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Evergreen Hills Development Concerns
Evergreenhills.com / West Hill LLC
NE corner of 14th Ave. NW & Kaiser Road NW
Revised subdivision of 150 units on 50 acres
* April 2006 - under construction
* October 2005 *
Work on this development is underway.
* January 20, 2004 *
Excerpted from the Cooper Point Assn. President’s letter to the City:
Grass Lake and Green Cove Creek have been acknowledged by the
City as requiring protection. One hundred and fifty new homes – with their
streets, driveways and lawns – will create a significant pollutant load into
these water bodies.
The Cooper Point Association has a number of very significant
concerns about the Mitigated Determination of Nonsignificance (MDNS) for the
Evergreen Hills.com proposed residential subdivision. The quality and the
quantity of stormwater runoff from the development, as well as the
destination of this runoff, are primary issues.
The downstream drainage systems of this development drain
into Grass Lake and Green Cove Creek. The entire SEPA analysis of this
issue, as contained in this MDNS, consists of one sentence which refers to
“such off-site improvements as necessary” to conform with applicable City
and County drainage manuals.
This is an entirely inadequate analysis of the
probable environmental impacts of pollutants that will run off of nearly 30
acres of impervious surfaces into a sensitive nearby freshwater lake and
salmon-bearing creek.
While this development may be vested for an earlier
series of City development ordinances, this vesting does not allow the City
to ignore its obligations under SEPA to consider and address the water
quality impacts of this development under state and federal water quality
standards. These state water quality standards (which are found at WAC
173-201A) clearly apply to Grass Lake and Green Cove Creek, and this
development’s drainage will empty entirely into these waterbodies.
One final water quality issue has also been side-stepped by
this MDNS. The current City sewer system in the vicinity of Grass Lake
overflows from time to time into the wildlife refuge, even under the current
series of hookups. This issue, which is well-documented by the City public
works department, will likely worsen with the additional sewage hookups of
this development. The SEPA analysis of this development should discuss and
address this issue in a manner adequate to answer the questions of concerned
nearby residents.
This MDNS is also inadequate in its analysis of the off-site
water quantity impacts of this development. This area does not percolate
well, and is prone to the lateral movement of shallow subsurface water on
top of the hardpan. It appears from the drawings and surveys accompanying
this proposal that the engineered stormwater detention ponds will be very
deep. The retention and discharge of this water is likely to worsen the
occasional flooding that already occurs on Kaiser Road during heavy rain
events. In addition, there are known instances of crawlspaces and possibly
drainfields within a short lateral distance of the development experiencing
seasonal flooding currently. These may experience increased seasonal
flooding if this development’s drainage system is not designed properly. The
MDNS is entirely silent on the issue of seasonal flooding of nearby roads
and property.
Some additional SEPA analysis of the various traffic
congestion impacts is also warranted.
The Cooper Point Association does not oppose
appropriate development of this site. The property is within City limits,
zoned for residential uses, and is contained with the Urban Growth Boundary
established under the Growth Management Act. These factors combine to
indicate that this property is appropriate to develop.
This development will remove dozens of acres of forest and
vegetation and replace them with roads, roofs, driveways and lawns. The
drainage from such a large, dense development will be difficult to engineer
and treat. It must not degrade the water quality of Grass Lake or Green Cove
Creek. A single sentence analysis of these impacts and their mitigation is
entirely inadequate, and does not square with the requirements of the State
Environmental Policy Act.
Eric D. Johnson
President, Cooper Point Association
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