2010/05/26 Council Agenda Packet

April 15, 2009 Page 3 In any event, the SEIS should contain a full analysis of the land use -related impacts that will be created by the mismatch of the small-scale industrial, commercial and residential uses that have been proposed in the middle of an industrial area of the City, as this is sure to pose unique challenges to neighboring industrial uses, as well as users within the Proposal site. Utility Capacity. StockPot uses a considerable amount of water in its industrial processes, and the Proposal will create additional demand on the City's water supply and sewer system. As noted in our MDNS Letter, the SEIS should evaluate these impacts and consider requiring the applicant to pay for any necessary capital improvements to the water supply or sewerage system. .See also WAC 197-11-444. Subsections (1)(c), (1)(c), and (2)(d) (impacts to water supplies, "public services and utilities," "energy and natural resources" to be considered). The SEIS should also include a full analysis of the Proposal's impacts on the availability and/or quality of the utilities provided to the properties surrounding the Proposal site. =See id, Loss of Industrial Lands. Consistency with Land Use Policies, The Proposal will lead to additional loss of industrial lands in the City. This proposed conversion of industrial lands ought to be thoroughly analyzed in the SEIS because the loss of industrial lands will affect the long-term prosperity of the County, the City, and its residents. The SEIS should fully analyze this issue because (I) the loss of industrial lands is among the most significant impacts of the Proposal, and (2) the proposed conversion of industrial lands is inconsistent with Everett City regulations and policies relating to industrial lands. See, e.g., EVERETT COMP. P1,AN, Policies 2.3.1 and 2.3.9. These issues ought to be analyzed, and mitigation measures for these impacts should be assessed in the SEIS. Alternatives Analysis. The SEPA rules provide that "[a]lternatives should be emphasized" in an EIS for a "nonproject action" such as the Proposal. See WAC 197-11-442(2); see also WAC 19711-704(2)(b). Because the scoping process guides the contents of the EIS, see, e.g., WAC 197-11-420(2), -500(4), now is the time to thoroughly analyze the alternatives offered to ensure that they properly address the impacts of the Proposal. Specifically, the SEIS should discuss the scope and character of the industrial areas that are to be `preserved' under alternatives I and 2. The description of the Proposal distributed during the April 7, 2009 SEIS scoping meeting describes only two alternatives in addition to the "no action" alternative. Alternative 1 proposes "27.2 gross acres of more intensive industrial development" in the Proposal area—which is over 140 acres. Alternative 2 is described as "[a]n alternative with more Industrial land preservation and with less mixed use," without any additional details on the extent of the industrial land to be preserved, or how the industrial uses on this land will be protected. In order to provide the City with the environmental information it needs to make a reasoned decision on the Proposal, (1) the SEIS should include specific details about these alternatives ----with respect to industrial lands preservation, as well as other issues, (2) mitigation measures should be detailed in each alternative, and (3) more than two alternatives should be analyzed.