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SE Bypass
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SE Bypass EIS Analysis
Adequacy Review

There is an ongoing discussion relating to the determination of "adequacy" of the FEIS.  The Mayor is taking the position that the Staff has that responsibility and it rests with the SEPA Official.  But the SEPA Official is the Planning Director and he has not been involved in the preparation or evaluation of the environmental documentation.  The Public Works Engineering Director has been the one preparing the documentation and presumably will be the one to evaluate its "adequacy."  Since the Issaquah Municipal Code requires that the Planning Director act as the SEPA Official in the absence of written authorization from the Mayor to the contrary, and no such authorization exists, this constitutes a direct violation of Issaquah Municipal Code.

From a pure contractual point of view I argue that the determination of "adequacy" is the responsibility of the City Council.  State Statute assigns contractual authority for the city to the City Council.  There is no disagreement that the City Council has the final responsibility for the "build/no-build" decision.  There is also no disagreement that the environmental documentation has been prepared under a contract with the consulting firm of Parsons Brinckerhoff, Quade and Douglas.  Therefore, the City Council is the appropriate body for assessing the "adequacy" of the various environmental documents for the purpose of supporting the "build/no-build" decision.

The reader should know that the Statement of Work (SOW) between the City of Issaquah and Parsons Brinckerhoff, Quade & Douglas has been changed eleven times so far.  As the contractual authority for the City, one would expect that the City Council would have approved the details of each change.  In fact, the City Council has only voted on five of the changes and often without any details of the change.  I argue that this is a clear violation of State Statute.

The Mayor is arguing that several of the environmental studies for the project were deferred until the permit phase of the project.  Change Order #10 is said to be the source of Council Authorization for such deferrals.  A review of Change Order #10 will show that it authorizes the update of several studies to include the impacts of the new South Alignment C configuration.  There is no discussion in the text relating to the deferral of any work previously authorized for the project.

There is also a second version of Change Order #10 that would require even less update of the environmental documentation.  I refer to this second version as Change Order #10v2.  The problem with this second version is that it is dated several days after the City Council voted to adopt the earlier version of Change Order #10.  That said, there is also no discussion in the text relating to the deferral of any work previously authorized for the project.  Thus I conclude that the City Council has every right to expect the FEIS to meet their needs for making the "build/no-build" decision – the FEIS should be "adequate" for their purposes.

When the City of Issaquah adopted its Land Use Code in April of 1996, the city imposed the State Environmental Policy Act (SEPA) provisions as the standard of determination for the significance of environmental impacts resulting from projects within its jurisdiction.  This provision includes use of the SEPA Checklist as a means of evaluating the significance of a project.  When the SE Bypass was initially scoped to determine the elements of the affected environment for analysis in December of 1996, the SEPA Checklist was not used – a direct violation of Issaquah Municipal Code.

The following tabulation uses the questions from the SEPA Checklist to achieve an objective evaluation of the Technical Reports which analyze the impacts to the various elements of the affected environment.  There are also a few questions which are not taken from the checklist, but still have relevance to the citizens of Issaquah.

The column headed by “Covered by SOW?” refers to the Statement of Work directing the efforts Parsons Brinckerhoff, Quade & Douglas – the consulting firm actually carrying out the environmental analysis of the SE Bypass Project.  The column headed “Answered?” is an evaluation of the applicable technical report content relating to the Checklist questions.  Finally, the column headed “Adequate?” is an attempt to grade the report content in terms of preparing the reader for the build/no-build question faced by each of our City Councilors.

Issaquah’s Municipal Code (Title 18.10) requires EIS’s to contain an Analysis of the Economy, the Social policy, and the Cost-Benefit of all projects in the City found to have significant potential impact to the environment.  The Economic and Social elements are addressed in the EIS documents for the SE Bypass.  The Cost-Benefit Analysis is not provided – another direct violation of Issaquah Municipal Code.

Air Quality

Hazardous Materials

1. The SOW does not contain a specific reference to SR-900 or the SR-900 Interchange.  It does require analysis of the Interchange operations and I-90 Operations as part of the requirements of Task 7.  Task 15 was added by Change Order #5 and specifically requires analysis of the SR-900 Interchange.  Since Change Order #5 was initiated in July, 1999, the results of the analysis should be part of the DEIS and the SDEIS.

2. Congestion on 2nd Ave is not addressed in the SOW until it was added as part of Change Order #8.  Change Order #8 involved tasking for the SDEIS.

3. Congestion in the Commercial Business District on Front St. N. is not referenced in the SOW.  There is reference to analyzing the LOS at the intersection of Front/Gilman and Front/Sunset.

4. The project is for a new road so the entire document is analyzing that impact.

5. The analysis of the project does not demonstrate sufficient benefit to offset the environmental damage that results.

6. The project does damage wetlands in the southend and has the potential to damage the Issaquah Creek, the North and South Tributary, and the East Fork of the Issaquah Creek.  This potential in not adequately discussed within the EIS.  (See the analysis of water quality and quantity impacts)

7. Though not specifically required by the SOW, the tabulations of traffic volumes shows that the project does result in induced traffic flows.  These results are not specifically highlighted for the reader.

1. The documentation relies on the Wellhead Protection Plan for much of the analysis yet it does not even include all the details as to the portion of aquifer recharge associated with the project area.  The north end of the project has a great potential of intercepting groundwater flows and altering their final destinations.  The surface water runoff could also be diverted from its current recharge destination.
   The Earth Technical Report contains boring records which report groundwater levels at several boring locations both in the north and south end of the project.  The report does not attempt to quantify the groundwater flows at or near the finished project roadway surface even though such encounters are clearly probable.

Wetlands

1. Both the Technical Report and Supplement Memorandum indicate degradation of wetlands, but the mitigation measures proposed are superficial at best.