uncontrolled contamination, veins of arsenic and mercury- enriched bedrock in the headwater streams and aquifers of both forks may be responsible for some elevated concentrations of these metals (Ecology 2004).” Since the TMDL study says nothing conclusive about mine sources of mercury, it is not included in the EIS.

Response to Comment 12: Explanation of General Geologic Hazards The comment is noted.

Response to Comment 13: Table 3.1-5 Listing Applicable Ordinances The document focuses on the conditions and impacts relevant to unincorporated Snohomish County, and therefore local municipal ordinances are not listed.

Response to Comment 14: Table 3.1-6, Buffer Widths of Proposed CAR Table 3.1-6 outlines existing adopted not proposed stream buffer widths. The Critical Areas Regulations Update is under preparation in a separate process as noted on pages 3-2 and 3-3 of the DEIS. The DEIS and FEIS assumed implementation of the current adopted CAR.

Response to Comment 15: Table 3.1-8 Beneficial Use Designations Main stem Stillaguamish has been added to the “Char; Extraordinary primary contact” category in Table 3.1-8 Please see FEIS Chapter 4.

Response to Comment 16: Wetlands Text is added in FEIS Chapter 4 to state that wetlands also have an important effect on stormwater hydrology.

Snohomish County Comprehensive Plan 5-19 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 17: Impervious Cover and Forest Cover While large scale deforestation and agricultural practices can have a large scale impact on run- off characteristics, this paragraph states that increased impervious surface area is particularly important in determining surface runoff in urban areas.

Response to Comment 18: Low Flows “Low flows” is added to this sentence for the FEIS. Reduction in summer low flows is also described on DEIS page 3-53 in the context of Impacts Common to All Alternatives.

Response to Comment 19: Flood Hazard Areas While the County has conducted recent analyses of floodplain elevations along the Stillaguamish River, the results of these analyses have not been adopted by FEMA. The revised floodplain elevations determined by these recent analyses does not change this section of the DEIS on Flood Hazard Areas. The text will be revised to specifically mention potential impacts along the Stillaguamish River. It is anticipated that stormwater regulations will adequately regulate flood levels at the larger order river scales by reducing peak flows at the subwatershed scale. In UGA areas not fully urbanized and better vegetated there could be localized impacts where mitigation is less than 100% effective because engineered surface water systems may not be 100% effective in replicating natural systems. In most cases, FEMA designations will not change. Because increased flooding will be an indirect impact, the exact locations and extent of increased flooding are not predictable at this stage in the planning process.

Response to Comment 20: Flood Hazard Areas Citation The most current official FEMA flood elevations were published in 1999.

Response to Comment 21: Figure 3.1-3 Stream Typing Snohomish County stream typing is modeled after an earlier version of Washington State’s DNR water typing system, but the two systems no longer correspond. Snohomish County Code (SCC) 30.62.300 (1) states that: “Streams are classified based on the water typing criteria in former WAC 222-16-030 as adopted by the state in June 1993 . . .” Furthermore, per SCC, 30.62.040, critical areas are not necessarily all mapped, but are decided on a case-by-case basis as individual permit applications are reviewed. Where applicable, the stream typing maps corrected by the tribes (as well as several other current information sources) are consulted on a case-by-case basis by Snohomish County permit reviewers, and carry substantial weight.

Response to Comment 22: Figure 3.1-4 Coho and Chinook Presence See response to previous comment. Figure 3.1-4 is a large-scale map and is limited in its ability to render detail. Also, the U.S. Fish and Wildlife Service published “Critical Habitat Proposed for Washington’s Coastal-Puget Sound Population of Bull Trout” in the June 25, 2004 edition of the Federal Register. The current proposal no longer presumes that Coho presence is presumptive of bull trout habitat.

Snohomish County Comprehensive Plan 5-20 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 23: Figure 3.1-5 Critical Areas Again, large-scale maps are limited in their ability to render detail. Also, refer to Response to Comment 21 above. Per SCC, 30.62.040, critical areas are not necessarily all mapped, but are decided on a case-by-case basis as individual permit applications are reviewed.

Response to Comment 24: Marysville Trough Comment acknowledged. Text is edited to reflect the comment. Please see FEIS Chapter 4.

Response to Comment 25: Water Balance The water balance was developed by the USGS and cited in their 1996 study of water resources of Snohomish County. A water budget is a simple tool for describing the overall water availability, and is not intended to represent specific areas or seasonal fluctuations. More detailed sub-basin scale assessments may be warranted at a later date in areas that may experience significant land use change.

Response to Comment 26: Table 3.1-12 Groundwater Contaminant Sources Antibiotics and cryptosporidium are added to the agriculture land use section in Table 3.1-12 in FEIS Chapter 4. An herbicide is a type of pesticide, and pesticides are included in the agricultural section of the table.

Response to Comment 27: Groundwater Quality Comment acknowledged. This section is focused on the relationship between groundwater and impervious area. Habitat effects are addressed elsewhere in DEIS Section 3.1.7.

Response to Comment 28: Table 3.1.13 Aerial Photo Interpretation The EIA calculations are based on EIA factors used in Surface Water Modeling Protocols by Snohomish County. A range of EIA estimates are used depending on the age of the development. In general, more recent development has higher EIA as a result of storm drainage, and stormwater infiltration is not explicitly identified in the default values. These factors were used as defaults for the land use analysis. Since the groundwater assessment was limited to a screening level landscape analysis that identified areas of concern at a sub- basin scale, these defaults are considered reasonable for identifying areas of concern.

Response to Comment 29: Pilchuck River Groundwater Based The City of Snohomish does receive water from the Pilchuck River and can be considered a groundwater-based system, but this is not what is referenced on page 3-86, last paragraph. Snohomish PUD is referenced on page 3-86, third paragraph, referring to Snohomish Public Utility District. The acronym is spelled out for clarification. See FEIS Chapter 4.

Response to Comment 30: Pets as Cause of Contamination Comment acknowledged, pets are added on page 3-86, last paragraph. See FEIS Chapter 4. Please also note Snohomish County is not currently involved in Aquifer Storage and Recovery projects or planning.

Snohomish County Comprehensive Plan 5-21 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 31: Mitigation, Add Wetland Protection and Protection of Recharge and Discharge Locations A cross reference to wetlands mitigation measures is added to page 3-93 of the DEIS. The measures referencing low impact development, minimization of impervious surface, and infiltration are intended to address protection of recharge and discharge locations. See FEIS Chapter 4.

Response to Comment 32: Wetland Antidegradation The surface water anti-degradation citation is added. See FEIS Chapter 4.

Response to Comment 33: Drainages with Stanwood Label In Figure 3.1-17 the “Stanwood” label refers to the City of Stanwood, not drainages, and the term Coastal Drainages refers to those groundwater basins along the coast outlined in a yellow line not within WRIAs 3, 5, 7, or 8. The maps are amended for clarification in FEIS Chapter 4.

Response to Comment 34: Burn Road Area The Burn Road area was included in the analysis. Figure 3.1-19, Predicted Net Groundwater Effect (%) – Alternative 2 versus Alternative 1, highlights the major differences between the two alternatives through percent change. Table C-3, Net Groundwater Effect, located in DEIS Appendix C , gives the results of the analysis for every groundwater sub-basin. Burn Hill Road drainages had a -1.1% change and are therefore indicated in the figure with gray shading. This is due to Rural Residential land use decreases and Urban Low Density Residential increases. Please note that several groundwater tables were corrected and updated in the FEIS, but this result for Alternative 2 did not change.

Response to Comment 35: Figure 3.1-20 Nitrate Loading Toxicity The drinking water standard for nitrate is 10 mg/L, which reflects the toxicity concerns noted.

Response to Comment 36: Stanwood and Arlington Change – Why Not Significant? The land areas and factors used to predict groundwater effects for Alternatives 2 and 3 are the same as for Alternative 1 (No Action) in the sub-basins associated with Arlington City and Arlington North sub-basins. Similarly, for Alternatives 1 through 3 there are only minor changes in the Church Creek and Douglas Creek sub-basins near Stanwood. Therefore, no significant change from Alternative 3 compared to the No Action Alternative is predicted. The Recommended Plan and Council Map List show greater effects in Douglas Creek and Church Creek due in part to the higher impervious surface assumptions for lands in cities applied to recently annexed areas.

Response to Comment 37: Demand on Arlington Heights Area The consumptive use of water is predicted to increase in the Arlington South sub-basin under Alternative 3 because of the increased land use designated residential compared to Alternatives 1 and 2.

Snohomish County Comprehensive Plan 5-22 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 38: Add Municipal and Regional Plans to Discussion The analysis focuses on unincorporated UGA and Rural areas, which are subject to County critical area regulations. Draft information from WRIA technical committees was considered in the DEIS preparation, primarily information available as of December 2003. SIRC technical assessment information is added to pages 3-120 and 3-121. Please see FEIS Chapter 4.

Response to Comment 39: Page 3-115 State Quality of Mapping Information Re: Blockages and Habitat Comment noted. Text is revised in FEIS Chapter 4 to clarify that maps in the document do not indicate all man-made blockages and that all habitat types are not necessarily accurately depicted.

Response to Comment 40: Include Wetlands Use by Fish and Wildlife Comment noted. Text on page 3-116 is revised in FEIS Chapter 4 to state that fish and wildlife conservation areas and wetlands are addressed by County regulations, as well as streams.

Response to Comment 41: Recognize Local Jurisdiction Regulations The analysis focuses on unincorporated UGA and Rural areas, which are subject to County critical area regulations.

Response to Comment 42: Wetland Loss Data Comment noted. The Stillaguamish Implementation Review Committee information is added to 3-121, as shown in FEIS Chapter 4.

Response to Comment 43: Poaching and Pets as Threats Comment noted. Disturbance by pets and poaching as well as increased human recreational activity is added to Page 3-125, as shown in FEIS Chapter 4.

Response to Comment 44: Historic Logging Historical logging is mentioned in the DEIS section. However logging is added on pages 3-118 and 3-120 as shown in FEIS Chapter 4.

Response to Comment 45: Stillaguamish Basin Size at 685 Square Miles According to SIRC 2001 the basin area is 700 square miles. In a brief search, more reports indicate the basin is 700 square miles, but 685 square miles is reported as well. The DEIS text is clarified to say 700 square miles instead of 701 square miles. See FEIS Chapter 4.

Response to Comment 46: Boulder River Boulder River is added as an important tributary to page 3-120. See FEIS Chapter 4.

Snohomish County Comprehensive Plan 5-23 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 47: Fecal Coliform Exceedances The word “several” to describe fecal coliform exceedances is replaced with “many” on page 3- 121. See FEIS Chapter 4.

Response to Comment 48: Need to Add Wetland Loss Table 3.1-16 is based on the Drainage Needs Reports. Wetland loss was not specifically evaluated in these studies, but since this likely applies to all of these areas, a statement is added to the text for the FEIS regarding the loss of wetlands. See FEIS Chapter 4.

Response to Comment 49: Wetland Loss in Impacts Common to All Wetland loss is mentioned on DEIS page 3-128 under ”Impacts Common to All Alternatives.” Paragraph 1 mentions “reduced riparian and wetland areas” and Paragraph 3 also notes the indirect effect of urbanization on wetlands within a watershed.

Response to Comment 50: Forest Removal and Increased Flow and Historically Lower Infiltration The commenter’s statement “Certainly 150 years ago there was less water making it to the groundwater due to interception and evapotranspiration” is not supported by studies known to the EIS preparation team. Numerous studies show that groundwater levels are falling from historic levels. Although interception and evapotranspiration does reduce groundwater compared to a clear-cut area, the precipitation that does fall on a cleared area infiltrates but also flows over the ground as surface runoff because the ground cannot infiltrate the precipitation fast enough. Currently, there is much less water making it to groundwater due to impervious surfaces and surface runoff.

Response to Comment 51: Unmapped Critical Areas Per SCC 30.62 critical areas aren’t necessarily all mapped, but are decided on a case-by-case basis as individual permit applications are reviewed based on the best available information.

Response to Comment 52: Page 3-134 Watershed Recovery Plan WRIA plans are mentioned on page 3-125. The EIS focuses on impacts in unincorporated areas, and municipal regulations would not apply until annexed. Cross references are made to wetland mitigation measures. See FEIS Chapter 4.

Response to Comment 53: Stronger Enforcement of Penalties A mitigation measure is added regarding enforcement. See FEIS Chapter 4.

Response to Comment 54: Prairie Creek Missing on Figure 3.1-26 Per SCC, 30.62.040, critical areas including streams aren’t necessarily all mapped, but are decided on a case-by-case basis as individual permit applications are reviewed.

Response to Comment 55: Tourism Impacts on Trails and Rivers Human recreation activity is added to discussion on Page 3-119, 3rd paragraph. See FEIS Chapter 4.

Snohomish County Comprehensive Plan 5-24 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 56: Wetlands in Lowlands Increasing Storage – Incorrect Comment noted. Paragraph has been modified. See FEIS Chapter 4.

Response to Comment 57: Mention Juxtaposition Juxtaposition (landscape position) has been included. See FEIS Chapter 4.

Response to Comment 58: Limited Buffers – Lack of Science Support The Critical Areas Regulations Update is under preparation in a separate process as noted on pages 3-2 and 3-3 of the DEIS. The DEIS and FEIS assumed implementation of the current adopted CAR.

Response to Comment 59: Wetlands Inventory – Strike Paragraph The first paragraph has been clarified as the County does not possess a current comprehensive wetlands inventory, but relies on the National Wetlands Inventory and site specific wetland reports. Please see FEIS Chapter 4.

Response to Comment 60: Acre Estimates of Wetlands A footnote has been added to the bottom of Table 3.1-24 to explain why these estimates are below the actual acreage of wetlands currently present in the County. Please see FEIS Chapter 4.

Response to Comment 61: Riverine – Need to Include Streams Riverine description is elaborated upon to indicate these generally are wetlands contained within a channel. Please see FEIS Chapter 4.

Response to Comment 62: Modify Description of Wetlands Impacts Common to All “Dredging” has been added to discussion of filling. The discussion has been revised to include the cumulative effects of developing small wetlands, the importance of wetlands in attenuating floodwaters, and why disturbing recharge areas can affect wetlands. Please see FEIS Chapter 4.

Response to Comment 63: Reductions of Wildlife Impacts of flooding wetlands and connection with the ESA food chain have been included. Please see FEIS Chapter 4.

Response to Comments 64: Mitigation of Mature Vegetation Removal on Resource Lands The County does not currently require mitigation for disturbance of mature vegetation on resource lands unless the vegetation is considered part of a critical area (wetland/stream buffer, fish and wildlife habitat conservation area).

Snohomish County Comprehensive Plan 5-25 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comments 65: Page 3-161 Potential to Restore Historically Lost Wetlands The potential for restoring historically lost wetlands has been included in the discussion under Impacts Common to All. Please see FEIS Chapter 4.

Response to Comment 66: Priority Animals Missing from Discussion Disturbance to priority wildlife species has been added. Please see FEIS Chapter 4.

Response to Comment 67: Page 3-164, Define Relationship between Critical Areas and Open Space An Incorporated Plan Feature includes adopted policies addressing open space designation. Policies associated with Goal LU-10 include critical areas as an aspect of open space. This policy is being carried forward with limited amendments in the Recommended Plan.

Response to Comment 68: DOE – List as Authority Over Wetlands DOE has been added as another authority over wetlands. Please see FEIS Chapter 4.

Response to Comment 69: Other Local Government Regulations The analysis focuses on unincorporated UGA and Rural areas, which are subject to County critical area regulations. The County Critical Areas Regulations Update is under preparation in a separate process as noted on pages 3-2 and 3-3 of the DEIS. The DEIS and FEIS assumed implementation of the current adopted CAR.

Response to Comment 70: Mitigation – Reference Watershed Plans and Mitigation Banks Wetland mitigation banking and Watershed planning references have been added. Please see FEIS Chapter 4.

Response to Comment 71: Wildlife Species A discussion of estuarine and near shore habitat use by marbled murrelets has been added to page 3-167. Please see FEIS Chapter 4.

Response to Comment 72: Bald Eagle Locations Use of other lakes and agricultural lands by bald eagles has been added to this paragraph. Please see FEIS Chapter 4.

Response to Comment 73: Wildlife Habitat The term historical has been replaced with wording to describe the time frame since European settlement of the Puget Sound area. A description of reforestation using primarily Douglas-fir has been added to this paragraph. Please see FEIS Chapter 4.

Snohomish County Comprehensive Plan 5-26 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 74: Address Wetlands in Riparian Areas Wetlands have been added to paragraph 4 on Page 3-169. Please see FEIS Chapter 4.

Response to Comment 75: Include Fish and Freshwater Mussels to Discussion on Page 3-170 Fish are discussed in Section 3.1.5 of the DEIS. The current list of listed and proposed endangered and threatened species and critical habitat; candidate species; and species of concern in Western Washington as prepared by the U.S. Fish and Wildlife Service, Western Washington Fish and Wildlife Office, for Snohomish County (October 8, 2004), does not include any fresh water mussels, however should any additional species be listed under ESA, current Critical Area Regulations would apply.

Response to Comment 76: Habitat Connectivity and Agricultural Lands A discussion of potential limited use or avoidance of open areas of agricultural land by species sensitive to crossing openings has been added to the discussion of wildlife corridor use. Please see FEIS Chapter 4.

Response to Comment 77: Page 3-171 Agricultural Lands in UGAs The discussion was intended to indicate that there would be loss of forest and agriculture lands in UGAs. Since GMA “designated” agricultural and forest lands are not located in UGAs the parenthetical comment notes that lands of long-term commercial significance for agriculture and forestry are generally located outside of unincorporated UGAs. The impacts of Alternative 3 are not shared by all alternatives in some cases, such as intrusion into Riverway Commercial farmland, and the unique impacts of Alternative 3 are addressed on page 3-174. The Frylands, Kellog Marsh, and Berry farms are outside of UGA boundaries. These lands were de-designated in the 1995 GMA Comprehensive Plan. However, please note that there is a net increase in Riverway Commercial Farmland under the Recommended Plan with the reclassification of a portion of the Harvey Airfield along the southern Snohomish UGA boundary. The Council Map List would convert some acres of designated farmland but less than Alternative 3.

Response to Comment 78: Long Term Displacement of Lowland Wildlife A discussion of impacts to low elevation species has been added to Section 3.1.7.2. Please see FEIS Chapter 4.

Response to Comment 79: Other Mitigation Measures for Listed Habitats This mitigation measure has been revised to address protection of listed species as required by current Snohomish County Critical Area Regulations. Please see FEIS Chapter 4.

Snohomish County Comprehensive Plan 5-27 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 80: Amount of Critical Areas Given Overlaps and Gaps Comment noted. The mapped acres of the critical areas overlap and may overstate mapped critical areas – primarily wetlands and streams, but there are unmapped resources. The text is clarified in FEIS Chapter 4.

Response to Comment 81: Relationship between Mineral Lands and ESA and Vesting It is unclear if the comment is addressing Endangered Species Act questions or generally refers to “Environmentally Sensitive Areas.” The DEIS section describes the location of designated mineral lands. It is not intended to provide a permitting analysis of potential mining operations. County permitting of mining operations would not change the applicability of Federal ESA laws. Regarding environmentally sensitive areas in general, environmentally sensitive areas were excluded from mapped mineral resources. Environmental review regarding mineral resource lands was conducted in a Supplemental EIS and addendum, issued in 2003. The following lands identified as environmentally sensitive were removed from the proposed Mineral Resource Overlay: • Designated as a Natural or Conservancy environment by the Snohomish County Shoreline Management Master Program; • Located within a 300-foot Chinook salmon/bull trout corridor; • Located within a 100-year floodplain; Additional site specific environmental review, including a hydrogeologic evaluation and an evaluation of impacts to the natural environment and critical areas, will occur during the review of permit applications related to mineral operations. The proposed code amendments implementing the mineral lands plan, except all procedural provisions, shall not apply to any development permit application that is complete prior to the effective date of the adopted mineral lands ordinance.

Response to Comment 82: County ESA Administrative Rule Comment noted. The Administrative Rule is added to the list. Please see FEIS Chapter 4.

Response to Comment 83: Add Avoidance of Critical Areas to Mitigation in Land Use Patterns Avoidance of critical areas in UGA expansions is addressed in the various Natural Resource mitigation measures in Section 3.1 of the DEIS. See FEIS Chapter 1 for a summary of mitigation measures largely carried forward from the DEIS. Also note that the Recommended Plan to a greater degree and the Council Map List to some degree, described in FEIS Chapter 2, reduce potential urban development or avoid several particularly sensitive areas as a result of the DEIS analysis, such as Little Bear Creek basin and others.

Snohomish County Comprehensive Plan 5-28 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 84: Include GMA Measures Regarding Preserving Natural Systems Other GMA goals for resource protection are added to page 3-205. Please see FEIS Chapter 4. Note that the analysis on page 3-216 identifies GMA requirements to protect critical areas and to consider best available science.

Response to Comment 85: City as Receivers of TDR The TDR program is more defined as part of the Recommended Plan, and the TDR receiving areas within UGAs is described in FEIS Chapter 2 and analyzed in FEIS Chapter 3.

Response to Comment 86: Visual Character Between Arlington and Marysville The analysis is addressing Alternative 1, which does not expand UGA boundaries or propose industrial or other development in the areas currently designated for “Other Land Use” or for “Rural Residential” that are between Arlington and Marysville. For this Alternative, the areas of infill would occur in existing UGA areas in the Smokey Point area that are urban/suburban currently. That Alternative 1 does not increase intensity of future land use in the “Other Land Use” and Rural Residential Areas between the two communities is clarified in FEIS Chapter 4.

Response to Comment 87: Seasonal Use of Mountains by the Tribes A sentence is added to page 3-263 regarding seasonal use of the mountains by the tribes, although as stated on the page their villages generally were located on rivers and estuaries. Please see FEIS Chapter 4.

Response to Comment 88: Hiking Trails in Eastern County Pages 3-281 and 3-282 address sidewalks and bicycle facilities as modes of travel, and do not address recreational trails. Recreation is generally addressed in Section 3.2.10; however recreation on federal lands is not a topic as the County is not the service provider in these areas.

Response to Comment 89: Railroad Rights of Way Snohomish County’s policies and programs support and encourage preservation and use of abandoned rail corridors for future bicycle and rail transportation, Objective TR10. Rail mass transit is a service provided by Sound Transit, and the County coordinates with that service provider.

Response to Comment 90: Critical Area Avoidance Pages 3-294 and 3-295 address impacts that future roadways may have on critical areas generally. The proposed arterial improvements are conceptual at this time allowing for flexible design and alignment. The County’s policies, programs and impact mitigation requirements that support and protect critical areas and wildlife habitat will guide the design of these arterial improvements.

Snohomish County Comprehensive Plan 5-29 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 91: Figure 3.2-3 and Missing Linkages To the County’s knowledge, no major linkages are missing from the Arterial Circulation Map. Figures 3.2-5 and 3.2-6 show proposed arterial linkages for each of the alternatives considered within the DEIS. Additional arterial linkages were identified to serve expansion and intensification areas for the growth scenarios.

Response to Comment 92: NASCAR Sound Level The 10-Year Update is a nonproject programmatic EIS. Future site-specific developments would be subject to site specific environmental review and permitting.

Response to Comment 93: Cultural Resources Additional information about the Stillaguamish Tribe is added to the Cultural Resources section. Please see FEIS Chapter 4.

Response to Comment 94: Transportation – Airports Air transportation is handled separately by the County’s Airport Master Plan and capital facilities plan. In addition, the Transportation Element’s inventory of Transportation Facilities and Services does provide information on air transportation, air fields and facilities.

Response to Comment 95: Noise – Arlington Airport As described in the first paragraph of DEIS Section 3.2.7 airport facilities require their own project-specific Master Plans and/or SEPA review. Please also see the summary of relevant airport master plans in FEIS Chapter 3 and Appendix I-D. This analysis shows consistency with airport master plan provisions.

Response to Comment 96: GMA Conflicts – Recreation in Floodplain/Agriculture The fourth bullet describes interim development of recreation facilities on lands in urban areas, not agricultural areas. The suitability of lands for recreation development on urban floodplain areas would be addressed by floodplain regulations.

Response to Comment 97: Alternative 3 and Stanwood and Arlington Schools The second paragraph on page 3-373 indicates that the total countywide student population is projected to rise to the overall number expressed in paragraph 1 under “Impacts of Alternative 3.” Alternative 3 would have the greater student population of those reviewed, but it is anticipated that the distribution of future students among the school districts would be similar to that projected through 2012 (Table 3.2-45). Arlington and Stanwood school districts project sizeable student increases between 2001 and 2012.

Response to Comment 98: Instream Flow Rules and Water Supply The estimates of future water demand for each Alternative are based on a gallons-per-capita estimate as a broad estimate of future demand. Each water supplier will update its plans regularly to address projected growth in their service area. These plans will need to address water supply in light of changing federal and state rules including “instream flow”.

Snohomish County Comprehensive Plan 5-30 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Water resource management planning for the watersheds of Snohomish County is an on-going process. Snohomish County and the City of Everett (a large water supplier in the County) have contributed to water resource planning workshops (Waldo 2003), and will likely continue to participate in the development of in-stream flow management measures.

Response to Comment 99: Drainage Ditches Conveying Natural Streams – Need Documentation and Signage The County currently has a GIS coverage that documents the approximate location of most streams in the County, including those that have historically been straightened along the edges of roads. While the County has installed signs along some of the major streams in the unincorporated areas, it does not have sufficient funding to initiate a program that would install signs along all streams.

Response to Comment 100: Known Flooding Problems – Lacking Some Data on Table 3.2-51 This table was intended to list the drainage problems that were analyzed by the County during recent drainage studies, but not to include all of the locally known drainage problems. As stated on page 3-406 of the DEIS, “The list in Table 3.2-51 does not necessarily represent a comprehensive list of all existing flooding problems in these UGAs since many of the smaller drainage systems in these UGAs have not been analyzed. If more of the smaller existing drainage systems had been analyzed for these studies, additional flooding problems likely would have been identified.”

Response to Comment 101: Infiltration While the statement that “soils conditions in much of Snohomish County generally tend to make the use of infiltration facilities infeasible” is believed to be true, the text is modified to clarify that infiltration is feasible in other parts of the County besides the Marysville UGA. Please see FEIS Chapter 4.

Response to Comment 102: Other Mitigation Measures – Cooperative Surface Water Efforts Comment noted. Under “Applicable Regulations and Commitments” joint County/drainage district/municipal efforts are added. Please see FEIS Chapter 4.

Response to Comment 103: Stormwater Detention Designs Benefiting Listed Species A sentence acknowledging designs serving multiple goals is added on page 3-424. Please see FEIS Chapter 4.

Response to Comment 104: Airport and Land Use Impacts Please see FEIS Chapter 3 and Appendix I-D. No consistency concerns were found with respect to airport master plans.

Response to Comment 105: Contact Information The comment is noted.

Snohomish County Comprehensive Plan 5-31 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

5.2.2.3 FEIS Letter 7: City of Arlington Utilities

Response to Comment 1: Water and Sewer Plan Data Update The Tables in Sections 3.2.12 and 3.2.13 related to Water and Sewer are updated with the commenter information. Please see FEIS Chapter 4.

Response to Comment 2: Water and Sewer Impacts The DEIS Water analysis is corrected in FEIS Chapter 4 to add Arlington to the list of higher growth UGAs similar to the DEIS Sewer analysis, particularly when considering forecasted employment. As seen in Figures 2.4-2 and 2.4-3 of DEIS Chapter 2, UGAs with the higher population growth include Southwest, Marysville, Lake Stevens, and Monroe UGAs. In DEIS Figures 2.4-5 and 2.4-6 the higher employment growth depends on whether the whole UGA (City plus Unincorporated) or the Unincorporated areas are considered. Reviewing whole UGA areas, Southwest, Monroe, Arlington, and Marysville have the higher projected employment growth. Considering the Unincorporated UGAs alone, higher employment is projected in Southwest, Marysville, Lake Stevens, and Maltby. 5.2.2.4 FEIS Letter 8: City of Bothell

Response to Comment 1: Residential Density Ranges Future density assumptions were based on an analysis of the actual historical development observed in each plan designation. For the 2025 land capacity estimates, the County updated the densities observed within the ULDR (4-6 DU/ac) designation by adding density information from single family plats recorded in 2001 and 2002 (as mentioned above). By adding these two recent years, and dropping the two “oldest” years (SF plats recorded in 1995 and 1996), the buildable density in ULDR rose from 4.76 DU/ac in the 2002 BLR to 5.02 DU/ac in the 2025 capacity update. The following observed densities were used for the other major categories of County residential designations (that were unchanged from the 2002 Buildable Lands Report): UMDR (6-12 DU/ac) = 11.12 UHDR (12-24 DU/ac) = 19.67 For the following new designations modeled for the 10-year update (which did not exist yet as County plan designations when the 2002 Buildable Lands Report was developed), the County used the following residential density assumptions: Urban Village (residential component) = 10 Transit/Pedestrian Center (residential component) = 19.67 Urban Center (residential component) = 19.67

Response to Comment 2: Proposed Future Land Use – General Comments In accordance with GMA, each jurisdiction is required to plan for its fair share of growth in its territorial limits and future annexation area as appropriate. The test of consistency among plans

Snohomish County Comprehensive Plan 5-32 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses is consistency with the Countywide Planning Policies as noted in DEIS page 3-220. It is recognized that over time, Comprehensive Plan review and amendments may lead to alternative future land use classes, but these MUGA planning efforts would be coordinated between the cities and County as pointed out in the commenter’s letter. In October 2003 Snohomish County adopted Appendix B to its Countywide Planning Policies (CPPs) to reflect the results of a 2-year collaborative process of developing MUGAs (municipal urban growth areas) within the large Southwest UGA. This process involved Bothell and the eight other cities within the SW UGA. In March, the CPPs were amended again to include a new policy (UG-17) that calls for documentation of the MUGAs in affected city and county comprehensive plans. Snohomish County will consider appropriate amendments to its comprehensive plan to respond to these revised CPPs within its comprehensive plan. The County has coordinated with each city in the process of developing population and employment allocations, and in preparing the Comprehensive Plan Update. Multi-agency planning commission meetings were also held. Please refer to FEIS Chapter 2.

Response to Comment 3: Proposed Future Land Use – Alternative 1 Comments There are differences in the regulations of zones that are roughly equivalent between the County and the City. Primarily, the County’s zones allow transfer of yield from unbuildable areas to buildable areas, whereas the City’s zones do not. This is accomplished in the County mainly through Planned Residential Developments (PRDs) and subdivisions using lot size averaging.

Response to Comment 4: Proposed Future Land Use – Alternative 2 Residential Densities The comments regarding compatibility depending on the density selected within the range are noted and forwarded to the appropriate decision makers. Also see Response to Comments 1 and 2 above.

Response to Comment 5: Proposed Future Land Use – Alternative 2 Comments Commercial The Recommended Plan and Council Map List designate an Urban Village within the Bothell MUGA at the intersection of Maltby Road and York Road, which would allow neighborhood scale commercial and multiple family residential development. The Urban Village would encourage pedestrian oriented development.

Response to Comment 6: Proposed Future Land Use – Alternative 2 UGA Expansion to Little Bear Creek Basin A focus of the DEIS analysis, particularly Section 3.1 Natural Environment, was the impacts of UGA expansion in particularly sensitive areas such as the Little Bear Creek Basin. Please note that the Recommended Plan does not include a substantive UGA expansion east of Bothell and the Council Map List includes a Southwest UGA expansion that is in the range of Alternatives 2 and 3.

Snohomish County Comprehensive Plan 5-33 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 7: Proposed Future Land Use – Alternative 3 The comments regarding the intensity of uses and size of UGA boundaries for Alternative 3 are noted and forwarded to the appropriate decision makers. Please see Response to Comment 6.

Response to Comment 8: Traffic Impacts The County opted to look at three land use alternatives with an increasing magnitude of growth in order to gauge the relative impacts and costs. In addition, the County does not want to incur more growth than it can pay for, nor more than it must accommodate under the Growth Management Act. Selection and adoption of a preferred land use alternative by the County decision makers will be guided, in part, by what the DEIS impacts analysis revealed. See FEIS Chapter 3 for a discussion of Recommended Plan and Council Map List transportation impacts and mitigation measures including costs and revenues.

Response to Comment 9: Time Constraints to Comment and Future Opportunities to Participate The comments are noted. Please see FEIS Chapter 2 for a description of intergovernmental and public comment opportunities regarding the 10-Year Snohomish County GMA Comprehensive Plan Update. 5.2.2.5 FEIS Letter 9: City of Everett

Response to Comment 1: Opportunity to Comment and Status of Everett Plan The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 2: Everett’s Planning Area The comments regarding Everett’s Planning Goals to increase density while protecting single- family neighborhoods are noted and forwarded to the appropriate decision makers.

Response to Comment 3: Changes to FLUM with Alternatives 2 and 3 The adopted FLUM in Figure 2.4-9 currently applies MDR and HDR classifications near a commercial node at the H Street/4th Avenue intersection in the subject area. DEIS Figure 2.4-12 is amended to clarify that Alternative 2 does propose higher densities in the area south of Everett Mall Way, north of 112th Street SW, and east of Highway 99. Please see FEIS Chapter 4 for the corrected map. The Recommended Plan and Council Map List propose added HDR and Urban Village in this area though to a lesser extent than Alternatives 2 and 3 east of 4th Avenue, and south of H Street where MDR is retained. Please note that the density range of MDR does support small lot single family.

Snohomish County Comprehensive Plan 5-34 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 4: Transition from Single Family to Multifamily The comments are noted. Property owners may or may not choose to implement higher densities on their properties even when the infrastructure is in place. The County needs to provide the capacity for future growth and consider reasonable measures. The market and individual property owner decisions will determine the timing of growth.

Response to Comment 5: Public Safety Data The EIS is a nonproject programmatic document. Public safety demands are generally indicated to increase under any Alternative as population and employment increase (DEIS Section 3.2.9). Mitigation measures on page 3-351 are applicable to larger and smaller areas of development – e.g. expanding services concurrent with demand, crime prevention through environmental design principles. As noted under mitigation measures, SEPA review for project level developments would determine impacts and mitigation measures.

Response to Comment 6: Urban Commercial Designation Airport Road In developing the alternative land use maps for analysis in the DEIS, the County was looking for alternative means of accommodating the growth in population and jobs that are expected over the next 20 years, with a particular emphasis on encouraging infill through changes in land use designations. This particular site received different land use designations in each alternative, including an “Urban Commercial” designation under Alternative 2. With the population growth that the Southwest UGA will experience over that period, was reasonable to explore possible sites for additional commercial development to serve that population. In developing its final recommendations for the Recommended Plan, County staff noted the concerns about commercial development at this location and generally concurs with the commenter’s conclusions. As a result, the Recommended Plan and Council Map List retain the existing “Urban Industrial” designation for this site.

Response to Comment 7: Implementation of Urban Village Designations See Response to Comment 6 regarding the site on the east of Airport Road south of 112th Street SW. Regarding the general question regarding the definition of the Urban Village designations, the DEIS describes the Centers concepts on pages 3-219 and 3-220. Further description of implementing policies and regulations associated with the Recommended Plan are included in FEIS Chapter 2.

Response to Comment 8: Urban Village North of 100th Street SE, west of 35th Avenue SE The Urban Village shown in Alternative 3 provided an opportunity to create a node within an established neighborhood and encourage pedestrian movements instead of automobiles. Upon further review the site size and surrounding uses make an Urban Village an incompatible use at this location.

Snohomish County Comprehensive Plan 5-35 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 9: 128th Street Center and Buffers The comments are noted. The County has been developing zoning and design standards for the Urban Centers as described in FEIS Chapters 2 and 3 to provide for compatibility at the edges with surrounding uses.

Response to Comment 10: Transfer of Development Rights (TDR) The TDR receiving areas are areas subject to greater densities, and the DEIS text on page 3- 219 is clarified in FEIS Chapter 4. The TDR receiving areas have been further defined with the Recommended Plan in FEIS Chapters 2 and 3.

Response to Comment 11: Design Criteria as Mitigation Design criteria are included as mitigation in DEIS Sections 3.2.1, 3.2.2 and 3.2.4. The Design criteria for Urban Centers have been more fully developed as is described in FEIS Chapters 2 and 3. More general design criteria (to apply to developments in future annexation areas for cities) were a topic for the County/City Planning Commission forums in November 2004. Additional design policies are proposed as part of the Recommended Plan as described in FEIS Chapter 2. It is expected that implementation will occur in phases.

Response to Comment 12: Centers The comments are noted. Please see Response to Comment 9 above.

Response to Comment 13: Plan and Zoning Consistency The WAC citations on page 3-206 relate to agricultural classifications. General RCW and WAC references are made regarding plan and zoning consistency. Snohomish County reviewed the zoning map for consistency with the Future Land Use Map, as suggested. This review identified sites where changes of land use designation may be appropriate, as well as those where changes of zoning may be appropriate. The former are handled as technical adjustments to the FLUM and were included in the final map presented to County Planning Commission and County Council as part of the 10-Year Update. Where zoning changes are called for, they will be included within an “area-wide rezoning” package that will accompany or immediately follow the comprehensive plan amendments. It should be noted, however, that the area-wide rezone would not necessarily produce a 100% correspondence between land use designations and zoning on every parcel of land. The land use designation represents the long-term vision for land, whereas the zoning classification provides the current regulations. As an example, sites that are currently developed for a particular land use, but which have long-term potential for redevelopment as another land use, may not be included in an area-wide rezone. In such cases the expectation is that the owner will pursue an individual rezone at such time as the market has ripened for the redevelopment – which may not happen for many years into the plan’s 20-year time horizon.

Response to Comment 14: MUGA Boundary Status In October 2003 Snohomish County adopted Appendix B to its Countywide Planning Policies (CPPs) to reflect the results of a 2-year collaborative process of developing MUGAs (municipal urban growth areas) within the large Southwest UGA. This process involved the nine cities within the SW UGA. In March 2005, the CPPs were amended again to include a new policy (UG-17) that calls for documentation of the MUGAs in affected city and county comprehensive

Snohomish County Comprehensive Plan 5-36 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses plans. As part of its interjurisdictional coordination efforts, the County will work with cities on “gaps and overlaps” in the Southwest UGA assignment of municipal urban growth areas. The Recommended Plan addresses additional MUGA policies in the Intergovernmental Coordination Chapter of the GPP. A MUGA map is also included with the Recommended Plan.

Response to Comment 15: Status of Areas Outside MUGAs The Recommended Plan does not include substantive SW UGA expansions, and the Council Map List shows a SW UGA expansion less than Alternative 3. A MUGA map is included with the Recommended Plan and Appendix II-E of this FEIS. Also the Recommended Plan includes more interjurisdictional policies regarding MUGAs.

Response to Comment 16: Parks The County’s 2002 to 2007 capital improvement program includes several projects including a South Everett Area Community Park and Paine Field Community Park Acquisition and Improvements. Please see page 3-359 of the DEIS. Future parks would be added based on the adopted Level of Service on page 3-356 and sited based on geographic need as much as possible as indicated on page 3-357.

Response to Comment 17: Potential Transportation LOS Problems The DEIS references Technical Memorandum 3-18: Major Highway and Arterial Projects for Snohomish County which presents the results of travel forecasting and level of service analysis for various highways and arterials within Snohomish County. A number of city arterials are identified along with mitigating improvement projects drawn from city plans and programs. This memorandum was not included within the body or appendices of the DEIS because it was too voluminous. It was made available on the County’s FTP web site under Planning and Development Services, Technical Memorandum 3-18: at the time the DEIS was circulated. The memorandum identified locations, needed improvements and resulting LOS for each facility. Also see FEIS Chapter 3 for a summary of City LOS issues at a similar level of detail as the DEIS. 5.2.2.6 FEIS Letter 10: City of Gold Bar

Response to Comment 1: Target Growth and UGA Boundaries No City preference was provided at the time population was distributed initially through Snohomish County Tomorrow. The DEIS reviewed Alternatives accommodating populations in the range of 4,350 to 5,169 and employment in the range of 200 to 205 as listed in DEIS Appendix A. Recommended Plan and Council Map List future population and employment levels are included in FEIS Appendix I-A. The Recommended Plan assumes no UGA Expansion at this time due to infrastructure needs, particularly sewer, which need to be evaluated and addressed in the City’s Capital Facilities Plan. The Council Map List includes a sizeable UGA boundary expansion studied in this FEIS.

Snohomish County Comprehensive Plan 5-37 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

5.2.2.7 FEIS Letter 11: City of Mill Creek

Response to Comment 1: Accommodate Mid-Range Population without SW UGA Boundary Expansion The DEIS tested a range of infill and UGA expansion options. Regarding focus on infill versus expansion for the FEIS Alternatives, please see Letter 1, Response to Comment 5.

Response to Comment 2: Lot Yield, Plan Urban/Rural Growth Consistency Even though the County used updated density assumptions by factoring into the 2025 land capacity estimates the observed densities in single family plats recorded during 2001 and 2002 (the 2002 Buildable Lands Report used density statistics up to the end of 2000), not enough time had passed yet for the full effect of the recent changes to the lot size averaging and PRD provisions to show up at the recorded plat stage. Consequently, more empirical experience is needed with the changes to know how much higher the single-family density assumptions should be for long-range capacity estimation purposes. See also FEIS Letter 8 from the City of Bothell, Response to Comment 1, regarding lot yield and buildable lands assumptions. See FEIS Letter 3 from the Puget Sound Regional Council, Response to Comment 6, regarding urban/rural growth splits.

Response to Comment 3: Accommodate Mid-Range Population without SW UGA Boundary Expansion until Buildable Lands Report is Revised The DEIS tested a range of infill and UGA expansion options. Regarding focus on infill versus expansion for the FEIS Alternatives, please see Letter 1, Response to Comment 5. 5.2.2.8 FEIS Letter 12: City of Monroe

Response to Comment 1: DEIS Consistent with City/County Discussions and Data/Projections for Monroe The comments are noted.

Response to Comment 2: Mineral Lands Designation for Palmer Property DEIS Figure 2.4-9 is a map of the currently adopted Future Land Use Map (adopted March 2004), and does not depict the proposed Mineral Resource Overlay. Neither the Palmer Property” nor the county-owned property in the North Kelsey area is proposed for designation in the proposed Mineral Resource Overlay.

Snohomish County Comprehensive Plan 5-38 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 3: Monroe UGA Expansion West of 161st Avenue Alternative 3 reviewed a potential UGA expansion west of 161st Avenue in a designated Rural/Urban Transition area. This area is not included in the Recommended Plan and Council Map List.

Response to Comment 4: Park and Recreation Facility Demand The approved 2001 Comprehensive Parks and Recreation Plan for Snohomish County recommended a level of service for community parks to be developed by Snohomish County at one community park for every 15,000 new residents. That recommendation was affirmed and set by the Snohomish County Council in the Snohomish County Capital Facility Plan. The population increase projected for the Monroe area will support the purchase and development of community parks depending on which alternative is selected and the distribution of the new population. 5.2.2.9 FEIS Letter 13: City of Mountlake Terrace

Response to Comment 1: Support of Alternative 1 The DEIS tested a range of infill and UGA expansion options. Regarding focus on infill versus expansion for the FEIS Alternatives, please see Letter 1, Response to Comment 5. 5.2.2.10 FEIS Letter 14: City of Mukilteo

Response to Comment 1: DEIS and Comprehensive Plan/Transportation Plan Update The DEIS was intended to test a range of land use alternatives, from which a preferred alternative and ultimately policy and capital plan updates could be prepared. Please see FEIS Chapters 2 and 3 for a description and analysis of the Recommended Plan and associated Comprehensive Plan/Transportation Plan Updates as well as the Council Map List.

Response to Comment 2: Overall Countywide Population Growth The comments about the City’s preferred Urban/Rural population and employment mix are noted and forwarded to the appropriate decision makers. A discussion of the adopted County GMA Plan urban/rural population mix is provided in FEIS Letter 3, Response to Comment 6. Please also see FEIS Chapter 2 for a comparison of population and employment mixes.

Response to Comment 3: Preferred Land Use/Alternative Mix of Alternative 2 and 3 The Recommended Plan and Council Map List shows the following land designations changes in the City’s area of interest: • Area west of SR525: The downzone to 4 du/ac is proposed in the Lund’s Gulch area due to environmental and infrastructure limitations. Also public properties are identified.

Snohomish County Comprehensive Plan 5-39 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

• SR-525 and Highway 99: An Urban Center is shown. • SR-525 and Beverly Park Road: HDR is newly shown on the west, and the east side shows an expanded Urban Commercial area. The changes along SR 525 south of Beverly Park Road recognize existing commercial uses and interests identified by the City. Other existing FLUM categories, e.g. Urban Industrial, would remain.

Response to Comment 4: SWUGA and MUGAs In October 2003 Snohomish County adopted Appendix B to its Countywide Planning Policies (CPPs) to reflect the results of a 2-year collaborative process of developing MUGAs (municipal urban growth areas) within the large Southwest UGA. This process involved Mukilteo and the eight other cities within the SW UGA. In March, the CPPs were amended again to include a new policy (UG-17) that calls for documentation of the MUGAs in affected city and county comprehensive plans. Snohomish County will consider appropriate amendments to its comprehensive plan to respond to these revised CPPs within its comprehensive plan. Paine Field is a regional aviation facility that is owned and operated by Snohomish County and that serves all of Snohomish County. As such, it may be inappropriate to place this facility – in whole or in part – within the jurisdiction of any individual city by placing it within one or two city MUGAs. Snohomish County will consider whatever relevant information may be forthcoming from Mukilteo or any other source that bears on this question.

Response to Comment 5: Number of Flooding Problems on DEIS Table 3.2-53 It is true that the Drainage Needs Report (DNR) did not perform a detailed analysis of flooding problems in the Picnic Point Creek basin. Budget constraints for the DNR project required that drainage systems be prioritized and therefore did not allow for all drainage systems and streams to be analyzed. In the Picnic Point Creek basin, nearly the entire upper half of the watershed lies within the City of Mukilteo and much of the remaining unincorporated portion of the basin either has been developed or lies within critical areas. Within the unincorporated portion of the basin, it was estimated that less than five percent of the basin still has the potential to be developed. As a result, it is not expected that additional development in the unincorporated portions of the basin would create significant flooding impacts.

Response to Comment 6: Drainage Problems Paine Field Airport The DEIS is considered a programmatic EIS and did not attempt to document all flooding problems throughout the County. To a large degree, information from previous drainage studies, such as the DNR, was relied upon to document potential impacts for the three DEIS Alternatives. However, the City’s concerns will be forwarded to staff in the County’s Planning and Development Services Department for the future review of development proposals in this area.

Response to Comment 7: Drainage from Paine Field This subject has been the topic of ongoing discussions surrounding an interlocal agreement between the City of Mukilteo and Paine Field. Also see Response to Comment 6.

Snohomish County Comprehensive Plan 5-40 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 8: Drainage Plan Costs of Enclosing Drainage Ditches Current County standards do not require that existing drainage ditches be replaced by enclosed pipe systems, so this is not considered a necessary project and was therefore not included in the estimate of capital drainage costs. Regarding Picnic Point Creek, it is true that the full extent of needed capital improvements in this basin was not estimated during the DNR study due to budget constraints. Nevertheless, the County did perform some field investigations and habitat surveys in this basin during the DNR study and did recommend several projects to address identified erosion and fish passage problems.

Response to Comment 9: Streams Crossing Jurisdictional Boundaries- Picnic Point Creek During the DNR project, the County analyzed stream flows, current conditions, and capital needs in multiple basins that cross jurisdictional boundaries, including Swamp Creek, North Creek, Quilceda Creek, Allen Creek, and Cemetery Creek. Due to budget constraints, though, the County was not able to analyze flows and conditions in all streams and drainage systems. Regarding Picnic Point Creek, habitat surveys were performed on the lower reaches of the main stem and habitat and fish passage conditions were evaluated. Of the four culverts that were evaluated for fish passage conditions along the main stem, three culverts were not considered to be a barrier while the fourth culvert at Picnic Point Road was identified as a barrier and two projects were proposed to address this issue.

Response to Comment 10: WRIA 7 and 8 Boundaries You are correct that County boundaries for WRIA 7 and 8 do not match the boundaries designated by the state. The references to the WRIA boundaries will be removed from all of the groundwater figures. See Chapter 3 and 4 maps in this FEIS.

Response to Comment 11: Transportation List of 37 Arterial Units Subject to Operational Analysis and LOS Determinations Locations and detailed information for the 37 arterial units subject to ongoing monitoring by Snohomish County is provided by Snohomish County’s Concurrency Management Report last published on April 2004 and available at the Public Works Department. A table has been included in FEIS Appendix II-D. The DEIS only summarized and referenced the information in the report in order to limit the volume of text within the DEIS.

Response to Comment 12: Proposed Bike Routes Most bicycle-related improvements are associated with arterial road projects identified by Technical Memorandum 3-18, Major Highway and Arterial Projects for Snohomish County which was made available at the time the DEIS was circulated. This document along with the DEIS and Proposed Transportation Element were provided to the City by Snohomish County. The FEIS describes transportation improvements associated with the Recommended Plan and Council Map List in Chapter 3. A bicycle facilities map associated with the Council Map List shows both proposed exclusive and shared bikeways used for transportation. See FEIS Chapter 3.

Snohomish County Comprehensive Plan 5-41 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 13: Five Arterial Units with Confirmed LOS Problems The technical information requested is available from Snohomish County’s Concurrency Management Report last published on April 2004. The projects identified and analyzed within Technical Memorandum 3-18, Major Highway and Arterial Projects for Snohomish County (see web location in Response to Comment 12), are aimed at resolving operational and capacity deficiencies. Projects are presented with current and future LOS and improvements to capacity/operations where applicable. The five projects listed within Table 3.2-21 are currently identified within Snohomish County’s 6-Year Transportation Improvement Program. Design feasibility studies prepared for these projects is available by contacting the County Transportation Engineering Services for the detailed operations data cited that is beyond the scope and size of the DEIS. The 5 segments are highlighted in the table included in FEIS Appendix II-D.

Response to Comment 14: Quantifiable LOS Results Please see Technical Memorandum 3-18, Major Highway and Arterial Projects for Snohomish County, which was downloadable from the County’s web-site, for the 10-Year Update at the time of the DEIS circulation and can be requested from the County Public Works Department. This provides the detailed information requested. Please note that modeling has been completed for the Recommended Plan and Council Map List as described in FEIS Chapter 3.

Response to Comment 15: LOS for Each Project on DEIS Table 3.2-25 Please see Response to Comment 14.

Response to Comment 16: List of LOS Problem Locations on Table 3.2-23 Please see Response to Comment 14.

Response to Comment 17: Paine Field Boulevard Extension Comment noted. The City’s Paine Field Boulevard Extension Project provides mitigation to increased WSF ferry service demand through more direct access and vehicular street capacity by providing new arterial access through Japanese Gulch to the future relocated Mukilteo Multimodal Terminal. The project is well documented in the City Comprehensive Plan and has been listed in Appendix D of the County’s DEIS as project WS-47. The project is added to DEIS Table 3.2-25. Please see amendments in FEIS Chapter 4.

Response to Comment 18: Inclusion of Four New Roadways in City’s 2004 Transportation Plan The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 19: 148th Street SW The County has taken no action to officially declare 148th Street SW (35th to 52nd Avenue West) at its final design configuration. The DEIS simply identifies those arterials that are likely candidates, and that there are no current plans to enhance the arterial’s design. We apologize

Snohomish County Comprehensive Plan 5-42 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses for any confusion. Nothing would preclude the City of Mukilteo from considering an alternative design if the roadway is part of an annexation.

Response to Comment 20: Mukilteo – Clinton Ferry Route and Traffic Mitigation In order to meet and help mitigate the forecasted demand for increased ferry ridership between Clinton and Mukilteo, several regional transportation projects have been proposed in Mukilteo: The Washington State Ferry system Mukilteo Multimodal Terminal project will build a new expanded terminal near the waterfront along the BNSF tracks between Mukilteo Lane and Front St. and east of SR 525 and west of the Mt. Baker Avenue rail crossing. It will have a two-slip dock with vehicle holding capacity for two boat loads of vehicles, toll booths with HOV priority, new passenger facilities, an overhead pedestrian bridge connecting ferry, transit and rail modes, a transit center with seven bus bays, an HOV priority staging area and by-pass lanes, bike facilities with bike staging, and pedestrian promenades. Currently under design, construction will begin July 2008 with a completion in June 2010. The $133 million project was funded by the 2003 Legislative Transportation Package and previously secured funds. Appendix D of the DEIS contains a summary description of the Sound Transit Mukilteo Station Project which will build a commuter rail station in order to provide commuter rail capacity directly to the relocated Mukilteo Ferry terminal. Also, providing mitigation to increased ferry service demand through more direct access and vehicular street capacity is the City’s $116 mil. Paine Field Blvd. Extension Project, providing new arterial access through Japanese Gulch to the relocated Mukilteo Multimodal Terminal. This project is documented in the City Comprehensive Plan and has been included in the DEIS in Appendix D as project WS-47.

Response to Comment 21: Arterial Classes on DEIS Figure 3.2-3 and City Arterial Classes As pointed out, some minor discrepancies exist between the City’s and County’s functional classification map. The County periodically makes amendments to its arterial class map taking into consideration changes made to city system functional classifications. Changes that the County has found prudent have been made as shown on FEIS Figure 3.2-2, Arterial Circulation – County Council Plan.

Response to Comment 22: Improvements may be Required At 121st Street SW/Beverly Park Road and Highway 99 The 121st Street SW roadway was modeled for the Recommended Plan and Council Map List. The County will continue to look for opportunities to improve east/west arterial circulation.

Response to Comment 23: Appreciation for Opportunity Comment The comment is noted. 5.2.2.11 FEIS Letter 15: City of Snohomish

Response to Comment 1: Comments in Process Comments received as of 5 p.m. on June 18, 2004, the close of the comment period are included in this FEIS.

Snohomish County Comprehensive Plan 5-43 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 2: Support for Study of a UGA Reduction in South Snohomish The Recommended Plan identifies a UGA reduction along the South Snohomish UGA boundary identifying a Riverway Commercial Farmland Designation in place of an Urban Industrial/Airport classification. The Council Map List would preserve the current UGA boundary and keep the current Urban Industrial/Airport classification. These alternatives are addressed in FEIS Chapter 3. The factors considered for this UGA reduction in the Recommended Plan included: The proposed UGA removal is consistent with the recommended Density Fringe flood hazard designation for this area. The proposal area can readily convert to agricultural uses as there is no public investment in urban infrastructure and the existing A-10 zoning has precluded any previous urban development. 5.2.2.12 FEIS Letter 16: Snohomish County Agricultural Advisory Board

Response to Comment 1: Surface Water/Water Quality Additional text is added to section 3.2.14 (Drainage Systems) as shown in FEIS Chapter 4 to briefly summarize the findings of a study conducted by the County in 2004 regarding the impacts of upstream development upon downstream agricultural properties adjacent to Ebey Slough and Sunnyside Boulevard. A reference to this additional discussion will also be added to section 3.1.3 (Surface Water/Water Quality). While the findings from this study are not necessarily transferable to all other areas of the County, the study did attempt to evaluate the impacts of increased upstream runoff upon downstream agricultural property in this particular area.

Response to Comment 2: 100-Year Floodplain and Impacts on Farms It is true that much of the designated farmland in the County is located within 100-year floodplains. However, the three UGA alternatives in the DEIS do not propose large UGA expansions within these flood hazard areas. This is also true of the Recommended Plan and Council Map List, which show less expansion than Alternative 3. The County’s flood hazard code meets the state and federal requirements that prohibit a cumulative increase in 100-yr flood levels of more than one-foot above base levels. This standard applies to all development within the floodplain, whether located in agricultural or urban areas. Localized increases in flood levels, diversions or velocities due to development must be addressed through the County’s requirements for new development. To reflect the fact that the presence of floodplains is considered when making land use decisions for the Comprehensive Plan, a new row is added in Table 3.1-5 of the EIS to include the County’s flood hazard area regulations. Please see FEIS Chapter 4.

Response to Comment 3: Stanwood 100-Year Floodplain Issues Table 3.1-9 has been corrected and now shows the breakdown between floodplain in the County UGA versus the city portions of the UGA. Please see FEIS Chapter 4.

Snohomish County Comprehensive Plan 5-44 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 4: Percent of Land in Urban and Agricultural Use Table 3.2-1 shows the area and acreage of various FLUM categories as currently adopted as well as critical areas. Approximately 98 square miles of designated agricultural lands are included in the FLUM, and 231 square miles of UGA area estimated to be designated in the FLUM. A far greater number of rural designations, 372 square miles, and forest lands 1,425 square miles are included in the adopted FLUM. GMA considers lands of long-term commercial significance for forestry and agriculture as well as mineral extraction to be resource lands. FEIS Chapter 4 includes clarifications that agricultural lands make up nearly 5% of the FLUM designations and forestry nearly 65%. Production of peas and potatoes on bottomland soil is added to the discussion in FEIS Chapter 4.

Response to Comment 5: Right to Farm Issues The DEIS does not indicate that reclassification of farmland is insignificant in Alternative 3. In DEIS Section 3.21 the following discussion is provided: This Alternative converts about 32 acres of Riverway Commercial Farmland to urban uses… In addition, those areas that become adjacent to UGAs as a result of expansion, would experience more conflicts with urban uses and more pressure to develop at urban levels. Alternative 3, in this arena, has the greatest potential for impacts of the three Alternatives. Analysis of the FEIS Alternatives with respect to agriculture designations is found in the Relationship to Plans and Policies section of FEIS Chapter 3.

Response to Comment 6: Population/Employment/Housing As noted on page 3-237 the employment estimates excluded the category of Construction and Resources of which agriculture is a part. The contribution of agriculture to County employment is added in FEIS Chapter 4 and FEIS Appendix II-C.

Response to Comment 7: Aesthetics The DEIS is a programmatic document providing a qualitative aesthetic analysis of the change in visual character due to the Alternatives. It is not intended to provide quantitative impact analysis given the general nature of the FLUM alternatives and the range of possible implementing regulations. Your comments regarding the effect of urbanization on the County quality of life and effects upon agri-tourism are noted and forwarded to the appropriate decision makers. 5.2.2.13 FEIS Letter 17: City of Sultan

Response to Comment 1: City Recommended UGA Boundary The comments are noted and forwarded to the appropriate decision makers. The Recommended Plan and Council Map list include UGA expansions, though not of the same size and configuration as Alternative 3. The UGA proposals in the FEIS Alternatives are intended to resolve UGA/Rural split parcels, avoid some critical areas with the remainder to be regulated in the future by the City’s strong environmental regulations, and recognize areas able to be served with utilities, and support growth targets.

Snohomish County Comprehensive Plan 5-45 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

5.2.2.14 FEIS Letter 18: City of Woodinville

Response to Comment 1: Air Quality The comments are noted and forwarded to the appropriate decision makers. In the DEIS, it was stated that traffic increases due to population growth in Snohomish County would constitute a significant air quality impact only if the countywide vehicle miles traveled (VMT) greatly exceeded the assumed values used by PSRC as part of their recent regional air quality analysis and that minor variations in Snohomish County population for the Comprehensive Plan Alternatives would not alter PSRC’s conclusion that future Puget Sound regional emissions will be less than the allowable emission budgets mandated by the air quality maintenance plans. On the basis of these population and VMT thresholds, Alternatives 1 and 2 were determined to contribute emissions but that these would be consistent with the PSRC conformity analysis because: 1) the forecasted Alternative 1 and 2 countywide populations were under the PSRC population forecast, and 2) the percent change in VMT was less than the PSRC VMT percent change; and 3) while the VMT values slightly exceeded PSRC values this may be due to similar but not identical base years and traffic model assumptions; and 4) the PSRC projected emissions indicated that the four-county projected emissions would be less than the “budget.” However, for Alternative 3, it was found that the Alternative 3 population would exceed PSRC forecasted population and VMT (by 13%); therefore the DEIS stated that it cannot be concluded that future countywide emissions under Alternative 3 would not contribute to long-term regional air quality impacts. Since the issuance of the DEIS, PSRC has found a much greater “cushion” between forecasted emissions and emission budgets (80-85% cushion rather than an 18-19% cushion for the four county region). Therefore, while Alternative 3 would continue to have the higher growth levels of the alternatives tested and higher VMT relative to the other alternatives, it is not expected that the population and VMT exceedances would constitute a significant air quality impact. Regular County coordination with PSRC regarding allowable emission budgets developed by Ecology and EPA is already required under existing Transportation Conformity regulations, and would ensure that Snohomish County’s contribution to the emissions in the four-county area is considered in conjunction with other county contributions. The Recommended Plan and Council Map List would have impacts in the range of Alternatives 2 and 3 as described in FEIS Chapter 3.

Response to Comment 2: Surface Water/Water Quality and Little Bear Creek Basin Please see Letter 1, Response to Comment 3.

Response to Comment 3: Groundwater and Little Bear Creek Basin Please see Letter 1, Response to Comment 3.

Response to Comment 4: Fisheries and Little Bear Creek Basin Please see Letter 1, Response to Comment 3.

Snohomish County Comprehensive Plan 5-46 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 5: Land and Shoreline Use UMDR in SE Maltby UGA In place of the UMDR classification at this location in SE Maltby under Alternative 3, Urban Industrial is proposed in the Recommended Plan and Council Map List. Traffic impacts are identified in FEIS Chapter 3, and in a separate technical report available concurrent with the FEIS.

Response to Comment 6: Discussion of Compatibility with Woodinville Comprehensive Plan As the comment notes, the Draft EIS provides a generalized discussion of the compatibility of land use designations along the boundaries between incorporated and unincorporated areas. The Draft EIS states that while some inconsistencies exist, they are isolated and not expected to result in significant impacts. In order to provide more specific information for municipalities and the County to evaluate areas of land use incompatibility, this Final EIS includes an analysis of specific County and city land use designations at the edges between unincorporated and incorporated lands. Please refer to Final EIS Chapter 3 and Appendix I-D for this analysis and related mitigation measures.

Response to Comment 7: Bikeways on SR-9 The consistency of proposed bikeways on SR-9 related to County and City plans is noted and forwarded to the appropriate decision makers.

Response to Comment 8: Public Services – Drainage The comments regarding support for treatment of specific basins including Little Bear Creek are noted. Please see Response to Comment 2 above.

Response to Comment 9: Consideration of Comments for Preferred Alternative See Response to Comment 5 above.

Snohomish County Comprehensive Plan 5-47 December 13, 2005 10-Year Update FEIS

Snohomish County Comments and Responses

5.3 Interest Groups Interest groups, such as local nonprofit agencies, advocacy groups, etc. submitted comments on the DEIS and are listed in Table 5.3-1. Interest group letters appear following the responses to comments.

Table 5.3-1 Interest Group Comments FEIS# Log # Commenter Date 19 E208 1000 Friends of Washington (Kristin Kelly) 6/18/04 20 E226 League of Women Voters of Snohomish County (Julie Langabeer) 6/18/04 21 E358 League of Women Voters of Snohomish County (Peggy Toepel, Chair, 6/18/04 Water Issues) 22 126 Master Builders Association (Mike Pattison) 6/17/04 23 E251 Pilchuck Audubon Society (John Mauro) 6/17/04 24 147 Snohomish County-Camano Association of Realtors (Nathan Gorton) 6/18/04 25 E118 Snohomish County Committee for Improved Transportation (Deborah 6/11/04 Knutson and Richard White) 26 118 Stevens Pass Greenway (Jerry B. Schutz) 6/15/04

5.3.1.1 FEIS Letter 19: 1000 Friends of Washington

Response to Comment 1: Observations about DEIS Alternatives 1, 2 and 3 The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 2: Recommend Focusing Growth in Centers and Existing UGAS The comments are noted and forwarded to the appropriate decision makers. Please see Letter 1, Response to Comment 5.

Response to Comment 3: Maintain Levels of Service The comments are noted and forwarded to the appropriate decision makers. Please see FEIS Chapter 2 for a discussion of Plan and regulation amendments including Transportation and Surface Water. A Parks Plan update is expected to begin in 2005.

Response to Comment 4: Protect Farms and Forests The comments are noted and forwarded to the appropriate decision makers. The 10-Year Update Alternatives generally seek to avoid UGA expansions into designated farmland and forestry areas, with Alternative 3 proposing to reclass over 30 acres of designated farmland adding it to the Arlington UGA (Table 2.4-4 of DEIS). Alternatives 1 and 2 avoid designated agriculture and forestry lands.

Snohomish County Comprehensive Plan 5-49 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

In the Arlington UGA, the proposed UGA expansion near the Stillaguamish River (reclassifying Riverway Commercial Farmland) is reduced in the Recommended Plan and Council Map List in comparison to Alternative 3. In addition a proposed addition to Riverway Commercial Farmland is proposed along the South Snohomish UGA boundary with the Recommended Plan. Please see Letter 1, Response to Comment 3.

Response to Comment 5: Do Not Overdevelop Open Spaces, Farms and Forests with Capital Facilities The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 6: Do Not Allow FCC The comments are noted and forwarded to the appropriate decision makers. Please note that the Recommended Plan and Council Map List include a population reserve for a FCC. More study will be needed in later phases to establish a FCC should one or more FCC be proposed.

Response to Comment 7: Adopt Phasing Regulations The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 8: Extend SWM Fees The comments are noted and forwarded to the appropriate decision makers. Extension of SWM fees is a revenue option mitigation measure in DEIS Section 3.14.

Response to Comment 9: Higher Design Standards in UGAs; Do Not Reallocate REET The comments are noted and forwarded to the appropriate decision makers. Regarding design issues, the Recommended Plan includes design coordination policies in the Interjurisdictional Coordination chapter.

Response to Comment 10: Parks Mitigation Fees The comments are noted and forwarded to the appropriate decision makers. Parks and Recreation are addressed in the DEIS, including mitigation measures for higher impact fees. School facilities and impacts are addressed in DEIS Section 3.2.11. Parks and Schools are both addressed in the County’s Capital Facilities Plan, which must be updated periodically to ensure continuing compatibility with the County FLUM and GPP. 5.3.1.2 FEIS Letter 20: League of Women Voters, Natural Resources

Response to Comment 1: Accommodate Reasonable Growth without Destroying Quality of Life The comments are noted and forwarded to the appropriate decision makers.

Snohomish County Comprehensive Plan 5-50 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 2: Preferred Alternative and GMA Goals The comments are noted and forwarded to the appropriate decision makers. Please see Letter 1, Responses to Comments 3 and 5.

Response to Comment 3: Create Plan for Future Generations The comments are noted and forwarded to the appropriate decision makers. Please see Letter 1, Responses to Comments 3 and 5.

Response to Comment 4: Combine Alternatives 1 and 2 The comments are noted and forwarded to the appropriate decision makers. Please see Letter 1, Responses to Comment 5.

Response to Comment 5: Alternative 3 Proponents – Consider All Community The comments are noted and forwarded to the appropriate decision makers. 5.3.1.3 FEIS Letter 21: League of Women Voters, Water Issues

Response to Comment 1: Population Impacts on Water Resources – Eliminate Alternative 3 The comments are noted and forwarded to the appropriate decision makers. All Alternatives are considered in the DEIS for the range of water issues identified by the commenter. The DEIS analysis has been considered in the preparation of the FEIS Alternatives. The County Council will make choices regarding growth.

Response to Comment 2: Growth Impacts on Natural Infrastructure, Water Demand, Overflow and Overdraw The comments are noted and forwarded to the appropriate decision makers. Please note that through the EIS process, the County has solicited feedback from water service providers. Planning for land use and water services is a cooperative County effort. The County has an obligation to plan for land use in unincorporated areas and consider water service in its Capital Facilities Plan, but implementation is primarily through municipalities and special districts.

Response to Comment 3: Groundwater Depletion The comments are noted and forwarded to the appropriate decision makers. The comparison of the FEIS Alternatives to the No Acton Alternative in terms of Groundwater is included in FEIS Chapter 3. Please also see Response to Comment 3, Letter 1.

Response to Comment 4: Water Supply Systems The comments are noted and forwarded to the appropriate decision makers.

Snohomish County Comprehensive Plan 5-51 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

The listed water plans are summarized from water service provider plans. As these plans are periodically updated, they will be included in the County’s Capital Facility Plans. The County’s CFP is updated regularly to be applicable to a 6-year planning period.

Response to Comment 5: Sewer/Wastewater Please note that through the EIS process, the County has solicited feedback from wastewater service providers. Page 3-392 does indicate that several sewer/wastewater plans are out of date or have different time horizons. As these plans are periodically updated, they will be included in the County’s Capital Facility Plans. The County’s CFP is updated regularly to be applicable to a 6-year planning period. However, page 3-393 does not state that Capital Facility Planning requirements do not assure implementation. The mitigation measures list code requirements for adequate wastewater service for new development and indicate wastewater service providers prepare capital plans to meet growth projections. Capital facility plans identify planned improvements and revenue sources to fund them.

Response to Comment 6: Storm Drainage Needs The comments are noted and forwarded to the appropriate decision makers. Please also see Response to Comment 3.

Response to Comment 7: Public Costs Snohomish County has worked hard since the late 1990’s to improve the inventory of the constructed and natural drainage system. Prior to that time, the county’s inventory consisted of moderately accurate hand drawn maps taken from construction as-builts. By 2002, as an outcome of the Drainage Needs Report, a high-accuracy version of the constructed drainage system was available including reports concerning system condition. The first order of business after the completion of the DNR was to expand the annual construction program Now that work is well underway on reducing the $85 million drainage infrastructure back log (nearly $10 million of which has been currently addressed), the County is turning its attention to identifying and shaping a response to systematic repair and replacement of the aging infrastructure system. Work to both define the extent of the issue and formulate a plan of action is expected to near completion in 2006.Response to Comment 8: Not Feasible to Grow Out of Infrastructure Deficit The comments are noted and forwarded to the appropriate decision makers. 5.3.1.4 FEIS Letter 22: Master Builders Association

Response to Comment 1: Written Comments Supplement Oral Testimony The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 2: Support for Alternative 3 and Consideration of Docket Requests The comments are noted and forwarded to the appropriate decision makers.

Snohomish County Comprehensive Plan 5-52 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Please see Letter 1, Response to Comment 5 regarding UGA infill and expansion. Please see FEIS Chapter 2 for more information on growth levels, safety factors, inclusion of docket items, and other features of the Recommended Plan and Council Map List. The County Council has been considering PDS and Planning Commission recommendations and will make choices regarding growth.

Response to Comment 3: UGA Expansions – Alternative 3 11.5 Square Miles Most of the County land is in “Other Agency” ownership as shown in DEIS Table 2.4-4 – approximately 53%. It is appropriate to compare UGA expansions to designated UGA lands. The UGA expansions relative to the existing designated UGA lands (cities plus unincorporated UGA) represent 2% to 10% expansions, with Alternative 2 at the 2% level, the Recommended Plan at the 4% level, Council Map List at the 7.7% level, and Alternative 3 at the 10% level. However, expansions are not the only means of accommodating future growth since the UGAs have a substantive supply of buildable lands at urban densities as demonstrated with the No Action Alternative. To meet GMA goals, the County must demonstrate that it has used reasonable measures to increase capacity within existing UGAs before expansion. The Recommended Plan and Council Map List propose infill similar to Alternative 3. The Recommended Plan provides for limited UGA expansion more similar to Alternative 2, and the Council Map List provides for UGA expansions between Alternatives 2 and 3. Both the Recommended Plan and the Council Map List provide a reserve allocation for a FCC should additional urban lands be needed in the future. Please see FEIS Chapter 3 Relationship to Plans and Policies section for a discussion of reasonable measures.

Response to Comment 4: Design Standards To facilitate infill development in a manner compatible with various neighborhood characteristics, design standards developed in consultation with neighboring cities are a proposed policy and regulatory measure. A description of the policies accompanying the Recommended Plan is found in FEIS Chapter 2. The County Council will consider PDS and Planning Commission recommendations and determine appropriate policies.

Response to Comment 5: Employment Growth The comments are noted and forwarded to the appropriate decision makers. Please note that the Recommended Plan and Council Map List include employment in the range of 345,000 to 350,000 similar to DEIS Alternatives 2 and 3.

Response to Comment 6: Impervious Surface Limits Measures to decrease impervious surface, such as low impact development, are intended to retain the allowable density under standard development approaches, but cluster development and utilize natural drainage systems. A description of the policies accompanying the Recommended Plan is found in FEIS Chapter 2. Future development regulations implementing policies such as promotion of low impact

Snohomish County Comprehensive Plan 5-53 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses development would be the subject of phased environmental review in addition to public participation efforts. The County Council has been considering PDS and Planning Commission recommendations and will determine appropriate policies.

Response to Comment 7: Enforce Existing Regulations Before Enacting New Ones Groundwater regulations are not fully in place in Snohomish County following the adoption of the Groundwater Management Plan. See also Response to Comment 6.

Response to Comment 8: Implementation of WRIA Plans WRIA plans address more than restoration of degraded areas, as they also address protection of remaining resources. A description of the policies accompanying the Recommended Plan is found in FEIS Chapter 2. Future development regulations implementing policies such as promotion of WRIA plans would be the subject of phased environmental review in addition to public participation efforts.

Response to Comment 9: Buffer Sizes The County Critical Areas Regulations Update is under preparation in a separate process as noted on pages 3-2 and 3-3 of the DEIS. The DEIS and FEIS assumed implementation of the current adopted CAR.

Response to Comment 10: Greater Impacts Under Alternative 3 The comments are noted and forwarded to the appropriate decision makers. Please also see Response to Comment 3 regarding the County’s need to demonstrate reasonable measures are taken before the UGA is expanded.

Response to Comment 11: Offsite Mitigation The comments are noted and forwarded to the appropriate decision makers. The County Critical Areas Regulations Update is under preparation in a separate process as noted on pages 3-2 and 3-3 of the DEIS. The regulations typically specify allowances for onsite and offsite mitigation.

Response to Comment 12: No Net Loss of UGA Boundaries DEIS page 1-33 lists potential mitigation measures to resolve Plan and Policy conflicts. The idea of no net loss of UGA land in the context of the FLUM alternative selected by the County is a policy issue. The comment is acknowledged and forwarded to the appropriate decision makers.

Response to Comment 13: Alternative 3 Residential Dwellings The comments are noted and forwarded to the appropriate decision makers. Please refer to FEIS Chapter 3 for a discussion of housing units under the Recommended Plan and Council Map List, which overlap the ranges of housing projected by Alternatives 2 and 3.

Snohomish County Comprehensive Plan 5-54 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 14: Design Standards and Aesthetic Review The comments are noted and forwarded to the appropriate decision makers. Please refer to Response to Comment 4.

Response to Comment 15: Transportation The number of arterials that can drop below the County’s level of service (LOS) standards is not the only measure by which the County will judge the practicality or cost-effectiveness of serving proposed land use alternatives. Besides LOS, the County also needs to consider the miles of new or improved arterials needed to provide access and circulation for proposed UGA expansions under each alternative. Alternative 3 requires a 20+ miles of arterial roadway mileage over and above Alternatives 1 and 2. The additional cost of about $265 to $300 million, associated with the additional arterial mileage, will need to be weighed against the additional growth that Alternative 3 will accommodate. Also see FEIS Chapter 3 for a discussion of transportation implications and the Recommended Plan and Council Map List.

Response to Comment 16: Police/Fire/EMS The information submitted is part of the record. The DEIS noted that future development as a whole would likely enhance the tax base and revenues available to affected jurisdictions and special districts providing emergency services. The DEIS does not quantify the costs and revenues associated with each alternative with respect to emergency services that are provided by multiple agencies. Some limited capital cost information is included (e.g. roads, parks, surface water). Fiscal information is not required to be included in an EIS.

Response to Comment 17: Park Fees The comments are noted and forwarded to the appropriate decision makers. Park impact fees allow growth to partially contribute to new park facilities for which growth creates a demand. Impact fees cannot, by law, pay the entire cost of providing park facilities. Impact funds are matched with other dollars in order to provide park facilities. Alternatives to park impact fees are available to developers as outlined in SCC 30.66A.

Response to Comment 18: Infill in Alternative 3 The comments are noted and forwarded to the appropriate decision makers. Please refer to Response to Comment 3.

Response to Comment 19: Water Systems The comments are noted and forwarded to the appropriate decision makers. Because the analysis is programmatic and cumulative, it is noted on DEIS page 3-381 that water supply capabilities should be continually monitored. Capital facility planning is a way to accomplish regular coordinated planning with the various service providers.

Response to Comment 20: Sanitary Sewer The comments are noted and forwarded to the appropriate decision makers. Please note that the analysis indicates that sewer/wastewater plans are out of date or have different time horizons. As these plans are periodically updated, they will be included in the County’s Capital

Snohomish County Comprehensive Plan 5-55 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Facility Plans. The County’s CFP is updated regularly to be applicable to a 6-year planning period.

Response to Comment 21: Telecommunications The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 22: Alternative 3 UGA Expansion of 11.5 Square Miles Please see Response to Comment 3.

Response to Comment 23: Regularly Update Inventory of Buildable Land The Buildable Lands Report was prepared in accordance with State legislation and local guidance of Snohomish County Tomorrow. It will be updated on a regular basis as required by GMA.

Response to Comment 24: FLUM Changes Please see Response to Comment 3.

Response to Comment 25: Growth Not Solely Accommodated by Intensification Please see Response to Comment 7 under FEIS Letter 3 Puget Sound Regional Council and Letter 1, Response to Comment 5.

Response to Comment 26: Critical Areas Regulations Review The County Critical Areas Regulations Update is under preparation in a separate process as noted on pages 3-2 and 3-3 of the DEIS.

Response to Comment 27: Stream Buffers are Adequate Please see Responses to Comment 26.

Response to Comment 28: Buffer Expansions Reducing Buildable Lands See Responses to Comment 26. Through the separate review of critical area regulations, the County will consider the impacts to land. Please also note that the various EIS Alternatives include safety factors including the Recommended Plan and Council Map List.

Response to Comment 29: Added Lakes Regulations Not Needed Please see Responses to Comment 26.

Snohomish County Comprehensive Plan 5-56 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 30: Oppose Bigger Buffers; Avoid Strict No Touch Regulations Please see Responses to Comment 26.

Response to Comment 31: Percent of Urban Land Please see Response to Comment 3.

Response to Comment 32: Alternative 3 More Intense Urban The comments are noted and forwarded to the appropriate decision makers. Please see Response to Comment 3.

Response to Comment 33: Oppose Design Criteria The comments are noted and forwarded to the appropriate decision makers. Please refer to Response to Comment 4.

Response to Comment 34: Support for TDR That Is Market Driven The comments are noted and forwarded to the appropriate decision makers. Please see the TDR elements associated with the Recommended Plan and Council Map List as described in FEIS Chapter 2.

Response to Comment 35: Land Committed to Urban Development – Not An Adverse Impact While it is true that commitment of land is important for housing and economic reasons (addressed in DEIS Section 3.2.3), the purpose of the EIS is to describe environmental impacts including to the built environment. In terms of the built environment, commitment of land to urban uses of various types is a long-term unavoidable impact because the type and amount of land committed limits flexibility and is fairly “permanent”. While it may depend on the community perceptions whether the commitment of the property is adverse, it is irreversible for the long- term and unavoidable.

Response to Comment 36: Expansion in Alternative 3 Wouldn’t Undermine Infill Alternative 3 would significantly expand UGA boundaries. Development on “greenfields” can be easier than redevelopment, making infill in existing urban areas relatively less attractive. Demonstrating reasonable measures to accommodate infill is a GMA requirement. Please see further discussion in FEIS Chapter 3.

Response to Comment 37: Reducing UGA Lands Only Where There Is Corresponding Increase See Response to Comment 12.

Snohomish County Comprehensive Plan 5-57 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 38: Housing Costs Due to Impact Fees and Utility Fees The County considers housing policies in its Housing Element, and regularly monitors affordable housing issues in the Growth Monitoring Report and periodically in more depth such as the 2002 Housing Evaluation Report. A fair share housing allocation is estimated in Chapter 3 of this FEIS. Each jurisdiction will consider the best means to balance provision of services to new growth and the need for affordable housing consistent with a balancing of GMA goals. Since potential traffic impact fee increases are under consideration, the issue of impact fees and affordability is described in FEIS Chapter 3.

Response to Comment 39: Disagree that Land Supply Does Not Affect Housing Affordability The DEIS analysis on page 3-251 does not suggest that land supply never affects housing prices. It indicates that there is a projected 11% land supply safety factor, which would indicate that land supply would not affect land prices. Each Alternative has a safety factor related to its target population growth. Through its annual Growth Monitoring Report, annual Comprehensive Plan docket process, and Comprehensive Plan review every seven years, if land supply is projected to be a factor affecting housing supply and affordability, the County can address it.

Response to Comment 40: Oppose Land Development Phasing DEIS Table 3.2-32 presents several possible measures for County consideration that could help balance land use, financing and LOS given funding shortfalls, including development phasing. Associated with the Recommended Plan are proposed policies and regulations that are described in FEIS Chapter 2. A countywide Development Phasing Overlay is not proposed as part of the Recommended Plan. The DPO in Lake Stevens is due to sunset; the DPO mechanism will remain in place but is not identified for application to a particular area once the DPO sunsets in Lake Stevens.

Response to Comment 41: Increased Impact Fees (Transportation) The comments are noted and forwarded to the appropriate decision makers. A range of mitigation measures is offered to address transportation impacts including transportation impact fee increases, which allow growth to contribute to facilities for which it creates a demand.

Response to Comment 42: Ball fields The County Council recently adopted an ordinance allowing ball field use of agriculturally zoned property provided it is not designated agricultural land. Additionally, park land may be made available through the PRD process if the land is made available for public recreation and the land addresses one of the needs outlined in the Snohomish County Comprehensive Parks Plan. If this land is accepted by the Parks Department, the value of that land, and any facilities provided by the developer, may be used to offset a portion of the required Park Mitigation Fees. The ability to receive credit for onsite recreation facilities is considered in park impact fee regulations.

Snohomish County Comprehensive Plan 5-58 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 43: Parks Fees Please see Responses to Comments 17 and 42.

Response to Comment 44: Water Demand The comments are noted and forwarded to the appropriate decision makers. Please also see Response to Comment 19.

Response to Comment 45: Little or No Increase in Flooding in Alternative 3 For the basins studied, Alternative 3 showed slight increases in flooding problems in some basins and no increases in flooding problems in other basins. Little Bear Creek basin was an exception and indicated more significant increases in flooding, as noted on DEIS page 3-417.

Response to Comment 46: Appreciation for Consideration and Desire to Continue Participation The comments are noted and forwarded to the appropriate decision makers. 5.3.1.5 FEIS Letter 23: Pilchuck Audubon Society

Response to Comment 1: Earth, Topography, Soils, Erosion Because the DEIS is nonproject, programmatic, and areawide in nature, given the 20-year planning horizon, it is not possible to identify specific cases where erosion-driven sedimentation, water quality, and flooding impacts would occur. The DEIS does call out areas of erosion hazard on page 3-6 and potential water quality and flooding impacts on pages 3-52 to 3-63. As noted in the comment, the risk of these impacts would generally increase with increased density of development or impervious surface. Regardless of which alternative is implemented, the County would apply critical area – erosion hazard, stormwater, and flood hazard regulations to reduce impacts.

Response to Comment 2: Air Quality It is unlikely that localized alterations of traffic patterns caused by roadway improvements would adversely affect air quality. Even if improving roadways in one part of the County attracted vehicle traffic away from other locations, it is unlikely this would cause any significant air quality impacts. Transportation air quality impacts in the Puget Sound region are commonly grouped into two categories: local "hot spot" impacts associated with CO emissions at individual congested intersections; and regional impacts associated with summertime ozone concentrations in southern King County caused by the combined emissions from the entire Puget Sound region. The local "hot spot" impacts would not be significantly impacted by localized roadway improvements. If any municipality proposes to improve their roadways they must first conduct localized CO "hot spot" modeling. If the hot-spot modeling predicts any future CO exceedances, the municipality must commit to mitigation measures before the projects are funded. The issue of regional impacts would probably not be affected by localized road improvements. If a municipality improves one roadway, that might cause drivers on other nearby roadways to alter their routes by several blocks to take advantage of the new improvements. That might alter traffic patterns within a localized area (e.g., within a one-mile

Snohomish County Comprehensive Plan 5-59 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses radius) but it would not significantly change cumulative driving patterns or cumulative emissions within the entire Puget Sound region.

Response to Comment 3: Surface Water It is believed that changes caused by new development to stormwater flows and land cover, and their associated impacts, can be partially mitigated, but not completely mitigated given the information known, for the reasons cited under Response to Comment 5, FEIS Letter 2, Department of Fish and Wildlife. Because the DEIS is nonproject, programmatic, and areawide in nature, given the 20-year planning horizon, precise levels of impervious surface increases and the effectiveness of programmatic mitigation measures is not proposed at this level of review. The DEIS lists a number of potential mitigation actions, including the possibility of limiting the amount of impervious surface that is allowed for new development

Response to Comment 4: Groundwater The impact analysis for the groundwater assessment was limited to a screening level landscape analysis that identified areas of concern at a sub-basin scale. Projecting long term impacts to groundwater is very complex and requires additional site specific analysis that is beyond the scope of a DEIS of this scale. Little Bear Creek was identified as the most likely area to experience measurable impacts to groundwater quality and quantity from Alternatives 2 and 3. Specific quantification of the magnitude of these impacts requires additional analysis. Specific impacts in other sub-basins would similarly require additional analysis. The DEIS acknowledges that significant impacts may occur and provides general guidance for Snohomish County to implement monitoring and mitigation activities prior to initiating development. Also see the updated groundwater analysis in FEIS Chapter 3 and Appendix I-C.

Response to Comment 5: Plants, Animals, Vegetation, Wetlands, Wildlife, and Fisheries The nature and application of yet-to-be developed plans and policies is not fully known – such as the extent to which critical area regulations will be updated by County decision makers, the restoration and no-net-loss policies and regulations of the future Shoreline Master Program, the implementation of Draft WRIA Plans that are programmatic rather than regulatory, etc. Therefore several mitigation measures in the DEIS Natural Resources Sections recommend strategies to avoid UGA expansion in the more sensitive areas of the County in addition to recommended increased regulatory guidance. Direct impacts to protected critical areas should be mitigated by County critical area regulations and requirements for no-net-loss of functions and values, particularly as these regulations are updated to address Best Available Science. The extent to which indirect and/or cumulative impacts (such as effects of runoff on water quality) could be reduced or offset will depend on the County’s implementation of revised critical area and shoreline regulations, restoration plans, and regional watershed plans. The level of significance of impacts would be more precisely determined through environmental reviews of regulation and plan updates underway, as well as through project-specific environmental review.

Response to Comment 6: Land and Shoreline Use The DEIS analysis identifies the locations at which some alternatives affect designated agricultural lands and mineral lands.

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• The analysis shows that none of the DEIS Alternatives propose reclassification of designated forest lands. (No Action p. 3-190; Alternative 2 p. 3-194; Alternative 3 p. 3-199) • Alternative 3 proposes to reclass over 30 acres of designated farmland adding it to the Arlington UGA. (p. 3-199) • Based on earlier mineral lands mapping Alternatives 2 and 3 were thought to affect some mineral lands as described in the Land Use Section and Relationship to Plans and Policies sections (p. 3-194 and 3-199). However, Please see response to Comment 3, Letter 1. Mitigation measures suggest avoidance of designated resource lands, not only design and aesthetic review (p. 3-201). Where avoidance is not selected by decision makers, then compliance with de-designation criteria is needed (see DEIS Section 3.2.2). For a description of the Recommended Plan and Council Map List effects related to designated resource lands, please see FEIS Chapters 2 and 3. Generally, these alternatives reduce agricultural conversion in comparison to Alternative 3 and do not affect mineral lands.

Response to Comment 7: Aesthetics Aesthetic analysis of the 20-year long-range plan is programmatic and qualitative. It is not intended to be quantitative. The analysis for the No Action referenced by the commenter states: In the rural areas, continued low-density development may result in a more built-out large-lot pattern, with a corresponding decrease in the open pastoral visual appearance that currently characterizes much of the rural area. In general, however, potential impacts to visual character are not expected to be significant. The open, low-density character of the rural area would continue and would be visually distinct from the urban areas and RUTAs. The commenter appears to be addressing rural cluster developments. Rural clusters are required to cluster to preserve open space or in the case of the RUTAs preserve future urban development options. Rural clusters in proximity to UGAs and noticeable by more persons would occur in RUTAs, which constitute a small area relative to the total rural classification (37 square miles versus 335 net square miles per DEIS Table 3.2-1, less than 10% of the total 372 square miles of rural land). Given the size of the rural area, the overall conclusion, that rural level development would be at a level not expected to significantly affect low-density character, appears appropriate.

Response to Comment 8: Transportation While increased travel demand can be mitigated to the County’s selected levels of service by a range of options related to land use, alternative modes, and road improvements, the increase in traffic itself is anticipated to be a significant unavoidable impact of growth. Please see the clarified discussion of Significant Unavoidable Impacts in FEIS Chapters 1 and 4. The traffic forecasting model used to generate traffic volumes for the alternatives is based on trip decisions, which reflect current trends in TDM, concurrency management, and CTR consistent with regional modeling efforts. The programs traditionally reduce vehicle trips by less then 5 to 10%. For the DEIS alternatives, the magnitude of the roadway improvements is based on maintaining existing level of service standards.

Response to Comment 9: Energy The energy analysis is programmatic consistent with the nonproject nature of the Comprehensive Plan Update. To the extent that data is available at this broad review level, such

Snohomish County Comprehensive Plan 5-61 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses as reporting VMT for each alternative, they are included. Mitigation measures do get at the concept of compact growth, such as “centers” (see DEIS page 3-338). With the amount of population growth expected it is likely that energy demands will increase. Managing the growth such as focusing growth in centers is likely to reduce the potential demand for energy but not completely abate the demand. That is the intent of the conclusions under Section 3.2.8.4.

Response to Comment 10: Police, Fire, and EMS Compact growth can be designed in a manner to reduce impacts to public safety services. This is recognized in the analysis and mitigation measures (growth in an area with existing services, DEIS page 3-348; crime prevention through design, DEIS page 3-351). The DEIS notes that compact growth in urban areas can be more easily served by existing facilities and services. However, recognition of congestion is also important (for example, SR- 522 in Lake Forest Park, Kenmore, and Bothell where the corridor is at ultimate capacity and emergency access in the urban corridor is critical): The smaller travel distance needed to respond to service calls within urban areas would help to keep emergency response times low. However, traffic congestion in more urban areas may also tend to increase response times (or require more personnel and equipment to maintain existing response times). The public service analysis is programmatic consistent with the nonproject nature of the Comprehensive Plan Update, and due to the variability in location of growth and the ability of the various districts and municipalities to respond. Mitigation measures address the need for greater planning and coordination. The Comprehensive Plan was amended in late 2004 to include a fire protection level of service based on fire flow, a consistent measure regardless of the service provided.

Response to Comment 11: Parks Unavoidable impacts are that there will be an increased park demand and increased capital, maintenance, and staffing costs. It does not state that the County will be unable to meet a level of service to provide services to meet the demands. This is clarified in FEIS Chapter 4.

Response to Comment 12: Prioritize UGA Infill over Expansion Recommendations are noted and forwarded to the appropriate decision makers. Snohomish County has evaluated potential “infill” sites and UGA expansions by considering the goals of the GMA, as well as the direction provided by the Countywide Planning Policies and the General Policy Plan. Please see Letter 1, Response to Comment 5 regarding UGA infill and expansions with the Recommended Plan and Council Map List. Please also see FEIS Chapter 2 for a description of map and policy aspects of the Recommended Plan. Some of the recommendations can only be partially addressed in the GPP – such as the siting of major public facilities – because Snohomish County may only regulate the location of facilities built by other public agencies, such as school districts and utility districts. Several recommendations are already addressed in various GPP policies that are expected to remain largely unchanged – such as the policies addressing UGAs and those addressing urban centers. Snohomish County can more easily control the siting of facilities that it will own and operate, such as solid waste transfer or disposal facilities, correctional facilities, etc. Implementation program actions, such as modifications to the zoning map and zoning regulations will also be considered to further increase the estimated holding capacity of the land.

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Response to Comment 13: Greater Resources and Focus on Urban Centers Recommendations are noted and forwarded to the appropriate decision makers. The Urban Center concept is reflected in all of the studied alternatives including the No Action Alternative. Many of the Society’s suggested recommendations are being incorporated into Urban Center Program The approach for the Urban Centers was to first determine appropriate locations and designate them with a circle (this was done in 1995 with the adoption of the Comprehensive Plan). Second, for each circle parcel specific boundaries would be drawn to identify the area encompassing the urban center (this was done in 2003 for 164th St/I-5 and is proposed in all action alternatives for 128th, 164th, SR 527 and two centers on SR 99). Third, for each delineated urban center a conceptual master plan would be completed that outlined the specific location of the various uses and identified local road and pedestrian improvements (this is in progress for 164th). Lastly, code amendments would be adopted to guide the orderly development of the urban center developments (the urban center demonstration ordinance currently accomplishes this step; the regulations are proposed for amendment with the Recommended Plan). The County is currently working with citizens on the 128th Street Urban Center. More information about the County’s program can be found at http://www1.co.snohomish.wa.us/Departments/PDS/Divisions/LR_Planning/Projects_Programs/ Urban_Centers/.

Response to Comment 14: Transportation Choices and “Fix-It-First” Approach Recommendations are noted and forwarded to the appropriate decision makers. Table 3.2-32 is provided in the DEIS to show a range of policy choices related to land use, revenues, and levels of service. Coordinated transit service is addressed on page 3-309 of the DEIS. These choices are considered further in the Recommended Plan in proposed policies and regulations. Please see FEIS Chapter 2. Regarding the commenter’s statement of the County’s focus on road projects, please note the County’s balanced program of expenditures includes: operations, maintenance, small-capital projects as well as larger arterial-capacity projects. Small capital projects include safety improvements, operational improvements, and pedestrian improvements.

Response to Comment 15: Prioritize Investment in Most Applicable Tools Recommendations are noted and forwarded to the appropriate decision makers. Regarding resource lands, please see Response to Comment 6. Regarding FCC planning, Alternative 3,the Recommended Plan, and the Council Map List include a population reserve for a FCC (please see FEIS Chapter 2 for policy and regulation proposals). More study will be needed in later phases to establish a FCC should one or more be proposed. It should also be noted that the Recommended Plan and Council Map List have a greater emphasis on infill than other alternatives. The Recommended Plan and Council Map List propose UGA expansions in the range of Alternatives 2 and 3 with the Recommended Plan closer to Alternative 2 and the Council Map List closer to Alternative 3.

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Response to Comment 16: Precautionary Principle in Planning Future Growth Comments are noted and forwarded to the appropriate decision makers.

Response to Comment 17: Consider Recent Demographic Data The DEIS alternatives, the Recommended Plan, and the Council Map List are consistent with the range of population endorsed for study by Snohomish County Tomorrow (see DEIS Appendix A). The OFM low range population is less than the OFM “most likely” estimate and less than the “No Action” as well as under the Snohomish County Tomorrow range. As noted on page 2-23 of the DEIS, “[t]he SEPA-Required No Action Alternative represents the Low Alternative considered in the Draft EIS. The lower number of 795,725 is less than the amount of the population that can be accommodated within the current UGA boundaries at the year 2025.” The County conducts annual growth trend analysis, and based on that review, the County is likely to achieve its original GMA target of 712,000 (increased to 714,000 when the Lake Stevens Subarea Plan was adopted). The County is considering alternative population levels both below and above the “most likely” population figure, but not below its adopted plan capacity. If growth should slow the County has opportunities annually and periodically as required by GMA to review its plan and implementing regulations to adjust accordingly.

Response to Comment 18: Strengthen Development Regulations Comments are noted and forwarded to the appropriate decision makers. Please also see the description of the Recommended Plan in FEIS Chapter 2 regarding some implementing regulations.

Response to Comment 19: Citizen Input The County’s summary of the PDS stakeholder interviews in 2003 is available from the Planning and Development Services Department. The comment also appears to summarize public workshops in May 2004 where the DEIS Alternatives were reviewed by citizen participants for potential amendment towards a preferred alternative. A summary of the public workshops was presented at a Joint Planning Commission and County Council meeting on June 29, 2004. The overall “Alternative” preference of citizens attending the three workshops in Lynnwood, Monroe, and Arlington was Alternative 1, No Action. Some preferences varied by location. For example, Alternative 2 was most preferred in Monroe. Alternative 1 and Alternative 3 were nearly equally supported in Arlington. Participants also filled out a questionnaire. Infill (increased densities in current urban growth areas) was favored over a combination of infill and expansion, 52.7% to 47.3%, respectively. The FCC concept received relatively less attention at the workshops, with comments varying from how a FCC could be integrated into the plan to those who did not favor a FCC.

Response to Comment 20: Conclusion The comments are noted and forwarded to the appropriate decision makers.

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5.3.1.6 FEIS Letter 24: Snohomish County – Camano Island Association of Realtors

Response to Comment 1: Support for Alternative 3 The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 2: Housing Affordability The DEIS does not state that net migration is the sole cause of housing price rise, nor does it state that growth controls have no effect on housing costs. The DEIS demonstrates that there is a strong and statistically significant correlation between net migration and housing costs, and that price increases were greater during the 1970s, before GMA than during the 1990s, after GMA was instituted. The DEIS shows the historical housing price experience in housing costs from the 1970s to 2000 in Snohomish County. Artificial restriction in land supply may, as the comment states, cause, or correlate with price increases when demand exceeds capacity. Alternative 2 increases capacity of the existing UGA by raising the intensity of land use on 3.5 square miles, principally residential, and by modestly expanding UGA boundaries by 2.4 square miles. In combination, the capacity for housing units increases under Alternative 2 by as much as 33,063. Alternative 3 increases intensity on 6 square miles of “infill” and expands the UGA by 11.5 square miles over Alternative 1 (the no- change alternative), increasing the capacity for housing units by 60,769. 1 Another factor in the demand-supply relationship is location. Land supply would be “artificially restricted” only where demand exists. By definition, the UGA is a quantity of land sufficient for 20 years of development, and by design it is the land most likely to develop as well. Moreover, because the UGA is updated no less than every ten years (and there are substantive reviews every seven years), it is expected that the 20-year supply of UGA will not come near to exhaustion. It is therefore unlikely that the GMA takes much “buildable” land out of the supply for housing. And while land outside the UGA is typically less expensive than land inside the UGA, it is also true that extending urban roads and utilities to land outside the UGA is more expensive2. Staley and Gilroy’s paper is one of many research or argumentative papers on the subject of the impacts of urban growth boundaries on housing affordability, and has been critiqued for methodological issues. The Staley and Gilroy paper along with others relevant to Washington State are summarized below: • Daniel M. Warner, in November 2004 published a brief called “The Growth Management Act and Affordable Housing” for the American Planning Association. His conclusion was “it is very difficult to determine whether increases in housing costs can be attributed to growth- management controls. The best that comes out of any of these studies — including the

1 The highest projected number of new housing units under Alternative 2 is 358,442. The lowest projected capacity of new units under Alternative 1 is 325,379. The difference is 33,063. The highest projected number of new housing units under Alternative 3 is 386,148. The difference between this and the lowest projection under Alternative 1 is 60,769. 2 See, for example, “The Costs of Sprawl—Revisited,” Robert Burchell, et al. TCRP Report 39 of the Transportation Research Council (1998); “The Costs of Sprawl—2000,” Robert Burchell, et al. (2002); and “Summary of the Fiscal Impacts of Compact Development,” Snohomish County PDS staff report submitted to Snohomish County Council (September 2005).

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Washington Policy Center — is that growth control may have some modest effect but that mostly, it is not growth controls that drive housing costs up, it is growth — population increase.” He also indicated some possible responses: “There are various responses — if not solutions — to the problem of affordable housing. These include inclusionary zoning (requiring all new developments to have some percentage of housing geared to lower- income buyers — perhaps impact fees on those properties could be reduced); linkages (requiring the new commercial development contribute to an affordable housing fund or build suitable nearby housing); promoting community land trusts (typically a nonprofit entity that buys land and builds low-rent housing); flexible residential zoning (permitting granny flats). Allowing everything to be built up like Los Angeles is not a reasonable solution. Opening up large areas of vacant land for development would in no way solve the problem of affordable housing.” • The Washington Research Council (WRC), a public policy organization governed by business leaders, has noted that restrictive growth policies in the face of rising housing demand may contribute to a decline in home ownership and an increase in housing unaffordable to average-income families. Recent suggestions in a policy brief by the WRC (PB02-9, May 23, 2003), to provide for affordable housing include: Infill Development – involves directing a substantial share of new housing into existing urban areas. Nearly universally accepted, this approach has a number of advantages including, providing additional housing opportunities near downtowns, encouraging community revitalization, reducing sprawl, reducing auto-dependence, and providing public infrastructure (water, sewer, communications, etc.) more efficiently to more densely populated areas. Smart Growth – projects that incorporate mixed uses, with high density housing located over street-level retail, zero lot lines, alleys possibly, which allow garages and cars to be moved out of sight and encourage community interaction, are increasingly being accommodated by local communities around the state. Buildable Land – definitions (vacant land, under- or partially-used land, and land that is not affected by environmentally sensitive constraints like steep slopes or wetlands) and inventories that help to ensure a sufficient supply of land within the urban growth area, necessary to accommodate projected growth. • The Washington State Office of Community Development (OCD), in its Affordable Housing fact sheet March 2002, acknowledged the debate on the influence of GMA requirements and housing prices. “Recently, some people have asserted that urban growth areas are restricting the supply of available land and, therefore, increasing the costs of housing. However, others contend that many urban growth areas contain far more than the required 20-year supply of urban land, thereby reducing the amount of rural and resource land. Many other factors, often overlooked in the affordability issue, are more directly and dramatically increasing the costs of housing. They include the following: Economic growth is usually associated with higher housing prices. Lumber prices have risen sharply. The average size of a housing unit has nearly doubled in the last 40 years. Lot sizes have increased since the 1940s (from 3,000 to 5,000 square feet to 7,000 to 10,000 square feet). Building codes are stricter to ensure safety and energy efficiency. Building permits often take longer to obtain in high-growth communities. Developers have a greater incentive to build “higher-end” housing since the profit margin is greater than for affordable housing.”

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OCD notes that options to encourage affordable housing range from allowing a variety of housing types and densities, providing density bonuses or minimum densities, encouraging infill, promoting mixed uses, and several other measures. • The Reason Public Policy Institute (RPPI) based in California published a study of affordability in three states that require growth management planning, Washington, Oregon and Florida. The study was published in December 2001. Following a regression analysis, the authors concluded that the longer a County planned under Washington State’s GMA, the faster housing prices increased, accounting for 26 percent of the estimated growth in housing prices. From 1990 to 1995, housing prices increased by 16.9 percent, or 3.4 percent per year. According to the study, Washington State’s GMA may have added about 0.7 percentage points to the housing inflation rate for each year the County had a comprehensive plan in place. Based on the estimates from the statistical analysis, housing prices would have increased 2.7 percent per year without the effects of the GMA. • Some critiques of the RPPI study by 1000 Friends of Washington (now Futurewise), a public policy group that monitors GMA, included that counties fully planning under GMA and non- GMA counties are too different to conclude that changes in housing costs are due to the GMA; the RPPI study did not account for significant increases in home size and home quality in many Washington counties during the 1990s; and the RPPI study did not consider the public costs of development, noting that one analysis in Oregon estimated that each single-family home receives a $12,000 subsidy from taxpayers even after impact fees and tax revenues were considered. • The Washington State Land Use Study Commission reviewed the impacts of GMA on housing affordability. Their 1996 Annual Report noted the interest and concern in the issue of land supply and housing costs: The Annual Report discussed that there are many reasons that contribute to the cost of housing, including: the cost of land, population growth rates, the health of the economy, interest rates, income and employment based on a wide variety of sources.3 The Land Use Study Commission also provided a summary from a Washington State specific study: Growth Management in Washington State: Impact on Affordable Housing, Washington State University Center for Real Estate Research, p. 91 (1995). That report indicated that “Changes in the [affordability] indices over time cannot be attributed solely to the GMA. Prevailing interest rates may be the single most significant factor affecting the affordability of all housing, including affordable housing. The impact of external economics on interest rates are beyond the reach of any government activity. Also, change in home prices and incomes are related to local market pressures, which may result in price changes which do not allow GMA impacts to be isolated.” (p. 86). • Analysis of academic research on the house price effects of Portland's urban growth boundaries indicates that that region has managed growth in such a way that 20 years of land supply is sufficient to maintain reasonable levels of house price inflation; i.e. no worse 3 “Housing Market Takes Off: Boeing’s surge, bustling economy push prices up,” Puget Sound Business Journal (10- 25- 96); “Through the roof again?,” Seattle Times (11-17-96); “Growth Controls: policy analysis for the second generation,” Peter Navarro and Richard Carlson, 24 Policy Sciences 127-152(1991); “Must Growth Restrictions Eliminate Moderate Priced Housing,” Thomas I Miller, 52 Journal of the American Planning Association 319- 325(1986); “The Impact of Interest Rates, Income, and Employment upon Regional Housing Prices,” Alan K. Reichert, 3 Journal of Real Estate Finance and Economics 373-391 (1991); “Urban Land Supply: Natural and Contrived Restrictions,” Louis A. Rose, 25 Journal of Urban Economics 325-345 (1989); and “The Effects of Land- Use Constraints on House Prices,” Henry O. Pollakowski and Susan M. Wachter, 66 Land Economics 315-324 (1990).

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than without growth management. This is relevant to Washington because it is the most extensive source of research pertaining to a system of growth management like that of Washington State. 4 • A literature review on this subject, prepared by County staff and presented to the County Council in September 2005, examined over 100 peer-reviewed studies and found that there is no conclusive support for a growth management effect on house prices. These studies lead us to conclude that the house price effects of urban growth boundaries are very hard to isolate, and that restricting land supply to 20 years of growth is unlikely to have a great impact on house price inflation.5

Response to Comment 3: Current Inventory County records indicate that new lot production (3,381 lots through September 2004) is running 237% of last year, 254% of 2002, and 645% of 2001 recordings. The UGA has not changed significantly during that period. Clearly, the UGA inventory of platted but undeveloped lots has little to do with the size of the UGA, especially when the UGA contains 12,000 acres or more designated for residential growth in the unincorporated area alone.6 The DEIS demonstrates that all three alternatives are sufficient for 20 years of growth at the given population levels. Land capacity is estimated for the Recommended Plan and Council Map List in this EIS and both show sufficient capacity for the target growth levels over 20 years.

Response to Comment 4: Conclusion The comment urges the County to 'either (include) substantial new buildable lands or (increase) densities in Urban Growth Areas." The Recommended Plan and Council Map List both use a combination of these approaches to provide sufficient capacity for the target growth levels over 20 years. 5.3.1.7 FEIS Letter 25: Snohomish County Committee for Improved Transportation

Response to Comment 1: Impact of Being a Bedroom Community for King County The comments are noted and forwarded to the appropriate decision makers. Each of the Alternatives included employment targets as shown on DEIS page 2-15. Also please see FEIS Chapter 2, which describes the employment features of the Recommended Plan and Council Map List.

4 “The link between growth management and housing affordability: that academic evidence,” Arthur C. Nelson, Rolf Pendall, Casey J. Dawkins, and Gerrit J. Knaap (2002). 5 “Summary of the Effects of Urban Growth Restrictions on House Prices,” Snohomish County PDS staff, report to Snohomish County Council (September 2005). 6 Alternative 1 (current plan) has 11,895 acres, alternative 2 has 13,150 acres, and alternative 3 has 16,376 acres designated Urban Low Density Residential, Urban Medium Density residential, or Urban High Density Residential. This excludes mixed-use designations which also allow residential development. Source: DEIS Table 2.4-3.

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Response to Comment 2: Targeting Transportation Resources to Grow Jobs Comment noted. The County’s GPP presents Economic Development and Transportation Goals that have a detailed set of objectives and policies that are aimed at promoting economic development. The objectives and policies as presented explain what the County wants to accomplish and how it should proceed to make it happen. The County Department of Public Works has an ongoing, working relationship with Snohomish County Committee for Improved Transportation (SCCIT) and Economic Development Council (EDC) including: • Briefings, outreach • Attendance at SCCIT meetings • Partnerships in initiatives such as an ongoing effort to identify tools to evaluate the relative economic-development value of alternative transport projects.

Response to Comment 3: Components for Economic Growth The comments are noted and forwarded to the appropriate decision makers. Please see Responses to Comments 1 and 2.

Response to Comment 4: Recommendations The comments are noted and forwarded to the appropriate decision makers. Please also see Response to Comment 2 regarding current County policies. FEIS Chapter 2 describes the policy amendments associated with the Recommended Plan.

Response to Comment 5: Conclusion The comments are noted and forwarded to the appropriate decision makers. 5.3.1.8 FEIS Letter 26: Stevens Pass Greenway

Response to Comment 1: No Position on Alternatives; Consider Values of the Greenway The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 2: Support Retention of Resource Lands; Allow Urban Development with Funded Highway Capacity Improvements All Alternatives propose to maintain designated forest lands. No designated farmlands are proposed for reclassification near Highway 2. The County will continue to work with WSDOT and the adjoining cities and towns as necessary to help ensure that coordinated highway, intersecting road, and transit improvements are implemented taking into consideration adopted plans and programs including the Stevens Pass Greenway Corridor Management Plan.

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Response to Comment 3: Greenway Mission and Goals The goals of the Sevens Pass Greenway are consistent with the goals of Snohomish County Comprehensive Plan for the preservation of greenways and resource lands. Policy LU-10.B.5 references the regional significance of the Stevens Pass Greenway and a need for cooperation with public and private groups. This policy is retained and carried forward with the Recommended Plan.

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5.4 Citizen Comments – Alternatives and Land Use Designations This section of Chapter 5 responds to comments made by private citizens regarding the May 5, 2004 DEIS for the Snohomish County GMA Comprehensive Plan 10-Year Update. For convenience, citizen comment letters have been sorted into five major groups: (1) Unsigned or signature not legible; (2) No Address; (3) North County: (4) Southeast County; and (5) Southwest County. Within each grouping, comment letters have been placed in alphabetical order. In addition, many of the comment letters address the potential Urban Center designation in the vicinity of Interstate 5 and 128th Street. These letters are identified with an asterisk (*) in the tables below and addressed in Section 5.4.6 of this Chapter.

5.4.1 Citizen Comments – Unidentified Table 5.4-1 lists unidentified citizen letters that were received during the public comment period. Each comment letter appears following the responses to comments. Some of these comments addressed the potential Urban Center designation in the vicinity of Interstate 5 and 128th Street SE. These letters are noted with an asterisk (*) in the FEIS # column of this table and are addressed in Section 5.4.6 of this Chapter.

Table 5.4-1 Unsigned or Illegible Citizen Comments FEIS# Log # Commenter Date *27 86 Signature Unknown No Date 28 140 Unsigned 6/8/04 29 141 Unsigned 6/18/04 *30 102 I-5/128th Form Unsigned No Date *31 91 I-5/128th Form Unsigned 6/15/04 *32 E25 [email protected] 6/13/04 *33 E356 [email protected] 6/8/04 *34 E42 [email protected] 6/16/04 *35 E52 [email protected] 6/17/04 *36 [email protected] 6/12/04 *37 E188 [email protected] 6/18/04 *38 [email protected] 6/12/04 *39 [email protected] 6/15/04 *40 E357 [email protected] for Tiffany 6/18/04 *41 E293 [email protected] 6/18/04 *42 [email protected] 6/17/04 *43 E325 [email protected] 6/13/04 *44 [email protected] 6/12/04

* These letters address the potential Urban Center at Interstate 5 and 128th Street. Please refer to Section 5.4.6 for the responses to these comments.

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5.4.1.1 FEIS Letters Number 27 and 30 – 44 Responses to these letters can be found in Section 5.4.6 Citizen Comments—Urban Center at Interstate 5/128th Street SE, below. 5.4.1.2 FEIS Letter Number 28: Unsigned

Response to Comment 1: Development Timing and Location The comments are noted and forwarded to the appropriate decision makers. 5.4.1.3 FEIS Letter Number 29: Unsigned

Response to Comment 1: Use Highway 9 for Business and Residential Development The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 2: Schools and Transportation The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 3: Plan New Development with Schools The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 4: Plan for Affordable Housing and Jobs The comments are noted and forwarded to the appropriate decision makers.

Snohomish County Comprehensive Plan 5-72 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

5.4.2 Citizen Comments – No Address Table 5.4-2 lists citizen comment letters that did not include an address. Each comment letter appears following the responses to comments.

Table 5.4-2 Citizen Comments – No Location FEIS# Log # Commenter Date 45 E30 Shirley Bailey 6/17/04 46 E36 Richard Beers 6/17/04 47 E380 Richard Wertz 6/5/04

5.4.2.1 FEIS Letter 45: Shirley Bailey

Response to Comment 1: Preserve Rural Areas and Natural Resources Your comments are noted and forwarded to the appropriate decision makers. As shown in Chapter 2 of this Final EIS, the Recommended Plan does not include substantive UGA expansions in the Little Bear Creek basin compared with Alternatives 2 and 3. The Council Map List includes a smaller SW UGA expansion in between Alternatives 2 and 3. Please also see Response to Comment 3, Letter 1.

Response to Comment 2: Support for Mixed Use Development in Urban Area The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 3: Opposition to Draft EIS Alternative 3 The comments are noted and forwarded to the appropriate decision makers. 5.4.2.2 FEIS Letter 46: Richard Beers

Response to Comment 1: Support for No Action and Request for Additional Analysis Comments regarding preference for No Action are noted and forwarded to the appropriate decision makers. The additional requested analysis for a detailed analysis of two to four communities that have adhered to GMA requirements is not within the scope of this DEIS. Additional information on this topic may be available at the Washington Department of Community, Trade and Economic Development website. The DEIS does disclose potential impacts associated with the three alternatives described in the DEIS, including an analysis of cumulative long-term impacts that may result in the future under each alternative. The FEIS addresses two alternatives in the range of the DEIS alternatives.

Snohomish County Comprehensive Plan 5-73 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

5.4.2.3 FEIS Letter 47: Richard Wertz

Response to Comment 1: Support for Alternative 1 The comments are noted and forwarded to the appropriate decision makers.

Snohomish County Comprehensive Plan 5-74 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

5.4.3 Citizen Comments – North Table 5.4-3 lists citizen comment letters that pertain to North Snohomish County (see Figure 5.4-1) received during the public comment period. Each comment letter appears following the responses to comments.

Table 5.4-3 Citizen Comments -- North Snohomish County FEIS# Log # Commenter Date 48 E31 Tim Bailey 6/18/04 49 119 John Burkholder 6/17/04 50 E63 Ron Carlson 6/9/04 51 E83/76 Kevin Conaway 6/8/04 52 E90/81 Bruce Crawford 5/20/04 53 E96/129 Jim Cummins 6/18/04 54 141 Dennis Derickson 6/16/04 55 125 Benjamin R. Durham 6/16/04 56 E145/85 Frances Calame for Herbert Frondorf 6/14/04 57 E146/50 Laura Frondorf 6/9/04 58 E171/131 Bob Heavey 6/18/04 59 E183/145 Joel Hylback 6/18/04 60 E193/63 Wanda J. Johnson 5/10/04 61 E134 Lilian Cruz for David B. Johnston 6/18/04 62 80 Jack Johnston 6/14/04 63 132 Jack Johnston 6/18/04 64 E210 Jay King for Estelle King 5/28/04 65 E214/65 Bill Klein 5/16/04 66 E219/100? Arvid Kraft 6/16/04 67 E221/153 Ralph Krutsinger 6/18/04 68 51 W. Smith for Laellemand Family LTD Partnership 6/8/04 69 E227/122 Case Lanting Undated 70 E248/124 Kay and Ed Mattson 6/14/04 71 E253/49 Alex McGregor 6/8/04 72 E286/134 Ron Palmer 6/16/04 73 E389/66 Marilyn Peppard 5/21/04 74 E363/136 Denise Van Wyck 6/18/04 75 E365/45 Cornelius Ver Muhn 6/7/04 76 E377/77 Jerry Weber 6/8/04

Snohomish County Comprehensive Plan 5-75 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

5.4.3.1 FEIS Letter 48: Tim Bailey

Response to Comment 1: Support for Commercial Zoning in Strategic Locations The comments are noted and forwarded to the appropriate decision makers. 5.4.3.2 FEIS Letter 49: John Burkholder

Response to Comment 1: Granite Falls UGA The Granite Falls UGA is proposed to expand in DEIS Alternatives 2 and 3. The Recommended Plan and Council Map List propose an expansion generally in the range of Alternatives 2 and 3. The County coordinated with the City on the proposed expansions. Please see Chapter 2 of this FEIS for a discussion regarding the preparation of the action alternatives. 5.4.3.3 FEIS Letter 50: Ron Carlson

Response to Comment 1: 5-Acre Rural Area Zoning Designation The comments are noted and forwarded to the appropriate decision makers. Please note that the Draft EIS alternatives did not consider increased rural densities and the Recommended Plan and Council Map List retain the 5-acre minimum lot size in the rural area. 5.4.3.4 FEIS Letter 51: Kevin Conaway

Response to Comment 1: Support for Property Inclusion in UGA The comments are noted and forwarded to the appropriate decision makers. The property at 8411 84th Street NE would be included in the Recommended Plan and Council Map List. Please refer to Chapter 2 of this Final EIS. 5.4.3.5 FEIS Letter 52: Bruce Crawford

Response to Comment 1: Arlington UGA Boundary Adjustment The comments are noted and forwarded to the appropriate decision makers. Please note that the Recommended Plan and Council Map List UGA boundary follows the bluff line as recommended in the comment letter. 5.4.3.6 FEIS Letter 53: Jim Cummins

Response to Comment 1: Support for Alternative 3 The comments are noted and forwarded to the appropriate decision makers.

Snohomish County Comprehensive Plan 5-76 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

5.4.3.7 FEIS Letter 54: Dennis L. Derickson, David Evans Associates

Response to Comment 1: Request for Inclusion of Property in Marysville UGA The comments regarding the property located between 100th Street NE and 88th Street NE (extended) and immediately west of 83rd Avenue NE (extended) are noted and forwarded to the appropriate decision makers. Under the Recommended Plan and Council Map List the property between 100th Street NE and 88th Street NE would be included in the Marysville UGA. The alternative UGA boundary suggested is not included in either the Recommended Plan or Council Map List. Please refer to Chapter 2 of this Final EIS.

Response to Comment 2: Potential Future Use of Property for Military Housing The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 3: History of Site Selection for Military Housing The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 4: Site Analysis Not Included in Draft EIS The proposed urban area under the Recommended Plan and Council Map List is within the range of total urban area considered in the Draft EIS alternatives. This Final EIS includes additional analysis of the Recommended Plan and Council Map List, including the property addressed in this comment letter. Please refer to Chapter 3 of this Final EIS.

Response to Comment 5: Potential Additional SEPA Analysis The comments are noted. Please refer to Chapter 3 of this Final EIS.

Response to Comment 6: 88th Street NE and 83rd Ave NE Extensions Comments regarding 88th Street NE and 83rd Ave NE extensions are noted. As indicated in the comment letter, 88th Street SE is already under consideration for inclusion in the County’s Transportation Element. The County will consider the suggestion to also include the 83rd Avenue NE extension. Additional analysis will be needed to decide if the extension should be pursued by the County or by development proponents.

Response to Comment 7: No Significant Impacts on Neighboring Properties Comments regarding potential impacts of future development are noted. Any future site-specific development proposal at this location would be subject to project level review and SEPA analysis.

Snohomish County Comprehensive Plan 5-77 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 8: Drainage Issues Comments regarding the proposed use of on-site infiltration and low impact development approaches to reduce potential downstream drainage impacts of future development are noted. Any future site-specific development proposal at this location would be subject to project level review and SEPA analysis.

Response to Comment 9: Land Use Designations Comments regarding historic land use designations on the property are noted. Under the Recommended Plan and Council Map List, this property would be included in the Marysville UGA. Please refer to Chapter 2 of this FEIS.

Response to Comment 10: Property Status as Agricultural Land Comments regarding agricultural designation of a portion of the property are noted. Under the Recommended Plan and Council Map List, this property would be included in the Marysville UGA. Please refer to Chapter 2 of this FEIS.

Response to Comment 11: Existing Rural/Urban Transition Area Designation Comments regarding the Rural/Urban Transition Area designation of a portion of the property are noted. Under the Recommended Plan and Council Map List, this property would be included in the Marysville UGA. Please refer to Chapter 2 of this Final EIS.

Response to Comment 12: Alternative UGA Expansion Boundary Comments regarding an alternative UGA boundary are noted. This alternative boundary includes an area slightly larger than the site referenced in this comment letter. Under the Recommended Plan and Council Map List, the potential UGA expansion would not include the expanded area identified in the alternative UGA boundary.

Response to Comment 13: 2002 Buildable Lands Report Comments regarding the 2002 Buildable Lands Report and on-going development activity in the vicinity of the referenced property are noted.

Response to Comment 14: City of Marysville Support for Proposed UGA Expansion Comments regarding the City of Marysville support for the proposed UGA expansion are noted.

Response to Comment 15: Request for Inclusion of Property in Marysville UGA Comments regarding the proposed UGA expansion are noted. Under the Recommended Plan and Council Map List, this property would be included in the Marysville UGA. Please refer to Chapter 2 of this Final EIS.

Snohomish County Comprehensive Plan 5-78 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

5.4.3.8 FEIS Letter 55: Benjamin Durham, Himalaya Homes

Response to Comment 1: Programmatic SEPA Analysis Comments regarding the programmatic nature of the SEPA analysis are acknowledged.

Response to Comment 2: Comments Focus on Detailed Review of Specific Sites Comments are acknowledged.

Response to Comment 3: Request for Expanded Arlington UGA Boundaries Comments regarding the proposed Arlington UGA expansion area are noted. Under the Recommended Plan, this property would not be included in the Arlington UGA, and is partially included in the Council Map List. Please refer to Chapter 2 of this Final EIS.

Response to Comment 4: Reference to Area Specific Analysis of Proposed Expansion Area The comment references some potential inaccuracies in buildable lands information. Each site is discussed in the remaining responses to this letter below.

Response to Comment 5: Critical Areas Constraints and Housing Capacity The buildable lands analysis was referenced in the DEIS in some sections in terms of cumulative total acres and capacities since it is a programmatic document. To respond to the comment, County PDS staff reviewed the subject parcel and its treatment in the buildable lands analysis. About 45% of the total gross area of the site was not included in the buildable lands analysis due to environmental constraints. In addition, high development costs (relocation of an overhead fiber optic line and frontage improvements) were cited as reasons for diminishing the economic viability of the property. Although these types of market factors were not assessed at the parcel level in the buildable lands analysis, they were considered at the global level through application of the market availability capacity reduction factors, which attempt to account for market conditions that tend to make land less likely to develop or redevelop during the plan horizon.

Response to Comment 6: Site Capacity for Additional Development The buildable lands analysis was referenced in the DEIS in some sections in terms of cumulative total acres and capacities since it is a programmatic document. However, PDS staff has reviewed the subject property to respond to the comment that relates to an earlier County study of buildable lands. The comment expresses a concern that the lots in the plat of Harbor View Village were incorrectly shown as representing additional housing unit capacity even though the plat was recorded in 2000 and is now 100% build out. This concern is resolved by the fact that the buildable lands maps depict additional housing unit capacity as of April 1, 2001 (the base year for establishing additional capacity as documented in the 2002 buildable lands report). As of April 1, 2001, the vast majority of these lots had not yet been built on and thus represented additional housing unit capacity as of that date. The only exception to this in the

Snohomish County Comprehensive Plan 5-79 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses plat was a short section of two streets which already had new housing built as of that date, and for which consequently no additional housing unit capacity was shown on the maps. These types of parcel-level determinations for all recently recorded plats countywide were made by PDS staff for the 2002 buildable lands analysis by consulting with appropriate city staff and by reviewing aerial photography taken in March 2001.

Response to Comment 7: Land Use Designation The area in question is actually designated “Urban Low Density Residential – Limited (4- 5/DU/acre)” on the FLUM by the County, not R-5 as the letter indicates. Also, the existing zoning for the area in question is mostly RC (Rural Conservation), but with developer rezones to implement the plan properly considered, the area (outside critical areas and buffers) was appropriately counted in the buildable lands analysis as representing urban residential capacity.

Response to Comment 8: Site Capacity for Additional Development The commenter’s Exhibit B map shows that the site labeled “Whispering Pines” yielded 23 units at time of application review. The buildable lands analysis had calculated that an effective potential for 28 units existed on the site, a difference of 5.

Response to Comment 9: Site Capacity for Additional Development The commenter’s Exhibit B map shows that the site labeled “Himalaya Heights” yielded 26 units at time of application review. The buildable lands analysis also calculated that an effective potential for 26 units existed on the site, a difference of 0.

Response to Comment 10: Site Capacity for Additional Development The commenter’s Exhibit B map shows that the site labeled “Cedar View I” yielded 20 units at time of application review. The buildable lands analysis also calculated that an effective potential for 20 units existed on the site, a difference of 0.

Response to Comment 11: Land Use Designations and Site Capacity for Additional Development The commenter’s Exhibit B map shows that the site labeled #7 has “massive critical areas.” No additional information is provided. In fact, the buildable lands analysis did take into account the wetlands, streams and buffers on the site, and accordingly eliminated from development consideration nearly half of the site due to environmental constraints.

Response to Comment 12: Differences between Programmatic and Site Specific Analysis Comments regarding the difference between area-wide programmatic analysis and site-specific analysis are noted.

Response to Comment 13: Potential Revenues Associated with Development Comments are noted. A comparison of potential property tax revenues was not part of the analysis in the DEIS. The DEIS is an informational document focusing on environmental

Snohomish County Comprehensive Plan 5-80 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses impacts. Some limited capital cost information is included. Fiscal information is not required to be included in an EIS.

Response to Comment 14: Marysville School District Comments regarding the Marysville School District budget are noted. As described in the DEIS, the Marysville School District estimating an enrollment increase of approximately 28% between 2001 and 2012. The DEIS does not analyze budgets within each school district. The DEIS is an informational document focusing on environmental impacts. Some limited capital cost information is included. Fiscal information is not required to be included in an EIS.

Response to Comment 15: Impacts of Development on Revenues Comments are noted.

Response to Comment 16: Developer Contribution to Public Infrastructure Comments are noted.

Response to Comment 17: Construction Employment Comments are noted.

Response to Comment 18: Inclusion of Proposed Area in Marysville UGA Comments are noted. Please refer to the description of the Recommended Plan and Council Map List in Chapter 2 of this FEIS.

Exhibit B, Site #8 Site #8 was included in the commenter’s Exhibit B but not referenced in the letter’s text. The Exhibit B map shows that the site labeled #8 is “Inconsistent with City of Marysville Comprehensive Plan dated September 2003.” No additional information is provided. However, 2 of the 3 parcels indicated actually had pending subdivisions underway at the time of the 2002 buildable lands report and were correctly depicted as having additional housing unit capacity consistent with the project applications, most of which have now been built. Specifically, the southern parcel indicated (Northwest Pointe, Division 1) at the time of the 2002 buildable lands report was subject to a subdivision proposal of 53 units, which County staff used as a direct input for that parcel in the 2002 buildable lands database. Similarly, the northwestern parcel indicated (Northwest Pointe, Division 2) had a subdivision proposal of 27 units, which PDS staff used as a direct input for that parcel. As a result, it is not clear what “inconsistency” is being referred to since most of the indicated area was already subject to pending subdivisions that were simply mirrored in the 2002 buildable lands analysis. 5.4.3.9 FEIS Letter 56: Herbert Frondorf

Response to Comment 1: Inclusion of Property in Marysville UGA The Marysville UGA expansion area proposed under the Recommended Plan and Council Map List includes the area north of 84th Street NE up to the section line separating sections 13 and

Snohomish County Comprehensive Plan 5-81 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

24 at Township 30 North, Range 6 East and between the existing UGA boundary and Highway 9 to the east. Therefore property north of 84th Street NE in this vicinity would be within the UGA under these alternatives. Please refer to Chapter 2 of this FEIS. 5.4.3.10 FEIS Letter 57: Laura Frondorf

Response to Comment 1: Inclusion of Property in Marysville UGA The comments are noted and forwarded to the appropriate decision makers. The Marysville UGA expansion area proposed under the Recommended Plan and Council Map List includes the area north of 84th Street NE up to the section line separating sections 13 and 24 at Township 30 North, Range 6 East and between the existing UGA boundary and Highway 9 to the east. Therefore property north of 84th Street NE in this vicinity would be within the UGA under these alternatives. Please refer to Chapter 2 of this FEIS. 5.4.3.11 FEIS Letter 58: Bob Heavey

Response to Comment 1: Do Not Support Racetrack or Alternative 3 Industrial Designation between Marysville and Arlington The comments are noted and forwarded to the appropriate decision makers. In DEIS Alternative 3, the Recommended Plan, and Council Map List include industrial designations in this area. Any future site specific development will be subject to site-specific SEPA review. 5.4.3.12 FEIS Letter 59: Joel Hylback

Response to Comment 1: Support for Alternative 3 The comments are acknowledged and forwarded to the appropriate decision makers.

Response to Comment 2: Support for UGA Expansion in Lakewood Area North of 172nd The comments are acknowledged and forwarded to the appropriate decision makers. A UGA expansion in the Lakewood area north of 172nd Street NE is included in the Recommended Plan and Council Map List. Please Chapter 2 of this FEIS.

Response to Comment 3: Support for UGA Expansion in North Marysville Area The comments are acknowledged and forwarded to the appropriate decision makers. Area south of 156th Street NE would be included in the UGA under the Recommended Plan and Council Map List. Please refer to Chapter 2 of this FEIS. 5.4.3.13 FEIS Letter 60: Wanda J. Johnson

Response to Comment 1: Arlington UGA Expansion The comments are noted and forwarded to the appropriate decision makers. The proposed UGA expansion area in the vicinity of Burn Road and adjacent to the northeast corner of the

Snohomish County Comprehensive Plan 5-82 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses existing Arlington UGA was shown in Alternative 3 of the Draft EIS. This area is not included in the UGA under the Recommended Plan and Council Map List. Please refer to Chapter 2 of this FEIS. 5.4.3.14 FEIS Letter 61: David B. Johnston

Response to Comment 1: Request for Stanwood UGA Expansion Comments regarding Stanwood UGA expansion are noted and forwarded to appropriate decision makers. The referenced area is not included in the Stanwood UGA under the Recommended Plan or Council Map List. Please refer to Chapter 2 of this FEIS.

Response to Comment 2: GMA Goals Comments regarding GMA goals are noted.

Response to Comment 3: Snohomish County GPP Goal LU-1 Comments regarding the referenced GPP Land Use goal are noted. Please refer to the Plans and Policies analysis in the Draft EIS and this Final EIS.

Response to Comment 4: Snohomish County GPP Goal LU-3 Comments regarding the referenced GPP Land Use goal are noted. Please refer to the Plans and Policies analysis in the Draft EIS and this Final EIS.

Response to Comment 5: Request for Stanwood UGA Expansion Comments regarding Stanwood UGA expansion are noted and forwarded to appropriate decision makers. The referenced area is not included in the Stanwood UGA under the Recommended Plan or Council Map List. Please refer to Chapter 2 of this FEIS. 5.4.3.15 FEIS Letter 62: Jack Johnston

Response to Comment 1: Support for Arlington UGA Expansion Comments regarding Arlington UGA expansion are noted and forwarded to the appropriate decision makers. The property is partially included in the Recommended Plan and included in Council Map List. Please refer to Chapter 2 of this FEIS. 5.4.3.16 FEIS Letter 63: Jack Johnston

Response to Comment 1: Support for Arlington UGA Expansion Comments regarding Arlington UGA expansion are noted and forwarded to the appropriate decision makers. The property is partially included in the Recommended Plan and included in Council Map List. Please refer to Chapter 2 of this FEIS.

Snohomish County Comprehensive Plan 5-83 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

5.4.3.17 FEIS Letter 64: Estelle King

Response to Comment 1: Re-designation of Property The property at 6804 through 7102 35th Avenue NE is included in the Recommended Plan and Council Map List as Reservation Commercial. Please refer to Chapter 2 of this FEIS. 5.4.3.18 FEIS Letter 65: Bill Klein

Response to Comment 1: Arlington Area UGA Expansion The comments are noted and forwarded to the appropriate decision makers. The referenced property is in the vicinity of Burn Road and adjacent to the northeast corner of the existing Arlington UGA. It is not included in the UGA under the Recommended Plan or Council Map List. Please refer to Chapter 2 of this Final EIS. 5.4.3.19 FEIS Letter 66: Arvid Kraft

Response to Comment 1: Lakewood UGA Area Expansion The comments are noted and forwarded to the appropriate decision makers. Under the Recommended Plan and Council Map List the area between Interstate 5 and 19th Avenue Northeast and north of 156th Street Northeast in the Lakewood Area of North Marysville would be partially included within the UGA. Please refer to Chapter 2 of this Final EIS. 5.4.3.20 FEIS Letter 67: Ralph Krutsinger

Response to Comment 1: Closure of 156th Street NE Snohomish County opposed closing of 156th Street NE at the Burlington Northern Santa Fe railroad line. However, the County was pre-empted by a federal decision. Placing 156th Street NE on the County’s six-year transportation improvement program would have no effect on the closure and could be misleading to the public.

Response to Comment 2: UGA Expansion along 25th Avenue NE, north of 172nd Street NE Comments regarding the referenced property are noted and forwarded to the appropriate decision makers. Under the Recommended Plan, this area would not be located in the Arlington UGA; it would be partially included in the Council Map List. Please refer to Chapter 2 of this FEIS.

Response to Comment 3: UGA Expansion south of 156th Street NE, west of Interstate 5 Comments regarding the referenced property are noted and forwarded to the appropriate decision makers. Under the Recommended Plan and Council Map List, this area would be located in the Marysville UGA. Please refer to Chapter 2 of this FEIS.

Snohomish County Comprehensive Plan 5-84 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

5.4.3.21 FEIS Letter 68: Lallemand Family Limited Partnership

Response to Comment 1: Lakewood Area UGA Expansion The comments are noted and forwarded to the appropriate decision makers. Under the Recommended Plan and Council Map List, the property located at the northwest corner of the intersection of 19th Avenue Northeast and 156th Street Northeast in the Lakewood Area of North Marysville would not be included within a UGA expansion area. Please refer to Chapter 2 of this FEIS. 5.4.3.22 FEIS Letter 69: Case Lanting

Response to Comment 1: Lakewood Area UGA Expansion The comments are noted and forwarded to the appropriate decision makers. Under the Recommended Plan and Council Map List a portion of the area that is located south of 156th Street Northeast, east of 23rd Avenue Northeast, and west of Interstate 5 is within the UGA. Depending on specific property boundaries, some of the referenced area may not be included within the proposed UGA. Please refer to Chapter 2 of this FEIS. 5.4.3.23 FEIS Letter 70: Kay and Ed Mattson

Response to Comment 1: Property Specific Land Use Designations Under the Recommended Plan and Council Map List the proposed land use designation for the properties in question would be Urban Commercial. Residential uses are allowed in mixed-use developments. Comments regarding support for Draft EIS Alternative 3 are noted and forwarded to appropriate decision makers. 5.4.3.24 FEIS Letter 71: Alex McGregor

Response to Comment 1: Support for Growth Management Planning Expansion The comments are noted and forwarded to appropriate decision makers. 5.4.3.25 FEIS Letter 72: Ron Palmer

Response to Comment 1: Stanwood UGA Expansion The comments are noted and forwarded to the appropriate decision makers. The referenced property on Beach Drive is not proposed for any change to land use designation under the Recommended Plan or Council Map List. Please refer to in Chapter 2 of this FEIS.

Snohomish County Comprehensive Plan 5-85 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

5.4.3.26 FEIS Letter 73: Marilyn Peppard

Response to Comment 1: Arlington UGA Expansion The comments are noted and forwarded to the appropriate decision makers. Under the Recommended Plan, the portion of 25th Avenue Northeast in Arlington that includes the 17500 block through the 18000 block is not included in a UGA expansion area and the land use designation for this area would remain Rural Residential-5. The Council Map List would partially include this area in a UGA. Please refer to Chapter 2 of this FEIS. 5.4.3.27 FEIS Letter 74: Denise Van Wyck

Response to Comment 1: UGA Expansion south of 172nd Street NE and east of 67th Avenue NE The comments are noted and forwarded to the appropriate decision makers. Under the Recommended Plan and Council Map List, the area generally located south of 172nd Street NE and east of 67th Avenue NE would be partially within the UGA. Please refer to Chapter 2 of this FEIS for a more specific identification of UGA boundaries in this area. 5.4.3.28 FEIS Letter 75: Cornelius Ver Muhn

Response to Comment 1: Lakewood Area UGA Expansion The comments are noted and forwarded to the appropriate decision makers. Under the Recommended Plan and Council Map List the property located at the southwest corner of 19th Avenue Northeast and 156th Street Northeast in the Lakewood area of North Marysville would not be within the UGA. Please refer to Chapter 2 of this FEIS. 5.4.3.29 FEIS Letter 76: Jerry Weber

Response to Comment 1: Lakewood Area UGA Expansion The comments are noted and forwarded to the appropriate decision makers. Under the Recommended Plan and Council Map List the area between Interstate 5 and 19th Avenue Northeast and north of 156th Street Northeast in the Lakewood Area of North Marysville would not be included within the UGA. Please refer to Chapter 2 of this FEIS.

Snohomish County Comprehensive Plan 5-86 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

5.4.4 Citizen Comments – Southeast Table 5.4-4 lists citizen comment letters on southeast County issues (see Figure 5.4-1) that were received during the public comment period. Each comment letter appears following the responses to comments.

Table 5.4-4 Southeast County Citizen Comments FEIS# Log # Commenter Date 77 E32/167 Thomas Ballard 6/16/04 78 E48/114 Misty Braswell 6/16/04 79 E65 John Carswell 6/18/04 80 E92 Margaret Crossman 6/18/04 81 E125 Kerek R. Edwards 6/18/04 82 E135/78 Connor Fleming 6/8/04 83 E136/40 Frank Fleming 6/3/04 84 E137/42 Geri Fleming 6/3/04 85 E138/41 Molly Fleming 6/3/04 86 E139/43 Pierce Fleming 6/3/04 87 E148/130 Dennis Gallagher 6/18/04 88 E225 Geoffrey Lang 6/18/04 89 E232/E233/143 Larry Lian 6/18/04 90 E296/117 Frank Platt 6/18/04 91 E309 Nancy Bainbridge Rogers 6/21/04 92 E318/135 Patricia Saunders 6/18/04 93 E322 Beverly Setzer 6/10/04 94 E321 Donald Setzer 6/18/04 95 E38 Jenny and Troy Michael Ziefel 6/18/04

5.4.4.1 FEIS Letter 77: Thomas Ballard

Response to Comment 1: Land Use Designation for Property along SR-9 The comments are noted and forwarded to the appropriate decision makers. Under the Recommended Plan and Council Map List, the land use designation of properties in the vicinity of the intersection of SR 524 (Maltby Road) and SR 9 would remain Rural Residential-5. Please refer to Chapter 2 of this FEIS. 5.4.4.2 FEIS Letter 78: Misty Braswell

Response to Comment 1: Support for Draft EIS Alternative 1 Comments are acknowledged and forwarded to the appropriate decision makers.

Snohomish County Comprehensive Plan 5-87 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 2: No Action Alternative The No Action alternative does maintain the existing UGA boundaries while allowing growth to occur and densities to increase through rezones ad other forms of infill. It does not, however, incorporate changes of land use designation as a further infill action. Such an alternative would represent one of a large number of potential hybrid alternatives that would fall between the “bookends” of Alternatives 1 and 3. Accommodating the population and employment growth targets for the County while respecting the growth preferences of the cities and also meeting the goals of GMA will require a combination of strategies for infill, as well as some UGA expansion.

Response to Comment 3: Concurrency Requirements and Fully Contained Communities The comments on concurrency are noted. It is difficult to evaluate the effectiveness of the concurrency management system on “managing traffic volumes” because it does not in fact lower congestion levels. Congestion is, and will continue to increase. Concurrency management simply prevents it from reaching certain levels of congestion. Comments regarding the impacts of urban growth and development on SR 2 and 9 are acknowledged. The recent nickel gas tax, slated to finance improvements on state highways, includes funds for improvements to SR-2 and SR-9. These improvements will help relieve some of the short-term congestion. With regard to FCCs, the Draft EIS identified this as a policy option, but did not locate one in the County. The Recommended Plan carries forward this policy option (as does the Council Map List) and identifies policy and regulation criteria for location of a future FCC. If a specific FCC is proposed, it would be reviewed through a separate environmental process, consistent with SEPA requirements.

Response to Comment 4: Support to Draft EIS Alternative 1 Comments are acknowledged and forwarded to the appropriate decision makers. 5.4.4.3 FEIS Letter 79: John Carswell

Response to Comment 1: Clearview Land Use Designations The comments are noted and forwarded to the appropriate decision makers. Under the Recommended Plan and Council Map List, land use designations in the Clearview area would not be changed. Please refer to Chapter 2 of this FEIS. 5.4.4.4 FEIS Letter 80: Margaret Crossman

Response to Comment 1: Support for Alternative 2 (modified) Comments are acknowledged and forwarded to appropriate decision makers.

Response to Comment 2: Rural Cluster Development Regulations Comments are acknowledged and forwarded to appropriate decision makers.

Snohomish County Comprehensive Plan 5-88 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

5.4.4.5 FEIS Letter 81: Kerek R. Edwards

Response to Comment 1: Property Specific UGA Expansions The comments are noted and forwarded to the appropriate decision makers. Under the Recommended Plan and Council Map List there would be no UGA expansion in the vicinity of the listed properties and all would remain as currently designated. Please refer to Chapter 2 of this FEIS. 5.4.4.6 FEIS Letter 82: Connor Fleming

Response to Comment 1: Support for Alternative 3 Comments are noted and forwarded to the appropriate decision makers. 5.4.4.7 FEIS Letter 83: Frank Fleming

Response to Comment 1: Support for Alternative 3 Comments are noted and forwarded to the appropriate decision makers. 5.4.4.8 FEIS Letter 84: Geri Fleming

Response to Comment 1: Support for Alternative 3 Comments are noted and forwarded to the appropriate decision makers. 5.4.4.9 FEIS Letter 85: Molly Fleming

Response to Comment 1: Support for Alternative 3 Comments are noted and forwarded to the appropriate decision makers. 5.4.4.10 FEIS Letter 86: Pierce Fleming

Response to Comment 1: Support for Alternative 3 Comments are noted and forwarded to the appropriate decision makers. 5.4.4.11 FEIS Letter 87: Dennis Gallagher

Response to Comment 1: Agricultural Lands Designations Comments regarding are noted and forwarded to the appropriate decision makers. Please refer to the Plans and Policies discussion in the Draft and Final EIS for review of policies related to removal of agricultural lands designations.

Snohomish County Comprehensive Plan 5-89 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

5.4.4.12 FEIS Letter 88: Geoffrey Lang

Response to Comment 1: Value of Urban/Rural Diversity Comments are noted and forwarded to the appropriate decision makers.

Response to Comment 2: Preserve Urban/Rural Diversity Comments are noted and forwarded to the appropriate decision makers.

Response to Comment 3: Support for Draft EIS Alternative 1 or Alternative 2 Comments are noted and forwarded to the appropriate decision makers. 5.4.4.13 FEIS Letter 89: Larry Lian

Response to Comment 1: Lake Stevens UGA Expansion The comments are noted and forwarded to the appropriate decision makers. Under the Recommended Plan and Council Map List, the UGA boundary would not border the two lots in question and these lots have not been identified for inclusion within the UGA boundary. Please refer to Chapter 2 of this FEIS. 5.4.4.14 FEIS Letter 90: Frank Platt

Response to Comment 1: Rezone Request at Chapel Hill Road/Davies Road The comments are noted and forwarded to the appropriate decision makers. Under the Recommended Plan and Council Map List, the land use designation for these properties would remain at Urban Low Density Residential (4-6 du/ac). Please refer to Chapter 2 of this FEIS. 5.4.4.15 FEIS Letter 91: Nancy Bainbridge Rogers

Response to Comment 1: Background Information on Lundeen Property Comments are noted.

Response to Comment 2: Support for Alternative 3 Support for Alternative 3 is noted and forwarded to the appropriate decision makers.

Response to Comment 3: Re-inclusion of Lundeen in Lake Stevens UGA Comments that provide the rationale for re-inclusion of the Lundeen property in the Lake Stevens UGA are noted and forwarded to the appropriate decision makers. Please note that under the Recommended Plan, this property is not included in the Lake Stevens UGA; it is included in the Council Map List. Please refer to Chapter 2 of this FEIS.

Snohomish County Comprehensive Plan 5-90 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 4: Alternative 3 Capacity for Growth Comments regarding the potential buildable lands capacity under Alternative 3 are noted. The capacity of the Recommended Plan and Council Map List are described in Chapter 2 and analyzed in Chapter 3 of this FEIS.

Response to Comment 5: Preferred Alternative Final EIS As noted in the Comment, this Final EIS provides a description of the Recommended Plan and Council Map List (Chapter 2) and associated environmental analysis (Chapter 3). Please see Response to Comment 3.

Response to Comment 6: Comparison of Alternatives 1, 2, and 3 Comments regarding the relative impacts of Draft EIS Alternatives 1, 2 and 3 are noted. Please refer to the Draft EIS for a full analysis of relative impacts. As stated in the Comment, the programmatic analysis of impacts in the Draft and Final EIS does not take the place of, or preclude, site-specific SEPA review for specific development proposals.

Response to Comment 7: Development Capacity under Alternative 3 Comments regarding the availability of buildable lands are noted. Please refer to the Draft and Final EIS for a full analysis of buildable acres and development capacity.

Response to Comment 8: Transportation Infrastructure Comments regarding transportation infrastructure under Alternative 3 in general and specifically at the Lundeen property are noted. 5.4.4.16 FEIS Letter 92: Patricia Saunders

Response to Comment 1: Support for Alternative 1 Support for Alternative 1 is noted and forwarded to the appropriate decision makers. 5.4.4.17 FEIS Letter 93: Beverly Setzer

Response to Comment 1: Support for Alternative 1 Support for Alternative 1 is noted and forwarded to the appropriate decision makers.

Response to Comment 2: Rural Cluster Ordinance Comments regarding the rural cluster ordinance are noted and forwarded to the appropriate decision makers.

Response to Comment 3: Support for Alternative Transportation Modes Comments regarding the desirability of relatively more dense development to allow for use of alternative transportation modes are noted.

Snohomish County Comprehensive Plan 5-91 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 4: Fully Contained Communities Opposition to Fully Contained Communities is noted. 5.4.4.18 FEIS Letter 94: Donald Setzer

Response to Comment 1: Support for Alternative 1 Support for Alternative 1 is noted and forwarded to the appropriate decision makers. 5.4.4.19 FEIS Letter 95: Jenny Ziefel and Troy Michael

Response to Comment 1: Support for Alternative 1 Support for Alternative 1 is noted and forwarded to the appropriate decision makers.

Snohomish County Comprehensive Plan 5-92 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

5.4.5 Citizen Comments – Southwest Table 5.4-5 lists citizen comment letters on southwest County issues (see Figure 5.4-1) that were received during the public comment period. Each comment letter appears following the responses to comments. Some of these comments addressed the potential Urban Center designation in the vicinity of Interstate 5 and 128th Street SE. These letters are noted with an asterisk (*) in the FEIS # column of this table and are addressed in Section 5.4.6 of this Chapter.

Table 5.4-5 Citizen Comments – Southwest Snohomish County FEIS# Log # Commenter Date *96 E3 Al Aicher 6/14/04 *97 E4 Bill and Annette Allen 6/6/04 *98 E24 Ronelle Armstrong 6/16/04 *99 E26 Ken Ashelman 6/9/04 *100 E27/E28 Todd Ashton 6/17/04 *101 E27/E28 Todd Ashton 6/18/04 *102 E29 Mark and Shari Auker 6/17/04 *103 E33 Junell Balli 6/27/04 *104 E35/46 Joanna H. Barker 6/7/04 *105 E37 Stephanie Benson 6/14/04 *106 E38 Marie Bentson 6/15/04 *107 E43 John F. Bolten 6/22/04 *108 E44 Robert Bosc 6/25/04 *109 E45 Bradley Cullen 6/17/04 *110 E49 James Brauch 6/26/04 *111 E51 Amy and Bill Bright 6/14/04 112 E53 Daryle Brown 6/17/04 *113 E56 Darlene Burgess 6/15/04 *114 E57 Erich Burnett 6/14/04 *115 E58 Jennifer Burnett 6/14/04 *116 E59 Casey Burpee 6/18/04 *117 E64 Linda E. Carrier 6/14/04 *118 E66 Rod Castillo 6/17/04 *119 E68 Linda Chapa 6/15/04 *120 E80 Mark Clark 6/15/04 *121 E81 Joshua D Clifton 6/6/04 122 E82 Sheree Collins 6/18/04 123 E83/108 Daryl Connell 6/17/04 *124 E85 Richard Cook 6/12/04

Snohomish County Comprehensive Plan 5-93 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

FEIS# Log # Commenter Date *125 E86/75 Wyman L. Cook Jr. 6/8/04 *126 E87 Tricia Cooke 6/17/04 *127 E88/84 Dulcie and Earl Coonrod 6/14/04 *128 E97 Joanne L. Cundy 6/8/04 *129 E98 Cori Cuttell 6/17/04 130 99/98 Jeff M. Daggett 6/11/04 *131 E101 Jim David 6/3/04 *132 E102 Julie David 6/3/04 *133 E104 Linn A Davis 6/13/04 *134 N/A Mark Davis 6/16/04 *135 E106 Crystal Dean 6/18/04 *136 E109 John Detore 6/18/04 *137 E111 Pamela DeYoung 6/17/04 *138 E113 Bruce Dittemore 6/17/04 *139 E114 Joanne Dittemore 6/18/04 *140 E115 BJ Dixon 6/18/04 *141 E116 Danny R. Dolan 6/14/04 *142 E117 Tim Doll 6/14/04 *143 E120 Jan and Wally Donion 6/17/04 *144 E122 Mike and Joan Dougherty 6/18/04 *145 E123/83 Mary Jane D. Eayrs 6/12/04 146 E124/64 Mike Echelbarger 5/14/04 *147 E130/103 Vasile Fabian 6/16/04 148 E133 James and Kristi Felt 6/18/04 149 E134/115 James Fintz 6/17/04 *150 E144 Dale and Debbie Frolander 6/15/04 *151 E147 Shannon M Fuhrman 6/14/04 *152 E149 Dewey Gallahar 6/6/04 153 E150/38 Leo and Marla Gese 6/1/04 *154 E151/123 Gladys Gonsalves 6/18/04 *155 E152 Jeff Gray 6/18/04 *156 E153 Linda Gray 6/18/04 *157 E155 Dura Greenfield 6/17/04 *158 E158 Toni Griffin 6/15/04 *159 E159 Daniel Hackney 6/11/04 *160 E160 Pamela Hafey 6/13/04 *161 E161 Donna Brown for Randy Hall 6/17/04 162 E16274 Allan Halvorson 5/28/04

Snohomish County Comprehensive Plan 5-94 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

FEIS# Log # Commenter Date 163 E163/72 Robert Hamm 5/27/04 164 Kay Miller for Laurel Hammer 6/15/04 *165 E165 Janice Hanefeld 6/5/04 *166 E166 Kim and Corinna Hansen 6/16/04 *167 E169 Karleen Hauenstein 6/18/04 *168 E172 Sherri Heldt 6/7/04 *169 E175 Karen Hensley 6/14/04 *170 E177/82 May Hinrichs 6/8/04 *171 E178 Janet Hoffman 6/17/04 *172 E179 Michael and Tammie Hogan 6/17/04 *173 E180 Brian and Jo Holm 6/17/04 174 121 Brian Holtzclaw 6/18/04 *175 E181 Dina Hopkins 6/16/04 *176 E182 Ted Huff 6/15/04 *177 Joan Jacober for Alice Brown 6/17/04 *178 E187 Tim and Careen Jensen 6/6/04 179 E189/190/99 Dean and Susan Johnson 6/14/04 *180 E192 Trevor Johnson 6/15/04 181 E194 David Johnston 6/18/04 *182 E200 Joshwa Thangadurai, Arthy Joshwa and Dan Joshwa 6/13/04 *183 E201 James Jovanovich 6/17/04 *184 E202 Zoe Jovanovich 6/18/04 *185 E203 Debbie Kammenga 6/18/04 *186 E204 Kris Kappel 6/12/04 *187 E205 Karvonen Household 6/17/04 *188 E206 Bob Keller 6/17/04 *189 Bob Keller 6/18/04 *190 E209/79 J.L. Kessler 6/6/04 *191 E211 Bruce Monforton for Shirlee Kippen 6/19/04 *192 E212 A B Kittelman 6/17/04 *193 E213 Ronald Klang 6/15/04 *194 E215 Paul Klemp 6/7/04 *195 E217 Monika Knotek 6/18/04 *196 E218 Donald and Lisa Koontz 6/18/04 *197 E223 Vik Kwastein 6/7/04 *198 E224 Leslie and Richard LaBarge 6/12/04 *199 E230/44 Roberta Leonard 6/4/04 200 165 Winston Lessley 6/8/04

Snohomish County Comprehensive Plan 5-95 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

FEIS# Log # Commenter Date *201 E231 Shannon Levin for Greg Levin 6/14/04 *202 E235 Karen Lindblad 6/17/04 202a 95 Henry E. Lippek 6/15/04 (4/6/04) *203 E238 G. Lloyd 6/14/04 *204 E244 Somphien Manivanh 6/18/04 205 E245/124 Miriam Marcus-Smith 6/18/04 *206 David Ray and Karen Sue McElliott 6/17/04 *207 E254 Bob McMurray 6/17/04 *208 E255 George and Patricia Ann McNees 6/15/04 *209 E256 James McWhorter 6/9/04 *210 E257 Shari McWhorter 6/8/04 *211 John and Sharon Melseth 6/16/04 212 E260/E261/152 Mary and Steve Messmer 6/3/04 213 E260/E261/152 Mary and Steve Messmer 6/17/04 *214 E263 James Mitchell 6/17/04 *215 E264 Alfred and Jean Mitterndorfer 6/17/04 *216 E265 Mr. and Mrs. Morley 6/7/04 217 E266/E267/88 Jerry Morrier 5/31/04 218 E266/E267/88 Jerry Morrier 6/16/04 *219 E268 Jim and Judi Morse 6/14/04 *220 E271 Linda and Al Muzzy 6/18/04 *221 E272 Mark Myers 6/14/04 *222 E273 Ronald Nelson 6/7/04 *223 E274 Jeff and Carol Nikolaidis 6/16/04 224 E279 Norris Noe 6/17/04 225 E280 Patt Noe 6/15/04 *226 E281 Lisa Ogle 6/18/04 *227 E282 Dianne Olsen 6/18/04 *228 E285 Mr. and Mrs. Page 6/12/04 *229 E284/96 William and Mary Page 6/16/04 *230 E287 Linda Parton 6/17/04 *231 E290/94 Matt and Cheryl Perhateh 6/15/04 *232 E291 James Petersen for Dianna Petersen 6/16/04 *233 E292 Linda Petropulos 6/4/04 *234 E295 Jon and Michelle Pietig 6/18/04 *235 E297 Mr. And Mrs. Gary Porter 6/13/04 *236 E300/52 Carl Powers 6/6/04 *237 E303 Patty and Bruce Qualey 6/16/04

Snohomish County Comprehensive Plan 5-96 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

FEIS# Log # Commenter Date *238 E306/104 Rebecca Riesen 6/16/04 *239 E307 Shirley Rinell for Ernest Rinell 6/18/04 *240 E307 Shirley Ann Rinell 6/18/04 *241 E308 Bob and Lori Riner 6/13/04 *242 E310/93 Norman Rood 6/15/04 *243 E311 David Ross 6/7/04 *244 E312 Krista Rowe 6/15/04 245 E315 Tracy Ruef 6/18/04 *246 E317 Kelly Satterlee 6/17/04 247 E320 Jerry Sebranke 6/17/04 *248 E323 Denise Shafer 6/15/04 *249 E324 Debbie Shaffer 6/8/04 250 E326/106 Elliot and Sonya Shaw 6/12/04 *251 E328/54 Deedee Slaybough 6/9/04 *252 E329/92 Judd Slaybough 6/11/04 *253 E327/53 Ressa Slaybough 6/9/04 *254 E330 Corey Smith 6/18/04 *255 E335 Mary and James Snyder 6/13/04 *256 E338 Pamela Somers 6/14/04 *257 E339 Michelle St. Sauver for Lynn St. Sauver 6/18/04 *258 E340 Lynn St. Sauver for Stan St Sauver 6/18/04 259 E342 Kim Stevens for William and Micky Stevens 6/178/04 260 E344/71 Edward Stimmel 5/19/04 *261 E349 Jennifer Stuart 6/17/04 *262 E352 Arlene Sutton 6/18/04 263 E364/150 Alan Vanderlugt 6/18/04 *264 E367 Steven Vincent 6/8/04 265 36/39 Van and Adriana Vorwerk 6/2/04 *266 E371 John Wagner 6/5/04 *267 E373 Mannon Wallace 6/5/04 *268 E374 Tammy Wallace 6/18/04 *269 E375 Michael Wandler 6/18/04 *270 E376 Martin and Lorrie Watson 6/17/04 *271 E379 Betty Welliver 6/14/04 *272 Mr. and Mrs. Wiese 6/18/04 273 E385/138 Julia Winchell 6/8/04 *274 E387 Everett and Donna Witte 6/15/04 275 E388/110 Cynthia Wong 6/16/04

* These letters address the proposal for an Urban Center at Interstate 5 and 128th Street. Please refer to Section 5.4.6 for the response to these comments.

Snohomish County Comprehensive Plan 5-97 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

5.4.5.1 FEIS Letter 112, Daryle Brown

Response to Comment 1: Opposition to All Alternatives The comments are noted and forwarded to the appropriate decision makers. 5.4.5.2 FEIS Letter 122: Sheree Collins

Response to Comment 1: Support for Draft EIS Alternative 1 The comments are noted and forwarded to the appropriate decision makers. 5.4.5.3 FEIS Letter 123: Daryl Connell

Response to Comment 1: Site Specific Land Use Designation Request The property retains the UMDR classification under the Recommended Plan and Council Map List. Please refer to Chapter 2 of this FEIS. 5.4.5.4 FEIS Letter 130: Jeff M. Daggett

Response to Comment 1: Support for Draft EIS Alternative 3 The comments in support of Draft EIS Alternative 3 are noted and forwarded to the appropriate decision makers. 5.4.5.5 FEIS Letter 146: Michael D. Echelbarger

Response to Comment 1: Site Specific Land Use Designation Request The comments are noted and forwarded to the appropriate decision makers. Under the Recommended Plan and the Council Map List, the land use designation for the referenced property area would remain Urban Low Density Residential. Please refer to Chapter 2 of this FEIS. 5.4.5.6 FEIS Letter 148: Jim and Kris Felt

Response to Comment 1: Support for Draft EIS Alternative 3 The comments in support of Draft EIS Alternative 3 are noted and forwarded to the appropriate decision makers. The referenced location at 156th Street SE is included in the UGA under the Council Map List. It is not included in the Recommended Plan. Please refer to Chapter 2 of this FEIS.

Snohomish County Comprehensive Plan 5-98 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

5.4.5.7 FEIS Letter 149: James Fintz

Response to Comment 1: Importance of Public Involvement Comments are noted. Please refer to the Chapter 2 in the Draft and Final EIS for a description of the public involvement process to date.

Response to Comment 2: Support for Draft EIS Alternative 3 The comments in support of Draft EIS Alternative 3 are noted and forwarded to the appropriate decision makers.

Response to Comment 3: Urban Levels of Development on Surrounding Property Comments regarding development levels in the area surrounding the commenter’s residence are noted.

Response to Comment 4: GPP Housing Policies Comments regarding GPP Housing Element policies are noted. Please note that the property at 2917 83rd Ave NE, Everett is included in the Recommended Plan and Council Map List. Please refer to Chapter 2 of this FEIS.

Response to Comment 5: Surrounding Land Use Designations Comments regarding surrounding land use designations are noted. Please also see Response to Comment 4.

Response to Comment 6: Request for Inclusion in UGA Comments are noted and forwarded to the appropriate decision makers. 5.4.5.8 FEIS Letter 153: Leo and Maria Gese

Response to Comment 1: Support for Draft EIS Alternative 3 The comments in support of Draft EIS Alternative 3 are noted and forwarded to the appropriate decision makers. 5.4.5.9 FEIS Letter 162: Allan Halvorson

Response to Comment 1: Support for Draft EIS Alternative 3 The comments in support of Draft EIS Alternative 3 are noted and forwarded to the appropriate decision makers.

Snohomish County Comprehensive Plan 5-99 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

5.4.5.10 FEIS Letter 163: Robert S. and Jane F. Hamm

Response to Comment 1: Inclusion of 156th Street SE in UGA The comments are noted and forwarded to the appropriate decision makers. Under the Recommended Plan, the referenced area is not included within the UGA; it is included in the UGA with the Council Map List. Please refer to Chapter 2 of this FEIS. 5.4.5.11 FEIS Letter 164: Kay Miller for Laurel Hammer

Response to Comment 1: Support for Draft EIS Alternative 3 The comments in support of Draft EIS Alternative 3 are noted and forwarded to the appropriate decision makers.

Response to Comment 2: Description of Existing Conditions Around Property Comments are noted.

Response to Comment 3: Inclusion of 156th Street SE in UGA The comments are noted and forwarded to the appropriate decision makers. Under the Recommended Plan, the referenced area is not included within the UGA; it is included in the UGA with the Council Map List. Please refer to Chapter 2 of this FEIS. 5.4.5.12 FEIS Letter 174: Brian L. Holtzclaw

Response to Comment 1: Docket Proposals SW-16, SW-17, SW-18A Under the Recommend Plan, UGA infill proposals are included. With the Council Map List both the UGA infill and expansion proposals are included. Please refer to Chapter 2 of this FEIS.

Response to Comment 2: Purpose of Comment Letter Purpose of the comment letter to comment on alternative land use designations for specified properties is noted.

Response to Comment 3: Comments on Docket Proposal SW-16 (TMG-1) The comments are noted and forwarded to the appropriate decision makers. Please see Response to Comment 1.

Response to Comment 4: Comments on Docket Proposal SW-17 (TMG-11) The comments are noted and forwarded to the appropriate decision makers. Please see Response to Comment 1.

Snohomish County Comprehensive Plan 5-100 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 5: Comments on Docket Proposal SW-18A (TMG-14) County mapping is always under continuous updating and the 320-acre area you noted has been included in updated service district maps. Silver Lake Water District (SLWD) resolution 567 expanded the boundary of the district between 164th and 180th Street as far east as the existing Urban Growth Area (UGA) for Mill Creek. There are existing trunk line capacity restrictions that affect the sanitary service area of SLWD which are being addressed by King County and the affected service providers but which have not yet been fully resolved. SLWD must also plan for how service to the expanded service area will be provided. The property in SW-18A is east of this expansion area. The district has not initiated formal planning for how sewer service will be provided for the area east of the UGA. Please also see Response to Comment 1.

Response to Comment 6: UGA Impacts to Little Bear Creek Please refer to the Draft and Final EIS discussion of potential impacts to Little Bear Creek associated with Alternative 2, Alternative 3, the Recommended Plan and the Council Map List. The comment is correct in noting that the analysis is cumulative and programmatic in nature. Specific quantification of the magnitude of the impacts from this individual area would require additional analysis that is not within the scope of this EIS.

Response to Comment 7: Alternative 3 Population Target Comments are noted. The Draft EIS states that the Alternative 3 population target is above the OFM “most likely,” but within the OFM forecasted growth range for 2025.

Response to Comment 8: Alternative 2 and 3 Development Capacity Comments are noted. Please refer to the Draft EIS for a complete analysis of population and employment capacity under Alternatives 2 and 3. Refer to Chapter 3 of this Final EIS for an analysis of the population and employment capacity of the Recommended Plan and Council Map List.

Response to Comment 9: Potential Mitigation Measures The Draft EIS identifies policy options available to Snohomish County in response to potential impacts associated with future growth near identified critical areas. The EIS does not make findings of inadequacy of existing regulations, but rather identifies additional options for consideration by Snohomish County. Potential future changes to buffer widths, storm detention standards or other similar measures would be accomplished through separate review and action by the County and would be subject to SEPA review. As part of that review, potential impacts to land capacity could be analyzed.

Response to Comment 10: Water and Sewer Service Area Please see Response to Comment 5 above.

Snohomish County Comprehensive Plan 5-101 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 11: Future Population Growth and Transportation Costs Comments regarding the challenges of funding transportation improvements are noted. Please refer to the Draft and Final EIS analyses of transportation needs for a complete discussion of transportation needs under the different alternatives.

Response to Comment 12: Transportation Revenue Assumptions The impact fee and property tax revenues computed for DEIS Table 3.2-29 will not likely be generated at a fixed or straight-line rate from 2005 through 2025. The absolute amount of revenue is higher for the later timeframe (2013 through 2025) than the early timeframe (2005 through 2012) for all three alternatives. However, as noted in the comment letter, the average annual increase is greater for the earlier timeframe that the later one. This is attributable to the growth and development forecast prepared by the County. More of the growth occurs (is front- loaded) in the earlier timeframe (2005 –2012), so the average annual increase in revenues is higher as well. Also, there are no assumed increases in fee rates, so the present value of the fees declines over time.

Response to Comment 13: Property Tax Revenues Documentation The property tax revenues are derived by taking into account forecasted growth in the number of residential units and growth in commercial square footage; this over two selected timeframes (2005–2012 and 2013–2025). Annual increases in assessed valuation allowed under current state law were also considered in determining future property tax revenues. The effect of these computations is to take into account growth and development as it occurs from the present and forecasted toward 2025. Increases in property valuation are taken into account across the County for both residential and commercial properties. This is a fairly traditional approach to property tax revenue forecasting.

Response to Comment 14: Assumptions regarding Source of Funding for Transportation Improvements Comment noted. The FEIS includes increased accounting for the developer contributions. However, note that when developers receive credits against impact fees for construction of arterial improvements, there is no net gain for the County. The value of the construction is offset by a reduction in impact fees received. Arterial project costs, in the form of impact mitigation fees, are also paid by developers as a contribution to cover arterial project costs, but developers can receive reimbursement for frontage improvements and dedication of right-of-way or other arterial improvements. The development community’s overall revenue contributions are accounted for within the revenue forecasts, so that when a comparison of arterial project costs versus available revenues for project-related improvement is performed, the County can see the revenue short-fall amounts. Lastly, developers can also finance road improvements to mitigate impacts that would ordinarily cause an arterial unit to fall into arrears and trigger a concurrency problem. This type of revenue measure might be used as part of an approach that would involve phasing of a development, particularly where the County doesn’t have financing for a needed road project. These types of revenues are not included within the overall revenue forecast, but would relate to additional mitigation.

Snohomish County Comprehensive Plan 5-102 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 15: Closing Comments Comments are noted. 5.4.5.13 FEIS Letter 179: Dean and Susan Johnson

Response to Comment 1: Opposition to Inclusion of 156th Street SE area in UGA Comments in opposition to inclusion in the UGA are noted and forwarded to the appropriate decision makers. Under the Recommended Plan, the property at 5304 156th Street S.E. would not be within the UGA; it is included in the UGA in the Council Map List. Please refer to Chapter 2 of this FEIS.

Response to Comment 2: History and Potential Impacts of Inclusion in UGA Comments regarding the status of development in the 156th Street SE area are noted. With regard to traffic congestion in your area, please refer to the analysis of current and forecasted traffic volumes in the Draft and Final EIS. The County has included a number of road improvement projects in your area, which are intended to help mitigate congestion problems on the arterial system. The County is committed to maintaining an adequate level of service for County arterials and has a concurrency management system in place to monitor level of service conditions on County arterials and identify strategies to alleviate level of service deficiencies. 5.4.5.14 FEIS Letter 181: David B. Johnson

Response to Comment 1: Identification of Site Specific Requests Comments that identify the specific properties addressed in this letter are noted.

Response to Comment 2: Request for Inclusion in UGA Comments are noted and forwarded to the appropriate decision makers. Properties requested for addition are not included in either the Recommended Plan or Council Map List. Please refer to Chapter 2 of this FEIS.

Response to Comment 3: Support for Draft EIS Alternatives 2 and 3 Comments are noted and forwarded to the appropriate decision makers. 5.4.5.15 FEIS Letter 200: Winston Lessley

Response to Comment 1: Support for Alternative 3 The comments are noted and forwarded to the appropriate decision makers.

Snohomish County Comprehensive Plan 5-103 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 2: Alternative 2 SW UGA Land Use Designation Changes The comments are noted and forwarded to the appropriate decision makers. 5.4.5.16 FEIS Letter 202a: Henry E. Lippek

Response to Comment 1: Identification of Area As described in the comment letter, the residential area of concern is north of 168th SW, west of 52nd Street as it becomes Beverly Park Road to the north, south of Picnic Point Road/Shelby Road to Puget Sound. This is an unincorporated area located between the cities of Mukilteo to the north and Edmonds and Lynnwood to the south.

Response to Comment 2: Prohibit Multifamily development; Maintain Large Lot Character of Neighborhood Comments and recommendations regarding opposition to duplexes or multi-family homes and support for single family residential designations with a minimum lot size of 7200 square feet contained in the letter and the attached materials to the letter are noted and forwarded to the appropriate decision makers. Portions of this neighborhood are identified for ULDR. Please refer to Chapter 2 of this FEIS. 5.4.5.17 FEIS Letter 205: Miriam Marcus-Smith

Response to Comment 1: Status of Comments Your comments on the Draft EIS on the 10-Year Comprehensive Plan Update are noted and forwarded to the appropriate decision makers as part of the public record.

Response to Comment 2: Development Activity in Surrounding Area The comments are noted and forwarded to the appropriate decision makers. Please refer to Chapter 2 of this FEIS regarding classifications of properties in the surrounding area.

Response to Comment 3: Support for Draft EIS Alternative 1 with Modifications Your comments are noted and forwarded to the appropriate decision makers. 5.4.5.18 FEIS Letter 212: Mary and Steve Messmer

Response to Comment 1: Support for Alternative 3 Your comments are noted and forwarded to the appropriate decision makers. Please note that under the Recommended Plan, a UGA expansion in the vicinity of the properties located at 4433 169th Street SE and 4503 169th Street SE as shown under Alternative 3 would not occur. The properties are included within the UGA in the Council Map List. Please refer to Chapter 2 of this FEIS.

Snohomish County Comprehensive Plan 5-104 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

5.4.5.19 FEIS Letter 213: Mary and Steve Messmer

Response to Comment 1: Support for Alternative 3 Please see Letter 212, Response to Comment 1. 5.4.5.20 FEIS Letter 217: Jerry Morrier

Response to Comment 1: Support for Draft EIS Alternative 3 Your comments are noted and forwarded to the appropriate decision makers. 5.4.5.21 FEIS Letter 218: Jerry Morrier

Response to Comment 1: Support for Draft EIS Alternative 3 Your comments are noted and forwarded to the appropriate decision makers. 5.4.5.22 FEIS Letter 224: Norris Noe

Response to Comment 1: Support for Draft EIS Alternative 3 Your comments are noted and forwarded to the appropriate decision makers. 5.4.5.23 FEIS Letter 225: Patt Noe

Response to Comment 1: Support for Draft EIS Alternative 3 Your comments are noted and forwarded to the appropriate decision makers. The properties are not included in the Recommended Plan UGA expansion, but are included in the Council Map List. Please refer to Chapter 2 of this FEIS.

Response to Comment 2: Preference for Pedestrian Access to Shopping Your comments are noted and forwarded to the appropriate decision makers. 5.4.5.24 FEIS Letter 245: Tracy Ruef

Response to Comment 1: Concern Over Future Growth Your comments are noted and forwarded to the appropriate decision makers.

Response to Comment 2: Support for Draft EIS Alternative 1 Your comments are noted and forwarded to the appropriate decision makers.

Snohomish County Comprehensive Plan 5-105 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 3: Shift Density Away from Neighborhood The comments are noted and forwarded to the appropriate decision makers. Under the Recommended Plan or Council Map List, the land use designation for the property at 22311 49th Ave SE would not change. Please refer to Chapter 2 of this FEIS. 5.4.5.25 FEIS Letter 247: Jerry Sebranke

Response to Comment 1: Site Specific Land Use Designation Request The comments are noted and forwarded to the appropriate decision makers. All properties referenced continue with ULDR under the Recommended Plan or Council Map List. Please refer to Chapter 2 of this FEIS.

Response to Comment 2: Site Specific Land Use Designation Request The comments are noted and forwarded to the appropriate decision makers. The property referenced continues with ULDR under the Recommended Plan or Council Map List. 5.4.5.26 FEIS Letter 250: Elliot and Sonya Shaw

Response to Comment 1: Support for Draft EIS Alternative 3 Comments in support of Draft EIS Alternative 3 are noted and forwarded to appropriate decision makers. The subject property is not included in the UGA in the Recommended Plan, but is included in the Council Map List. Please refer to Chapter 2 of this FEIS. 5.4.5.27 FEIS Letter 259: William K and Mickey C Stevens

Response to Comment 1: Support for Draft EIS Alternative 3 Comments in support of Draft EIS Alternative 3 are noted and forwarded to appropriate decision makers. The subject property is not included in the UGA in the Recommended Plan, but is included in the Council Map List. Please refer to Chapter 2 of this FEIS.

Response to Comment 2: Drainage Impacts Comments on potential mitigation for impacts to rivers and streams are noted and forwarded to the appropriate decision makers. Please refer to the analysis in the Draft and Final EIS for additional discussion of this issue.

Response to Comment 3: Closing Comments Comments are noted.

Snohomish County Comprehensive Plan 5-106 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

5.4.5.28 FEIS Letter 260: Edward Stimmel

Response to Comment 1: Inclusion of 156th Street SE in UGA The comments are noted and forwarded to the appropriate decision makers. The subject property is not included in the UGA in the Recommended Plan, but is included in the Council Map List. Please refer to Chapter 2 of this FEIS. 5.4.5.29 FEIS Letter 263: Alan Vanderlugt

Response to Comment 1: Support for Draft EIS Alternative 1 Comments in support of Draft EIS Alternative 1 are noted and forwarded to appropriate decision makers. Please refer to Chapter 2 of this FEIS. 5.4.5.30 FEIS Letter 265: Van and Adriana Vorwerk

Response to Comment 1: Support for UGA Expansion East of Mill Creek Comments are noted and forwarded to the appropriate decision makers. Please refer to Chapter 2 of this FEIS for a description of the Recommended Plan and Council Map List, which differ in their approach to the Southwest UGA expansion proposals. 5.4.5.31 FEIS Letter 273: Julia Winchell

Response to Comment 1: Support for Draft EIS Alternative 1; Opposition to Draft EIS Alternative 3 Your comments are noted and forwarded to the appropriate decision makers.

Response to Comment 2: Plan for Less Growth Your comments are noted and forwarded to the appropriate decision makers. 5.4.5.32 FEIS Letter 275: Cynthia Wong

Response to Comment 1: Comments Pertaining to Chevron Point Wells Property The comments on the Draft EIS on the Snohomish County 10-Year Comprehensive Plan Update are noted and forwarded to the appropriate decision makers.

Response to Comment 2: Comments on Draft EIS Alternative 2 Your comments are noted and forwarded to the appropriate decision makers. Please note that under the Recommended Plan and Council Map List the land use designations for the Chevron Point Wells property would be as proposed under Alternative 2. Please refer to Chapter 2 of this FEIS.

Snohomish County Comprehensive Plan 5-107 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 3: Comments on Draft EIS Alternative 3 Your comments are noted and forwarded to the appropriate decision makers. Please see Response to Comment 2.

Snohomish County Comprehensive Plan 5-108 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

5.4.6 Citizen Comments – Urban Center at Interstate 5/128th Street SE Table 5.4-6 lists letters that address the potential Urban Center at Interstate 5/128th Street SE. The table includes the letter number, commenter, date of comment and a key that identifies the comments in the letter and the sub-section of this FEIS that responds to this comment.

Table 5.4-6 Citizen Comments – Urban Center at Interstate 5/128th Street SE FEIS# Log # Commenter Date Comment Key *27 86 Illegible No Date 1. Preference – Section 5.4.6.1 *30 102 I-5/128th Form Unsigned No Date 1. Preference – Section 5.4.6.1 *31 91 I-5/128th Form Unsigned 6/15/04 1. Preference – Section 5.4.6.1 *32 E25 [email protected] 6/13/04 1. Preference – Section 5.4.6.1 *33 E356 [email protected] 6/8/04 1. Preference – Section 5.4.6.1 *34 E42 [email protected] 6/16/04 1. Preference – Section 5.4.6.1 *35 E52 [email protected] 6/17/04 1. Preference – Section 5.4.6.1 *36 [email protected] 6/12/04 1. Preference – Section 5.4.6.1 *37 E188 [email protected] 6/18/04 1. Preference – Section 5.4.6.1 *38 [email protected] 6/12/04 1. Preference – Section 5.4.6.1 *39 [email protected] 6/15/04 1. Preference – Section 5.4.6.1 *40 E357 [email protected] for 6/18/04 1. Preference – Section 5.4.6.1 Tiffany *41 E293 [email protected] 6/18/04 1. Preference – Section 5.4.6.1 *42 [email protected] 6/17/04 1. Preference – Section 5.4.6.1 *43 E325 [email protected] 6/13/04 1. Preference – Section 5.4.6.1 *44 [email protected] 6/12/04 1. Preference – Section 5.4.6.1 *96 E3 Al Aicher 6/14/04 1. Preference – Section 5.4.6.1 *97 E4 Bill and Annette Allen 6/6/04 1. Preference – Section 5.4.6.1 *98 E24 Ronelle Armstrong 6/16/04 1. Preference – Section 5.4.6.1 *99 E26 Ken Ashelman 6/9/04 1. Preference – Section 5.4.6.1 *100 E27/E2 Todd Ashton 6/17/04 1. Preference – Section 5.4.6.1 8 *101 E27/E2 Todd Ashton 6/18/04 1. Preference – Section 5.4.6.1 8 *102 E29 Mark and Shari Auker 6/17/04 1. Preference – Section 5.4.6.1 *103 E33 Junell Balli 6/27/04 1. Preference – Section 5.4.6.1 *104 E35/46 Joanna H. Barker 6/7/04 1. Preference – Section 5.4.6.1 *105 E37 Stephanie Benson 6/14/04 1. Preference – Section 5.4.6.1 2. Traffic – Section 5.4.6.2 *106 E38 Marie Bentson 6/15/04 1. Preference – Section 5.4.6.1 *107 E43 John F. Bolten 6/22/04 1. Preference – Section 5.4.6.1

Snohomish County Comprehensive Plan 5-109 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

FEIS# Log # Commenter Date Comment Key *108 E44 Robert Bosc 6/25/04 1. Preference – Section 5.4.6.1 *109 E45 Bradley Cullen 6/17/04 1. Preference – Section 5.4.6.1 *110 E49 James Brauch 6/26/04 1. Preference – Section 5.4.6.1 2. Neighborhood Agreement – Section 5.4.6.3 *111 E51 Amy and Bill Bright 6/14/04 1. Preference – Section 5.4.6.1 *113 E56 Darlene Burgess 6/15/04 1. Preference – Section 5.4.6.1 *114 E57 Erich Burnett 6/14/04 1. Preference – Section 5.4.6.1 *115 E58 Jennifer Burnett 6/14/04 1. Preference – Section 5.4.6.1 *116 E59 Casey Burpee 6/18/04 1. Preference – Section 5.4.6.1 *117 E64 Linda E. Carrier 6/14/04 1. Preference – Section 5.4.6.1 *118 E66 Rod Castillo 6/17/04 1. Preference – Section 5.4.6.1 *119 E68 Linda Chapa 6/15/04 1. Preference – Section 5.4.6.1 *120 E80 Mark Clark 6/15/04 1. Preference – Section 5.4.6.1 *121 E81 Joshua D Clifton 6/6/04 1. Preference – Section 5.4.6.1 *124 E85 Richard Cook 6/12/04 1. Preference – Section 5.4.6.1 *125 E86/75 Wyman L. Cook Jr. 6/8/04 1. Preference – Section 5.4.6.1 *126 E87 Tricia Cooke 6/17/04 1. Preference – Section 5.4.6.1 *127 E88/84 Dulcie and Earl Coonrod 6/14/04 1. Preference – Section 5.4.6.1 *128 E97 Joanne L. Cundy 6/8/04 1. Preference – Section 5.4.6.1 *129 E98 Cori Cuttell 6/17/04 1. Preference – Section 5.4.6.1 *131 E101 Jim David 6/3/04 1. Preference – Section 5.4.6.1 *132 E102 Julie David 6/3/04 1. Preference – Section 5.4.6.1 *133 E104 Linn A Davis 6/13/04 1. Preference – Section 5.4.6.1 *134 N/A Mark Davis 6/16/04 1. Preference – Section 5.4.6.1 *135 E106 Crystal Dean 6/18/04 1. Preference – Section 5.4.6.1 *136 E109 John Detore 6/18/04 1. Preference – Section 5.4.6.1 *137 E111 Pamela DeYoung 6/17/04 1. Preference – Section 5.4.6.1 2. Vote – Section 5.4.6.4 *138 E113 Bruce Dittemore 6/17/04 1. Preference – Section 5.4.6.1 *139 E114 Joanne Dittemore 6/18/04 1. Preference – Section 5.4.6.1 *140 E115 BJ Dixon 6/18/04 1. Preference – Section 5.4.6.1 *141 E116 Danny R. Dolan 6/14/04 1. Preference – Section 5.4.6.1 *142 E117 Tim Doll 6/14/04 1. Preference – Section 5.4.6.1 *143 E120 Jan and Wally Donion 6/17/04 1. Preference – Section 5.4.6.1 2. Traffic – Section 5.4.6.2 3. Preference – Section 5.4.6.1 *144 E122 Mike and Joan Dougherty 6/18/04 1. Preference – Section 5.4.6.1 *145 E123/83 Mary Jane D. Eayrs 6/12/04 1. Preference – Section 5.4.6.1

Snohomish County Comprehensive Plan 5-110 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

FEIS# Log # Commenter Date Comment Key *147 E130/10 Vasile Fabian 6/16/04 1. Preference – Section 5.4.6.1 3 *150 E144 Dale and Debbie Frolander 6/15/04 1. Preference – Section 5.4.6.1 2. McCollum Park – Section 5.4.6.5 3. Schools – Section 5.4.6.6 4. Housing – 5.4.6.7 *151 E147 Shannon M Fuhrman 6/14/04 1. Preference – Section 5.4.6.1 *152 E149 Dewey Gallahar 6/6/04 1. Preference – Section 5.4.6.1 *154 E151/12 Gladys Gonsalves 6/18/04 1. Preference – Section 5.4.6.1 3 *155 E152 Jeff Gray 6/18/04 1. Preference – Section 5.4.6.1 *156 E153 Linda Gray 6/18/04 1. Preference – Section 5.4.6.1 *157 E155 Dura Greenfield 6/17/04 1. Preference – Section 5.4.6.1 *158 E158 Toni Griffin 6/15/04 1. Preference – Section 5.4.6.1 *159 E159 Daniel Hackney 6/11/04 1. Preference – Section 5.4.6.1 *160 E160 Pamela Hafey 6/13/04 1. Preference – Section 5.4.6.1 2. Natural Environment – Section 5.4.6.8; Traffic – Section 5.4.6.2; Schools – 5.4.6.6 3. Housing – Section 5.4.6.7 4. Preference – Section 5.4.6.1 *161 E161 Donna Brown for Randy Hall 6/17/04 1. Preference – Section 5.4.6.1 Traffic – Section 5.4.6.2; Schools – 5.4.6.6 *165 E165 Janice Hanefeld 6/5/04 1. Preference – Section 5.4.6.1 *166 E166 Kim and Corinna Hansen 6/16/04 1. Preference – Section 5.4.6.1 *167 E169 Karleen Hauenstein 6/18/04 1. Preference – Section 5.4.6.1 *168 E172 Sherri Heldt 6/7/04 1. Preference – Section 5.4.6.1 *169 E175 Karen Hensley 6/14/04 1. Preference – Section 5.4.6.1 *170 E177/82 May Hinrichs 6/8/04 1. Preference – Section 5.4.6.1 *171 E178 Janet Hoffman 6/17/04 1. Preference – Section 5.4.6.1 *172 E179 Michael and Tammie Hogan 6/17/04 1. Preference – Section 5.4.6.1 2. Natural Environment – Section 5.4.6.8 3. Preference – Section 5.4.6.1 *173 E180 Brian and Jo Holm 6/17/04 1. Preference – Section 5.4.6.1 *175 E181 Dina Hopkins 6/16/04 1. Preference – Section 5.4.6.1 2. Schools – Section 5.4.6.6 3. Traffic – Section 5.4.6.2 4. Housing – Section 5.4.6.7 *176 E182 Ted Huff 6/15/04 1. Preference – Section 5.4.6.1 *177 Joan Jacober for Alice Brown 6/17/04 1. Preference – Section 5.4.6.1 *178 E187 Tim and Careen Jensen 6/6/04 1. Preference – Section 5.4.6.1 *180 E192 Trevor Johnson 6/15/04 1. Preference – Section 5.4.6.1

Snohomish County Comprehensive Plan 5-111 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

FEIS# Log # Commenter Date Comment Key *182 E200 Joshwa Thangadurai, Arthy 6/13/04 1. Preference – Section 5.4.6.1 Joshwa and Dan Joshwa *183 E201 James Jovanovich 6/17/04 1. Preference – Section 5.4.6.1 *184 E202 Zoe Jovanovich 6/18/04 1. Preference – Section 5.4.6.1 *185 E203 Debbie Kammenga 6/18/04 1. Preference – Section 5.4.6.1 *186 E204 Kris Kappel 6/12/04 1. Preference – Section 5.4.6.1 *187 E205 Karvonen Household 6/17/04 1. Preference – Section 5.4.6.1 *188 E206 Bob Keller 6/17/04 1. Preference – Section 5.4.6.1 *189 Bob Keller 6/18/04 1. Preference – Section 5.4.6.1 *190 E209/79 J.L. Kessler 6/6/04 1. Preference – Section 5.4.6.1 *191 E211 Bruce Monforton for Shirlee 6/19/04 1. Preference – Section 5.4.6.1 Kippen *192 E212 A B Kittelman 6/17/04 1. Preference – Section 5.4.6.1 2. Traffic – Section 5.4.6.2 *193 E213 Ronald Klang 6/15/04 1. Preference – Section 5.4.6.1 2. Traffic – Section 5.4.6.2 *194 E215 Paul Klemp 6/7/04 1. Preference – Section 5.4.6.1 *195 E217 Monika Knotek 6/18/04 1. Preference – Section 5.4.6.1 *196 E218 Donald and Lisa Koontz 6/18/04 1. Preference – Section 5.4.6.1 *197 E223 Vik Kwastein 6/7/04 1. Preference – Section 5.4.6.1 *198 E224 Leslie and Richard LaBarge 6/12/04 1. Preference – Section 5.4.6.1 *199 E230/44 Roberta Leonard 6/4/04 1. Preference – Section 5.4.6.1 *201 E231 Shannon Levin for Greg Levin 6/14/04 1. Preference – Section 5.4.6.1 *202 E235 Karen Lindblad 6/17/04 1. Preference – Section 5.4.6.1 *203 E238 G. Lloyd 6/14/04 1. Preference – Section 5.4.6.1 *204 E244 Somphien Manivanh 6/18/04 1. Preference – Section 5.4.6.1 *206 David Ray and Karen Sue 6/17/04 1. Preference – Section 5.4.6.1 McElliott *207 E254 Bob McMurray 6/17/04 1. Preference – Section 5.4.6.1 *208 E255 George and Patricia Ann McNees 6/15/04 1. Preference – Section 5.4.6.1 *209 E256 James McWhorter 6/9/04 1. Preference – Section 5.4.6.1 *210 E257 Shari McWhorter 6/8/04 1. Preference – Section 5.4.6.1 *211 John and Sharon Melseth 6/16/04 1. Preference – Section 5.4.6.1 *214 E263 James Mitchell 6/17/04 1. Preference – Section 5.4.6.1 *215 E264 Alfred and Jean Mitterndorfer 6/17/04 1. Preference – Section 5.4.6.1 *216 E265 Mr. and Mrs. Morley 6/7/04 1. Preference – Section 5.4.6.1 *219 E268 Jim and Judi Morse 6/14/04 1. Preference – Section 5.4.6.1 *220 E271 Linda and Al Muzzy 6/18/04 1. Preference – Section 5.4.6.1 *221 E272 Mark Myers 6/14/04 1. Preference – Section 5.4.6.1

Snohomish County Comprehensive Plan 5-112 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

FEIS# Log # Commenter Date Comment Key *222 E273 Ronald Nelson 6/7/04 1. Preference – Section 5.4.6.1 2. Neighborhood Agreement – Section 5.4.6.3 *223 E274 Jeff and Carol Nikolaidis 6/16/04 1. Public Comment – Section 5.4.6.9 2. Preference – Section 5.4.6.1 *226 E281 Lisa Ogle 6/18/04 1. Preference – Section 5.4.6.1 *227 E282 Dianne Olsen 6/18/04 1. Preference – Section 5.4.6.1 *228 E285 Mr. and Mrs. Page 6/12/04 1. Preference – Section 5.4.6.1 *229 E284/96 William and Mary Page 6/16/04 1. Preference – Section 5.4.6.1 *230 E287 Linda Parton 6/17/04 1. Preference – Section 5.4.6.1 *231 E290/94 Matt and Cheryl Perhateh 6/15/04 1. Preference – Section 5.4.6.1 *232 E291 James Petersen for Dianna 6/16/04 1. Preference – Section 5.4.6.1 Petersen *233 E292 Linda Petropulos 6/4/04 1. Preference – Section 5.4.6.1 *234 E295 Jon and Michelle Pietig 6/18/04 1. Preference – Section 5.4.6.1 2. Traffic – Section 5.4.6.2 3. Preference – Section 5.4.6.1 *235 E297 Mr. And Mrs. Gary Porter 6/13/04 1. Preference – Section 5.4.6.1 *236 E300/52 Carl Powers 6/6/04 1. Preference – Section 5.4.6.1 *237 E303 Patty and Bruce Qualey 6/16/04 1. Preference – Section 5.4.6.1 *238 E306/10 Rebecca Riesen 6/16/04 1. Public Comment – Section 5.4.6.9 4 2. Neighborhood Agreement – Section 5.4.6.3 3. Preference – Section 5.4.6.1 *239 E307 Shirley Rinell for Ernest Rinell 6/18/04 1. Preference – Section 5.4.6.1 *240 E307 Shirley Ann Rinell 6/18/04 1. Preference – Section 5.4.6.1 *241 E308 Bob and Lori Riner 6/13/04 1. Preference – Section 5.4.6.1 *242 E310/93 Norman Rood 6/15/04 1. Preference – Section 5.4.6.1 *243 E311 David Ross 6/7/04 1. Preference – Section 5.4.6.1 *244 E312 Krista Rowe 6/15/04 1. Preference – Section 5.4.6.1 *246 E317 Kelly Satterlee 6/17/04 1. Preference – Section 5.4.6.1 *248 E323 Denise Shafer 6/15/04 1. Preference – Section 5.4.6.1 *249 E324 Debbie Shaffer 6/8/04 1. Preference – Section 5.4.6.1 *251 E328/54 Deedee Slaybough 6/9/04 1. Preference – Section 5.4.6.1 *252 E329/92 Judd Slaybough 6/11/04 1. Preference – Section 5.4.6.1 *253 E327/53 Ressa Slaybough 6/9/04 1. Preference – Section 5.4.6.1 *254 E330 Corey Smith 6/18/04 1. Preference – Section 5.4.6.1 *255 E335 Mary and James Snyder 6/13/04 1. Preference – Section 5.4.6.1 *256 E338 Pamela Somers 6/14/04 1. Preference – Section 5.4.6.1 *257 E339 Michelle St. Sauver for Lynn St. 6/18/04 1. Preference – Section 5.4.6.1 Sauver *258 E340 Lynn St. Sauver for Stan St Sauver 6/18/04 1. Preference – Section 5.4.6.1

Snohomish County Comprehensive Plan 5-113 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

FEIS# Log # Commenter Date Comment Key *261 E349 Jennifer Stuart 6/17/04 1. Preference – Section 5.4.6.1 *262 E352 Arlene Sutton 6/18/04 1. Preference – Section 5.4.6.1 *264 E367 Steven Vincent 6/8/04 1. Preference – Section 5.4.6.1 *266 E371 John Wagner 6/5/04 1. Preference – Section 5.4.6.1 *267 E373 Mannon Wallace 6/5/04 1. Preference – Section 5.4.6.1 *268 E374 Tammy Wallace 6/18/04 1. Preference – Section 5.4.6.1 *269 E375 Michael Wandler 6/18/04 1. Preference – Section 5.4.6.1 *270 E376 Martin and Lorrie Watson 6/17/04 1. Preference – Section 5.4.6.1 *271 E379 Betty Welliver 6/14/04 1. Preference – Section 5.4.6.1 *272 Mr. and Mrs. Wiese 6/18/04 1. Preference – Section 5.4.6.1 *274 E387 Everett and Donna Witte 6/15/04 1. Preference – Section 5.4.5.1

5.4.6.1 Preference Many of the comments received expressed a preference for one of the Draft EIS Alternatives, or for Alternative 4, a citizen initiated alternative. All comments that express a preference for a particular alternative are noted and forwarded to the appropriate decision maker. Please note that Alternative 4 is a component of a citizen initiative and was not an element of the Future Land Use changes under consideration in the DEIS alternatives. Please note that the proposed Urban Center in the vicinity of Interstate 5 and 128th St SE is included in the Recommended Plan and Council Map List. Please refer to Chapter 2 of this FEIS. 5.4.6.2 Traffic Comments stated that traffic congestion is a problem currently in the Interstate 5/128th Street SE area and that designation of the area as an Urban Center would exacerbate traffic congestion. Many of the comments identified 128th Street SE, Meadow Road and Cascadian Way as existing streets with congestion and safety concerns. Please refer to the transportation analysis in Chapter 3 of this FEIS for information on transportation impacts and potential mitigation measures associated with the Recommended Plan and Council Map List, including an Urban Center designation at this location. If the Snohomish County Council adopts an Urban Center designation at this location, appropriate arterial improvements and accommodations for public transportation would be elements of a master plan for the Center’s development. The intent of facility and service improvements would be to ensure mobility, access and safety. 5.4.6.3 Neighborhood Agreement There is a neighborhood agreement. It covers most of the southeast quadrant of the 128th/I-5 Urban Center. The agreement was signed in 1989 and was negotiated with the surrounding single-family neighborhood. Three property owners make up the majority of the land area covered by the agreement. The agreement spells out zoning, allowed uses, bulk standards and infrastructure improvements. Snohomish County did not officially adopt it and there is some

Snohomish County Comprehensive Plan 5-114 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses disagreement over who is the neighborhood. The comments regarding the neighborhood agreement are forwarded to the appropriate County decision makers. 5.4.6.4 Vote on Alternatives Several of the comments stated that they were voting on the alternative and/or the designation of an Urban Center at Interstate 5/128th Street SE. A citizen-initiated flyer that was distributed in the area was entitled “Vote on the 1-5/128th Street Housing and Transit Plan.” However, the identification of the Recommended Plan and Council Map List in this Final EIS, including the proposed Urban Center designation, were not based on a formal or informal vote, as may have been implied in this flyer. Please refer to Chapter 2 for a description of the criteria used in identification of FEIS alternatives. Similarly, formal adoption of the updated Comprehensive Plan and related regulatory amendments will occur by legislative action of the County Council, not through a popular vote. Although a vote was not tallied, identification of the Recommended Plan and Council Map List did include consideration of all comments received on the Draft EIS. In addition, all comments received during the Draft EIS public comment period have been included in this Final EIS and forwarded to appropriate decision makers for their consideration. 5.4.6.5 McCollum Park McCollum Park is included in the potential Urban Center as a public facility that will serve the Urban Center and larger area. Snohomish County does not intend to sell or develop the Park. 5.4.6.6 Schools Comment letters stated the schools in the area are currently over-crowded and the development associated with an Urban Center designation would increase over-crowding in the schools. Please refer to the school impact analysis in this Final EIS for a discussion of potential impacts associated with schools under the Recommended Plan and Council Map List. The County works in partnership with the school districts regarding their capital improvement plans and impact fees, and collects impact fees from new residential development. 5.4.6.7 Housing The intent is to provide a variety of housing choices inside and outside the urban centers that meet the needs of different income groups. Within the urban centers the ability to make efficient use of land and infrastructure, and provide housing in proximity to jobs, and services is one strategy to promote affordable housing. Comments regarding affordable housing opportunities and need for coordination between agencies that provide housing in Snohomish County are noted and forwarded to the appropriate decision makers. 5.4.6.8 Natural Environment Comment letters expressed concern over impacts to habitat, wetlands and streams in the area resulting from Urban Center designation. Developing inside the UGA and within urban centers is intended to promote compact growth to avoid expanding into environmentally sensitive and rural lands along the UGA boundaries. Inside or outside of UGAs, the County will apply critical area policies and regulations to avoid or mitigate for impacts. These comments are noted and forwarded to the appropriate decision makers.

Snohomish County Comprehensive Plan 5-115 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

5.4.6.9 Public Notice and Comments Additional public involvement and opportunities to comment on the Recommended Plan and Council Map List were provided as part of the public involvement process and hearings on the Comprehensive Plan 10-Year Update. See Chapter 2 of the FEIS. One comment questioned why the flyer describing Alternative 4 was not sent to the commenter’s address. Fliers describing Alternative 4 were not developed or distributed by Snohomish County but were part of a citizen initiative and were privately distributed. Please refer to Chapter 2 of the Draft and Final EIS for a description of public involvement activities to date.

Snohomish County Comprehensive Plan 5-116 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

5.5 Citizen Comments – SEPA and Environmental Citizen comments related to DEIS environmental topics are included in this subsection. A list of the commenters is provided in Table 5.5-1. Comment letters follow the responses to comments.

Table 5.5-1 Citizen Comments -- Environmental FEIS# Log # Commenter Date 276 139 Unsigned 6/18/04 277 47 Paul Brandal 6/3/04 278 128 Chen Carlson 6/18/04 279 109 John and Kathy Dewherst 6/17/04 280 E 128/E129 John and Kathleen (West) Evans 6/18/04 281 E143 Bonnie M. Frederick 6/18/04 282 E154 G. Green 6/16/04 283 87 Gene Grieve 6/14/04 284 E156/E157 Gene Grieve 6/18/04 285 E173 Terrill W. Hendrickson 6/18/04 286 E174 Corinne R. Hensley 6/18/04 287 E220 Lily Su Hoyne for George Kresovich 6/18/04 288 E269 Jody McVittie 6/18/04

289 E283 Jim Orrell 6/18/04 290 E304 Adrienne Quinn 6/18/04 291 E332 Ralph Smith 6/18/04 292 144 S. Michael Smith 6/16/04 293 101 F. Robert Strahm 6/17/04 294 E350 Pam Stubsten and Frank Wichman 6/17/04 295 116 David K. Toyer 6/18/04 296 137 Nancy Walker 6/18/04

5.5.1.1 FEIS Letter 276: Unsigned

Response to Comment 1: Too Much Money for Sounder The comments are noted and forwarded to the appropriate decision makers. Snohomish County coordinates with multiple agencies that provide alternative forms of transit including Sound Transit. Sound Transit’s operations are based on a voter approved plan. Comments regarding Sound Transit’s services may be made to that agency.

Snohomish County Comprehensive Plan 5-117 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

5.5.1.2 FEIS Letter 277: Paul Brandal

Response to Comment 1: Urban Growth Effects on Agriculture The DEIS is intended to be a programmatic areawide document. Potential improvements in the Sunnyside floodplain, such as a pump station or other alternative technical solution, are being addressed through a separate County process that is focused on this specific area. Comments regarding the need for a pump station are forwarded to the appropriate decision makers. Comments regarding traffic flow needing to be diverted from farming activity are noted. The DEIS addresses traffic impacts due to varying land use patterns of different future land use concepts. Alternatives that promote further growth inside current UGAs would take advantage of existing infrastructure, and lessen the need for additional roadways to serve traffic to areas within expanded UGAs. Alternatives that focus more on infill than expansion include Alternatives 1, 2, Recommended Plan, and Council Map List. 5.5.1.3 FEIS Letter 278: Cheri Carlson

Response to Comment 1: Consider Arlington Airport Layout Plan Please see FEIS Chapter 3 and Appendix I-D for an analysis of airport master plans and future land use patterns associated with the Recommended Plan and Council Map List. No significant consistency concerns were identified. 5.5.1.4 FEIS Letter 279: John and Kathy Dewherst

Response to Comment 1: Need Preferred Alternative That Can Be Afforded Selected capital facility costs have been identified for the Recommended Plan and Council Map List in FEIS Chapter 3.

Response to Comment 2: Separate Costs of New Growth from Existing Deficiencies The purpose of the DEIS is as an informational document. SEPA does not require a fiscal analysis or a cost benefit analysis (WAC 197-11-448 and 450). However, to facilitate the planning process and assist in capital facility planning, the document compares the impacts of increased growth on capital facilities (roads, parks, drainage) in an order of magnitude fashion, including optional cost information. With this information, decision makers can balance land use, revenues, and levels of service to ensure that the facilities required to meet the County’s levels of service are within the County’s means. Distinctions between existing deficiencies and future growth, and costs/revenues, are described in the DEIS: • Roads: Possible existing road deficiencies are described on DEIS pages 3-274 and 3-275. Impacts due to added growth are described on pages 3-289 to 3-295. Costs and revenues are reported on 3-297 to 3-299. Appendix A of the Transportation Needs Report (TNR) will identify which major capacity-projects will be part of the “cost basis” for computing impact fees by each TSA (A-F). As noted, impact fees cannot include existing deficiencies and a careful evaluation is required to identify any. Please see FEIS Chapter 3.

Snohomish County Comprehensive Plan 5-118 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

• Parks: There are no existing park deficiencies, and the current LOS standards are being met, as explained on DEIS pages 3-356 to 3-357. The costs on page 3-363 are due to new growth. Revenue sources are described on page 3-363. • Drainage: Existing drainage deficiencies are described on pages 3-403 to 3-407. Impacts due to added growth are described on pages 3-410 to 3-417. The costs documented on pages 3-418 to 3-424 include the costs of many existing deficiencies that would be impacted by future development, but do not necessarily include the costs needed to address all existing deficiencies. Potential revenue sources are described on pages 3-420 to 3-422. Selected capital facility costs have been identified for the Recommended Plan and Council Map List in FEIS Chapter 3.

Response to Comment 3: Total Cost for Each Alternative SEPA does not require a fiscal analysis or a cost benefit analysis (WAC 197-11-448 and 450). However, the DEIS shows the total cost for each alternative by major capital facility cost as described in Response to Comment 2. The cost for non-capital based services such as police is not estimated, as the County does not have an adopted level of service (e.g., officers per 1,000 population). However, the increase in demand for law enforcement is estimated in the DEIS. Mitigation measures are recommended. The impacts of the Recommended Plan and Council Map List in terms of public safety needs are described in FEIS Chapter 3.

Response to Comment 4: Balance Between Transportation Network and Land Use The DEIS describes the transportation improvements required to meet current level of service requirements for the three Alternatives. Table 3.2-32 presents various policy mitigation options balancing land use, levels of service, and revenues that could also be implemented which would meet the requirements of State Law. With this information, decision makers can balance land use, revenues, and levels of service to ensure that the facilities required to meet the County’s levels of service are within the County’s means. The Transportation Element associated with the Recommended Plan provides a blend of transportation, funding, land use and policy changes that will meet the requirements of a balanced system. See the description of Comprehensive Plan amendments associated with the Recommended Plan in FEIS Chapter 2. Any land use alternative that is selected by County decision makers will require a balanced system. Some level of service (LOS) problems exist on the County’s arterials today. County arterials will likely have LOS problems at different times in the future as well. Technical Memorandum 3-18: Major Highway and Arterial Projects for Snohomish County presented the results of travel forecasting and level of service analysis for various highways and arterials within the County. This report was made available on the County’s website under the 10-Year Comprehensive Plan Update at the time the DEIS was circulated, and is available from the Public Works Department. This DEIS analysis includes east-west and north-south roads and identifies a network of roads needed to handle UGA expansion east of 35th Avenue SE. For the proposed UGA expansion areas to the east of 35th Avenue East, new collector arterials are recommended to serve proposed growth. Recommended road improvement projects, which are proposed to implement these improvements to the arterial system, will help mitigate forecasted level-of-service problems noted in the DEIS. Existing level-of-service deficiencies are addressed through the County’s Concurrency Management System. The DEIS discusses a number of policy measures that can be evaluated and implemented, together with infrastructure improvements, to address the projected revenue shortfalls noted in the DEIS and achieve a

Snohomish County Comprehensive Plan 5-119 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses balance between proposed land-use patterns, arterial level-of-service policies and standards, and forecasted revenues. Also see Response to Comment 3.

Response to Comment 5: Multifamily Locations are Problematic Any development in unincorporated Snohomish County under any land use category will be subject to the County’s critical areas regulations. Clustering of development may be an appropriate solution where there are significant wetlands or other critical areas present. Some of the proposed higher-density, multi-family land uses are located in areas that currently do not have neighborhood services or public transit service. The proposed land uses in these areas do include the types of land uses, such as, Urban Village and Urban Commercial, which would encourage the provision of neighborhood services in the future. In addition, these proposed higher-density; multi-family land uses have been clustered and located along arterials so as to promote the provision of transit in the future.

Response to Comment 6: Need Design and Locational Policies The Recommended Plan includes amended design standard policies for the Urban Centers as well as code amendments. See FEIS Chapter 2, and proposed GPP amendments.

Response to Comment 7: Sprawl, Auto Dependency, and Unhealthy Communities The DEIS includes a discussion of “Relationship to Plans and Policies” which describes the alternatives’ consistency with State GMA, Countywide, and County goals and policies, including goals related to land use patterns and transportation services. For example, in terms of Alternative 3, it is noted that “…more extensive UGA boundary expansions could have an undermining effect on … infill efforts.” See DEIS Section 3.2, page 3-229. The impacts of the Recommended Plan and Council Map List in terms of plans and policies are described in FEIS Chapter 3.

Response to Comment 8: Promote Greater Transit and Alternative Modes The land use alternatives in the DEIS include both those land uses and land use patterns that will likely promote greater use of transit and other shared-ride modes and those that will probably foster dependence on single-occupancy vehicles. Examples of the former include compact, mixed-use, higher-density land uses along transit corridors, such as Urban Center, Village Center, and Transit/Pedestrian Village designations adjacent to I-5 and SR-99. Large areas of Urban Low Density Residential are examples of the latter. Mitigation measures proposed to increase the use of transit and alternative modes are included on DEIS pages 3- 308 to 3-309.

Response to Comment 9: Cost and Supply of Oil – Implications for Snohomish County The DEIS does qualitatively describe impacts of the alternatives in terms of energy in Section 3.2.8. The analysis suggested to review the world’s projected oil supply through the year 2080 and effects on Snohomish County is beyond the scope of the DEIS. The planning horizon for the 10-

Snohomish County Comprehensive Plan 5-120 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Year Update of the County Comprehensive Plan is 2025. In addition, the future price of oil and its impacts are uncertain at present and the potential of alternative energy sources and technologies to replace petroleum-based transportation technologies are also unknown.

Response to Comment 10: Urban Form and Infill and Vision 2020 All Alternatives studied in the DEIS and FEIS include the “Centers” concept, and promote infill to differing degrees: • The No Action provides a significant amount of population growth within the current UGA boundaries by infill based on current Future Land Use Map designations, but this population is lower than the “most likely” OFM Forecast. • Alternative 2 included 3.5 square miles of infill and 2.4 square miles of UGA expansion. Centers are included in similar locations as the No Action and new locations are considered. • Alternative 3 included 6 square miles of infill and 11.5 square miles of UGA expansion. Centers are included in similar locations as the No Action and Alternative 2, and more new locations are considered. • Infill for both the Recommended Plan (6.6 square miles) and Council Map List (6.7 square miles) would be similar to but slightly greater than the Alternative 3 infill proposal (6 square miles). Under the Recommended Plan, total Urban Growth Area expansion of 4.3 square miles would be intermediate to expansions proposed under Alternatives 2 (2.4 square miles) and 3 (11.5 square miles). Under the Council Map List, total Urban Growth Area expansion (7.2 square miles) would be intermediate to expansions proposed under Alternatives 2 and 3, but closer to Alternative 3, and greater than under the Recommended Plan. Cities will also be updating their Comprehensive Plans to ensure goals regarding infill and avoidance of sprawl are met. The Recommended Plan includes amended design standard policies. It implements design standard regulations for the Urban Centers. See FEIS Chapter 2.

Response to Comment 11: Land Use Patterns that Promote Healthy Communities Please see Response to Comments 8 and 10.

Response to Comment 12: Variety of Housing Types, Styles, Forms and Configurations Areas of infill under any of the alternatives include moderate density, high density, and mixed use districts that offer the flexibility to develop alternative forms of housing such as townhouses, cottages, and vertical and horizontal commercial/multifamily developments. A description of the acres needed at various densities to meet housing needs is described in DEIS Chapter 3.2.3. Please see the discussion of the RLUNA model in particular. The RLUNA results related to the Recommended Plan and Council Map List are described in FEIS Chapter 3.

Response to Comment 13: Goals and Policies v. Implementation The comments are noted. Please see FEIS Chapter 2 for a discussion of the policy and regulatory amendments that are part of the Recommended Plan and Council Map List.

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5.5.1.5 FEIS Letter 280: John and Kathleen Evans

Response to Comment 1: How Growth Fits in Existing Neighborhoods The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 2: Coordinated Approach to Development – PDS Create Regional Teams The comments are noted and forwarded to the appropriate decision makers. PDS provides the opportunity for state, regional and local agencies to participate in review of County development applications; however, PDS does not maintain regional permit review teams.

Response to Comment 3: Ombudsman Office; Regular Neighborhood Meetings; Educational Sessions The comments are noted and forwarded to the appropriate decision makers. PDS strives to respond quickly and accurately to any public complaints concerning development activity in unincorporated Snohomish County; however, PDS does not maintain an ombudsman office.

Response to Comment 4: Loss of Trees and Wildlife The comments are noted and forwarded to the appropriate decision makers. Please note the mitigation measures in Sections 3.1.6 and 3.1.7 of the DEIS On page 3-165 a mitigation measure promotes the preservation of native vegetation including mature trees and promotes low impact development which reduces the size and promotes greater integration of drainage facilities as part of the natural landscape. The County currently has a demonstration ordinance for low impact development. The Recommended Plan includes amended policies addressing low impact development as summarized in FEIS Chapter 2.

Response to Comment 5: Traffic Level and Speed Comment noted. The County currently reviews the effect of development access on the existing street system and the development street system at the time of permit application. This process is currently being scrutinized and proposed to be improved as part of the County’s update of its policies and procedures. The County is analyzing the benefits of quicker and short-term improvements that can provide immediate improvement of traffic flow and be much easier to finance, as part of the Recommended Plan. Please see FEIS Chapter 2.

Response to Comment 6: Traffic Law Enforcement; Explore Traffic Issues Upfront Comment noted. Citizens reporting unsafe driving behavior or chronic speeding can always help enforcement. These complaints are usually followed by an examination of the reported problem and eventual action with respect to enforcement and traffic control changes.

Response to Comment 7: Construction Noise and Air Impacts, Multiple Developments, and Enforcement The comments are noted and forwarded to the appropriate decision makers. Please note the mitigation measures provided in DEIS Sections 3.1.2.3 and 3.2.7.3 that identify potential

Snohomish County Comprehensive Plan 5-122 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses measures to reduce construction noise. Please also note the multijurisdictional implementation of dust controls with the Puget Sound Clean Air Agency.

Response to Comment 8: Summary of Comments, Protect Existing Residents as Well As Accommodate Housing The comments are noted and forwarded to the appropriate decision makers. 5.5.1.6 FEIS Letter 281: Bonnie M. Frederick

Response to Comment 1: Schools The impact of the Alternatives upon school facilities is addressed programmatically in DEIS Section 3.2.11. Please also see FEIS Chapter 3 for a discussion of school impacts associated with the Recommended Plan and Council Map List.

Response to Comment 2: SW UGA Growth – Allocate to Other Places The growth is allocated among all of the designated UGAs. The Southwest County UGA is the largest and has a substantial portion of buildable land, generally in areas where infrastructure exists or could be provided. Additionally, the County is required to consider reasonable measures to accommodate growth by infill and not rely on UGA expansion only. Please see DEIS Chapter 2 for a discussion of growth allocations and buildable lands, as well as DEIS Chapter 3.2.2 regarding reasonable measures. These same topics are addressed for the Recommended Plan and Council Map List in this FEIS in Chapters 2 and 3.

Response to Comment 3: Avoid Multifamily Residences Near 39th Avenue SE – Stress to Traffic, Environment, and Neighborhood The comments are noted and forwarded to the appropriate decision makers. Please note that the DEIS and FEIS address impacts to transportation and the environment and propose mitigation measures. Please also note the Recommended Plan policies regarding design in FEIS Chapter 2.

Response to Comment 4: Prefer Alternative 1 The comments are noted and forwarded to the appropriate decision makers. 5.5.1.7 FEIS Letter 282: G. Green

Response to Comment 1: Status of Alternatives’ Decision? Has One Been Selected Prior to SEPA Process Completion? The adoption of a final land use alternative has not occurred as of the date of this writing. Actions to approve an alternative may not occur prior to the completion of the SEPA process. Development in accordance with the alternative selected may not occur until implementing regulations including zoning map amendments are made. Please see FEIS Chapter 2 for a discussion of the approval process.

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Response to Comment 2: Taxes Have Gone Up – Is This Based on One of The Alternatives? The basis for the increase in the tax assessment is a topic for the County Assessor’s Department. Please see the County website for more information. Frequently asked questions and responses are found at: http://www1.co.snohomish.wa.us/Departments/Assessor/Services/FAQ/. Please note that proposed but not adopted land use plans would not have been the basis for tax assessments in June 2004.

Response to Comment 3: How Will Workshop Results be Used in Creating the Preferred Alternative? The results of the workshops in May/June 2004 were provided to the County Planning Commission and County Council at their joint workshop in June 2004. The results of the workshops, along with feedback from decision makers at the joint meeting, GMA requirements, population forecasts, capital costs, etc. were used to develop criteria by which the Recommended Plan was formulated; the Council Map List shares several features of the Recommended Plan Future Land Use Map. Please see FEIS Chapter 2.

Response to Comment 4: Developer Literature – What Are Property Owner Rights? Property owners may decide individually whether to maintain a property as it is presently being used, develop it according to applicable land use and zoning regulations, or sell it. 5.5.1.8 FEIS Letter 283: Gene Grieve, June 14, 2004

Response to Comment 1: First Submittal The comments are noted. A second submittal was received June 18, 2004, FEIS letter 284.

Response to Comment 2: Watershed Approach The 10-Year Update DEIS is a programmatic document addressing the nonproject proposals that affect lands across several regions of the County. Contents of nonproject EIS documents are not required to be site or area specific: WAC 197-11-442 Contents of EIS on nonproject proposals. (1) The lead agency shall have more flexibility in preparing EISs on nonproject proposals, because there is normally less detailed information available on their environmental impacts and on any subsequent project proposals. The EIS may be combined with other planning documents. (2) The lead agency shall discuss impacts and alternatives in the level of detail appropriate to the scope of the nonproject proposal and to the level of planning for the proposal. Alternatives should be emphasized. In particular, agencies are encouraged to describe the proposal in terms of alternative means of accomplishing a stated objective (see WAC 197- 11-060 (3)). Alternatives including the proposed action should be analyzed at a roughly comparable level of detail, sufficient to evaluate their comparative merits (this does not require devoting the same number of pages in an EIS to each alternative).

Snohomish County Comprehensive Plan 5-124 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

(3) If the nonproject proposal concerns a specific geographic area, site specific analyses are not required, but may be included for areas of specific concern. The EIS should identify subsequent actions that would be undertaken by other agencies as a result of the nonproject proposal, such as transportation and utility systems. (4) The EIS's discussion of alternatives for a comprehensive plan, community plan, or other areawide zoning or for shoreline or land use plans shall be limited to a general discussion of the impacts of alternate proposals for policies contained in such plans, for land use or shoreline designations, and for implementation measures. The lead agency is not required under SEPA to examine all conceivable policies, designations, or implementation measures but should cover a range of such topics. The EIS content may be limited to a discussion of alternatives which have been formally proposed or which are, while not formally proposed, reasonably related to the proposed action. Although programmatic and intended to provide order of magnitude analysis, the 10-Year Update DEIS does provide some quantitative estimates of impacts to surface water and groundwater. Some of the key drainage basins located within current UGAs and/or proposed UGA expansion areas were analyzed in order to better understand the potential impacts of the Alternatives. DEIS Section 3.2.14 documents the analysis of these drainage basins, in which future land use changes were projected based on assumed impervious surface factors for all lands in the studied basins, including lands in the cities and unincorporated Snohomish County. In addition, DEIS Section 3.1.4 and Appendix C address all the groundwater basins in the Groundwater Management Area, which includes the area under County jurisdiction in the County (areas to the east are largely National Forest Lands). The Groundwater analysis assumed impervious surface factors for lands in the cities, tribal lands, as well as unincorporated Snohomish County, for a cumulative analysis. These analyses were prepared in the context of prior studies for groundwater (Groundwater Management Plan) and surface water (Drainage Needs Reports; see Table 3.2-49). Please see FEIS Chapter 3 for information on these topics related to the Recommended Plan and Council Map List. Note that some of the groundwater information was also updated in FEIS (see Appendix I-C) particularly related to nitrates.

Response to Comment 3: Introduction Page 3-1 of the DEIS states in part the following: It should be noted that this EIS addresses the proposed Comprehensive Plan for unincorporated Snohomish County only. Although some sections of this Draft EIS discuss cumulative growth patterns that include both incorporated and unincorporated growth, this discussion is provided for additional context and analysis only. It is not intended to serve as environmental review for the incorporated areas. Each incorporated city within Snohomish County is considering its own comprehensive plan amendments to accommodate future population growth and other related GMA requirements. Each city will conduct its own environmental review process for proposed comprehensive plan amendments. This paragraph is intended to clarify that the EIS is focused on County lands, but does consider cumulative impacts and common issues with other jurisdictions. Each jurisdiction has a requirement to plan lands under its jurisdiction, and the cities are under various timelines to complete their plan updates along with the County.

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The County’s focus upon County lands, while recognizing cumulative issues, is appropriate for the following reasons: • The County does not have jurisdiction over City lands. The County is primarily addressing land under its jurisdiction. The EIS is an informational document to assist County decision makers make informed choices. • The County is not proposing amendments to the Countywide Planning Policies. The formulation and adoption of Countywide Planning Policies is addressed through Snohomish County Tomorrow and ultimately approved by the County Council. • GMA does not require a single Comprehensive Plan for the County and cities, nor a single environmental analysis. The primary point of planning coordination among the cities and County is consistency with the Countywide Planning Policies. This is addressed in DEIS discussion of plans and policies (DEIS Section 3.2.2). • The EIS addresses cumulative growth where appropriate to the topic and nature of natural or built systems that cross several jurisdictions: Topics addressing cumulative City/County growth include, but are not limited to, air quality, surface water, groundwater, transportation, energy, etc. In these cases cumulative growth assumptions are assumed and addressed. For example, the traffic analysis considered major city roads and city capital plans (p. 3-287 and 3-288). As another example, groundwater and surface water analyses included assumptions for added impervious surfaces in the municipal portions of the studied basins (please see Response to Comment 2). Comments were solicited from the cities and other agencies at several points: through scoping, public meetings and forums, individual meetings with the governments, and Snohomish County Tomorrow. Agency comments have led in part to the formulation of a Recommended Plan considered by the County Council in the Council Map List (see FEIS Chapter 2).

Response to Comment 4: Insufficient Coordination with the South County Cities and Citizens Coordination between cities (in any part of the County) and the County has occurred through several means: • Initial coordination of population allocations through the Snohomish County Tomorrow forum, during Fall 2003; • Solicitation of city comments regarding the 2004 docket proposals included as part of DEIS Alternative 3, in Fall 2003; • DEIS distribution to the cities and the 45-day comment period, over May/June 2004; • Review of the DEIS Alternatives with the cities, during the development of the Recommended Plan, such as through staff-level meetings; • Four Joint County/Municipal Planning Commission workshops, in November 2004; and • Final Population Allocations, during 2004/2005. Further, the County will continue to work on reducing plan inconsistencies through the growth target and plan reconciliation process consistent with GPP and Countywide Planning Policies (CPPs).

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Public participation over the process included focus groups, open houses, workshops, questionnaires at workshops, website communication, mailing lists, etc. Please see FEIS Chapter 2 for a discussion of public participation methods for the 10-Year Update to date.

Response to Comment 5: GMA Requirements Please see Response to Comment 3.

Response to Comment 6: Multicounty Planning Policies Multicounty Planning Policies are a part of Vision 2020 and are addressed in DEIS Section 3.2.2, Relationship to Plans and Policies. Review of the Recommended Plan and Council Map List in terms of Vision 2020 is found in FEIS Chapter 3.

Response to Comment 7: Comprehensive Plans and Consistency The primary point of planning coordination among the cities and County is consistency with the Countywide Planning Policies. This is addressed in DEIS discussion of plans and policies (DEIS Section 3.2.2). To the extent that each jurisdiction’s plans are consistent with the Countywide Planning Policies, their plans should generally be consistent. Analysis of the Recommended Plan, Council Map List, and Countywide Planning Policies is provided in FEIS Chapter 3. Each letter of comment on the DEIS, including letters from cities, are included in Chapter 5 of this FEIS. This FEIS has been distributed to each agency that commented. Agency comments have been considered by decision makers prior to action.

Response to Comment 8: UGA Expansion East of Bothell into Bear Creek The Alternatives test different infill and UGA expansion concepts. SEPA provides broad latitude for alternatives analysis in nonproject SEPA documents (WAC 197-11-442). Several points of public outreach occurred to solicit comments. The DEIS received a 45-day comment period through which the public could comment on the UGA and infill proposals. The three alternatives were the subject of public workshops in June 2004 at which citizens could amend, combine, or make their own alternative, and these were presented to the County Council and Planning Commission on June 29, 2004. Public participation opportunities following the issuance of the DEIS are described in FEIS Chapter 2. Cities were also contacted to determine their preferences for UGA infill and expansion areas. Some hydrologic analyses were conducted in the Little Bear Creek basin, as documented in the DEIS. Please also see Letter 1, Response to Comment 3.

Response to Comment 9: A Significant Area To provide a context for surface water quality impacts, a comparison of urban and rural basins in terms of water quality currently experienced is included on DEIS pages 3-42 to 3-47 and included North Creek as the prime urban basin example. Sub-basins within the North Creek basin were analyzed for surface water impacts, particularly focusing on areas of substantial land use changes, and the analysis included some areas of Bothell. Please see DEIS Tables 3.1-10 and 3.2-56 and Figures 3.1-15 and 3.2-26. Swamp Creek was also analyzed across jurisdictional boundaries. Also, please refer to FEIS Chapter 3.

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Response to Comment 10: North Creek Watershed Management Plan See Responses to Comments 2, 3, and 9 regarding drainage analyses. The purpose of the 10-Year Update EIS is to address the Countywide Plan update just as the County did in 1995 with its countywide environmental documents: • Snohomish County Comprehensive Plan General Policy Plan, Draft Environmental Impact Statement (EIS), April 1994. • Snohomish County Comprehensive Plan, General Policy Plan Transportation Element, Addendum to Draft EIS, October 1994. • Snohomish County GMA Comprehensive Plan General Policy Plan, 1995-2000 Capital Plan, Transportation Element, Final EIS, Summer 1995. The 2004/2005 EIS addresses similar topics as the 1995 documents. Because the 2004/2005 document addresses a Comprehensive Plan Update rather than a wholesale change of the plan, it provides analysis about “areas of focus” where land use amendments are proposed, and where appropriate to the topic, does provide quantitative information.

Response to Comment 11: Canyon Park 7 Koll Business Park To prioritize resources, areas where the proposed County future land use changes were greatest were studied. However, in relation to the No Action Alternative, there was information in the Drainage Needs Report (DNR). For the DNR study, a hydraulic model of nearly the entire main stem of the creek was constructed. For the portion of the main stem that flows through the City of Bothell, the hydraulic model was based on information collected from previous studies, and as such does not specifically reflect actual hydraulic conditions in the Canyon Park and Koll Business Park areas. The DNR study identified some potential flooding problems along the main stem of North Creek within the City of Bothell for existing conditions and for the No Action Alternative. These problems are accounted for in some of the tables in the DEIS, though not specifically discussed in the text since this is a programmatic EIS. Budget constraints prevented an analysis of the other two proposed UGA alternatives for the entire North Creek basin for the DEIS. Please note that the County conducted additional analyses of the Recommended Plan and Council Map List in the North Creek basin for the FEIS (see FEIS Chapter 3). If additional funding and/or information were available, then the County could potentially perform additional analyses along these specific downstream reaches of North Creek.

Response to Comment 12: Idealized Solutions for Groundwater in Report The groundwater analysis did review all basins in the County Groundwater Management Area including all cities and unincorporated lands in the SW UGA. See Response to Comment 2. Proposed groundwater mitigation is or can be implemented by County plans and policies. Policy amendments and proposed code amendments associated with the Recommended Plan are described in FEIS Chapter 2. Further implementation of policies into development codes may be phased for larger work programs. Phased environmental review is appropriate under SEPA for future implementation efforts (WAC 197-11-060(5)).

Response to Comment 13: Detention Systems The County does have an inventory of many of the existing residential detention facilities. The County also inspects a number of these facilities to help ensure that they are properly

Snohomish County Comprehensive Plan 5-128 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses maintained. While some residential detention facilities could potentially fail in the future, it is not necessary to assume that all of these facilities would fail due to a lack of maintenance.

Response to Comment 14: Higher Densities East of Bothell See Response to Comment 10 under FEIS Letter 279.

Response to Comment 15: Parks The 43 parks around Bothell include City and County parks. Analysis and maps showing proximity to existing parks is provided in Appendix D of the Snohomish County 2001 Comprehensive Parks Plan. The plan is available online at: http://www1.co.snohomish.wa.us/Departments/Parks/Services/Publications/Comprehensive_Pla n. The PDF format document contains all of the appendices including Appendix D.

Response to Comment 16: Alderwood Water and Sewer Service The proposed infill areas east of Bothell are included in sewer service boundaries (see DEIS Figure 3.2-16). Site specific design options to provide sewer service to particular parcels will be addressed with future site specific design and environmental review. As the Recommended Plan was prepared, contact was made with service providers. It appears that sewer capacity will be upgraded by 2010.

Response to Comment 17: Traffic Impacts The DEIS presented a traffic analysis addressing a range of traffic issues (Section 3.2.6). In addition to considering County and State facilities, it considered major city roads and city capital plans (DEIS p. 3-287 and 3-288). More information can be found in the supporting technical document to the DEIS: Technical Memorandum 3-18: Major Highway and Arterial Projects for Snohomish County available at the time the DEIS was circulated. This support document presents the results of travel forecasting and level of service analysis for various highways and arterials within Snohomish County. A number of city arterials are identified along with mitigating improvement projects drawn from city plans and programs. The technical report was summarized for the DEIS, but was not included within the body or appendices of the DEIS because it was too voluminous. It is available from the Public Works Department. The memorandum identifies locations, needed improvements and resulting LOS for each facility. It should be noted that concurrency programs are not mandated to be consistent but need to be highly coordinated. In the Puget Sound region, PSRC performs the role of certification and reconciliation.

Response to Comment 18: Fire Protection and Building Setbacks The DEIS addresses public safety in DEIS Section 3.2.9 consistent with the programmatic nonproject action. As noted on page 3-351, uniform fire codes will apply in terms of sprinkler and other requirements, as will additional SEPA review for site-specific developments.

Response to Comment 19: Report Content Please see Responses to Comments 2, 3, and 10.

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Response to Comment 20: Alternative 2 or 3 UGA Expansion East of Bothell Please see Responses to Comments 4 and 8.

Response to Comment 21: Cooperative Effort Please see Response to Comment 4.

Response to Comment 22: Supplemental Review See Responses to Comments 2 through 10. 5.5.1.9 FEIS Letter 284: Gene Grieve, June 18, 2004

Response to Comment 1: Presentation of Comments and Reference to First Letter The comments are noted. A first submittal was received June 14, 2004, FEIS letter 283.

Response to Comment 2: Mill Creek Please see Responses to Comments associated with FEIS Letter 11, particularly Response to Comment 1.

Response to Comment 3: Everett Please see FEIS Letter 9 and associated responses to comments.

Response to Comment 4: Silver Firs As part of its interjurisdictional coordination efforts, the County will work with cities on “gaps and overlaps” in the SW UGA assignment of municipal urban growth areas. The Recommended Plan addresses MUGA policies in the Intergovernmental Coordination Chapter of the GPP.

Response to Comment 5: Park Planning and Greenbelts The County has prepared the 2001 Comprehensive Parks Plan. It will be regularly updated, such as after adoption of the 10-Year Update. As part of its update, public comment will be solicited. Please see County Goal LU 10 in the GPP Land Use Chapter, and associated map of the General Policy Plan regarding open space corridors. The policy and map are included with the Recommended Plan. Also, the recently amended Countywide Planning Policy OD-9 encourages development of joint development regulations addressing open spaces, landscaping and other features. The Recommended Plan includes amended GPP policies addressing joint development standards (see Interjurisdictional Coordination Chapter).

Response to Comment 6: Planning Standards Please see Response to Comment 5 regarding joint development regulations.

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Response to Comment 7: Bothell Please see responses to comments associated with FEIS Letter 8.

Response to Comment 8: Mountlake Terrace Please see responses to comments associated with FEIS Letter 13.

Response to Comment 9: Lynnwood A letter from Lynnwood regarding the DEIS was not received. However the City was included in efforts to solicit comments described under FEIS Letter 283, Response to Comment 4.

Response to Comment 10: Mukilteo Please see responses to comments associated with FEIS Letter 14.

Response to Comment 11: Edmonds A letter from Edmonds regarding the DEIS was not received. However the City was included in efforts to solicit comments described under FEIS Letter 283, Response to Comment 4.

Response to Comment 12: City Coordination Please see FEIS Letter 283, Response to Comment 4. Please also see responses to comments associated with FEIS letters 9 and 14. The potential impacts of the expansion into Little Bear Creek, the largest UGA expansion area was an area of focus of the DEIS analysis. The DEIS considered Alternative 1 which did not have a UGA expansion in the Southwest County area, and the FEIS considers the Recommended Plan which has no significant SWUGA expansion. The Council Map List reduces Southwest UGA expansion in comparison to Alternative 3.

Response to Comment 13: High Quality Planning Needed The comments are noted and forwarded to the appropriate decision makers. Please also see FEIS Letter 283, Response to Comment 4, and responses to comments 5 and 6 of FEIS Letter 284 above.

Response to Comment 14: MUGA Boundaries In October 2003 Snohomish County adopted Appendix B to its Countywide Planning Policies (CPPs) to reflect the results of a 2-year collaborative process of developing MUGAs (municipal urban growth areas) within the large Southwest UGA. Documentation of the MUGAs in affected city and county comprehensive plans is required in Countywide Planning Policies. The Recommended Plan adds MUGA related policies and a MUGA map. A MUGA map is included in Appendix II-E of this FEIS for reference.

Response to Comment 15: Block by Block Analysis Please see FEIS Letter 283, Response to Comments 2, 3, 4 and 10 regarding level of SEPA review. In terms of plan requirements, subarea planning is optional under GMA (RCW 36.70A.080).

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Response to Comment 16: Supplemental Review See Responses to Comments 2 through 10, FEIS Letter 283.

Response to Comment 17: Joint Open Meetings Four Joint County/Municipal Planning Commission workshops were held in November 2004. Please also see other coordination efforts described in FEIS Letter 283, Response to Comment 4.

Response to Comment 18: Plan in Accordance with GMA The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 19: Follow Up Comments Comments received as of 5 p.m. June 18, 2004 are included in these FEIS responses to comments. Please see Section 5.2.2 for a list of municipal comments.

Response to Comment 20: South Snohomish County Vision The comments are noted and forwarded to the appropriate decision makers. 5.5.1.10 FEIS Letter 285: Terrill W. Hendrickson

Response to Comment 1: Integration of County and City Plans See Response to Comment 2, FEIS Letter 283, regarding coordination between the cities and the County. The analysis of capital facilities and services primarily focused on County impacts because the DEIS focused on unincorporated areas. However, several analyses for shared “systems” such as roads and drainage basins considered municipal lands and plans. The traffic analysis considered major city roads and city capital plans (DEIS p. 3-287 and 3-288). The groundwater impacts analysis reviewed impervious surface increases in the Groundwater Management Area regardless of city or county jurisdiction and included assumptions about impervious surface in the cities as well as the County. See DEIS Section 3.1.4 and Appendix C, also updated in this FEIS (See Appendix I-C). The drainage analysis in DEIS Section 3.2.14 addressed drainage impacts in selected basins and sub-basins where increased development was estimated to be greatest and included assumptions for added impervious surfaces in the municipal portions of the studied basins. See DEIS Figures 3.2-18 to 3.2-26.

Response to Comment 2: Unassigned UGA Regarding MUGAs, please see Letter 284, Responses to Comments 4 and 14. Regarding Alternatives 2 and 3 UGA expansions, these are substantially scaled back along the SW UGA eastern border with the Recommended Plan as described in FEIS Chapter 2; the Council Map List includes less Southwest UGA expansion than Alternative 3.

Snohomish County Comprehensive Plan 5-132 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 3: Areas in Transition; Protection of Landowners Not Selling The DEIS is a programmatic countywide or regional analysis and not intended to result in parcel or area specific analysis. Decisions to sell property are regulated by the market and not the County. Snohomish County does not have the authority to establish rules governing codes of conduct for real estate discussions and transactions. The state regulates real estate and business licenses and may have established codes of conduct. Regarding slopes and trees, the impacts of development to adjacent properties are required to be disclosed during site-specific SEPA review. Please note the mitigation measures in Sections 3.1.6 and 3.1.7 of the DEIS, including on page 3-165 mitigation measures to promote the preservation of native vegetation and particularly mature trees and to promote low impact development which reduces the area of disturbance to the topography to better maintain the natural landscape and reduce drainage needs. The County currently has a demonstration ordinance for low impact development. Low impact development policies are strengthened in the Recommended Plan.

Response to Comment 4: Regional Trails The purpose of the EIS is to identify impacts. Bicycle Routes are described in DEIS sections 3.2.6 as they relate to mobility, and 3.2.8 as they relate to recreation. It is noted in the Transportation impact analysis and the Parks impact analysis that added growth would lead to greater demand for trails (e.g. pp. 3-295 and 3-362 respectively). Based on this analysis, County transportation and parks planners may use the information to develop updated capital plans to meet the demand. A bicycle facilities map associated with the Recommended Plan (under separate cover) and associated with the Council Map List (see FEIS Section 3.2.6) shows proposed exclusive and shared bikeways used for transportation. The adopted parks plan presents the additional smaller recreational facilities available within the County. See FEIS Chapter 3 for analysis of the Recommended Plan and Council Map List.

Response to Comment 5: Open Space Corridors It was intended that the DEIS summarize existing information and plans without duplicating information that is found in referenced documents. The County’s map of open space corridors is provided in the adopted General Policy Plan. The map shows water bodies, agricultural lands, forestry lands, city and county park lands, public school sites, State park and open space lands, State DNR lands, national forests, City watershed areas, public and private golf courses, cemeteries, County trail lands, power line corridors, and other utility pipeline corridors. An updated version of the map is included with the Recommended Plan at: http://www1.co.snohomish.wa.us/Departments/PDS/Divisions/LR_Planning/Information/Maps/M aps/10YearUpdatePlanningCommissionrecomendations.htm. An analysis of impacts by existing/proposed UGA area is provided on DEIS pages 3-171 to 3-176. Mitigation measures to protect of wildlife habitat are provided on DEIS pages 3-176 and 3-177.

Response to Comment 6: Parks within 2 Mile Radius As described above, the DEIS summarizes existing information and plans without duplicating information that is found in referenced documents. The 2-Mile Radius area analysis is

Snohomish County Comprehensive Plan 5-133 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses contained in the 2001 Comprehensive Parks Plan in Appendix D. The plan is available for review online at: http://www1.co.snohomish.wa.us/Departments/Parks/Services/Publications/Comprehensive_Pla n, or for purchase at the Parks and Recreation Department.

Response to Comment 7: Use of 2001 Parks Plan and Figure 3.2-12 The list of projects on page 3-359 of the DEIS identifies projects planned in the near term between 2002 and 2007, several of which are located in the SW UGA. The Parks Plan has a horizon year of 2012 and lists additional planned projects. In addition, depending on the land use alternative chosen, the County will update its Comprehensive Parks Plan to address growth levels and location particularly for years 2012 to 2025. Figures 3.2-12 and 3.2-13 are intended to show existing developed parkland and undeveloped parkland owned by the County currently. It is not intended to show future planned parks necessarily (although some future facilities may occur on the undeveloped land). Please see the 2001 Comprehensive Parks Plan.

Response to Comment 8: Park Area Overlays The DEIS provided a programmatic order of magnitude analysis of impacts which is appropriate to the nonproject nature of the action and the number of DEIS topics addressed. The impact analysis identifies the need for future parks and by Alternative indicates particular locations of concern (particular park service areas). Similar analysis is provided for the Parks impacts of the Recommended Plan and Council Map List. Depending on the land use alternative chosen, the County will update its Comprehensive Parks Plan to address growth levels and location. This update is expected to begin following the 10-Year Update. 5.5.1.11 FEIS Letter 286: Corrine R. Hensley

Response to Comment 1: Alternatives and UGA Requests The 10-Year Update DEIS is a nonproject EIS. Contents of nonproject EIS documents are more flexible in terms of alternatives analysis per WAC 197-11-442 (quoted under Response to Comment 2, FEIS Letter 283). The DEIS included the adopted FLUM (Figure 2.4-9) and a No Action FLUM Map (Figure 2.4- 10) which are nearly identical. The No Action alternative is the continuation of the current FLUM with technical changes that do not substantively affect capacity. The No Action technical changes are identified on DEIS page 2-19: changes that 1) reconcile inconsistencies between plan designations and zoning, and 2) recognize public uses. These technical changes affect lands within the UGA boundaries. No changes to the currently established UGA boundaries are proposed as part of the No Action Alternative. DEIS Table 1.3-1 and Table 2.4-1 incorrectly indicated minor adjustments to UGA boundaries to address specific issues, and pages 1-5 and 2-21 indicate no major changes to UGA boundaries with the No Action Alternative. These tables and descriptions are corrected in FEIS Chapter 4 to show that the May 5, 2004 No Action Alternative does not include UGA boundary adjustments, just minor technical adjustments to some lands within the established UGA boundaries. The maps and data are accurate for the Alternative, but the descriptive text needs to be corrected. To identify the Alternative 1 technical changes inside the UGA a Figure 2.4-10A is provided in FEIS Chapter 4.

Snohomish County Comprehensive Plan 5-134 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Please note that through a separate seven year GMA compliance review, the County reviewed technical UGA boundary adjustments and in November 2004, some technical adjustments for split parcels (parcels split by UGA boundaries) were made. However, they are not a part of the May 5, 2004 DEIS No Action Alternative. They are part of Recommended Plan and Council Map List described in FEIS Chapter 2. For the Alternatives 2 and 3 maps, a map showing the full FLUM categories, and those showing only changes, are provided to ascertain the infill and expansion capacity changes (Figures 2.4- 11 to 2.4-14). Also close-up UGA by UGA maps were made available on the County’s website at the time the DEIS was circulated (see ). Docket proposals were included only formally in Alternative 3 as a group. Appendix B provided a list of docket proposals and related the broad DEIS analysis to the individual requests. Appendix B referenced the maps of individual docket requests available online: http://www1.co.snohomish.wa.us/Departments/PDS/Divisions/LR_Planning/Projects_Programs/ GMA/Annual_Docket/2004_Docket/. The maps are included in FEIS Volume 1 Appendix B. Each Alternative including the No Action is compared in the DEIS to a 2002 base year, so the increase in growth is compared to a common baseline.

Response to Comment 2: Data Sources Without specific DEIS page or figure/table locations it is difficult to determine the desired clarifications or corrections generally described in the comment. The DEIS includes in Chapter 2 graphs showing population and acres. Population and acres were not shown on the same graphs, but different ones. Reviewing Chapter 2 graphs and charts, we note that the Y-axis label was inadvertently omitted from Figure 2.4-15, FLUM Comparisons – Rural Lands. The Y-axis label should read “acres”. This is corrected in FEIS Chapter 4.

Response to Comment 3: Wastewater Unlike King County, Snohomish County is not the provider of sewerage services, although the County would review and may approve applications for smaller treatment facilities within smaller communities if they were submitted by the districts or other entities outside of municipal boundaries. The rates are established by the sewerage purveyors.

Response to Comment 4: Special District Planning The DEIS summarizes the capital facilities and services of school districts, water districts, and fire districts in the following DEIS Sections: • 3.2.9 Police, Fire and EMS • 3.2.11 Schools • 3.2.12 Water Systems The affected environment discussions summarize current special and municipal service provider plans based on the County’s Capital Facility Plan inventories. The impact analysis provides an order-of-magnitude comparison of demand under each alternative. Mitigation measures address current programs and regulations and efforts to improve policies and regulations.

Snohomish County Comprehensive Plan 5-135 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

The service providers were included in the DEIS comment process, and are regularly consulted as part of the County’s Capital Facility planning efforts.

Response to Comment 5: Cumulative and Indirect Impacts The impact analysis is largely based on cumulative and indirect impacts of development in unincorporated Snohomish County for many natural environment and built environment topics. Several topics addressed issues of common concern with south County/King County: consistency with multicounty policies in Vision 2020/Destination 2030 (3.2.2 Relationship to Plans and Policies), selected drainage basin reviews such as North Creek (3.2.14 Drainage), use of PSRC model assumptions for traffic modeling to provide consistency with regional modeling efforts (3.2.6 Transportation).

Response to Comment 6: FCC Criteria for FCCs are described on page 3-209 of the DEIS (Section 3.2.2); policy UG-15 referenced in the Text is included in DEIS Appendix E. The DEIS was part of an integrated SEPA/GMA process. The analysis was intended to address impacts of a range of alternatives to help determine a preferred land use plan and appropriate/associated policy/regulation amendments. See DEIS Section 2.3.2, page 2-5. The DEIS provided an overview of FCC requirements and Alternative 3 compliance. A more in- depth review of FCC compliance is made in FEIS Chapter 3 in association with the Recommended Plan and Council Map List. The FEIS has been made available to inform the public and decision maker process on the Plan Update itself.

Response to Comment 7: Alternative 3 Costs and UGA Requests Comments regarding the costs of Alternative 3 are noted and forwarded to the appropriate decision makers. A UGA by UGA distribution of population and employment in DEIS Appendix A breaks out Maltby and SW County UGAs. DEIS Appendix A combines the infill and expansion acres for the SW and Maltby UGAs, as does the land use analysis in DEIS Section 3.2.1, but was not intended to confuse readers. Infill acres for the Maltby UGA are equal to zero for both Alternatives 2 and 3. Maltby UGA expansion areas that contribute to growth capacity are zero for Alternative 2 because the Urban Industrial Classification was proposed for the Brightwater property in public ownership. Alternative 3 UGA expansion acres totaled approximately 121 acres for Medium Density Residential (Wellington Hills), 59 acres for Urban industrial, and 17 acres for Urban Commercial. Regarding agency and jurisdictional UGA requests, no reference pages are provided in the comment, but we assume the comment is referring to docket requests. Municipalities in some cases filed docket requests that are part of Alternative 3. DEIS Appendix B lists the individual docket requests.

Response to Comment 8: Comment Period Comment noted. Please note that the County established a comment period of 45 days, a maximum period under WAC 197-11-455. However, the planning process does include additional meetings and hearings with the Planning Commission and City Council regarding the proposed land use plans and associated policies. The public process is further described in FEIS Chapter 2.

Snohomish County Comprehensive Plan 5-136 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 9: Alternative 1 Sizing Factor As adopted, Policy LU 1.A.1 states: UGAs shall contain sufficient land capacity for a variety of land uses and densities, including green belts and open space, in suitable locations to accommodate the county's 20-year population projection allocated to the urban area. The total additional population capacity within the Snohomish County composite UGA as documented by both City and County comprehensive plans shall not exceed the total 20-year forecasted UGA population growth by more than 15 percent. An additional population allocation that is in addition to and not part of the initial 2025 urban area allocation may be reserved for future UGA expansions specifically for TDR receiving areas. Following the initial establishment of the UGAs in the General Policy Plan, subsequent recalculation of the percent by which additional population capacity exceeds the 20-year forecasted population growth shall occur following the adoption of all UGA plans or at the time of the mandatory 5-year comprehensive reevaluation of UGA remaining capacity as required by Policy LU 1.A.9. It is proposed to be amended with the Recommended Plan, but would retain the capacity goal of the 20-year forecast plus 15 percent. The County has recalculated the percent of additional population based on a new 20-year OFM forecast for 2025 during a comprehensive reevaluation of remaining capacity as allowed in the latter sentences of the policy. Prior capacity estimates only address the 2012 planning horizon. The new No Action capacity analysis addresses a 2025 planning horizon. As described on DEIS page 3-246, the 18% safety factor is based on updated capacity information, market factors, and more recent density data: As described in Chapter 2, a safety factor is an allowance in the size of a UGA in recognition that all developable land is not going to develop as originally anticipated over the upcoming 20-year period. In sizing UGAs, Snohomish County generally seeks to provide a safety factor of approximately 15%. A 15% safety factor allows for some flexibility in future development while still maintaining a compact urban area. As shown above, however, the No Action Alternative would result in an 18% safety factor. This occurred as a result of updated capacity information, including market factors and more recent development density data, prepared after the Alternative was identified. This means that the original UGA boundaries could potentially accommodate a greater population in the year 2025 (approximately 5,800 more persons for a total UGA population growth level of 197,846) and still allow for a 15% safety factor. The No Action Alternative represents the capacity for development under current plan/zoning classifications. It accommodates a population of approximately 862,254 less than the OFM most likely population forecast of 930,000. Other alternatives test higher populations within the OFM population forecast range. Each Alternative including the No Action is compared in the DEIS to a 2002 base year, so the increase in growth is compared to a common baseline.

Response to Comment 10: No Action Alternative See Response to Comment 9.

Snohomish County Comprehensive Plan 5-137 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 11: Technical Corrections and Densities The No Action technical changes are identified on DEIS page 2-19: changes that 1) reconcile inconsistencies between plan designations and zoning, and 2) recognize public uses. The No Action includes existing plan/zoning classes and the capacity of development under these existing plan/zone classes. It also recognizes lands that are developed for public uses or that will be developed for public uses and that do not contribute to capacity. See Response to Comment 1 above.

Response to Comment 12: No Action – Minor UGA Adjustments Please see Response to Comment 1.

Response to Comment 13: Safety Factor and Policy Amendment Comment noted. Please see the summary of policy amendments associated with the Recommended Plan in FEIS Chapter 2.

Response to Comment 14: Low Growth Alternative Please see Responses to Comments1 and 11.

Response to Comment 15: Alternative 2 Safety Factor Alternative 2 is sized for a population of 896,105, and based on a capacity analysis the safety factor is calculated at 14%. This is comparable to the safety factor used to size the UGAs for the original 2012 plan horizon.

Response to Comment 16: Cathcart Business Park Alternative 2 Figure 2.4-12 identifies public/institutional and urban industrial uses at the Cathcart site. Alternative 3 Figure 2.4-14 proposes mixed institution, housing, and commercial uses. The Recommended Plan and Council Map List in FEIS Chapter 2 show medium density, urban village, industrial, and commercial uses. The nature of future development on the Cathcart site would be determined consistent with the applied zoning and future site-specific environmental reviews. Current information regarding the use of the property for consolidated County maintenance facilities may be obtained from the Public Works Department.

Response to Comment 17: Infill Land Use Changes Infill is described on page 2-19 as changes within UGA boundaries that create additional population or employment capacity. This is added to the DEIS Chapter 4 Glossary and References in FEIS Chapter 4.

Response to Comment 18: Island Crossing The DEIS was issued with the best available status information on Island Crossing. Appeals have concluded and the Island Crossing area retains its rural level land classes.

Response to Comment 19: GPP First Plan Analysis Question noted and forward to the appropriated decision makers.

Snohomish County Comprehensive Plan 5-138 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 20: Groundwater and Cross Valley Water District PDS has been working with water districts and reviewing comprehensive water district plans throughout the County, including Cross Valley Water District, Alderwood, and Silver Lake in the SW UGA as part of coordinated capital facility planning efforts. PDS staff directly facilitates the Water Utility Coordinating Committee, and attempts to identify and address all water supply issues through this committee in cooperation with the County Department of Health. Coordinated planning for future water supply demands is being forecasted through 2025 in the DEIS and FEIS. Regarding effects of the Recommended Plan and Council Map List in terms of environmentally sensitive areas, please see Response to Comment 3, Letter 1.

Response to Comment 21: Groundwater Mitigation The impact analysis for the groundwater assessment was limited to a screening level landscape analysis that identified areas of concern at a sub-basin scale. Projecting long term groundwater impacts and recommending specific mitigation measures is very complex and requires additional site specific analysis that is beyond the scope of an EIS of this scale. It is possible to manage land use and achieve groundwater protection, but the issues and solutions are very site specific. The DEIS acknowledges that impacts may occur and provides general guidance for Snohomish County to implement more specific monitoring and mitigation activities prior to initiating development. Please note the groundwater analysis has been updated in FEIS Appendix I-C, but mitigation measures are the same.

Response to Comment 22: Impervious Surface Development Regulations – Timing The adoption of development regulations to limit the amount of impervious surface installed by new development is primarily mentioned in the DEIS as a potential mitigation measure. Please note that the County has adopted a demonstration ordinance for low impact development, which has initiated policy discussions related to impervious surfaces. Your comments regarding the adoption of development regulations for impervious surfaces will be forwarded to the decision makers. Policy amendments associated with the Recommended Plan would strengthen concepts of low impact development as identified in FEIS Chapter 2. Some development regulation amendments are proposed to be adopted concurrent with the Plan Update as described in FEIS Chapter 2 and some will be implemented in phases.

Response to Comment 23: School Impacts The County coordinates with the school districts to help develop their capital facility plans/impact fee programs. The County adopts the school capital facility plans and incorporates them into the Snohomish county capital facility plan. The County solicits school district comments regarding the impact of growth and needed mitigation through the planning process. No school district, to date, has asked the County to deny permits based on lack of school capacity.

Snohomish County Comprehensive Plan 5-139 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 24: School District Input School Districts are contacted through the Capital Facility Plan process and have been contacted through the 10-Year Update review process as well, including being part of the DEIS distribution.

Response to Comment 25: Water Supply The groundwater analysis in DEIS Section 3.1.4 assumed that sub-basins that would experience increases in residential development would also experience increased demand on local groundwater. This is reflected in the projected incremental change in consumptive use for each sub-basin. Mitigating for increased demand on local groundwater would require collaboration between the County and larger water districts that draw from a more managed regional water supply. Please note the groundwater analysis has been updated in FEIS Appendix I-C, but mitigation measures are the same. Water supply is addressed as a public service in DEIS Section 3.2.12. The section uses per capita estimates to estimate future water demand cumulatively, but notes that water supply capabilities should continually be monitored, particularly in emerging areas. A cross reference is added in the Water Systems mitigation to the Groundwater mitigation. Please see FEIS Chapter 4.

Response to Comment 26: Rural Sewer Systems Rural wastewater treatment systems would need to meet the provisions of the County Health District and Comprehensive Plan/Zoning requirements. In Snohomish Health District Sanitary Code Chapter 8.1.4 the Health District allows community on-site sewage disposal systems for all lots, parcels and tracts not served by public sewer.

Response to Comment 27: Rural Septic Service Rural population is expected to increase by 2025, but still be approximately 20% of the total County population as described in DEIS Chapter 2. The estimates of wastewater demand are based on a per capita flow estimates. For rural areas, the rural population (separated in DEIS Table 2.4-2) would require appropriate on-site or community wastewater systems to meet demand at the particular locations where rural uses are designated and developed. Please note that the Recommended Plan indicates that the Rural growth would be about 15% of the planned countywide increase, and the Council Map List assumes 14% of the growth would be Rural.

Response to Comment 28: Flooding in King County To prioritize resources, areas where the proposed County future land use changes were greatest were studied. The flooding problems listed in the DEIS do account for some predicted flooding problems in King County, particularly for the main stem of North Creek. The analysis of potential flooding problems along Swamp Creek and Little Bear Creek was limited to Snohomish County. If additional funding and information were available, then additional analyses of downstream flooding could be conducted.

Response to Comment 29: Cross-Jurisdiction Drainage Mitigation Coordination One of the proposed mitigation measures listed in the DEIS is to implement the WRIA plans (see section 3.1.5.3). In the development of the WRIA 8 salmon conservation plan, Snohomish

Snohomish County Comprehensive Plan 5-140 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

County has coordinated closely with King County. Though not specifically listed in the DEIS, Snohomish County has also coordinated with King County in the development of the Tri-County salmon recovery plan.

Response to Comment 30: Adoption of DOE Stormwater Standards The County currently has a valid NPDES MS4 permit. Adjustments to the County’s current regulatory program for drainage and grading will be addressed following the reissuance of the County’s NPDES MS4 permit when the state requirements are clarified.

Response to Comment 31: Safety Factor Calculations After establishing the urban land supply with potential for development, the land capacity methodology then considers two categories of reductions for uncertainty: (1) the miscellaneous public purpose reduction and (2) the market availability reduction factor. The use of the miscellaneous public purpose reduction is intended to account for vacant, partially-used or redevelopable parcels in the buildable lands inventory that may be used for purposes other than new residential or employment uses over the next 20 years. A 5% reduction factor was used to account for the uncertainty of land availability for development due to: potential new regulations requiring larger detention ponds, potential need for regional or local stormwater facilities, potential need for transmission line, utility, or road or rail rights-of-way, potential need of land for public or institutional uses like police/fire stations, churches, water supply storage facilities, wastewater treatment and pump stations, landfills and transfer stations, cemeteries, libraries, daycares, small parks or open space, municipal offices, and other uses where we do not today have a specific map coverage to use. The use of the market availability reduction factor is intended to address the fact that not all developable land will be available for development over the GMA planning timeframe since not all landowners are willing to develop their property for a variety of reasons (investment, future expansion, personal use). The state publications on “Providing Adequate Urban Area Land Supply” (1992) and the “Buildable Lands Program Guidelines” (2000) both recommend that the methodologies “assume that a certain percentage of vacant, under-utilized, and partially-used lands will always be held out from development.” Since the current 10-year plan update reestablishes a 20-year plan horizon (to the year 2025), the present capacity analysis uses the same market availability reduction factors associated with the original capacity analysis performed for the 1992-2012 planning period: 15% for vacant land and 30% for partially-used and redevelopable land. Results from the recent Snohomish County property owner survey conducted by the Gilmore Research Group support these percentages. Please refer to the “Draft Snohomish County UGA Land Capacity Analysis Technical Report” published April 29, 2005 for a more detailed description of these two reduction factors used for the County’s land capacity analysis. Once the potential developable land supply has been reduced to account for the above two uncertainties, we are left with a developable land supply estimate that we estimate would be made available for development within the UGA over the next 20 years. It is this remaining amount of developable land supply that is used to calculate the amount of “excess” land capacity that exists within the UGA relative to 20-year forecasted growth (i.e., the “safety factor”). The excess residential land capacity estimate therefore excludes land that is estimated will not be used or available for new residential uses over the next 20 years and therefore cannot be counted as part of the 20-year residential land supply. This approach is consistent with the state publication “Providing Adequate Urban Area Land Supply” (1992) which shows

Snohomish County Comprehensive Plan 5-141 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses the market availability reduction step as separate and logically distinct from the subsequent UGA safety factor (excess capacity) calculation step.

Response to Comment 32: Special District Plan Coordination Please see Response to Comment 4.

Response to Comment 33: School, Water and Sewer Plans Please see Response to Comment 4.

Response to Comment 34: No Action Please see Response to Comment 1.

Response to Comment 35: Formal Amendments Later The DEIS was part of an integrated SEPA/GMA process. The analysis was intended to address impacts of a range of alternatives to help determine a preferred land use plan and appropriate/associated policy/regulation amendments. The Recommended Plan and Council Map List propose UGA infill, UGA expansion, and growth levels in the range of DEIS Alternatives. The policy and regulation amendments are related to and necessitated by the proposed FLUM update, or are internal consistency measures required by GMA, or are related to DEIS mitigation measures. They have been the subject of the public hearing process at which the public could comment on the merits of the proposals. Issue papers, proposed ordinances, and the FEIS were made available to the public and decision makers consistent with the planning process and SEPA requirements. Larger scope implementation items will be reviewed in a phased manner as described in DEIS Sections 2.3.5 and 2.3.6.

Response to Comment 36: Final Amendments and SEPA Process Please see Response to Comment 35.

Response to Comment 37: Incremental Review Subsequent nonproject and project actions may rely on existing environmental documentation and focus on the issues not otherwise addressed, consistent with SEPA. Please see the SEPA Handbook published by DOE for further discussion, available at the following web link: http://www.ecy.wa.gov/programs/sea/sepa/handbk.htm. As noted in Section 2.7 of the document: It is often possible to use existing documents to satisfy all or part of the requirements of SEPA. Existing environmental documents that analyze all or part of the environmental impacts of a proposal may be adopted, addended, or incorporated by reference. If there are any remaining environmental concerns, they can be addressed in supplemental analysis— such as a supplemental EIS or by an addendum issued with the new threshold determination.

Snohomish County Comprehensive Plan 5-142 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 38: SEPA Addenda Process An addendum is described on page 2-11 of the DEIS as analysis or information that does not substantially change the prior environmental analysis of significant impacts, based on WAC 197-11. If the addendum is issued prior to the completion of a FEIS, it would be a part of the FEIS and subject to agency appeals as allowed in SCC 30.61.300, or judicial appeals described in WAC 197-11-680. If a completed SEPA environmental document is adopted for an action with an addendum, the threshold determination and attached addendum may be appealed subject to the terms of appeal allowed for the DS or DNS per SCC 30.61.300.

Response to Comment 39: Future Use of Document As the EIS is programmatic and covers a large area and time period under various alternatives, the document may be used in whole or in part to address future actions. Please see Response to Comment 35 and 37.

Response to Comment 40: GPP Implementation A summary of the GPP review is included in Response to Comment 19.The 10-Year Update is an update and not a replacement of the 1995 plan. It updates and course-corrects the 1995 plan to apply to a 2025 time horizon. Some policy and development regulation amendments are proposed to be adopted concurrent with the Plan Update as described in FEIS Chapter 2 and some will be implemented in phases.

Response to Comment 41: Docket Analysis The purpose of the 10-Year Update/EIS is to evaluate alternatives testing different population and employment levels and infill and expansion proposals. The analysis is intended to support the update of the Comprehensive Plan that applies countywide, and not to take the focus away from the larger policy decisions that are under consideration. However, at the same time, the County has an annual docket process and considered how to integrate it into the DEIS and Update process. The 2004 Docket is part of the 10 Year Update of the County's Comprehensive Plan. All Council-approved docket proposals, the "Final Docket,” were studied under "Alternative 3". The County Council held a public hearing to set the 2004 Final Docket on October 29, 2003. The County received 113 docket proposals. Approximately 80 items were advanced for review. The customary staff recommendation (whether to include or exclude from the docket) for each proposal was replaced by an evaluation of how well the proposal corresponded with the Update's proposed future land use alternatives. The staff evaluation assessed each docket proposal to see if it fit into "Alternative 3" as well as population and employment forecasts, land use policy consistency, and City support. Docket proposals were included only formally in Alternative 3 as a group as part of the ranged analysis in the DEIS. DEIS Appendix B provided a list of docket proposals and related the broad DEIS analysis to the individual requests. Most are private requests. Appendix B referenced the maps of individual docket requests available online. Any site-specific developments that may be proposed on these sites would be subject to subsequent environmental review. Docket maps are provided in this FEIS in Appendix I-B along with brief summary sheets of each item.

Snohomish County Comprehensive Plan 5-143 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 42: Alternative 2 and Docket Requests Please see Response to Comment 41.

Response to Comment 43: Rural Service Demand The statement is from the GPP Introduction, page 13. The statement is meant to say, “Demand in rural areas will likely have a corresponding decrease than if growth were not focused in UGAs.” This is clarified in FEIS Chapter 4.

Response to Comment 44: Rural Population Increase Please see Response to Comment 6, FEIS Letter 3.

Response to Comment 45: Where Has Population Moved Please see Response to Comment 6, FEIS Letter 3.

Response to Comment 46: Public Preferences for UGAs Annual Growth Monitoring Reports indicate annual trends in population. Please see the following web link: http://www1.co.snohomish.wa.us/Departments/PDS/Divisions/LR_Planning/Information/Maps/D emographics/Growth_Monitoring/2004_GMR_Report.htm.

Response to Comment 47: Maltby Population Distribution A population target for the Maltby UGA is shown only for Alternative 3 (311 persons by 2025). This target was created since Alternative 3 added an area of urban medium density and urban low density residential designations immediately adjacent to the existing Maltby UGA boundary in the Wellington Hills area. Population targets were not created for the Maltby UGA under Alternatives 1 and 2 since new urban residential designations were not proposed immediately adjacent to the UGA as they were under Alternative 3.

Response to Comment 48: Population versus Employment Distributions Employment forecasts are based on a capacity analysis of buildable lands for each Alternative. Each Alternative varies location and type of employment related land use class, particularly in the UGAs. In Alternative 3, it is noted on DEIS page 3-199 that several UGA border areas would have commercial and industrial uses. If these areas were not included in the UGA and remained Rural, it is possible that they would provide capacity for rural employment. The main reason for the drop in the 2025 rural employment target under Alternative 3 is noted in footnote #3 at the bottom of page A-4 – the sheet labeled “2025 SCT Employment Target Allocation Used for Development of Final Nov-20-03 Alt 2 and Final Dec-8-03 Alt 3 MAZ Allocations – Based on Preliminary City Responses to Draft Initial Targets as of Aug-21-03.” The footnote states: “Only Alt 3 assumes creation of proposed Tulalip UGA (within which total 2000 employment was estimated to be 1,588. Rural employment total for 2025 is therefore reduced only under Alt 3 as a result.” It is the shift of the area associated with the proposed Tulalip UGA under Alternative 3 (with all its existing and projected employment) into the UGA

Snohomish County Comprehensive Plan 5-144 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses and out of the rural area, which causes the 2025 rural area employment allocation under Alternative 3 to drop.

Response to Comment 49: Rural Placed in UGAs None of the alternatives propose to remove all of the designated Rural land in the County. The amount of Rural Residential classed land varies as much as 3% under Alternative 3. Please see DEIS Table 3.2-2.

Response to Comment 50: Safety Factors and Other Deductions Please see Response to Comment 9.

Response to Comment 51: Change Development Codes to Accommodate Growth Comments to intensify in current UGA boundaries as an alternative are noted. Alternative 1 (the “no action” alternative) in the DEIS represented a scenario of continuing growth within the existing UGA boundaries. The UGA boundaries were originally created in 1995 for a target population of 714,000 (projected for the year 2012). The current UGA boundaries, which have not changed appreciably since 1995, are now estimated to accommodate over 741,303, while maintaining a reasonable “safety factor” of additional capacity. This change is due to the higher densities that we are now experiencing in both city and unincorporated areas, resulting from changes in county code and other “reasonable measures” that have been implemented since 1995 to increase the capacity of our urban areas. Alternative 1 presumes that we will continue to experience these higher urban densities in accord with the current policies and implementing code measures of the past several years. Further, please note that the Recommended Plan and Council Map List promote greater infill than Alternative 3 and less expansion than Alternative 3 and reach populations around the OFM most likely population levels. Under Alt 1 (No Action), the total 2025 UGA population capacity was estimated in the DEIS to be 741,303, with a total 2025 UGA population allocation of 706,763. Alt 2 assumed a total 2025 countywide population of 896,105 with a 2025 UGA population allocation of 729,139. Alt 3 assumed a total 2025 countywide population of 950,369 (without the FCC population reserve) with a 2025 UGA population allocation of 771,636. The OFM most likely projection for 2025 is roughly 930,000, so a 2025 UGA population allocation would reasonably be expected to fall somewhere between 750,000 and 760,000. As can be seen, capacity within the existing UGA under the No Action alternative (741,303) falls far short of being able to accommodate the level of UGA population growth expected with the OFM most likely forecast (especially when you add in a UGA safety factor). Clearly, measures to create additional urban capacity through a combination of infill and UGA expansion are necessary in order to achieve a 2025 countywide population approximating the OFM most likely forecast.

Response to Comment 52: No Action Could Take All Growth The UGA sizing safety factor is an additional amount of development capacity provided within UGAs in recognition that some developable land may not be developed or fully developed in the next twenty-year period. The No Action alternative has the capacity for 862,254 persons plus an 18% safety factor. It is within the range of the OFM population forecasts and has been an option before the decision makers.

Snohomish County Comprehensive Plan 5-145 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 53: Public Uses A “Public Use” land use designation was not utilized for the FLUM in the County’s initial GMA plan, which was adopted in 1995. However, subsequent UGA-level planning projects completed in the late 1990’s did create such land use designations within selected UGAs, such as Lake Stevens and Mill Creek. In general, these designations are only applied to lands that have actual public facilities present on the land, such as schools, parks, public works facilities, and other sites that are actively in public use and are owned by a public entity. A public use designation helps the FLUM provide a better picture of the extent of the public infrastructure needed to support urban growth.

Response to Comment 54: Public Uses and SEPA Review Please see Response to Comment 53 regarding Public Use land classes. Adopted FLUM public use classes were reviewed with the subarea plans that created them. The No Action Alternative is reviewed in the 10-Year Update DEIS programmatically (however as noted previously the Public Use technical corrections the category applies to existing public uses or lands owned by public entities for public uses). Existing public uses would have been subject to SEPA at the time developed. Future public uses not yet developed on such properties would be subject to SEPA review at the time of permit application review; however, public uses are typically developed as a result of capital facility plans or functional plans (e.g. water and sewer system plans) which also would require SEPA review.

Response to Comment 55: Agency or City Public Uses Please see Response to Comment 54.

Response to Comment 56: Essential Public Facilities GMA defines essential public facilities as including (RCW 36.70A.200): …Essential public facilities include those facilities that are typically difficult to site, such as airports, state education facilities and state or regional transportation facilities as defined in RCW 47.06.140, state and local correctional facilities, solid waste handling facilities, and in- patient facilities including substance abuse facilities, mental health facilities, group homes, and secure community transition facilities as defined in RCW 71.09.020. In general, Public designations are only applied to lands that have actual public facilities present on the land, such as schools, parks, public works facilities, and other sites that are actively in public use and are owned by a public entity. The Public Use category is applied to some properties that would be considered essential public facilities. See also Responses to Comment 53 and 54.

Response to Comment 57: Necessary Public Facilities Please see Response to Comment 56

Response to Comment 58: Technical Corrections Since the corrections either resolve inconsistencies with the plan/zoning classes (which currently apply) or recognize public uses, they are not seen as increasing capacity for development beyond what is currently allowed. Please see Responses to Comments 1 and 11.

Snohomish County Comprehensive Plan 5-146 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Please see Chapter 4 of this FEIS for an Alternative 1 map identifying non-capacity related FLUM “changes”.

Response to Comment 59: Implement GPP The Comment is noted and forwarded to the appropriate decision makers. Please see Response to Comment 52. Also, please see Letter 1, Response to Comment 5.

Response to Comment 60: Intensifying over Expansion The Comment is noted and forwarded to the appropriate decision makers. Please see Response to Comment 52. Also, please see Letter 1, Response to Comment 5.

Response to Comment 61: Maintain Existing UGA Boundaries The Comment is noted and forwarded to the appropriate decision makers. Please see Response to Comment 52. Also, please see Letter 1, Response to Comment 5.

Response to Comment 62: No Action Technical Corrections Please see Response to Comment 58.

Response to Comment 63: Current UGAs Please see the reasonable measures analysis in FEIS Chapter 3. The County has also prepared a Reasonable Measures analysis available from PDS upon request.

Response to Comments 64: No Lowering Density One area is shown for reduced density in the Lund’s Gulch area due to environmental constraints. The reduced density is shown in Alternative 3, the Recommended Plan and Council Map List. Otherwise the focus of the proposals inside UGAs is intensification.

Response to Comments 65: Intensification and Expansion Please see Response to Comments 52 and 59. Also, please see the reasonable measures analysis in FEIS Chapter 3.

Response to Comment 66: Infill is Important The comment is noted and forwarded to the appropriate decision makers. Several Urban Centers are shown along Highway 99 in all Alternatives.

Response to Comment 67: Infill Limited by Reclassification Alternative 1, 2, and the Recommended Plan focus more heavily on infill development than UGA expansion. The Council Map List has a nearly equal attention between infill and UGA expansion. These alternatives would include upzones to create the additional infill capacity.

Snohomish County Comprehensive Plan 5-147 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 68: Undefined/Water Acres Table 2.4-4 lists acres estimates from the City’s GIS System. Unidentified land uses tend to be rights-of-way without land classification or “slivers” of polygons. The differences are not consequential. As explained on page 2-10 and DEIS Appendix A : To assist in the preparation of the programmatic EIS analysis, Geographic Information System (GIS) analysis was used to study alternatives, evaluate potential impacts, and prepare maps and data for various natural and built environment topics. GIS is an analytic tool that allows for the in-depth analysis of land use characteristics useful for growth management planning. The GIS analysis prepared in conjunction with this EIS is intended to allow for a policy-level comparison of alternatives. Because the GIS analysis depends on databases with varying dates and assumptions, minor variances in acreage estimates and boundary locations are expected. The Growth Management Act encourages monitoring, and the County can further refine and update its databases and its approach over time as appropriate.

Response to Comment 69: Agriculture Table 2.4-4 identifies FLUM designated acres, not present use.

Response to Comment 70: Agriculture Decreases As Table 2.4-4 indicates, Alternative 3 includes proposals to reclassify designated agricultural land. Please see Response to Comment 3, FEIS Letter 1.

Response to Comment 71: Rural Residential Decreases The comment is noted.

Response to Comment 72: Urban Densities Increase The comment is noted.

Response to Comment 73: Public Uses Please see Response to Comment 53.

Response to Comment 74: Alternative 2 Urban Commercial The difference between Alternative 1 and 2 is explained by Table note 1 which indicates that Centers are designated under Alternative 1 with “overlays” and not base FLUM designations. Alternative 2 increases “Centers” categories and reduces “Urban Commercial.” Commercial uses are possible in Centers as part of mixed-use developments. Note 1 associated with Table 2.4-4 is further expanded to explain this and added to the Urban Commercial line. Please see FEIS Chapter 4.

Response to Comment 75: Rural Freeway Service The variation of one acre is not intended to imply a formal proposed change to the Rural Freeway service. Please see Response to Comment 68 regarding GIS data accuracy.

Snohomish County Comprehensive Plan 5-148 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 76: Other Land Uses As explained below Table 2.4-4 on page 2-20, Other Land Uses is “a holding designation pending focused planning for urban uses.” The Other Land Use Category is defined in the current General Policy Plan as: This category includes (1) land with various subarea comprehensive plan designations such as Airport, Reformatory, and Fairgrounds, (2) areas that are within the UGA but still have an Agriculture designation on a subarea comprehensive plan or were designated as interim agricultural land prior to the adoption of the General Policy Plan, and (3) areas within the UGA that will be studied for their potential as future employment land. Subdivisions or rezones within the Other Land Uses designation will be delayed until the development potential of these areas is determined in more detailed UGA plans with appropriate urban land use designations. As proposed the Recommended Plan and Council Map List would reclassify “Other Land Use” to basic land class categories.

Response to Comment 77: Centers and Alternative 1 DEIS Table 2.4-4 note 1 indicates that Centers are designated under Alternative 1 with “overlays” and not base FLUM designations. Please see FEIS Figure 2.4-10.

Response to Comment 78: Availability of Document The Full DEIS, all sections and appendices, was made available on the County website (see: ). In addition a CD was made available for $5.00, and hard copies for $35. Additional reference copies were placed at a number of libraries as indicated in the DEIS Distribution list. The document comprehensively addressed a wide number of topics, and the intent was to provide information to assist the public review process of the 10-year Update.

Response to Comment 79: Centers and Alternative 1 Please see Response to Comment 77.

Response to Comment 80: No Action UGA Boundaries Please see Response to Comment 1. There are 4 square miles of technical corrections within the UGA boundaries, but no UGA boundary expansions with this Alternative.

Response to Comment 81: King County Mixed Communities The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 82: Concentrated Growth Please see FEIS Letter 279, Response to Comment 10.

Response to Comment 83: No Action Increased Densities Please see Response to Comment 58.

Snohomish County Comprehensive Plan 5-149 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 84: No Action and UGA Boundaries Please see Responses to Comments 1 and 11 and 58.

Response to Comment 85: No Action Safety Factor Please see Response to Comment 9.

Response to Comment 86: Alternative 1 with Alternative 2 or 3 Infill Please see Response to Comment 51 above and Response to Comment 5, FEIS Letter 1. Also please see the reasonable measures analysis in FEIS Chapter 3.

Response to Comment 87: Alternatives and Growth Rates As described in Section 2.2.3 and Appendix A, the State OFM provided the forecasted population numbers. A population of 930,000 approximately was considered the “most likely” level by 2025. Please also see Response to Comment 17, FEIS Letter 23.

Response to Comment 88: Data Replication The data sources are noted for tables and graphs and vary by topic. Acres, population, and employment estimates were generated based on inputs of mapping information, and Geographic Information System outputs. Methodologies are summarized. Without specific references to tables, graphs, and data sources, it is difficult to provide more elaboration.

Response to Comment 89: No Action Residential and Employment The No Action Alternative would accommodate residential and employment uses according to FLUM and zoning allowances. The capacity for residential and employment is described on pages 2-16 and 2-17 of the DEIS.

Response to Comment 90: Balanced Approach to Employment and Residential By 2025, reviewing the number of jobs to housing units, the No Action could have a jobs/housing balance of 0.96 to 1.01 (331,906 jobs and 325,379 to 344,902 dwellings; See DEIS Chapter 3.2.3).

Response to Comment 91: No Action Technical Changes Please see Responses to Comments 53 and 58.

Response to Comment 92: SW UGA New Growth The Comprehensive Plan provides the capacity for growth, and capacity for growth (buildable lands) exists near infrastructure in the Southwest UGA. Most growth is occurring now in the SW UGA, and it is the largest UGA. Monitoring for changes in market preferences is provided for in the County’s annual Growth Monitoring Report, annual Comprehensive Plan docket process, and Comprehensive Plan review every seven years.

Snohomish County Comprehensive Plan 5-150 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 93: Alternative 1 Rural There are no UGA boundary adjustments per Response to Comment 1. There are no rural reclassifications as a consequence.

Response to Comment 94: Growth Monitoring Report The DEIS uses the 2002 Buildable Lands Report approach, further refined to include a single, empirically-evaluated methodology (see the comparison chart developed for the “Draft Snohomish County UGA Land Capacity Analysis Technical Report” published April 29, 2005 in Appendix II-B), and including updated buildable lands information (land developed since 2001) and recent density trends.

Response to Comment 95: Maltby UGA Employment The Recommended Plan and Council Map List do propose designation of three new urban industrial areas for potential new economic development initiatives: 1) a large area between Arlington and Marysville that includes both an expansion to the UGA and a re-designation of land within the existing UGA; 2) land within the Cathcart Regional landfill site, which is located within the existing UGA and is no longer needed for public uses and is therefore available for a designation for other employment land; and 3) the Wellington Hills site located just south of the Brightwater site, which is adjacent to the existing UGA. These three sites provide larger parcels that can be attractive to larger industrial or business developers and will more than compensate for the “loss” of 100 acres of urban industrial land to the Brightwater project.

Response to Comment 96: Alternatives’ Capacity Please see Response to Comment 94.

Response to Comment 97: Alternative 2 The capacity of buildable lands with the infill intensifications and the UGA expansions is expected to accommodate the population of 896,105 plus a 14% safety factor.

Response to Comment 98: Current UGA Boundaries Please see Response to Comment 1.

Response to Comment 99: Cathcart Development Please see Response to Comment 16.

Response to Comment 100: Alternative 3 and SW UGA The Southwest UGA is the largest UGA under any Alternative. The SW UGA would remain the largest UGA with the greatest capacity for development of buildable lands under Alternative 3 even though other individual UGAs are also intensifying/expanding.

Snohomish County Comprehensive Plan 5-151 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 101: County-City Coordination on Increased Densities Population and employment allocations have been coordinated through Snohomish County Tomorrow. Policy issues were a subject of County and City joint planning meetings in November 2004 (4 meetings). The DEIS analysis showed that the cities as a group would need to increase capacities to accommodate their share of population targets (see DEIS Section 3.2.3; capacity of 89,822 including Everett Marina and Transit Station plans, and an allocation of 95,168). FEIS Chapter 3 presents a review of City and County capacity related to the Recommended Plan and Council Map List.

Response to Comment 102: Balanced UGAs The distribution of population and employment for each UGA is provided in DEIS Appendix A.

Response to Comment 103: Continuation as Bedroom Community The alternative plans and growth scenarios analyzed in the DEIS look at both population and employment growth that is projected for Snohomish County over the next twenty years. The Recommended Plan and Council Map List attempt to move beyond simply accommodating probable growth (what is likely to occur) into capturing and promoting a vision of Snohomish County for the future (what the County wishes to become). Economic development objectives are a part of the final recommended plan amendments, which will include sufficient land and policy support for future business development and job-creation within the County that can lessen the County’s dependence on jobs in King County.

Response to Comment 104: Employment Distribution Please see DEIS Appendix A for specific employment allocations upon which the graphs in Chapter 2 are based.

Response to Comment 105: Growth Accommodation without Technical Corrections Please see Response to Comment 58.

Response to Comment 106: Cathcart Review At a programmatic level, the DEIS reviews natural and built environment impacts. Future site- specific developments would need appropriate levels of SEPA review to address site-specific concerns. Under present County regulations, the Cathcart site is undergoing a separate environmental review for purposes of a consolidated maintenance facility proposal. Wetlands, traffic, and other issues are being considered.

Response to Comment 107: SR-9 Speed Limit Cathcart/Maltby Area State Route 9 is a highway of statewide significance and is under the jurisdiction of the Washington State Department of Transportation. Snohomish County has no jurisdiction with regard to setting speed limits on state routes. The County does see the need to coordinate with

Snohomish County Comprehensive Plan 5-152 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses the WSDOT to ensure safe speeds on state highways particularly those that traverse urban areas or more intensely developed rural areas like Cathcart-Maltby area.

Response to Comment 108: Alternative 3 Infill The DEIS tested a range of infill and UGA expansion options. See Response to Comment 5, Letter 1 regarding infill and expansion related to the Recommended Plan and Council Map List.

Response to Comment 109: No Action Status Quo Please see Responses to Comments 1 and 11.

Response to Comment 110: Alternative 3 Safety Factor Alternative 3 is sized for a population of 950,369 (without the un-sited FCC), and based on a capacity analysis the safety factor is calculated at 11%.

Response to Comment 111: Safety Factor and Deductions Please see Response to Comment 31.

Response to Comment 112: Reduction Factor Differences Please see Response to Comment 31.

Response to Comment 113: Use of Prior Land Please see Response to Comment 9.

Response to Comment 114: Accommodate Growth without Expansion Please see Response to Comment 108.

Response to Comment 115: Rural Clusters The comments are noted and forwarded to the appropriate decision makers. The intent of the Rural Cluster Subdivision (RCS) is to allow a higher gross density than would be possible in a traditional rural subdivision in return for setting aside at least 45% of the total site as open space. By clustering more houses on the most buildable portion of a rural site and preserving larger contiguous undeveloped tracts, RCS subdivisions allow land owners a potentially higher return from developing their land while at the same time providing more protection of the rural character and natural environment than would a traditional 5-acre lot subdivision.

Response to Comment 116: Increased Growth without Expansion The No Action Alternative represents an increase in growth with current UGA boundaries. Please also see Response to Comment 108.

Response to Comment 117: No Action Economic Development Describing a scenario where the No Action economic development is not achieved as planned, and the alternative measures that would be employed in that case, would be speculative. However, Growth Monitoring Reports, the annual County docket process, and the seven-year GMA reviews, provide opportunities to adapt the Plan to changing circumstances if appropriate.

Snohomish County Comprehensive Plan 5-153 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 118: Employment Lands Valuable The comment is noted and forwarded to the appropriate decision makers.

Response to Comment 119: Alternative 1 Intensification The No Action Alternative represents an increase in growth with current UGA boundaries. Please also see Response to Comment 108. The EIS addresses Alternatives 1 through 3, the Recommended Plan and the Council Map List. A future land use alternative adopted within this general range would be addressed by the EIS. Future site-specific developments would require their own review as described under DEIS sections 2.3.5 and 2.36.

Response to Comment 120: City and County Document Conflicts The comment appears to be indicating there are differences between City plans and preferences and the DEIS Alternative land use plans. As part of the public review process, the County has coordinated with the cities at several levels to determine population targets, preferences for land use classes, and other related matters. Please see Response to Comment 9, FEIS Letter 3, and Response to Comment 4, FEIS Letter 283.

Response to Comment 121: Range of Alternatives Please see Response to Comment 119.

Response to Comment 122: FCC The Countywide Planning Policies were amended in 2004 to allow FCCs if reserving population will not bring Snohomish County above the high range of its population target. The County also reserved 15,000 of its 2025 future population allocation for possible FCCs. A FCC could provide an example of coordinated planning and development that provides a healthy environment for its residents. If population grows faster than anticipated, a FCC could provide an alternative way to grow other than expanding UGAs. By mixing uses on site, a FCC may be able to reduce off-site commuter and shopping trips. Based on GMA and CPP requirement and policies, a FCC must be compatible with surrounding uses and not cause undue development pressures on resource lands. Also, the FCC must be developed in accord with other existing policies and regulations of the County. The policies also refer to a detailed development agreement that will incorporate the master plan for the community as well as detailed terms of agreements on uses, phasing and mitigations. Please see FEIS Chapters 2 and 3 for more information on proposed FCC policies and regulations. Also see Response to Comment 6 above.

Response to Comment 123: FCC Policies Please see Response to Comment 6 and 122.

Response to Comment 124: Alternative Policies Please see Response to Comment 35.

Snohomish County Comprehensive Plan 5-154 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 125: Docket SEPA Review Please see Response to Comment 41.

Response to Comment 126: Docket Items are Projects The Docket process is a process whereby property owners or agencies can request changes to the County Comprehensive Plan. It is not a process that provides “project” permits. Docket items are legislative amendments. Future site-specific developments on any docket sites would require their own SEPA review. Please see WAC 197-11-704 for a description of project versus nonproject actions.

Response to Comment 127: Mix of Housing and Employment All Alternatives include Centers with mixed housing and employment opportunities, Alternative 1 through overlays, and Alternatives 2 and 3 with a variety of Center classifications. The location of Centers is more fully described in DEIS Section 3.2.1 in the Impact Analysis.

Response to Comment 128: Make Existing UGAs more Livable, Avoid Sprawl The comment is noted and forwarded to the appropriate decision makers.

Response to Comment 129: Other Alternatives All Alternatives assume intensification within existing UGA areas. Please also see Response to Comment 7, FEIS Letter 3, and Response to Comment 10, FEIS Letter 279.

Response to Comment 130: Visual Assessment Survey Similar to the County’s 1995 EIS on its Comprehensive Plan, the DEIS Aesthetics section is a qualitative analysis of aesthetic impacts consistent with the nonproject nature of the Plan Update. A summary of the survey is added to the DEIS Aesthetics Section in FEIS Chapter 4. Although the Visual Assessment Survey was completed over ten years ago, it provides some valuable information for the 10-year plan update. Policy amendments associated with the Recommended Plan implement some of the recommendations of the Visual Assessment Survey. Please see FEIS Chapter 2.

Response to Comment 131: City Densities Cities are required to have densities consistent with GMA requirements, generally 4 dwelling units per net acre, unless an area has significant critical areas of high quality. Some cities may need to make adjustments to their Comprehensive Plans as they have conducted their 7-year compliance reviews and/or plan updates to ensure they meet GMA density requirements.

Response to Comment 132: City Plans and Appeals Snohomish County has generally attempted to work with its cities on growth management issues through the Snohomish County Tomorrow process. In the past, the County has partnered with many of its cities on joint planning projects for urban growth areas that have resulted in comprehensive plan amendments by both parties. Snohomish County has also collaborated with the cities (through the SCT process) on the development of “reasonable

Snohomish County Comprehensive Plan 5-155 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses measures” strategies to achieve more efficient use of urban land within incorporated and unincorporated urban areas. The County has also provided comments to the cities on their comprehensive plans through SEPA or other opportunities. Although Snohomish County would not rule out the possibility of a formal appeal, it much prefers the collaborative approach to the resolution of growth management issues.

Response to Comment 133: Alternative without UGA Changes The No Action Alternative does not include UGA adjustments. Please see Response to Comment 1.

Response to Comment 134: Rural and Natural Resources Being Reduced The No Action Alternative does not reclassify rural uses. It would impact the least amount of critical areas in comparison to the other Alternatives. For the other Alternatives the EIS identifies policy and regulatory measures to reduce impacts, as well as suggested areas of UGA boundary adjustments to avoid impacts, both the resource and environmentally sensitive lands. Please see Response to Comment 5, Letter 1 regarding infill and expansion associated with the Recommended Plan and Council Map List.

Response to Comment 135: Financial Implications The Alternatives’ financial implications are reviewed for major capital facilities including roads (DEIS 3.2.6), parks (3.2.10), and drainage (3.2.14). Also see the Recommended Plan and Council Map List analysis in FEIS Chapter 3.

Response to Comment 136: Range of Choices Alternative 1 is a choice presented to the decision makers. Please see Response to Comment 52.

Response to Comment 137: Alternative 1 with More Intensification All Alternatives assume intensification within existing UGA areas. Please also see Response to Comment 7, FEIS Letter 3, and Response to Comment 10, FEIS Letter 279.

Response to Comment 138: Growth Alternatives Please see Response to Comment 7, FEIS Letter 3.

Response to Comment 139: Alternatives Outside the Range Please see Response to Comment 119. Alternatives that fall outside the range could require supplemental environmental review depending on the degree of difference and the land associated with the differences. Determinations regarding SEPA compliance are the responsibility of the lead agency, Snohomish County in this case.

Snohomish County Comprehensive Plan 5-156 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 140: Preferred Alternative Outside Range Please see Responses to Comment 119. Also, see Response to Comment 5, Letter 1. The Recommended Plan and Council Map List are in the range of UGA infill, expansion, and overall growth levels.

Response to Comment 141: No Action and Minor Actions Please see Response to Comment 1.

Response to Comment 142: Fix Problems with Implementation The comment is noted and forwarded to the appropriate decision makers.

Response to Comment 143: Individual Agency Projects Please see Responses to Comments 41, and 53, and 54.

Response to Comment 144: Spot Zoning Agencies and cities have requested few dockets as part of Alternative 3. The 10-Year Update is an update and not a replacement of the 1995 plan. It updates and course-corrects the 1995 plan to apply to a 2025 time horizon. Alternatives 2, 3, and the Preferred look at the locations where UGA infill or expansion may allow the County to increase its capacity to support forecasted population and employment growth. While DEIS Figures 2.4- 12 and 2.4-14 show the parcels proposed for change, DEIS Figures 2.4-11 and 2.4-13 show the changes in context. Similar context and change maps are included in FEIS Chapter 2 for the Recommended Plan and Council Map List.

Response to Comment 145: Proposed Action not Yet Defined The Proposed Action is an Update of the County Comprehensive Plan as described on page 2- 1. Since the No Action as well as the other Alternatives would accommodate a 2025 population within the OFM forecasted range, all Alternatives are under consideration until the County Council makes a decision. The paragraph that is repeated twice is corrected in FEIS Chapter 4.

Response to Comment 146: No Action Delays Proposed Action Please see Responses to Comments 1 and 52.

Response to Comment 147: Saved Financial Resources Since the No Action Alternative would accommodate growth to 2025, demand would increase for facilities. Please see Response to Comment 135. The No Action has financial implications, and if the Plan is not updated past 2012, the capital needs would probably not be addressed in a coordinated manner.

Response to Comment 148: Delay of Alternatives The comment is noted and forwarded to appropriate decision makers.

Snohomish County Comprehensive Plan 5-157 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 149: Development Pressures to Rural Lands Rural lands would only have urban services if they were reclassified as urban (or if there are health and safety risks in terms of sewer). The costs to extend sewer services are set by service providers. Sewer service is not provided by Snohomish County.

Response to Comment 150: Delaying the Proposed Action and Plan Coordination The purpose of Section 2.4.5 is to view the implications of “delaying” the proposed action, which is the Update of the County Comprehensive Plan. SEPA requires this analysis in WAC 197-11- 440(5). If the County Plan were not updated past 2012, there would be capital facility coordination issues, and out of date information, etc. However, the section only reviews “delay”. It does not mean that the delay would be indefinite.

Response to Comment 151: Fine Tuning of UGAs See Response to Comment 150.

Response to Comment 152: 1995 Plan Out of Date? The No Action Alternative would accommodate growth to 2025, and in that respect is not out of date. However, the Plan and its supporting data and related elements (e.g. Transportation and Parks) are geared to a 2012 horizon. Please note that the Proposed Action is an Update, and that the intent is for limited plan and policy amendment to match the new OFM forecasts and associated service needs.

Response to Comment 153: UGA Expansion Drivers UGA expansion options along with infill expansion options help to determine how to accommodate growth within the OFM forecasted population range. Alternative 3 has a much larger UGA expansion proposal than the other alternatives as it includes docket requests described in Appendix B as well as nearby lands to the docket requests (since the dockets were not necessarily abutting one another, study boundaries were drawn that looked at parcels immediately adjacent for study purposes).

Response to Comment 154: Population Distributions Please see Response to Comment 44.

Response to Comment 155: UGA Population Shares The commenter’s question about Unincorporated County share decreases is unclear, perhaps due to missing text in the letter. The size of the Marysville unincorporated UGA increases in Alternatives2 and 3, providing more buildable land under urban classes, and increasing the capacity for population. Regarding Southwest UGA and jurisdictions determining their future annexation areas, please see Response to Comment 14, FEIS Letter 284.

Snohomish County Comprehensive Plan 5-158 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 156: Rural Employment Distribution Decreases Please see Response to Comment 48.

Response to Comment 157: Cities’ Employment Cities commit to employment targets as part of the forecast allocation process through Snohomish County Tomorrow. The cities will need to demonstrate they have the capacity to meet their employment target.

Response to Comment 158: Employment Forecasts The targets are part of the Countywide Planning Policies. Employment forecasts are based on buildable lands analyses. The process and targets are determined through Snohomish County Tomorrow with staff assistance by the Snohomish County demographer. The County Council ultimately is responsible for adopting the amendments to the Countywide Planning Policies after Snohomish County Tomorrow participation.

Response to Comment 159: Employment Forecasts Please see Response to Comment 158.

Response to Comment 160: Maltby Employment – Share of UGAs Please see Response to Comment 95.

Response to Comment 161: Maltby Employment – Share of Unincorporated UGAs Please see Response to Comment 95.

Response to Comment 162: SW UGA Distribution In terms of unincorporated UGA lands, more employment classifications and targets are distributed to other UGAs with Alternatives 2 and 3, but the Southwest UGA is still has the largest share of employment growth no matter the Alternative. DEIS Appendix A provides the detailed employment breakdowns on which these graphs are based.

Response to Comment 163: Developable Residential Versus Employment Lands Most Snohomish County residents commute outside the County for jobs. It is true that with the DEIS Alternatives, there are fewer buildable acres proposed for employment categories than residential categories as shown in Figure 2.4-7. However, generally, less land is required to develop jobs than housing, depending on residential densities. While the land areas of the residential and employment classifications are not equal, in terms of jobs/housing balance, please note the following comparisons:

Snohomish County Comprehensive Plan 5-159 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Table 5.5-2 Jobs/Housing Balance Jobs/ Jobs/ Housing Housing Housing 2025 Range Housing Balance Balance Alternative Employment Low Range High Low Range High Range Alternative 1 331,906 325,379 344,902 1.02 0.96 Alternative 2 339,910 338,153 358,442 1.01 0.95 Alternative 3 351,318 364,290 386,148 0.96 0.91 Planning Commission Recommended Plan 345,357 352,226 373,360 0.98 0.92 County Council FEIS Map List 349,632 357,406 378,850 0.98 0.92

Response to Comments 164: Public Use Acres Public Use is described in Response to Comment 53. The figure represents “buildable land” acres, not public land that is already in use. There are about 17 buildable acres designated Public Use in Alternatives 1 and 2 and only 2 acres in Alternative 3 (see Table 2.4-3). These acres are so small compared to the scale of the graph that they do not register.

Response to Comments 165: Buildable Lands and Alternatives without UGA Expansion The No Action Alternative represents an increase in growth with current UGA boundaries. Please also see Response to Comment 108.

Response to Comment 166: Alternative 1 Map Please see Response to Comment 1.

Response to Comment 167: Alternative 2 Map The map with the changes only for Alternative 2 is provided on DEIS Figure 2.4-12.

Response to Comment 168: No Action Changes Map Because the No Action Map either incorporated adjustments based on adopted zoning or recognized public uses and did not include capacity changes a detailed change map was not provided. However, one is included in FEIS Chapter 4.

Response to Comment 169: FLUM Comparisons – Rural Lands DEIS Table 2.4-3 provides the rural acre figures represented on the graph in Figure 2.4-15.

Response to Comment 170: Rural Lands Bar Chart Please note that the graph is amended in FEIS Chapter 4 to show the missing Y-axis label “acres”. The scale of the graph started at 226,000 as it was generated in Excel. However, starting at zero would make the relative difference among the alternatives imperceptible.

Snohomish County Comprehensive Plan 5-160 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 171: FLUM Comparisons – Urban Classifications The purpose of the bar chart in 2.4-16 is to show acres by FLUM class. The population and employment growth comparisons are provided in DEIS Table 2.4-2, and their distribution by UGA is shown in DEIS Figures 2.4-1 to 2.4-6. In bar chart form, the growth is illustrated as follows in Figure 5.8-1:

Figure 5.8-1 Population and Employment Growth

1,200,000

1,000,000

800,000

Population 600,000 Emp loyment

400,000

200,000

0 Current (2 00 2) No A ct io n 20 25 A lt ernat ive 2 2 02 5 A lt ernat ive 3 20 25 Recommend ed Plan Count y Council FEIS 2025 Map List Alternative

In the chart, the population reserves are included in Alternative 3 and the Recommended Plan and Council Map List. Whether the FCC and TDR reserves are included or excluded Alternative 3 would continue to have the higher growth, followed by the Council Map List, and then the Recommended Plan.

Response to Comment 172: Docket Review Please see Response to Comment 41.

Response to Comment 173: Comprehensive Plan Review Please see Response to Comment 35.

Response to Comment 174: Implementing Zoning The package of plan amendments transmitted to the Planning Commission and County Council included certain elements of an implementation program, including an area-wide re-zoning proposal. Every parcel of land that has a change of designation on the future land use map may not be included in the area-wide rezone, because the plan is a long-term vision for the

Snohomish County Comprehensive Plan 5-161 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses future, while the zoning impacts the regulation of development – and can impact property value – immediately. Therefore, in cases where development or redevelopment is not expected to occur for several years, it may not be appropriate to change zoning immediately, but rather to wait for the market to mature and allow the owner to request the rezone later in the planning period. Also some implementing zoning may be phased on the basis of additional subsequent master planning. However, in cases where the current zoning is substantially inconsistent with the new land use designation, such as in new UGA expansion areas, rezoning will be proposed together with the comprehensive plan changes.

Response to Comment 175: Possibility of Maltby Incorporation Since the municipal incorporation of any unincorporated area is primarily a function of property owner desire, it is difficult to assess the probability that any particular area will incorporate or when that might happen. There is certainly a possibility that such an incorporation could occur in the Maltby area by 2025, although the relatively small size and population of the present Maltby UGA would suggest a fairly low probability that such an incorporation would occur in the near future. Since the conditions of incorporation are prescribed in state law, potential changes to those laws could potentially make such incorporation more or less difficult in the future.

Response to Comment 176: RUTAs The comment is referring to page 3-2 of the DEIS, first full paragraph. “As appropriate” means that portions of the R/UTA are incorporated into the UGAs of some but not all Alternatives. They are reclassified in Alternatives 2 and 3 but not Alternative 1.

Response to Comment 177: R/UTA Used for Residential or Employment? R/UTA areas are those areas adjacent to UGAs that may be suitable for future inclusion into UGAs. While Rural, they are designated for residential uses. When considered for inclusion in the UGA, they may be suitable for residential, commercial, or industrial classes. R/UTA policies allow for privately initiated master planning processes for properties a minimum of 80 acres, which could lead to the expansion of the UGA.

Response to Comment 178: Development Regulation Consistency Development regulations are required to implement the Comprehensive Plan, and therefore should be consistent. Note that implementing regulations may be phased. Please see Response to Comment 174.

Response to Comment 179: Site Specific Review Please see Response to Comment 2, FEIS Letter 283, and Response to Comment 41 of this Letter.

Response to Comment 180: Critical Area Regulations The Critical Areas Regulations Update is under preparation in a separate process as noted on pages 3-2 and 3-3 of the DEIS. The DEIS and FEIS assumed implementation of the current adopted CAR.

Snohomish County Comprehensive Plan 5-162 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 181: Fire Protection LOS The DEIS noted the need for a level of service related to fire protection as described in Goal CF 10. Since the time of the DEIS, the County completed its 7-Year GMA compliance review for its Comprehensive Plan in November 2004. Year 2004 amendments to Goal CF 10 and associated policies led to a level of service policy based on fire flow. Fire flow was chosen as the measure in part because the measure is consistent regardless of which agency provides protection. The levels of fire flow and sprinkler requirements are established in the building and fire codes adopted by the County. While fire flow is not provided for large lot residential development, it is required for urban levels of development, thereby making the level of service commensurate with the intensity of development. This level of service standard relies on the enforcement of adopted building and fire codes and water system plans for a given area.

Response to Comment 182: Modify LOS GMA requires a balanced capital facility plan. Funding deficiencies are noted for transportation, parks, and drainage, if growth occurs at any of the Alternatives’ growth levels. Modifying levels of service is one method to achieve a balance between land use, costs, and revenues. Other methods are to modify land uses (levels or locations) or costs (less expensive improvements). This is described on pages 3-3 and 3-4 of the DEIS. Please also see Chapters 2 and 3 of this FEIS regarding alternative LOS and road improvements considered with the Recommended Plan.

Response to Comment 183: Critical Areas The comment is noted and forwarded to the appropriate decision makers. All critical areas were considered in the environmental review of the alternatives.

Response to Comment 184: Erosion Hazard Protections The definition of Erosion Hazard Areas is summarized on DEIS page 3-6. Please see SCC 30.62 for regulations that apply to erosion hazard areas. As required by Section 30.62.200 of Snohomish County Code, development activity proposed in erosion hazard areas shall be protected by use of best management practices found in the Snohomish County Drainage Manual. All portions of erosion hazard areas on a site which are undisturbed by development activities shall be permanently protected by designation as native growth protection areas.

Response to Comment 185: Seismic Hazard Maps Seismic hazard mapping was obtained in draft form from DNR. See Figures 3.1 and 3.2. Additional seismic hazard information was obtained from the UGGS regarding the SWIFS, though not included on DNR mapping. Snohomish County has opted to use the 2003 International Building Code as adopted by the State of Washington Building Code Council. The earthquake hazard maps are depicted in Section 1615 of the IBC.

Response to Comment 186: Growth in UGAs and RUTAs On DEIS page 3-9, the text states: The Alternatives, or another Alternative within the range of the Alternatives in this EIS, will establish the land use designations that are the basis for zoning of individual parcels within unincorporated County land. Land uses within UGAs and RUTAs (see Section 2.2.2), where most growth is anticipated, will be a focus of the Earth impact discussion. Numerous existing

Snohomish County Comprehensive Plan 5-163 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

policies regarding soils and slope stability in the GPP would be implemented regardless of the land use alternative selected, and would help to mitigate the effects of development on earth resources. Discussion will frequently make reference to the various impact mechanisms associated with two patterns of growth—the infilling or intensification of UGAs and the expansion of UGA boundaries. Reference to RUTAs means the area of UGA expansion in Alternatives 2 and 3, which tend to be proposed in areas currently designated as RUTAs.

Response to Comment 187: Infiltration and Groundwater The impacts of the alternatives in terms of groundwater is described in DEIS Section 3.1.4 and FEIS Section 3.1.4 and Appendix I-C. The comments to ensure that groundwater areas are not degraded by the planning efforts are noted and forwarded to the appropriate decision makers.

Response to Comment 188: South Whidbey Island Fault Zone As stated on DEIS page 3-7 paragraph 6, the location of the fault zones on the mainland is unclear, but general ideas of location were described. For further information see the references cited. Draft State DNR mapping was included and shows some mapped faults on Figure 3.1-1. Also see FEIS Appendix II-F.

Response to Comment 189: Areas Outside Hazard Zones The referenced text is likely that on page 3-10. The relevant sentences state: All Alternatives would permit development that is at risk of some degree of catastrophic geologic hazards, including landslides, earthquakes, and volcanic eruptions. These geologic hazards are generally well mapped or understood, and may be avoided or minimized by siting developments outside of hazard zones. The word “outside” means clustered away from known hazard areas.

Response to Comment 190: Smaller Footprints to Reduce Impacts The comments are noted. As stated on DEIS page 3-2: It is reasonable to assume that the potential for impacts to the natural environment or built environment would increase as the potential density, intensity, or amount of development increases. While the impact analysis of the Draft EIS addresses the general or typical cases, it is important to recognize that conclusions are not absolutes. For example, large parcel residential developments—depending on layout, landscaping, impervious surface, etc.— may create a greater impact on environmental features than higher-density developments in an environmentally responsive pattern of development such as clustering. Additionally, the Draft EIS also considers the mitigating effects of numerous policies included in the current Comprehensive Plan or proposed Alternatives, as well as current or proposed development regulations.

Response to Comment 191: Liquefaction Map Please see DEIS Figure 3.1-2, Liquefaction Potential, based on DNR information.

Snohomish County Comprehensive Plan 5-164 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 192: Crustal Faults As stated on DEIS Page 3-7 paragraphs 4 and 6, large earthquakes (e.g. magnitude 7 on the Richter scale) are possible from crustal faults. However, crustal quakes also include many smaller, localized quakes. For a description of the differences in quakes from different fault types, please refer to a general geology text (e.g. Press, F. and R. Siever, 2001, Understanding the Earth, W.H. Freeman, New York). References for the possible SWIFZ locations in Snohomish County, may be found in paragraph 6, on page 3-7, and full citations are in DEIS Chapter 4, Glossary and References.

Response to Comment 193: Worst Case Maps Please see Response to Comment 188. Also please see Appendix II-F for an Aeromagnetic USGS estimating the location of the SWIF2 on the mainland.

Response to Comment 194: Building Standards The comment is noted and forwarded to the appropriate decision makers. Snohomish County has opted to use the 2003 International Building Code as adopted by the State of Washington Building Code Council.

Response to Comment 195: Goal NE 6 The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 196: All Natural Hazards Plan The "Natural Hazards Mitigation Plan" was adopted by Snohomish County and 42 other partner cities and districts in 2005. While the County adopted the plan, it does not have to be codified. The responsible agency is the Snohomish County Department of Emergency Management, which will be assisted by the Snohomish Department of Public Works. This is a working document with specific actions plans for each type of natural hazard. Work is well underway on plan recommendations. For example, the County has completed the hurdles at the local level to officially enter the County into the National Flood Insurance Program Community Rating System. Benefits from that program are expected to accrue to local residents beginning around April of next year. The County has remapping efforts of floodplains underway. The County has republished its flood preparedness bulletin, and for the first time, mailed the bulletin to the 16,000 plus floodplain or adjacent property owners in the County. Fall flood coordination meetings between diking districts, the County and the Army Corps of Engineers have occurred, potential trouble spots have been flagged, and plans of action developed in the event of floods. Call-out lists of staff have been completed to provide backup on the phones and in the field should a flood occur. Gages have been updated. A real time flood watch map is available on the web site which has been linked again, as in recent years to the County’s main web page so that County residents have a quicker access should flood concerns arise during the wet season.

Response to Comment 197: Maltby UGA and SWIF The potential mitigation measures are amended as requested. Please see FEIS Chapter 4. Please note the Recommended Plan and the Council Map List relationship to DEIS mitigation measures related to avoiding critical area impacts in Response to Comment 3, Letter 1. Recent information has revealed evidence of the South Whidbey Fault along the edge of the Maltby UGA according to King County’s Supplemental EIS for Brightwater which, in concert with USGS, found evidence of an active fault north of the proposed Brightwater facility.

Snohomish County Comprehensive Plan 5-165 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 198: Liquefaction Along Streams Please see Page 3-8, paragraph 2, “Most other communities have smaller areas with high potential for liquefaction.” As noted, these include areas associated with streams. As shown on Figure 3.1-2, Liquefaction Potential, areas of liquefaction occur along streams. This map is based on Draft DNR mapping information.

Response to Comment 199: Drainage Regulations Changing surface water regulations for new development is listed as a potential mitigation measure for several sections of the DEIS. Your comments will be forwarded to the decision makers.

Response to Comment 200: Odor Regulations The Snohomish County Code includes several provisions related to nuisance odors generated by homes, farms, and businesses. Title 7 (Health and Sanitation) covers solid waste disposal, sewage disposal, and restaurants. Title 30 (Unified Development Code) covers residential areas, farms, and wood waste operations. Furthermore, new and existing industrial facilities would also be subject to the nuisance odor regulations specified under Regulation I of the Puget Sound Clean Air Agency.

Response to Comment 201: Wood Smoke Emissions Wood smoke emissions (consisting of PM10, PM2.5, NOx, VOCs and toxic air pollutants) would be reduced if intensive residential development did not include wood stoves. The magnitude of the potential emission reduction would depend on type of heating appliances were installed instead of wood stoves.

Response to Comment 202: Natural Gas Fireplaces Requiring new developers to use natural gas fireplaces instead of conventional wood-burning appliances would reduce emissions for all pollutants (consisting of PM10, PM2.5, NOx, VOCs and toxic air pollutants). The magnitude of the potential emission reduction would depend on how often the owners use their natural gas fireplaces as compared to how often they would have used their wood-burning appliances.

Response to Comment 203: Increased Transit The alternatives assume that efforts will be made to optimize the housing density within urban areas and to encourage use of mass transit. See bullet 2 on page 3-30. A measure to reduce VMT including improving transit utilization is also listed on page 3-31 (last bullet continuing to page 3-32).

Response to Comment 204: Maintaining UGAs, Intensifying, and Improving Transit Comment noted. Encouraging the use of mass transit would help reduce local and regional air pollutant emissions. The more compact UGA boundaries are noted for Alternative 1 on page 3- 30, second bullet.

Snohomish County Comprehensive Plan 5-166 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 205: Alternative 3 Air Pollutant Levels There is no Emission Budget established for Snohomish County, nor has any agency specified allowable limits on countywide VMT. The State Implementation Plan specifies a regional Transportation Emission Budget for the entire Puget Sound air quality maintenance area that includes portions of Snohomish, King, Pierce and Kitsap Counties. However, the SIP does not specify emission limits for any individual county. Each year PSRC prepares a Transportation Conformity Analysis for the entire Puget Sound region. To demonstrate that the regional tailpipe emissions will be less than the 4-county emission budget, PSRC developed VMT estimates for the roadway networks in each county and used EPA models to estimate the combined regional tailpipe emissions. As shown in DEIS Table 3.1-3 the modeled 4-county regional tailpipe emissions are much lower than the allowable emission budget. DEIS Table 3.1-4 of the DEIS lists the population and VMT estimates that PSRC used for both the 4-county region and for Snohomish County alone. As seen in that table the forecasted VMT for Snohomish County is a fraction of the forecasted 4-county regional total. Therefore, minor deviations in the Snohomish County VMT are anticipated to have only a minor effect on the overall 4-county totals. Please also see Letter 18, Response to Comment 1 regarding recent PSRC emission forecasts showing a greater cushion between emission forecasts and allowable emission budgets, and how this pertains to the DEIS and FEIS alternatives.

Response to Comment 206: Drainage and Grading Regulations Snohomish County has not adopted the 2001 Stormwater Management Manual for Western Washington published by the Department of Ecology. Adjustments to the County’s current regulatory program for drainage and grading will be addressed following the reissuance of the County’s NPDES MS4 permit when the state requirements are clarified.

Response to Comment 207: Tributaries of Swamp, North, and Little Bear Creeks Tributaries to Swamp, North, and Little Bear Creeks are included in the “Salmon and trout spawning, core rearing and migration; extraordinary primary contact recreation” category since they are, ultimately, tributaries to Lake Washington.

Response to Comment 208: Water Quality Problems in King County Water quality concerns in streams are addressed in Snohomish County by its standards for new development, by its existing NPDES permit, and by its water quality program.

Response to Comment 209: Tree Retention Ordinance Planned residential developments within unincorporated Snohomish County are subject to standards for tree retention (SCC 30.42B.130). SCC 30.42.130 applies in rural and UGA areas and sets standards for tree retention in planned residential developments. At this time, there is no tree retention ordinance that applies to all areas and development circumstances in the County. Such an ordinance would, conceivably, improve tree density. Please note the mitigation measures in Sections 3.1.6 and 3.1.7 of the DEIS which promote the preservation of native vegetation/mature trees as well as low impact development. The County

Snohomish County Comprehensive Plan 5-167 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses currently has a demonstration ordinance for low impact development. The Recommended Plan strengthens low impact development policies.

Response to Comment 210: Flooding in King County See Response to Comment 28. Please also note that the Recommended Plan does not include substantive Southwest UGA expansions and the Council Map List reduces Southwest UGA expansion in relation to Alternative 3 (FEIS Chapter 2).

Response to Comment 211: Development Practices The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 212: Drainage Standards Comment noted. Section 3.2.14.1 of the DEIS already states that current County detention standards are based on matching peak flows for individual storm events. The DEIS also states that the County requires a safety factor of 1.3 to be used if the analysis is based on a single storm event rather than a continuous series of storm events. Adjustments to the County’s current regulatory program for drainage and grading will be addressed following the reissuance of the County’s NPDES MS4 permit when the state requirements are clarified.

Response to Comment 213: Water Quantity Water quantity is reviewed along with water quality in DEIS Section 3.1.3. See pages 3-40 to 3- 41 and the impact analysis on pages 3-52 to 3-63, including Table 3.1-10 and Figure 3.1-15.

Response to Comment 214: Summer Flows Reduced summer flow and its effect on stream water quality is a prevalent problem in urban areas with a high percentage of impervious surface area. Please see DEIS Sections 3.1.3 and 3.1.4 which describe effect of development on summer stream flows. FEIS Sections 3.1.3 and 3.1.4 address the Recommended Plan and Council Map List.

Response to Comment 215: Impacts to Streams The comments are noted and forwarded to the appropriate decision makers. Many of the suggested measures are related to low impact development techniques referenced in several mitigation sections in DEIS part 3.1 and in 3.2.14.

Response to Comment 216: Future Specific Projects The comments are noted. As stated on DEIS page 3-2, the Alternatives would lead to growth and urbanization as future development projects are implemented consistent with the Plans. However, future site-specific development will be further evaluated during the permitting process: All Alternatives would result in increased urbanization and growth within the County. This document addresses general or cumulative impacts on natural or constructed resources related to potential increased urbanization and growth that could result from each Alternative. Under any Comprehensive Plan Land Use Alternative, development could occur consistent with implementing zoning and development regulations that are consistent with the Comprehensive Plan. Specific developments may also have specific, direct impacts

Snohomish County Comprehensive Plan 5-168 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

on resources. This will be evaluated during the permitting process for each specific development, and is not part of this evaluation. Previously approved developments and vested applications (approved or formally requested in accordance with current plans and regulations) would continue in accordance with the terms of their approval or the rules under which they were vested. Future projects would be processed in accordance with the rules in place at the time the applications were deemed to be complete, and could be affected by Alternatives reviewed in this EIS if they, or another, are approved.

Response to Comment 217: Enforcement The comments are noted and forwarded to the appropriate decision makers. The County encourages citizens to report specific incidents in which drainage systems are not performing adequately so that the County can investigate these potential problems.

Response to Comment 218: Communication The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 219: Cross-Jurisdiction Mitigation Please see Response to Comment 28. Please also note that the County participates in WRIA 8 planning efforts that provide for jurisdictional coordination.

Response to Comment 220: Degradation of Streams – Alternatives The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 221: Price of Restoration The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 222: Current Regulations Insufficient The comments are noted and forwarded to the appropriate decision makers. Please note that the Natural Environment mitigation measures in DEIS Section 3.1 identify additional regulatory amendments to surface water, critical area, low impact development, and other regulations.

Response to Comment 223: Downstream Jurisdictions Please see Response to Comment 28. Please also note that the County participates in WRIA 8 planning efforts that provide for jurisdictional coordination.

Response to Comment 224: Regulations Implementing Policies “Incorporated Plan Features” list plan map or policies that relate to the EIS topic. “Applicable Regulations and Commitments” lists any current regulations that are in place. “Other Potential Mitigation Measures” identify amendments to plan maps, policies, or regulations that could reduce impacts.

Response to Comment 225: Existing Development The County’s Drainage Needs Reports identify existing deficiencies in the urban areas. Existing deficiencies are addressed in the Capital Facility Plan. The pace and funding are determined

Snohomish County Comprehensive Plan 5-169 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses through the capital planning process and budget decisions. The County’s recent increase in SWM fees within existing UGAs on an interim basis was specifically adopted to address existing drainage problems. Potential mitigation measures identified in DEIS Section 3.2.14 include a measure that would extend the increased surface water fees in order to address additional drainage problems.

Response to Comment 226: City Annexation Annexation of urban areas to cities is a GMA provision. The County is working with the cities to determine what type of joint standards or programs would need to be in place to facilitate future annexation. Please see interjurisdictional policy amendments associated with the Recommended Plan.

Response to Comment 227: Leadership to Implement Mitigation The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 228: Tree Protection and Infiltration The second bullet on DEIS page 3-64 identifies infiltration and low impact development measures. On page 3-165 a mitigation measure promotes the preservation of native vegetation and particularly mature trees.

Response to Comment 229: Groundwater Quality – Impacts Common to All As discussed in Response to Comment 21, the impact analysis for the groundwater assessment was limited to a screening level landscape analysis that identified areas of concern at a sub- basin scale. Wellhead protection planning is required under the Federal Safe Drinking Water Act for Group A water systems using groundwater, and requires evaluating the movement of groundwater toward pumping wells.

Response to Comment 230: Increased Demand and Impervious Surfaces The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 231: Rural Businesses without Sewer Table 3.1-12 is amended to copy the Residential “Septic” information under the Commercial category with qualifiers as suggested. Please see FEIS Chapter 4.

Response to Comment 232: Avoid Impervious Surface Increases The comments are noted and forwarded to the appropriate decision makers. Please note the mitigation measures on DEIS pages 3-92 and 3-93 which include impervious surface reductions, detention/infiltration requirements, avoidance of particularly sensitive basins, and other measures.

Response to Comment 233: Smart Growth Techniques Please see Response to Comment 232.

Snohomish County Comprehensive Plan 5-170 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 234: Wellhead Protection Plans Wellhead protection planning is required under the Federal Safe Drinking Water Act for Group A water systems using groundwater. Public water systems are required to provide safe drinking water and inform their customers about their water supply. Wellhead Protection Plans should be updated every 5 years. The Washington State Department of Health has primacy over this program. The success of a Wellhead Protection Plan is dependent on the degree of collaboration amongst stakeholders for implementing it. Water purveyors often do not have land use authority over the areas providing their water supply. The County recognizes this and is revising regulations pertaining to wellhead protection areas.

Response to Comment 235: Appendix C – Impervious Surface Estimates The comments are noted and forwarded to the appropriate decision makers. The data in Appendix C and DEIS Section 3.l.4 including the maps are intended to assist the decision- making process. Also see updated groundwater information in FEIS Chapter 3 and Appendix I- C.

Response to Comment 236: Little Bear Creek The EIS process is intended to describe potentially significant impacts and inform decision makers regarding proposed and alternative actions. Little Bear Creek was identified as a potentially significant impact area (aside from groundwater, surface water, infrastructure cost and feasibility, and city preferences were also concerns). It may be possible to manage land use and achieve groundwater protection, and it is noted in the DEIS that proposed land uses may be substantially mitigated but may not be eliminated. Please note that the Recommended Plan avoids substantive Southwest UGA expansions in the Little Bear Creek basin (see FEIS Chapter 2) and the Council Map List proposes less expansion than Alternative 3.

Response to Comment 237: Well Mapping A comprehensive web-interactive map and database system of potable water wells in Snohomish County has been completed. See the County’s groundwater website at www.groundwater.surfacewater.info. DEIS Page 3-86, third paragraph, is amended to reflect this information in FEIS Chapter 4.

Response to Comment 238: Proportional Impacts Reducing impervious surfaces and vegetation retention are part of the low impact development techniques referenced in mitigation measures on DEIS page 3-93 and further described in 3.2.14.3.

Response to Comment 239: Prohibiting Fertilizers, Herbicides, and Pesticides The comments are noted and forwarded to the appropriate decision makers. The Groundwater Management Plan referenced on DEIS page 3-93 includes measures related to education to limit groundwater contamination from these sources.

Snohomish County Comprehensive Plan 5-171 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 240: Net Groundwater Mitigation The comments are noted and forwarded to the appropriate decision makers. The mitigation measures include avoiding UGA expansion into Little Bear Creek basin. This is a measure employed by the Recommended Plan for multiple reasons (environmental, infrastructure, municipal preferences, etc.). The Council Map List proposes less Southwest UGA expansion than Alternative 3.

Response to Comment 241: Fault Lines and Water Availability It is unlikely that there is a significant relationship between geologic faulting and groundwater availability within the glacial sediments that support streams and wells in Snohomish County. Generally, the effect of faulting on groundwater supply is more of a concern in “hard rock” aquifers. Active movement along faults within or underneath the “softer” sediments within the glacial deposits could cause some deformation of sediments and ground movements at the surface, but the water contained within the sediments would not likely be affected, unless there was a catastrophic movement that shifted ground surface by tens of feet.

Response to Comment 242: Brightwater The references to Brightwater on DEIS pages 3-90 and 3-91 are made with respect to the information the sewer planning process has generated. This information is useful for the groundwater impact discussion.

Response to Comment 243: Stringers in Little Bear Creek Area The comments are noted and forwarded to the appropriate decision makers. The mitigation measures include avoiding UGA expansion into Little Bear Creek basin. This is a measure employed by the Recommended Plan in terms of the Southwest UGA expansion. The Council Map List proposes less Southwest UGA expansion than Alternative 3.

Response to Comment 244: Aquifer Production – Cross Valley Aquifer production is noted on DEIS page 3-91 to be a function of operational parameters, legal constraints (water rights), and aquifer/recharge conditions.

Response to Comment 245: Impervious Surface Increases and Groundwater Discharge Decreases The comment is noted. DEIS Page 3-81, fourth bullet, indicates that impervious surfaces affect groundwater recharge and reduce base flows.

Response to Comment 246: Phased Review Mitigation measures reference other actions in addition to phased review including UGA expansion avoidance, increased regulations, and others.

Response to Comment 247: Permeability and Water and Sewer Service Plans The comment is noted and forwarded to appropriate decision makers. Please note the Recommended Plan includes amended Utility Element goals and policies intended to encourage innovative methods for addressing water supply and wastewater treatment.

Snohomish County Comprehensive Plan 5-172 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 248: Education Efforts The Groundwater Management Plan was created as a result of Comprehensive Plan direction. Additional education efforts over the life of the Comprehensive Plan are anticipated.

Response to Comment 249: Goals and Policies Goals and policies provide the County Council direction that then can be translated and implemented by codes.

Response to Comment 250: Status of Implementing Goals The County’s current groundwater protection standards are located in the Unified Development Code 30.64 entitled “Groundwater Protection” with updated critical aquifer recharge area regulations. Critical aquifer recharge area regulations are in preparation as part of Critical Area Regulation amendments associated with a best available science review.

Response to Comment 251: Groundwater Protection – No Actions Taken The County began groundwater protection efforts in the late 1980’s through the Centennial grants process that provided funding for the County’s first intensive groundwater studies (USGS and others), Groundwater Management Plan (GWMP) development, Groundwater Management Program, and subsequent code development. All activities were developed in accordance with Washington Administrative Code 173-100. See also Response to Comment 250.

Response to Comment 252: Effectiveness of Groundwater Management Plan Please see Response to Comment 250. The Public Works Department Surface Water Management division implements the management plan with two full-time staff positions. The ongoing Groundwater Management Program activities include: • Providing the public with data on the groundwater resources of Snohomish County by compiling groundwater data and creating an on-line groundwater database. • Preparing a subarea groundwater study to evaluate groundwater issues and recommend solutions at a local scale. • Providing stewardship of groundwater in Snohomish County by recommending and implementing actions to protect groundwater quality for residential consumption and groundwater quantity for aquatic ecosystems. • Providing management, policy, and technical expertise to help protect the quality and quantity of the groundwater resources in Snohomish County. • Identifying development standards, policies, and regulations that would protect recharge to groundwater, prevent groundwater contamination, and maintain groundwater inputs to stream baseflows. • Coordinating and implementing groundwater management alternatives with purveyors, County departments, state and federal agencies, and interested parties as set forth by Snohomish County’s Groundwater Management Plan.

Snohomish County Comprehensive Plan 5-173 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 253: Reducing Impervious Surfaces The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 254: Infiltration Measures The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 255: Groundwater Plan Implementation Please see Response to Comment 252.

Response to Comment 256: Late Public Involvement in Groundwater Program The Groundwater Management Plan was created through a public process with the Snohomish County Ground Water Advisory Committee as described in the Project Summary, available on the County webpage at: http://www1.co.snohomish.wa.us/Departments/Public_Works/Divisions/SWM/Library/Publication s/Water_Quality/ground_water_mgmt_plan_1999.htm.

Response to Comment 257: Intensify Existing Areas The No Action (Alternative 1) intensifies existing areas within existing UGA boundaries. Also see Responses to Comments 52 and 59.

Response to Comment 258: Political Factors as Impacts The focus of the EIS is to identify natural and built environment impacts. Policy choices have been topics for the public hearing and review process.

Response to Comment 259: Local Well Recharge Rate The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 260: Species Level Analysis The level of the EIS review is described on page 3-1 of the DEIS. Also see Response to Comment 216.

Response to Comment 261: Areas Looked at Singly Without page references it is difficult to respond to the comment. The DEIS reviews a range of interrelated topics in a cumulative way, but also described by areas of focus such as WRIAs, drainage basins, UGAs, etc.

Response to Comment 262: Past, Present, and Future All Responsible The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 263: Countywide Areas The comments are noted and forwarded to the appropriate decision makers.

Snohomish County Comprehensive Plan 5-174 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 264: Bull Trout and Chinook Chinook and bull trout are protected by federal law; it’s not an “either or” situation. DEIS Page 3- 128, under Impacts Common to All Alternatives, is revised to clarify that it is presumed that health of Chinook salmon and bull trout stocks can be used as reasonable surrogates for the health of other fish stocks and their habitats. Although only federally listed species such as the Chinook and bull trout are afforded protection, by maintaining consistency with federal, state, county, and local regulations, impacts to other fish and their habitats would be minimized. Please see FEIS Chapter 4.

Response to Comment 265: Look at Entire System The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 266: Look at Salmon and Trout First As clarified in Response to Comment 265, the analysis in Section 3.1.5 on DEIS page 3-128 indicates: Salmon and trout are very sensitive to any change in the stream or estuarine environment and urban development can alter their habitat. Development activities can pollute water, degrade instream, riparian, and estuarine habitat, and alter the natural flow regime of rivers and streams. The mechanisms that impact Chinook salmon and bull trout (habitat loss, water temperature, altered flow regime, contaminants, sedimentation, scour, etc) also impact other sensitive fish species, as identified in Table 3.1-17 above. Generally, all of the identified fish species require good water quality and cool water temperatures to survive, grow, and reproduce. In addition, it is presumed that health of Chinook salmon and bull trout stocks can be used as reasonable surrogates for the health of other fish stocks and their habitats.

Response to Comment 267: Little Bear Creek Alternatives 2 and 3 are noted to increase impervious surfaces in the Little Bear Creek basin on pages 3-131 to 3-133. This is due to a combination of future development within the proposed UGA expansions for these alternatives together with other areas in the basin not located within the UGAs or the proposed expansion areas. These two alternatives would have greater impacts on Little Bear Creek than the No Action Alternative, which does not amend UGA boundaries in the Little Bear Creek basin but would still experience future development in the basin outside of the current UGA boundaries. Please also see the groundwater analysis in this FEIS for the Recommended Plan and Council Map List.

Response to Comment 268: Discourage Rural Development All Alternatives focus new growth in the UGAs and less new growth in the rural areas, but some growth would occur in the rural areas over the 20-year period. No Action Alternative would have the least impacts since it would convert less rural land to urban land and Alternative 3 the greatest. See Response to Comment 6, Letter 3.

Response to Comment 269: Little Bear Creek Alliances The Recommended Plan avoids Southwest UGA expansions in the Little Bear Creek basin compared with Alternatives 2 and 3, and the Council Map List proposes less Southwest UGA expansion than Alternative 3. Please see FEIS Chapter 2.

Snohomish County Comprehensive Plan 5-175 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 270: GPP Goals and Regulation Implementation Please see Response to Comment 224.

Response to Comment 271: Implementation Timeframe The comment is noted and forwarded to the appropriate decision makers. The Recommended Plan implementation components and timeframes are described in FEIS Chapter 2.

Response to Comment 272: WRIA Implementation The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 273: Impact Avoidance Impact avoidance is recognized, see Response to Comment 3, Letter 1 and FEIS Chapter 2 that describes DEIS UGA expansion avoidance measures and how the Recommended Plan and Council Map List compare.

Response to Comment 274: Plans in the DEIS Please see Response to Comment 35.

Response to Comment 275: Inventories Available critical area inventory maps are provided in the DEIS (for example, see Figure 3.1-5). The County will determine the timing and funding for updated critical area inventories, and consider federal and state sources that may be updated over time (e.g. DNR maps). Critical area regulations apply to mapped and unmapped resources. Site-specific studies are required at the permit process phase. Site-specific development is also subject to SEPA review.

Response to Comment 276: Species Found Later Please see Response to Comment 275.

Response to Comment 277: Policy Changes Please see Response to Comment 35. 5.5.1.12 FEIS Letter 287: Lily Su Hoyne for George Kresovich

Response to Comment 1: County Can Fashion Alternative with Elements of DEIS Alternatives The Recommended Plan and Council Map List combine elements from various alternatives as described in FEIS Chapter 2.

Snohomish County Comprehensive Plan 5-176 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 2: FCC Analysis Approach – Limited to a Single Alternative The Alternatives were fixed for purposes of environmental review to test different concepts. SEPA provides broad latitude for alternatives analysis in nonproject SEPA documents (WAC 197-11-442). The Recommended Plan and Council Map List include a reserve population for a FCC. Please see FEIS Chapter 2.

Response to Comment 3: Background – FCC Concept The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 4: FCC Amendments to Countywide Planning Policies The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 5: Effect of Countywide Planning Policies Policy UG-15 does not limit consideration of a FCC to any particular alternative, nor does it mandate its inclusion. The language of UG-15 indicates the “County may amend it comprehensive plan to incorporate criteria… for considering and acting upon individual FCC proposals…” See also responses to Comments 1 and 2.

Response to Comment 6: Phased Review of FCC The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 7: Future Consideration of FCC Location The comments are noted and forwarded to the appropriate decision makers. Because FCC locations have not been determined at the time of this writing, the FCC analysis is limited to a discussion of plans and policies in DEIS Section 3.2.2 and to a discussion of FCC policies and regulations with the Recommended Plan in FEIS Section 3.2.2. If a FCC is sited in the future, it would require its own environmental review.

Response to Comment 8: FCC Criteria The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 9: FCC Impacts – Address in Alternatives 1 and 2 Please see Responses to Comments 2 and 5.

Response to Comment 10: Accounting for FCC Population Please see Responses to Comments 2 and 5.

Snohomish County Comprehensive Plan 5-177 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 11: FCC Population as Addition to Basic Population Number “Reserve” allocations were assumed with Alternative 3, the Recommended Plan and with the Council Map List. Please see FEIS Chapter 2.

Response to Comment 12: FCC Challenges The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 13: DEIS Thorough and Credible The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 14: DEIS Organization around Three Alternatives The comments are noted. Please see Response to Comment 1.

Response to Comment 15: CPP Policy UG-15 – Review with All Alternatives See Responses to Comments 1, 2, and 5. 5.5.1.13 FEIS Letter 288: Jody McVittie

Response to Comment 1: Safety Factors Please see Response to Comment 31, letter 286

Response to Comment 2: Infill without Expansion – Hybrid Between Alternatives 1 and 2 Comments urging adoption of an alternative hybrid between Alternatives 1 and 2 are noted and forwarded to the appropriate decision makers. Please also see Letter 286, Response to Comment 51.

Response to Comment 3: Alternative 3 UGA Expansion The DEIS includes a discussion of “Relationship to Plans and Policies” which describes the alternatives’ consistency with State GMA, Countywide, and County goals and policies, including goals related to land use patterns and transportation services. For example, in terms of Alternative 3, it is noted that “…more extensive UGA boundary expansions could have an undermining effect on … infill efforts.” See DEIS Section 3.2, page 3-229. Please see a review of reasonable measures in FEIS Chapter 3, based on a technical report prepared by PDS. (See Appendix I-E.) The technical report was provided to decision makers. Also, please see Response to Comment 5, Letter 1, regarding infill and expansion proposals under the Recommended Plan and Council Map List.

Snohomish County Comprehensive Plan 5-178 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 4: Potential Mitigation Measures The DEIS listed three types of mitigation measures: • Incorporated Plan Features – Plan or policy features of the alternatives. • Applicable Regulation and Commitments – Agency regulations or programs in place. • Other Potential Mitigation Measures – to avoid or reduce impacts. The “other potential mitigation measures” in the DEIS were listed to identify measures not yet included in County plans or regulations that could be part of the Plan Update or applicable to developing a preferred land use map, such as places to avoid UGA expansions. The FEIS provides analysis of the Recommended Plan and Council Map List and identifies associated proposed land use plan features or proposed policies or regulations that would implement some of the DEIS mitigation measures. See FEIS Chapters 2 and 3.

Response to Comment 5: Reasonable Measures The DEIS was part of an integrated SEPA/GMA process. The analysis was intended to address impacts of a range of alternatives to help determine a preferred land use plan and appropriate policy/regulation amendments. See DEIS Section 2.3.2, page 2-5. Regarding reasonable measures, please see Response to Comment 3.

Response to Comment 6: Capital Deficits Please see Response to Comment 5 regarding the SEPA/GMA process. The DEIS clearly indicated the deficits in an order-of-magnitude fashion, as well as policy choices to mitigate deficits. The FEIS addresses the outcome of the balancing and proposed policies/regulations associated with the Recommended Plan; it also addresses the Council Map List. The EIS is an informational tool in the decision-making process – but public process is not limited to the EIS. The policy choices to balance land use, levels of service, and revenues are part of the Planning Process. The Recommended Plan and Council Map List land use plans, and associated policies and regulations, have been the subject of public hearings.

Response to Comment 7: Alternatives 1 and 2 Focus Growth in Cities; Alternative 3 Does Not Comments are noted. Alternative 3 does focus more on UGA expansions and less on infill. However, it includes consideration of the 2004 docket items. All Alternatives in the DEIS and the FEIS include the “Centers” concept, and promote infill to differing degrees as described in Response to Comment 10, Letter 279.Cities will also be updating their Comprehensive Plans to ensure goals regarding infill and avoidance of sprawl are met.

Response to Comment 8: Lake Stevens Urban Industrial Pending projects were considered when the capacity analysis was performed for the DEIS. The estimated jobs capacity in the Lake Stevens area reflects the fact that a large portion of that area referred to in the comment, which is designated Urban Industrial, is being developed for residential use.

Snohomish County Comprehensive Plan 5-179 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 9: Specify LOS Changes The DEIS presents three growth alternatives for consideration by the County in crafting a preferred growth alternative and land use plan. Potential changes in the County’s transportation level of service (LOS) policies and procedures are described beginning on page 3-301, under Summary of Policy Measures as Mitigation. Table 3.2-32 describes the LOS policy options the County can use to balance available revenues with the transportation demands of planned land use. The FEIS describes proposed measures taken from the DEIS mitigation discussion and applies it to the Recommended Plan and Council Map List. FEIS Chapter 3 notes the number of projects required for alternative LOS standards. The EIS is an informational tool in the decision-making process – but public process is not limited to the EIS. The policy choices to balance land use, levels of service, and revenues are part of the Planning Process. The Recommended Plan and Council Map List land use plans, and associated policies and regulations, have been the subject of public hearings.

Response to Comment 10: Surface Water Standards – Lake Stevens Lake Stevens surface water standards are described on DEIS pages 3-117 and 3-408 in summary manner consistent with the programmatic nature of the document.

Response to Comment 11: TMDL Studies for Snohomish River The text has been revised to include discussion of the Snohomish TMDL. Snohomish County is a cooperating entity in the implementation of the Snohomish TMDL plans. Please see FEIS Chapter 4.

Response to Comment 12: State Highway LOS Disclosure of level of service on state highways is a requirement of the Growth Management Act (GMA). The GMA simply requires the County to present information on state highway performance based on the state’s LOS system.

Response to Comment 13: Park and Ride Needs Assessment The County’s General Policy Plan and a number of county coordination efforts translate into substantive support to public transportation. Increases in transit accessibility and park-and-ride use has the benefit of offering the public transportation choices and, as you indicated, reduces traffic on the highway and arterial system. Chapter 4 of the FEIS includes a reference to the “Three County Park and Ride Needs Assessment.”

Response to Comment 14: Mitigation Options – Limit UGA Expansion For the 10-Year Update UGA expansion may occur subject to land capacity analyses for the purposes of accommodating new projected growth (CPP UG-14.d.2) and is not restricted to the 50% growth parameter necessarily. Please see DEIS page 3-209 and DEIS Appendix E. The measure on page 3-302 would apply CPP UGA-14.d.3 to the multiple UGA review as an alternative to UG-14.d.2. Please also note that the Recommended Plan in particular as well as the Council Map List limits UGA expansion compared to Alternative 3.

Snohomish County Comprehensive Plan 5-180 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 15: Land Development Phasing By using the term “speculative” the County means the amount of financial relief provided would be unknown and is open to speculation.

Response to Comment 16: Other Land Use Options The evaluation method suggested is not the one selected by the County. The County starts with fixed growth targets established in cooperation with the cities and performs an “incremental- type” evaluation. That is, evaluation of two increments of growth over-and-above the “no action” growth alternative. Impacts are discerned and then land use, available revenues, and LOS standards are balanced.

Response to Comment 17: Shifting Money from Non-Capacity Projects While shifting money from non-capacity projects is a real option available to the County, it is not without drawbacks as the commenter indicates. The trade-offs are added to page 3-303 in FEIS Chapter 4.

Response to Comment 18: Shifting Money from Maintenance While this is a financial option available to the County, it would have significant drawbacks. The trade-offs are added to DEIS page 3-303 as shown in FEIS Chapter 4.

Response to Comment 19: Increasing Funds While an increase in funding would be welcome and could benefit provision of services and facilities, the County chose to present a conservative revenue forecast for comparing the three proposed growth alternatives. This allowed a comparison of the incremental costs of each growth alternative. It is correct that a beneficial shift of REET funds to roads would have a corresponding decline of funding for another infrastructure category.

Response to Comment 20: LOS Considerations See Response to Comment 9.

Response to Comment 21: Water Supplies The DEIS section is based on the County’s 2001 GMA Comprehensive Plan Utility Inventory Report updated in 2003, as noted on pages 3-377 and 3-378. The date of the various plans created by municipalities or special districts is noted clearly in Table 3.2-46. The most significant water purveyors are the City of Everett, Alderwood Water and Sewer District, and Snohomish PUD noted on p. 3-378, and these purveyors have the more recent plans – 2000, 2003, and 2002 respectively. The DEIS analysis also acknowledges on page 3-381 that: …Water supply capabilities should continually be monitored, especially in emerging areas of the County… While Everett is a key water supplier, the location of growth in areas unsupplied by the City may need to be monitored to ensure adequate supplies. Throughout the County, especially urban areas, project specific review of the adequacy of water service and fire flow will be necessary. The recently completed “Clearview Reservoir” project strengthens the Southwest

Snohomish County Comprehensive Plan 5-181 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

UGA water supply system. This project provides a second major source of supply to the UGA and bolsters the Everett, Alderwood, Silver Lake, and Cross Valley systems that serve the Southwest and Maltby UGAs. Further, no development may occur without a demonstrated source of potable water (DEIS page 3-383). Through the EIS and Planning process, the County has solicited feedback from water service providers. Planning for land use and water services is a cooperative County effort. The County has an obligation to plan for land use in unincorporated areas and consider water service in its Capital Facilities Plan, but implementation is primarily through municipalities and special districts.

Response to Comment 22: Sewer Plans The DEIS section is based on the County’s 2001 GMA Comprehensive Plan Utility Inventory Report updated in 2003 (pages 3-387 and 3-389). The date of the various plans created by municipalities or special districts is noted clearly in Table 3.2-48. With few exceptions the plan summaries are based on plans created in the late 1990’s and early 2000’s. The DEIS analysis also acknowledges on page 3-391 that: Under any of the Alternatives, additional sanitary sewer service will be necessary. Expansions and upgrades of existing plants will be required under any Alternative. Especially in smaller service areas, funding of service extensions will continue to be an issue. There will also be extensions of sewer service lines. In areas such as Alderwood there has been a significant amount of suburban large-lot development that is unsewered, and a concern about how best to fund and switch residents over to sewer. Treatment plant capacity should continually be monitored, especially in emerging areas of the County. A plant’s capacity is affected by both residential growth, which increased the volume of domestic flows, and by commercial and industrial growth, which increases the pollutant loading on the treatment process. Due to time, expense, and uncertainty involved in siting, permitting, and building new wastewater treatment plants, only a few additional plants are likely to be built in Snohomish County during the next 20 years. The regional wastewater plan known as Brightwater is anticipated to be sited and built by the year 2010, with an ultimate capacity of 54 MGD by the year 2030. By 2012, the plant would be able to accommodate 36 MGD in flows, which will greatly increase Snohomish County’s capability to meet long-term wastewater treatment needs. The higher densities and infill development included in the Alternatives are proposed in large part in areas within existing sewer service areas as seen in Figures 3.2-15 to 3.2-17. Please note that through the EIS and Planning process, the County has solicited feedback from wastewater service providers. As provider plans are periodically updated, they will be included in the County’s Capital Facility Plans. The County’s CFP is updated regularly to be applicable to a 6-year planning period. In Response to Comment 11, TMDL information is added to the Fisheries section as shown in FEIS Chapter 4 and cross-referenced in the Sewer section. With implementation of TMDL plans, annual growth monitoring, regular Capital Facility Plan Updates, the County may adapt to changing circumstances.

Snohomish County Comprehensive Plan 5-182 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 23: Rural Growth and Densities The density figures on page 85 of the 2003 Growth Monitoring Report only include Rural Cluster Subdivision (RCS) projects, not all subdivisions within the rural area. RCS provisions allow a higher gross density than would be possible in a traditional rural subdivision in return for setting aside at least 45% of the total site as open space. By clustering more houses on the most buildable portion of a rural site and preserving larger contiguous undeveloped tracts, RCS subdivisions allow land owners a potentially higher return from developing their land while at the same time providing more protection of the rural character and natural environment than would a traditional 5-acre lot subdivision. The exact RCS requirements vary depending on the zoning and plan designation. The R-5 zone/Rural Residential designation allows the highest gross density of 1 lot per 2.3 acres. Other zones have lower base densities but allow a density bonus of 15-35 percent if larger proportions of the site are preserved as open space. Generally, the open space is set aside as restricted open space, which is permanent. Within the Rural/Urban Transition Area (RUTA), interim open space tracts can be set aside which can only be developed if the area is later re- designated urban. Among other requirements, the individual lots must conform to the R-7200 dimensions and setbacks requirements and be large enough to meet Snohomish Health District requirements for septic system development. 5.5.1.14 FEIS Letter 289: Jim Orrell

Response to Comment 1: Population Estimates do not Justify UGA Expansion The comments to retain the current UGA boundaries are forwarded to the appropriate decision makers. The County appears on track to achieve its original 2012 OFM population allocation of 712,000. Alternative 1 population estimates would accommodate a population within OFM forecasts for 2025, but would be less than the OFM Most Likely Estimate for 2025. Please see DEIS Chapter 2.

Response to Comment 2: Weak Linkages between Transportation and Land Use The County has attempted to employ a number of factors in determining level of service. However given the wide variety of roads and data collection requirements for these other criteria, a LOS based on vehicle volumes was pursued. This system calculates LOS for arterial segments rather then individual intersections and determination of maximum service volumes for each segment is based on several factors: traffic volumes, number of lanes, lane widths, arterial classification, transit service and number of signals per mile. Additionally at the time of development a safety evaluation of impacted arterials is conducted to evaluate the need for additional roadway improvements at high collision locations. The needs of bicyclists are addressed in several ways throughout the County. First, as shown in DEIS Figures 3.2-4 and 3.2-7 the County’s existing and proposed Bicycle Facility System has been defined (see FEIS Section 3.2.6 for an updated proposed Bicycle Facility System.). This figure provides guidance in the allocation of funds and improvements along roadways. Each roadway improvement project is evaluated for bicycle facility needs based on this figure along with existing roadway usage. Major corridor bicycle improvements are pursued by the County’s Parks and Recreation Department.

Snohomish County Comprehensive Plan 5-183 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Regarding bicycle/vehicle collision statistics inquiries should be made to the Public Works Department.

Response to Comment 3: More Emphasis on Capital Financing Plan The purpose of the DEIS is as an informational document. SEPA does not require a fiscal analysis or a cost benefit analysis (WAC 197-11-448 and 450). However, to facilitate the planning process and assist in capital facility planning, the DEIS compares the impacts of increased growth on capital facilities (roads, parks, drainage) in an order of magnitude fashion, including optional cost information. Additional financial information has been developed for the Recommended Plan and Council Map List in FEIS Chapter 3.

Response to Comment 4: Support for Alternative 1 No Action Comments in support of Alternative 1 are forwarded to the appropriate decision makers. Please see Responses to Comments 1 to 3 for information specific to identified concerns. 5.5.1.15 FEIS Letter 290: Adrienne Quinn

Response to Comment 1: Summary of Comments The comments are noted. Please see Responses to Comments 2 to 9 regarding specific comments and responses.

Response to Comment 2: Character and Location of Hilltop Sports LLC Property The comments are noted and forwarded to the appropriate decision makers. Please note the need for transportation improvements would be based on an application of County plans and regulations and determined at the site specific development level.

Response to Comment 3: DEIS Not Site Specific The comments are noted. Please see Responses to Comments 4 to 6 regarding specific comments and responses.

Response to Comment 4: Transportation See DEIS and FEIS Arterial Circulation Maps for potential system improvements. The need for local transportation related improvements would be determined at the site specific level.

Response to Comment 5: Site Already Developed The site is already in commercial use (shooting range and kennel), and is proposed to be added to the matrix in FEIS Chapter 4. The Urban Commercial classification allows for a broad range of commercial and mixed uses more intensive than that found on the site presently. It is possible that there would be additional intensification on the site when included in the UGA, otherwise it would not need to be included in the UGA. The table is amended in FEIS Chapter 4 to note that the conversion impacts would be less than for undeveloped or noncommercial sites, although further intensification could occur.

Snohomish County Comprehensive Plan 5-184 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 6: Few Adverse Impacts of Conversion The comments are noted. Please also see Response to Comment 5.

Response to Comment 7: Urge Selection of Alternative 2 or 3 The comments are noted and forwarded to the appropriate decision makers. Please see the Recommended Plan and Council Map List description in FEIS Chapter 2. These alternatives include the Hilltop Sports property.

Response to Comment 8: Need for More Commercial due to Island Crossing Decision The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 9: Designate Hilltop Property as Urban Commercial The comments are noted and forwarded to the appropriate decision makers. 5.5.1.16 FEIS Letter 291: Ralph Smith

Response to Comment 1: Support for Alternative 1 The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 2: Alternatives 2 and 3 Worsen Park Services, Land, and Resources The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 3: Undersupply of Trails, Poor Mapping The comments are noted and forwarded to the appropriate decision makers. Please note that the DEIS included maps of existing developed parkland and trails and County-owned undeveloped land in Figures 3.2-12 and 3.2-13. Additional close up maps are found in the County’s 2001 Comprehensive Parks Plan.

Response to Comment 4: King County Parks The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 5: County Neglecting Parks Planning The comments are noted and forwarded to the appropriate decision makers. Please note the County has prepared the 2001 Comprehensive Parks Plan. It will be regularly updated, such as after adoption of the 10-Year GMA Comprehensive Plan Update. As part of Parks Plan update, public comment will be solicited.

Response to Comment 6: Alternative 1 Most Fiscally Responsible The comments are noted and forwarded to the appropriate decision makers.

Snohomish County Comprehensive Plan 5-185 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 7: Improve Quality of Living as Greater Populations and Greater Densities are Allowed The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 8: Alternatives 2 and 3 Irresponsible The comments are noted and forwarded to the appropriate decision makers. 5.5.1.17 FEIS Letter 292: S. Michael Smith

Response to Comment 1: Population Estimates are not Precise; Set Capacity High The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 2: In 1995 Population was Underplanned While growth has exceeded allocations for 2012 in some locations, in general, the County appears on track to achieve its original 2012 OFM population of 714,000 (712,000 plus Lake Stevens Subarea Plan population adjustment). By 2025, the No Action Alternative (adopted Plan) would accommodate a population in the OFM population projections but would be less than the OFM most likely estimate. Therefore, the DEIS also reviewed other alternatives of greater population. Also see the Recommended Plan and Council Map List population projection in FEIS Chapter 2.

Response to Comment 3: Planning for Larger Population Preferable to Planning for Smaller Population The comments are noted and forwarded to the appropriate decision makers. Please note that the County has the ability to amend its plan annually and a requirement to review it more fully every seven years under GMA. If population growth occurs at a faster or slower pace, the Plan may be adjusted to balance land use, services/capital needs, and revenues.

Response to Comment 4: Higher Population Plans for Future instead of Catching Up The comments are noted and forwarded to the appropriate decision makers. Please also see Response to Comment 3.

Response to Comment 5: Alternative 3 Closer to State Midrange Alternative 3’s population of 950,000 to 965,000 is above the OFM “most likely” population estimate of 930,000.

Response to Comment 6: Focus on High End of Range for Infrastructure The comments are noted and forwarded to the appropriate decision makers. Please also see Responses to Comment 3 and 5.

Snohomish County Comprehensive Plan 5-186 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 7: Impossible to Overplan, but Possible to Underplan Please see Response to Comment 2.

Response to Comment 8: Plan Early for Infrastructure The comments are noted and forwarded to the appropriate decision makers. Please also see Response to Comment 3. 5.5.1.18 FEIS Letter 293: F. Robert Strahm

Response to Comment 1: DEIS Does not Correctly Size UGAs or Include Deductions The formula that the Commenter uses to calculate new units required within the UGA under Alternative 3 is in error. The math that is used to calculate the 2025 UGA population as 896,574 unfortunately only subtracted 2002-2025 rural population growth (stated to be 53,795) from the 2025 countywide total population figure, rather than subtracting total 2025 rural population under Alternative 3 (178,732). The correct figure for total 2025 UGA population under Alternative 3 is 771,637 (see DEIS Appendix A, page A-3). Consequently, the correct 2002- 2025 UGA population growth projection under Alternative 3 is 256,957, which is 124,937 persons fewer (33% less) than the figure the Commenter arrives at (381, 894). Using the correct UGA projected population growth significantly lowers the estimated new units required under Alternative 3. In addition, the “Alternative 3 Future Land Use” chart reviewed by the Commenter in Appendix A only shows the acres of UGA infill and expansion areas with proposed capacity changes (i.e. upzones or downzones). It does not show the capacity of lands that would continue with the same FLUM categories and which will contribute to the growth potential under any alternative. As a result, the Commenter is only using a portion of the actual developable acres within the UGA for his analysis and is comparing it to an inaccurately high estimate of required new housing units required. The analysis of land capacity for each DEIS alternative used the County’s buildable lands methodology as documented in the 2002 Snohomish County Tomorrow 2002 Growth Monitoring/Buildable Lands Report. This methodology included discounts for critical areas, roads, and lands for public purposes. The combination of buildable lands (see DEIS Figure 2.4- 8), the DEIS land use alternatives (see DEIS Figure 2.4-10 to 2.4-14), and the 2002 Buildable Lands report generated the statistics for each Alternative (see for example Table 2.4-1). This methodology has been documented in the “Draft Snohomish County UGA Land Capacity Analysis Technical Report” published April 29, 2005. 5.5.1.19 FEIS Letter 294: Frank Whichman

Response to Comment 1: Growth Coming from Outside County; Infill Development not Progressive The comments are noted. Growth would be a result of in-County births and in-migration. Infill development is a method to accommodate growth near existing infrastructure and with less impact to rural and resource lands than UGA expansion. The Recommended Plan includes

Snohomish County Comprehensive Plan 5-187 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses additional design standard policies. It implements design standard regulations for the Urban Centers. See FEIS Chapter 2.

Response to Comment 2: Create Healthier Environments – Larger Lots or Clustered Developments with Commons The comments are noted and forwarded to the appropriate decision makers. Please note that the DEIS addressed parks and recreation issues in Section 3.2.10, including the need for facilities in proximity to population centers.

Response to Comment 3: 128th Urban Center – Prefer Offices and Industrial The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 4: Conduct a Survey on Growth The comments are noted and forwarded to the appropriate decision makers. The County is required to accommodate its projected population and has a range from which to choose. It has prepared the DEIS alternatives to illustrate a range of population choices. Public participation to help develop and refine alternatives included focus groups, open houses, workshops, questionnaires at workshops, website communication, mailing lists, etc. Please see FEIS Chapter 2 for a discussion of public participation methods for the 10-Year Update to date.

Response to Comment 5: Measuring Progress by Quality of Life The comments are noted and forwarded to the appropriate decision makers. Please note that the DEIS includes mitigation measures to address impacts of traffic, noise, parks, etc. due to the range of alternatives reviewed. 5.5.1.20 FEIS Letter 295: David K. Toyer

Response to Comment 1: Support for Alternative 3 The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 2: Alternative 3 Minimally Affects Resource Lands and Minimally Expands UGA Boundaries Please see FEIS Letter 22, Response to Comment 3.

Response to Comment 3: Alternative 3 – Critical Area Impacts can be Mitigated The comments are noted and forwarded to the appropriate decision makers. While critical areas regulations and voluntary mitigation are useful tools to reduce impacts of development, the DEIS also identifies mitigation measures to reduce impacts to particularly sensitive areas such as Little Bear Creek basin.

Snohomish County Comprehensive Plan 5-188 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 4: Docket Proposals The Recommended Plan and Council Map List carry forward many, but not all, of the docket proposals. Please see FEIS Chapter 2. Docket proposals are considered annually. Any docket proposals that are not carried forward may be reviewed in subsequent years.

Response to Comment 5: Areawide Rezone Please see Letter 286, Response to Comment 174.

Response to Comment 6: Transportation Comments are noted and forwarded to appropriate decision makers. As further clarification the County can currently declare some roadways to be at “ultimate capacity” when environmental and financial impacts are excessive and/or prohibitive. The Central Puget Sound Growth Management Hearings Board (GMHB), under a previous appeal decision, has provided guidance on use of ultimate capacity. Under ultimate capacity, an arterial is not exempt from consideration under concurrency, where its LOS is caused by development to drop below adopted standards, but can be assigned alternative mitigation that may not include capacity- related improvements. Lower levels of service are a policy measure in DEIS Table 3.2-32. With regards to “adaptive design techniques” the County is considering a similar concept. See FEIS Chapters 2 and 3 for a description of potential new LOS standards and concurrency management systems (CMS) associated with the Recommended Plan.

Response to Comment 7: Land Use Phasing Table 3.2-32 presents several possible measures for County consideration that could help balance land use, financing and LOS given funding shortfalls, including development phasing. The Recommended Plan proposes policies that are described in FEIS Chapter 2.

Response to Comment 8: Increased Detention The comments are noted and forwarded to the appropriate decision makers. Please also see other mitigation measures related to low impact development, which may reduce the size of detention facilities for clustered development built in a manner to match better natural drainage solutions.

Response to Comment 9: Increased Buffer Enhancement Buffer enhancement is encouraged in DEIS mitigation measures such as on p. 3-136. The nature of implementing programs or regulations is not fully known at this time. The County Critical Areas Regulations Update is under preparation in a separate process as noted on pages 3-2 and 3-3 of the DEIS. The DEIS and FEIS assumed implementation of the current adopted CAR.

Response to Comment 10: Increased Buffers Please see Response to Comment 9.

Snohomish County Comprehensive Plan 5-189 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 11: Increased Impervious Surface Requirements Please see FEIS Letter 22, Response to Comment 6. Please also note that intensive development is possible on existing impervious surfaces in the form of redevelopment. Redevelopment is particularly encouraged in the Centers.

Response to Comment 12: Design Review Please see FEIS Letter 22, Response to Comment 4.

Response to Comment 13: Support for TDR The comments are noted and forwarded to the appropriate decision makers. The Recommended Plan identifies TDR receiving areas. The Council Map List would require TDR in a potential UGA expansion in east Arlington.

Response to Comment 14: Support for FCCs The comments are noted and forwarded to the appropriate decision makers. The FEIS Alternatives include a reserve population for one or more FCC’s. 5.5.1.21 FEIS Letter 296: Nancy Walker

Response to Comment 1: Impact to Environment and Quality of Life The comments are noted and forwarded to the appropriate decision makers. Please note that the EIS addresses a range of natural and built environment topics. It describes potential impacts of growth on the environment, land use, and public services/facilities, and it includes potential mitigation measures.

Snohomish County Comprehensive Plan 5-190 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

5.6 Public Hearing Comments Three public hearings to obtain oral comments on the DEIS were held on June 1, 3, and 8, 2004. Speakers are listed on Table 5.6-1. Transcripts follow responses to comments.

Table 5.6-1 Public Hearing Participants FEIS# Commenter Date 297 Randle Torset 6/1/04 298, 303a Margaret Fee 6/1/04 299 Ray Decker 6/1/04 300 Ann Hayes 6/1/04 301 Susan Camber 6/1/04 302 Bill Blake 6/1/04 303 Kristin Kelly 6/1/04 304 John Mauro 6/1/04 305 Jim Cummings 6/3/04 306 Mike Pattison 6/3/04 307 Kristin Kelly 6/3/04 308 Jim Van Niel 6/3/04 309 Nancy Rogers 6/3/04 310 Julie Langabeer 6/3/04 311 Peggy Toepel 6/3/04 312 John Mauro 6/3/04 313 Bob Heavy 6/3/04 314 Gerald Moyeir 6/3/04 315 Bev Setzer 6/3/04 316 Rueben Johnson 6/3/04 317 Jerri Watkins 6/3/04 318 John Shouman 6/3/04 319 Paul Brandal 6/3/04 320 Eileen Weber 6/3/04 321 John Ewald 6/3/04 322 Steve Hebiah 6/3/04 323 Joy Owens 6/3/04 324 Mary Dulin 6/3/04 325 Kristin Kelly (Second) 6/3/04 326 Cindy Howard 6/8/04 327 Larry Gardner 6/8/04 328 Tasha Branch 6/8/04

Snohomish County Comprehensive Plan 5-191 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

FEIS# Commenter Date 329 Susan Taylor-Alling 6/8/04 330 Dwight Hartman 6/8/04 331 Kathleen Wruck 6/8/04

5.6.1 June 1st Public Hearing Minutes 5.6.1.1 FEIS Commenter 297: Randle Torset

Response to Comment 1: Support Higher Growth Alternative The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 2: Parcel at 84th and Highway 9 The comments are noted and forwarded to the appropriate decision makers. The Baily and Wilson and Johnson requests are included in the Recommended Plan and Council Map List.

Response to Comment 3: Alternative 3 – Property Supports The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 4: Docket Sponsors The comments are noted. 5.6.1.2 FEIS Commenter 298: Margaret Fee

Response to Comment 1: Oppose NASCAR The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 2: Minimum Lot Size 5 Acres The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 3: City Water The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 4: Fish and Wildlife The comments are noted and forwarded to the appropriate decision makers. Fisheries and wildlife are addressed in the DEIS Sections 3.1.5 and 3.1.7.

Response to Comment 5: Building will Lead to Drainage and Water Quality Problems The comments are noted and forwarded to the appropriate decision makers. Drainage is addressed in FEIS Section 3.2.14.

Snohomish County Comprehensive Plan 5-192 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 6: Other Marysville Meeting Security The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 7: Bellevue Crime The comments are noted.

Response to Comment 8: Have Roads, Water and Sewer in Place The comments are noted and forwarded to the appropriate decision makers. Roads, water and sewer impacts are addressed in the DEIS Sections 3.2.6, 3.2.12, and 3.2.13 respectively.

Response to Comment 9: Adequate Emergency Access The comments are noted. Local Fire Districts implement Fire Codes. County Road Standards also include standards for access. County Public Works and Local Fire Districts are provided an opportunity for comment on development applications.

Response to Comment 10: Communication The comments are noted and forwarded to the appropriate decision makers. The EIS hearings were held multiple evenings to afford several opportunities for the public to present testimony. Please also see FEIS Chapter 2 for a discussion of the 10-Year Update public communication activities.

Response to Comment 11: Look Ahead before Planning Densities The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 12: Area Between Highway 9 and 67th – Future City? The area between 67th and Highway 9 is located in designated rural lands and is not identified for future inclusion in the Marysville or Arlington Urban Growth Areas.

Response to Comment 13: Take Everything into Consideration before Moving Ahead The comments are noted and forwarded to the appropriate decision makers. 5.6.1.3 FEIS Commenter 299: Ray Decker

Response to Comment 1: Include Property into Stanwood UGA The comments are noted and forwarded to the appropriate decision makers. The property is included in Alternative 3. However, it is not included in the Recommended Plan or Council Map List. Evaluation of the site indicated extensive critical areas including Church Creek, a wetland, and a ravine, that would limit urban development, the ability to provide infrastructure, and would be in turn subject to impact. Please see Volume I, Appendix B for a discussion of each docket request.

Snohomish County Comprehensive Plan 5-193 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

5.6.1.4 FEIS Commenter 300: Ann Hayes

Response to Comment 1: How Can the Alternatives Affect Future Population? The State OFM population forecasts provide a target range within which the County can plan its future growth. The EIS Alternatives establish future land use patterns and create capacity for growth. Snohomish County plans and regulations guide land use and intensity of land use (density, lot size, height, etc.) that can occur on the property. Ultimately the future County population is a result of many individual decisions by persons regarding locating/relocating in Snohomish County, family size preferences, property owner decisions to sell or redevelop their property, and other individual decisions. County growth plans channel growth into appropriate locations, and regulate the use of land, but do not control individual family size decisions.

Response to Comment 2: Wildlife Pushed Out The comments are noted and forwarded to the appropriate decision makers. Impacts to wildlife are addressed in DEIS Section 3.1.7.

Response to Comment 3: Alternative 1 Alternative 1 No Action, the adopted Future Land Use Map, has capacity for additional growth. It would accommodate a population of 862,254 approximately, and this is in the range of State OFM population forecasts. Please also see Response to Comment 1.

Response to Comment 4: Wildlife Corridors The comments are noted and forwarded to the appropriate decision makers. Impacts to wildlife are addressed in DEIS Section 3.1.7.

Response to Comment 5: Focus on Infill in Larger Towns See FEIS Letter 279, Response to Comment 10.

Response to Comment 6: Population Control Please see Response to Comment 1. 5.6.1.5 FEIS Commenter 301: Susan Camber

Response to Comment 1: FCC Tacked onto Alternative 3 Please see Responses to Comments 2 and 7 under FEIS Letter 287.

Response to Comment 2: FCC – Not Solution to Problem The comments are noted and forwarded to the appropriate decision makers. Please note the discussion of FCC policies in FEIS Chapter 3, which indicates the multiple steps the County would need to complete before a FCC(s) can be established. These steps will include public review of any future proposals and future environmental review.

Snohomish County Comprehensive Plan 5-194 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 3: Cost of a FCC Please see Responses to Comments 2 and 7 under FEIS Letter 287. 5.6.1.6 FEIS Commenter 302: Bill Blake

Response to Comment 1: Stillaguamish Watershed Plan The DEIS promotes implementation of watershed plans in DEIS Section 3.1 under various topics including fisheries. The Plans and Policies Section 3.2.2 noted that watershed plans were underway at the time of the DEIS writing. More recent status information is provided in FEIS Chapter 3.

Response to Comment 2: Make Sure There’s Land to Enjoy The comments are noted and forwarded to the appropriate decision makers. 5.6.1.7 FEIS Commenter 303: Kristin Kelly

Response to Comment 1: Economic Development Each Alternative includes a forecasted employment target. The Alternatives identify commercial and industrial uses, as well as resource uses, that would accommodate jobs. Policies and programs to encourage economic development would help implement the selected land use alternative. Please also see FEIS Chapter 2 for a discussion of policy amendments associated with the Recommended Plan.

Response to Comment 2: Type of Economic Development The comments are noted and forwarded to the appropriate decision makers. 5.6.1.8 FEIS Commenter 303a: Margaret Fee

Response to Comment 1: Funding for future roads The DEIS in section 3.2.3 discusses population growth for each alternative. The FEIS, Chapter 2, describes population growth for the Recommended Plan and Council Map List. The DEIS does not quantify the costs and revenues associated with each alternative. Some limited capital cost information is included (e.g. roads, parks, surface water). Fiscal information is not required to be included in an EIS. 5.6.1.9 FEIS Commenter 304: John Mauro

Response to Comment 1: Effects of Sprawl The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 2: Costs of Sprawl The comments are noted and forwarded to the appropriate decision makers.

Snohomish County Comprehensive Plan 5-195 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 3: Don’t Pass Costs On to Future Generation The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 4: Promote Infill and Redevelopment The comments are noted and forwarded to the appropriate decision makers. Please also see Response to Comment 12 under FEIS Letter 23, and Response to Comment 10, Letter 279.

Response to Comment 5: Infill more Responsible The comments are noted and forwarded to the appropriate decision makers.

Snohomish County Comprehensive Plan 5-196 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

5.6.2 June 3rd Public Hearing Minutes 5.6.2.1 FEIS Commenter 305: Jim Cummings

Response to Comment 1: NASCAR Review The 10-Year Update EIS addresses the countywide impacts of growth in unincorporated areas at a programmatic level. It reviews the impacts associated with implementing the relatively broad land use categories establishing residential densities and types, and location of commercial or industrial areas. Any site specific development such as was proposed with NASCAR would require its own supplemental environmental review.

Response to Comment 2: Dwayne Lane Reclassification of the Island Crossing area for urban commercial purposes is not included in the EIS Alternatives due to the Central Puget Sound Growth Management Hearings Board ruling as described on pages 2-14 and 2-15 of the DEIS.

Response to Comment 3: Business Growth and Impact on Jobs, Economy, and Population The EIS addresses the impact of population and employment growth at various levels. Please see DEIS Section 3.2.3, and FEIS Chapter 3 regarding population/employment/housing discussions. 5.6.2.2 FEIS Commenter 306: Mike Pattison

Response to Comment 1: Support for Alternative 3, Plan for Higher Numbers The comments are noted and forwarded to the appropriate decision makers. Please note that the County has the ability to amend its plan annually and a requirement to review it more fully every seven years under GMA. If population growth occurs at a faster or slower pace, the Plan may be adjusted to balance land use, services/capital needs, and revenues.

Response to Comment 2: Sufficient Housing The comments are noted and forwarded to the appropriate decision makers. Please see DEIS Section 3.2.3, and FEIS Chapter 3 regarding housing discussions.

Response to Comment 3: Alternative 3 and Ordinance 04006 Alternative 2’s population is closest to the initial population targets referenced in Ordinance 04006.

Response to Comment 4: Residential Growth Pays for Itself Please see FEIS Letter 22, Response to Comment 16.

Snohomish County Comprehensive Plan 5-197 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 5: Safety Factor The 11% safety factor refers to the amount of buildable land beyond that necessary to accommodate 950,369, not including a FCC allocation. This population figure is also above the OFM most likely population estimate of 930,000. Please also see Response to Comment 1.

Response to Comment 6: Regularly Update Buildable Lands Analysis The comments are noted. The County intends to regularly update the buildable lands analysis consistent with GMA. Additionally, the County publishes an annual growth monitoring report in conjunction with Snohomish County Tomorrow.

Response to Comment 7: Increase Density to Reduce Sprawl The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 8: Support for Alternative 3 The comments are noted and forwarded to the appropriate decision makers. 5.6.2.3 FEIS Commenter 307: Kristin Kelly

Response to Comment 1: DEIS Thorough The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 2: Contrasts of Alternatives The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 3: Focus Growth in Existing Urban Centers The comments are noted and forwarded to the appropriate decision makers. Please see Response to Comment 2, FEIS Letter 19.

Response to Comment 4: Maintain Levels of Service The comments are noted and forwarded to the appropriate decision makers. Please see Response to Comment 3, FEIS Letter 19.

Response to Comment 5: Transferring REET The comments are noted and forwarded to the appropriate decision makers. Please see Response to Comment 9, FEIS Letter 19.

Response to Comment 6: Expand Center Designations along I-5 The Urban Center concept is reflected in all of the studied alternatives including the No Action Alternative. Alternatives 2 and 3 extend the Centers concept to additional areas as does the Recommended Plan.

Snohomish County Comprehensive Plan 5-198 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 7: Protect Forests and Farms, Support TDR The comments are noted and forwarded to the appropriate decision makers. Please see Response to Comment 5, FEIS Letter 19.

Response to Comment 8: Focus Growth in Centers to Reduce Costs The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 9: Do Not Allow FCC The comments are noted and forwarded to the appropriate decision makers. Please note that the Recommended Plan and Council Map List include a population reserve for a FCC. More study will be needed to establish a FCC should one or more FCC be proposed in the future.

Response to Comment 10: Development Phasing The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 11: Surface Water Fees and Mitigation The comments are noted and forwarded to the appropriate decision makers. Extension of SWM fees is a revenue option mitigation measure in DEIS Section 3.14. Low impact development regulations are also a proposed mitigation measure (DEIS page 3-423). 5.6.2.4 FEIS Commenter 308: Jim Van Niel

Response to Comment 1: Limit UGA Expansions in Critical Areas The comments are noted and forwarded to the appropriate decision makers. Please also see Response to Comment 3, Letter 1.

Response to Comment 2: Infill Preferred over Sprawl The comments are noted and forwarded to the appropriate decision makers. Please refer to Response to Comment 5, Letter 1.

Response to Comment 3: Growth Expansion and Emergency Services The comments are noted and forwarded to the appropriate decision makers. Infill growth can be result in fewer impacts to public safety services than expanded growth due to existing facilities and infrastructure. Public safety is addressed in DEIS Section 3.2.9.

Response to Comment 4: Support for Alternative 1 or 2 The comments are noted and forwarded to the appropriate decision makers.

Snohomish County Comprehensive Plan 5-199 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

5.6.2.5 FEIS Commenter 309: Nancy Rogers

Response to Comment 1: Concurrence with Master Builders Association Comments The comments are noted and forwarded to the appropriate decision makers. Please see responses to comments associated with FEIS Commenter 306. Regarding a hybrid alternative, the Recommended Plan and Council Map List are described in FEIS Chapter 2. The Council Map List includes the Lundeen property.

Response to Comment 2: History of Lundeen Property The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 3: Inclusion in Alternative 3 DEIS Appendix B relates the broad DEIS analysis to particular docket requests. The FEIS includes individual docket sheets in Appendix I-B.

Response to Comment 4: Planning Consistency The comments are noted and forwarded to the appropriate decision makers. See also the plan and policy consistency analysis at DEIS pp. 3-229 to 3-233.

Response to Comment 5: Environmental Constraints The implications of expanding UGAs in terms of critical areas is an appropriate programmatic topic in a nonproject EIS, to help shape land use plan amendments. See also Response to Comment 3 above. At a site specific level further environmental analysis would be conducted when specific proposals are known.

Response to Comment 6: Infrastructure See the DEIS for overall analysis of Alternative 3, and DEIS Appendix B regarding dockets. FEIS Appendix I-B provides individual review of dockets.

Response to Comment 7: DEIS Comments Forthcoming Please see FEIS Letter 91 and associated responses to comment.

Response to Comment 8: Higher Growth – More Housing Opportunity Please note that the County has the ability to amend its plan annually and a requirement to review it more fully every seven years under GMA. If population growth occurs at a faster or slower pace, the Plan may be adjusted to balance land use, services/capital needs, and revenues.

Response to Comment 9: Support Alternative 3 or Hybrid The comments are noted and forwarded to the appropriate decision makers.

Snohomish County Comprehensive Plan 5-200 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

5.6.2.6 FEIS Commenter 310: Julie Langabeer

FEIS Response to Comment 1: Costs of Growth The comments are noted and forwarded to the appropriate decision makers.

FEIS Response to Comment 2: Alternative with Least Harm The comments are noted and forwarded to the appropriate decision makers. Please see FEIS Chapter 2 for a description of the Recommended Plan.

FEIS Response to Comment 3: Critical Areas Mitigation and Regulation The comments are noted and forwarded to the appropriate decision makers. The Comprehensive Plan is intended to define the land use plan and policies and associated supporting infrastructure and service needs for the County. The Critical Areas Regulations Update is under preparation in a separate process as noted on pages 3-2 and 3-3 of the DEIS. The DEIS and FEIS assumed implementation of the current adopted CAR. 5.6.2.7 FEIS Commenter 311: Peggy Toepel

Response to Comment 1: Groundwater, Water Supply, and Wastewater Services Please see Responses to Comments associated with FEIS Letter 21.

Response to Comment 2: Infrastructure Upgrade – Costs High The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 3: Margins of Capacity Please see Responses to Comments associated with FEIS Letter 21, and Responses to Comments 21 and 22 with FEIS Letter 288.

Response to Comment 4: Alternative 3 Too Much The comments are noted and forwarded to the appropriate decision makers. 5.6.2.8 FEIS Commenter 312: John Mauro

Response to Comment 1: Long Term Economic Gain and Smart Growth The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 2: Alternatives Process The comments are noted and forwarded to the appropriate decision makers.

Snohomish County Comprehensive Plan 5-201 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 3: Prioritize Infill Over Sprawl Please see Response to Comment 12 FEIS Letter 23.

Response to Comment 4: Infill and Lower Housing Prices The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 5: Transportation Costs of Alternatives The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 6: Parks Costs of Alternatives The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 7: Financial Incentives The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 8: Long Term Economic Viability The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 9: Incentives for Infill The comments are noted and forwarded to the appropriate decision makers. Please see FEIS Chapter 2, which describes policies associated with the Recommended Plan. Policies and regulation amendments address some of the incentives described in the comments.

Response to Comment 10: Costs of Sprawl The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 11: Transportation and LOS The comments are noted and forwarded to the appropriate decision makers. Please see FEIS Chapter 2, which describes policies associated with the Recommended Plan, including LOS approaches.

Response to Comment 12: Do Not Include a FCC The comments are noted and forwarded to the appropriate decision makers. Please note that the Recommended Plan and Council Map List include a population reserve for a FCC. More study will be needed in later phases to establish a FCC should one or more FCC be proposed.

Response to Comment 13: Precautionary Approach The comments are noted and forwarded to the appropriate decision makers.

Snohomish County Comprehensive Plan 5-202 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 14: Demographic Data See Response to Comment 17 in FEIS Letter 23.

Response to Comment 15: Strengthen Development Regulations The comments are noted and forwarded to the appropriate decision makers. 5.6.2.9 FEIS Commenter 313: Bob Heavy

Response to Comment 1: Look Backwards and Forwards The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 2: Alternatives 1 and 2 The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 3: Alternative 3 The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 4: Support for Infill The comments are noted and forwarded to the appropriate decision makers. 5.6.2.10 FEIS Commenter 314: Gerald Moyeir

Response to Comment 1: Careful Planning The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 2: Support for Alternative 3 The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 3: Growth Coming from Seattle The comments are noted and forwarded to the appropriate decision makers. 5.6.2.11 FEIS Commenter 315: Bev Setzer

Response to Comment 1: Concerns with Alternative 3 Growth The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 2: Protect Rural The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 3: Cost of Growth Spreading The comments are noted and forwarded to the appropriate decision makers.

Snohomish County Comprehensive Plan 5-203 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 4: Concern about FCC A FCC has not been sited. Please note that the Recommended Plan and Council Map List include a population reserve for a FCC (FEIS Chapter 2). More study will be needed in the future to establish a FCC should one or more FCC be proposed.

Response to Comment 5: Support Alternative 1 The comments are noted and forwarded to the appropriate decision makers. 5.6.2.12 FEIS Commenter 316: Reuben Johnson

Response to Comment 1: Growth of Planning Regulations The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 2: Appreciation for Docket The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 3: Mapping Errors in GMA Process; Support for This Planning Process The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 4: Historic Buildable Lands The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 5: Don’t Inundate Rural Areas with Growth The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 6: Example Rural Cluster in Arlington The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 7: Appreciation for Other Comments, e.g. Audubon The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 8: Support for Alternative 3 The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 9: Area North of Monroe – Sewer The comments are noted and forwarded to the appropriate decision makers.

Snohomish County Comprehensive Plan 5-204 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 10: Include North Monroe Area, Alternative 3 The comments are noted and forwarded to the appropriate decision makers. A portion of the Johnson property is proposed to be included in the UGA. See FEIS Chapter 2.

Response to Comment 11: Appreciate Process and Opportunity The comments are noted and forwarded to the appropriate decision makers. 5.6.2.13 FEIS Commenter 317: Jerri Watkins

Response to Comment 1: Zoning History The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 2: Include Area in UGA The comments are noted and forwarded to the appropriate decision makers. 5.6.2.14 FEIS Commenter 318: John Shouman

Response to Comment 1: Alternative 3 Allows Zoning for NASCAR The comments are noted and forwarded to the appropriate decision makers. The subject area classification has been considered as a docket item since 2002, before the NASCAR proposal was put forth.

Response to Comment 2: Support Alternative 1 or 2 The comments are noted and forwarded to the appropriate decision makers. 5.6.2.15 FEIS Commenter 319: Paul Brandal

Response to Comment 1: Need Local Food Producers The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 2: Pressure of Poor Detention on Farming In Floodplains Please see Response to Comment 1, FEIS Letter 16.

Response to Comment 3: Taller Buildings, Avoid Sprawl The comments are noted and forwarded to the appropriate decision makers. 5.6.2.16 FEIS Commenter 320: Eileen Weber

Response to Comment 1: Enjoy Multiple Housing The comments are noted and forwarded to the appropriate decision makers.

Snohomish County Comprehensive Plan 5-205 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 2: Urban Village Lifestyle Needed Rather than Car Culture The comments are noted and forwarded to the appropriate decision makers. Please also see FEIS Chapter 2 for a description of policy and regulatory amendments related to Urban Centers.

Response to Comment 3: Support for Urban Growth and Protection of Rural and Critical Areas The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 4: Need Sidewalks The comments are noted and forwarded to the appropriate decision makers. Please also see FEIS Chapter 2 for a description of policy and regulatory amendments related to Urban Centers.

Response to Comment 5: Support for Audubon The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 6: Increased Protection for Open Space and Farmland The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 7: Growth Pay for Itself The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 8: Tree Retention Ordinance The comments are noted and forwarded to the appropriate decision makers. See FEIS Letter 286, Response to Comment 209. 5.6.2.17 FEIS Commenter 321: John Ewald

Response to Comment 1: Support for Accessible Meeting Locations and Formats The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 2: Keep Mixed Character of County The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 3: Growth Should Occur Along Historical Lines – Keep it in Corridors Supported by Infrastructure The comments are noted and forwarded to the appropriate decision makers.

Snohomish County Comprehensive Plan 5-206 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

5.6.2.18 FEIS Commenter 322: Steve Hebiah

Response to Comment 1: Change Inevitable – Address People The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 2: Support for Alternative 3 The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 3: Cross Cultural Communities The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 4: Support Alternative 3 – Housing Opportunity The comments are noted and forwarded to the appropriate decision makers. 5.6.2.19 FEIS Commenter 323: Joy Owens

Response to Comment 1: Salmon Spawning in Ditches Water types are defined in SCC 30.62.300[1]. Waters with salmonids, including ditched streams, would be subject to the regulations. 5.6.2.20 FEIS Commenter 324: Mary Dulin

Response to Comment 1: Transportation Concerns The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 2: Transit Options and Adequate Transportation Needed The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 3: Support Alternative 1 The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 4: Adequate Bus Service The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 5: Tree Protection in UGA The comments are noted and forwarded to the appropriate decision makers. See FEIS Letter 286, Response to Comment 209.

Snohomish County Comprehensive Plan 5-207 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Response to Comment 6: Support Infill with Transportation; Protect Rural The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 7: Need Sufficient Professional Jobs in County The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 8: Infill Supports Transportation The comments are noted and forwarded to the appropriate decision makers. 5.6.2.21 FEIS Commenter 325: Kristin Kelly

Response to Comment 1: Design Policies The comments are noted and forwarded to the appropriate decision makers. The Recommended Plan includes amended policies and regulations addressing Centers design and coordinated design standards in UGAs.

Response to Comment 2: Don’t Shift Resources from Noncapacity Projects The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 3: More Resources – Non-motorized Paths The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 4: Property Tax Increase The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 5: Increase Impact Fees The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 6: Don’t Reallocate Parks and Surface Water Funds to Roads The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 7: Voter Approved Road Funds Unlikely The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 8: Alternative 3 Doesn’t Work The comments are noted and forwarded to the appropriate decision makers.

Snohomish County Comprehensive Plan 5-208 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

5.6.3 June 8th Public Hearing Minutes 5.6.3.1 FEIS Commenter 326: Cindy Howard

Response to Comment 1: Expand Centers on I-5 Corridor The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 2: Don’t Allow FCC The comments are noted and forwarded to the appropriate decision makers. Please note that the Recommended Plan and Council Map List include a population reserve for a FCC. More study will be needed in later phases to establish a FCC should one or more FCC be proposed.

Response to Comment 3: DOT 10-Lane Washington Corridor The study is only conceptual in nature. There are no approved alternatives or budget commitments. It is not considered in the transportation modeling of the Alternatives due to its speculative nature.

Response to Comment 4: Appreciation for Public Workshops The comments are noted. 5.6.3.2 FEIS Commenter 327: Larry Gardner

Response to Comment 1: Support Alternative 3 and Church Property Inclusion The comments are noted and forwarded to the appropriate decision makers. Please see FEIS Chapter 2 regarding which properties are carried forward in the Recommended Plan or Council Map List.

Response to Comment 2: McGregor Property – In Favor of Property Inclusion in UGA The comments are noted and forwarded to the appropriate decision makers. Please see FEIS Chapter 2, regarding which properties are carried forward in the Recommended Plan or Council Map List. 5.6.3.3 FEIS Commenter 328: Tasha Branch

Response to Comment 1: Docket Proposals in Alternative 1 Approximately 80 docket items were authorized for study by the County Council as part of Alternative 3. DEIS Appendix B reviews the items generally for compliance with docket criteria. Those docket items included in the Recommended Plan or Council Map List are described in FEIS Chapter 2. Docket items not carried forward either in the 2004 Docket/Alternative 3 or with the land use alternative ultimately accepted by the County Council may be resubmitted in later Docket processes.

Snohomish County Comprehensive Plan 5-209 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

5.6.3.4 FEIS Commenter 329: Susan Taylor-Alling

Response to Comment 1: Developer Interest in Land The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 2: Recreation Use of Property The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 3: Develop Wisely and Maintain LOS The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 4: Highway 9 Casino and Incompatibility The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 5: Need Adequate Development Regulations The comments are noted and forwarded to the appropriate decision makers. 5.6.3.5 FEIS Commenter 330: Dwight Hartman

Response to Comment 1: Southern UGA and Potential Exclusion The Recommended Plan identifies a UGA reduction along the South Snohomish UGA boundary identifying a Riverway Commercial Farmland Designation in place of an Urban Industrial/Airport classification. The Recommended Plan is addressed in FEIS Chapter 3. Please see Response to Comment 2, FEIS Letter 15 more information. 5.6.3.6 FEIS Commenter 331: Kathleen Wruck

Response to Comment 1: Support Alternative 1 The comments are noted and forwarded to the appropriate decision makers.

Response to Comment 2: Oppose NASCAR The comments are noted and forwarded to the appropriate decision makers.

Snohomish County Comprehensive Plan 5-210 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

Figure 5.4-1 Location of Commenters

Snohomish County Comprehensive Plan 5-211 December 13, 2005 10-Year Update FEIS Snohomish County Comments and Responses

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Snohomish County Comprehensive Plan 5-212 December 13, 2005 10-Year Update FEIS