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Friends of Edmonds Marsh, December 21, 2011.pdfDATE: December 21, 2011 TO: Rob Chave, Planning Manager, City of Edmonds Edmonds Planning Board, Phillip Lovell, Chair John Reed, Vice Chair JUL 10 2012 DEVELOPMETf SERVICE,,) col n- E: Kevin Clarke, Todd Cloutier, Bill Ellis, Kristiana Johnson, Valerie Stewart, Neil Tibbott FROM: Friends of Edmonds Marsh (FOEM) RE: Comments re. Harbor Square Redevelopment and Urban Mixed Use 3 Designation CC: Bob McChesney, Port of Edmonds Friends of Edmonds Marsh (FOEM) is an organization of citizens of Edmonds that have gathered together to promote the long-term health and ecological function of Edmonds Marsh. Our mission statement is attached. FOEM has reviewed the conceptual redevelopment master plan at Harbor Square Business Park (HS) as proposed by the Port of Edmonds. FOEM believes that HS redevelopment offers the opportunity to correct conditions resulting from past development in the Edmonds Bowl that have degraded the ecological functions of the marsh. FOEM supports the "Urban Mixed Use 3" (UMU 3) land use category for HS under the City of Edmond's revised Shoreline Master Program with the expectation that the Port's redevelopment will proceed with the provisions outlined below. We believe that incorporation of specific environmental design elements into the HS redevelopment can benefit the marsh; these design elements are expected to include enhanced buffers within setback areas, increased open space, and perhaps most importantly from the perspective of marsh health, improved stormwater management. Our mutual goals with the Port include day lighting the Willow Creek connection to Puget Sound which is expected to improve natural habitat functions, restore intertidal salt marsh characteristics, and maximize ecological functions and values with the marsh. FOEM believes redevelopment at Harbor Square can be a net benefit to the Edmonds Marsh, if redevelopment incorporates specific elements that we describe below. Background and Existing Conditions 1. The Edmonds Marsh is currently connected to Puget Sound through a tide gate that is placed in operation by the City each fall to limit water elevations within the marsh. This tide gate, the approximately 1,300 -foot culvert through which the marsh drains, and the BNSF RR tracks, severely limit the ecological functions of the marsh. For example, winter operation of the tide gate essentially prevents saltwater from entering the marsh, altering the salinity regime and significantly affecting plants, birds, and invertebrate life in the marsh. 2. A high proportion of the surface area within HS is currently impervious and existing parking, trail, and tennis court setbacks from the ordinary high water (OHW) line are minimal. 3. HS is situated immediately adjacent to the Edmonds Marsh. However, existing buffers along the Harbor Square shoreline with the Edmonds Marsh are narrow and include substantial quantities of non-native invasive species; they therefore provide only low levels of ecological function. 4. Existing stormwater management systems and infrastructure at HS discharge directly into the Marsh without significant treatment. 5. Buffer enhancement or expansion of buffers behind (landward of) the levee) would improve riparian habitat functions for passerine birds and small mammals and would improve aesthetic values and the overall ecosystem integrity; however, buffer expansion behind the levee would not materially improve estuarine marsh functions per se. 6. The proposed land uses that would be allowable behind the levee under UMU 3 (commercial, residential; parking) would not inherently differ from those uses allowed under UMU 2 (commercial; parking) in their potential to affect habitat or species important in the marsh ecosystem. However, a small incremental benefit might be derived from having less automobile traffic associated with residential use compared with the other potential uses. 7. Building heights in excess of currently allowed limits would not adversely impact marsh function' given the buffer provisions specified below. 8. Redevelopment behind the levee that results in improved stormwater treatment will improve water quality and ecological functions in the marsh. Harbor Square Redevelopment Under UMU 3 In this section, we outline our expectations for HS development: we assume that in redeveloping HS under the proposed UMU 3, the Port will do the following: 1. Preserve existing buffers. 2. Enhance existing buffers by removing invasive species and replanting with appropriate native species; FOEM will commit to work with the Port to coordinate use of volunteer work parties to assist in long-term maintenance of the enhanced buffers. 3. Where compatible with redevelopment, expand existing buffers to enhance habitat for small mammals and migratory birds and to increase the capacity of buffers to filter stormwater. 4. Design the redevelopment to increase shoreline setbacks where possible, to allow for expanded buffers 5. Utilize setback areas between the OHW line and buildings or parking for buffers that support wildlife habitat and promote infiltration of stormwater; these areas should be planted with native plantings. A pervious pedestrian walkway and marsh viewing areas to enhance passive public enjoyment of the marsh are desirable and could be located in the buffer. Lawn and other open areas should be located elsewhere in the site. 6. Capture and treat all stormwater on-site using low impact development (LID) techniques compatible with the latest Ecology Stormwater Manual and municipal stormwater NPDES provisions. 7. Support efforts to daylight Willow Creek through the newly constructed BNSF railroad bridge. 8. It is assumed that there would be no industrial discharges or release of potential contaminants from any use. Benefits of Harbor Square Redevelopment for the Edmonds Marsh In this section, we describe the benefits we anticipate to result from realization of the expectations listed in the previous section. 1. With redevelopment, the limited existing vegetated buffer area between the marsh (OHW) and existing upland modifications (paving, impervious surfaces) would be maintained and enhanced in the following ways: a. By removing non-native invasive vegetation and plantings of native species. b. By reducing the total area of impervious surfaces within the shoreline area. 2. Designated setbacks under UMU 3 would be enhanced contiguous with existing buffers or landscaped in native plants, but may include pervious public access trails and educational signs. 3. We believe and expect that the Port will continue to work actively with community groups including FOEM to enhance the character of the vegetation in buffer areas; FOEM will remain fully supportive of these efforts and plans for future marsh restoration; e.g., by controlling invasive species and planting/encouraging native species in the buffer. Thus, we believe that HS redevelopment would bring a net improvement in marsh buffer function, thereby enhancing marsh water quality and ecological functions. 4. Redevelopment would not affect existing drainage patterns from the levee crest into the marsh except where buffers are enhanced; buffer enhancement on either side of the levee crest would improve water quality entering the marsh. 5. We expect that redevelopment behind (landward of) the levee would not result in increased impervious area; allowance for taller buildings would allow increased open space and reduced impervious area. Resulting additional green space would aesthetically complement the marsh, reduce untreated stormwater by increasing infiltration, and may allow incorporation of other sustainable design features. 6. Redevelopment at HS will modernize on-site stormwater control and increase pretreatment capabilities to enhance future water quality and improve ecological functions in the marsh. 7. The quality of stormwater released from HS is important to the marsh and is critical to this FOEM endorsement: we expect the Port's HS redevelopment will improve water quality through the inclusion of several LID features such as rain gardens, detention vaults, and oil/water separators. We assume that all stormwater would be managed in accordance with the latest Ecology Stormwater Manual and NPDES requirements. We assume that no copper will be used on large surfaces exposed to weathering. 8. It can be assumed that residences with views into the marsh would provide watchful eyes and concerned stewards of the marsh that would reduce the potential for intentional vandalism, or ignorant acts that could degrade the marsh amenities or ecology (loose dogs, for example). Summary Based on the points above, FOEM believes that assigning a shoreline classification of UMU 3 to the newly designated Edmonds Marsh shoreline, and subsequent redevelopment of HS would have a number of significant and positive outcomes for the marsh: 1. Improved management of stormwater and improved quality of water entering the marsh. 2. improved buffers and buffer function. 3. Increased Port and resident stewardship of the marsh. 4. Port's support for daylighting the marsh to Puget Sound. We therefore encourage the City to adopt this new shoreline designation for the Harbor Square shoreline of the Edmonds Marsh. Attachments: FOEM mission statement Mission Statement: To expand and restore functional estuarine habitat within Edmonds Marsh and protect the remaining wildlife habitat by engaging the community to preserve, steward and enjoy our most natural asset. Vision: A healthy, functioning pocket estuary freely connected to Puget Sound that provides habitat for a diversity of native plants, fish and wildlife and is maintained as a recreational asset for the Edmonds community. Rational: * The current Edmonds Marsh is a remnant of a barrier estuary, a uniquely rich Puget Sound habitat that is an ecological and economic asset to our City. * Less than 20% of historical tidal wetlands in Puget Sound remain intact, Nearly 100% of barrier estuaries, like Edmonds Marsh, have been completely lost in central Puget Sound. * Since the founding of Edmonds, the Marsh has lost over 50% of it's original size, the majority of which was salt marsh habitat * Reestablishment of proper hydrology in the marsh system would add elasticity to handle flushing from storm events, improve storm water management, and help adapt to sea -level rise. * Preserving and enhancing current native plant, fish and wildlife resources provided by mudflat and remnant salt marsh habitat maintains local biodiversity, * Edmonds Marsh represents a unique opportunity for the community to help envision and create a healthy wildlife and recreation area that attracts visitors to our City Goals: * Inform the community of the existence and importance of Edmonds Marsh * Become an advocate in the effort to daylight Willow Creek * Identify and engage primary stakeholders * Scope, fund and contract a marsh enhancement/daylighting feasibility study that builds upon existing studies T 4 ga Contact- Susie Schaefer - susic.schaefer@comcast.net