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.