The monthly SR520 update meeting is tomorrow from 5:30-6:30pm at the Graham Visitors Center. Public citizens can learn about the upcoming construction activities on WABN and ask any questions regarding the project’s progress. LCC said this month's meeting is the usual update by the construction team.
Last month a formal presentation with the Montlake Phase team was given. A meeting summary from the presentation as well as answers from questions has been posted along with updated question and answer document and meeting materials.
The Laurelhurst Community Club (LCC) provided their meeting notes from last month's meeting as well which can be found here.
Some of the main concerns brought up at that meeting were:
Below is a letter LCC sent to the US Army Corps of Engineers requesting a public comment extension in response to WSDOT's wanting to amend its in-water permit for demolishing the Portage Bay Bridge section of the old SR520 bridge.
LCC told the Laurelhurst Blog that "there are some real concerns that their proposed changes will damage both Portage and Union Bay's ecosystems with pollutants."
October 21, 2016
To: Ms Rebecca McAndrew, US Army Corps of Engineers, Regulatory Branch
Re: Comments on Changes Washington State Department of Transportation, NWS-2008- 1246 Proposed permit modification, Portage and Union Bays portion of the SR520Replacement Bridge project.
The Laurelhurst Community Club offers these comments on the request for the permit change:
1. Lack of adequate notice-scope and time frame
The Laurelhurst Community Club (LCC) received no official notice about the request for a permit change from The Army Corps of Engineers to the Washington State Department of Transportation (WSDOT) regarding the demolition process of the existing SR520 Bridge as the project progresses into Portage and Union Bays. The shoreline of Union Bay is the southern border of the Laurelhurst residential neighborhood, and is used by citizens for access to recreational in-water activities. In addition, there are two state waterways on Union Bay, which have been improved, and maintained by neighbors with sweat equity and small local grants to provide public access, and protect the fragile wildlife habitat. Our community is very concerned about the lack of official notice, and transparency of both the process, and content of the requested change in permitting from WSDOT to the Army Corps of Engineers in the demolition and dredging in Union and nearby Portage Bays. Other affected parties should also have received official notification such as the Muckleshoot Tribe who have fishing rights in those waterways. The State and the City of Seattle environmental agencies who issue the shoreline work permits for the SR520 project have also not had adequate notice to comment. LCC requests that WSDOT and the Army Corps extend the comment period by 30 days, and re-issue the notification for the permit change to all parties listed in the EIS and SDEIS. This permit amendment is a significant change in the demolition process, and requires more research on the affects of such changes in accordance to NEPA and SEPA regulations.
2. Testing for bridge contaminates and ongoing monitoring requirements
Testing for the contents of the bridge materials should include all layers of painted surfaces , total range of metals in addition to TCLP , tributyl tin, other substances used in marine type paint such as anti-biofouling agents, PCB and dioxins be done prior to allowing a permit change. The FHWA Record of Decision (ROD) in 2011 did not contain substantial environmental analysis, nor render a related decision. The proposed process of dumping any materials from the existing SR520, and its bridge parts, into Portage and Union Bays was never vetted in the ROD under any scenario. Prior testing to determine what is embedded in the over 50 year old bridge has not been done. There is also no evaluation of the measurements of the amounts of dredging and filling and the lack of specific criteria or standards spelled out and plans for the process. The application for a permit change needs to be more specific, and NOT rely on self reporting. If not, the results are always a cheap option for the contractor, to the detriment of the fragile ecosystem in Union and Portage bays, and throughout Lake Washington. How can approval be granted for such a permit amendment without such testing data made public? It is important that both pre-testing and the later demolition monitoring be required by the Army Corps. Recent investigations by concerned citizens groups and the media have now documented how WSDOT currently refuses to conduct adequate testing and monitoring of the rubblization now occurring in demolition of the old bridge. There is photographic evidence that dust and slurry have been discharged into Lake Washington's waters and air, in violation of the Clean Water Act. The contractor, KGM and WSDOT continue to bounce the environmental responsibilities of the demolition process back and forth like a hot potato.. Neither will take responsibility, and claim that the process is safe by asserting that Best Management Practices are in place. In addition, the contractor found it cheaper, and easier to haul the rubblized debris up the lake in open barges to Kenmore's harbor, near a dense residential neighborhood, exposing their residents to pollutants in the air and waters from the pulverized bridge debris, and this location was also not included in the EIS. To date, WSDOT contractor has refused to provide a regular system for measuring turbidity and PH levels in its ongoing barging on Lake Washington. This has been left to the contractor for self reporting. The residents of the City of Kenmore have experienced detrimental turbidity along their shoreline, and the stirring up of embedded toxins in their harbor. Citizens see the rubblized dust fall into their shoreline, and into the air, and now are trying to pay out of their pockets for monitoring because this was not required in the WSDOT contract. This must be prevented in all future contracts to comply with NEPA/SEPA regulations and the Department of Ecology. Thus, LCC asks that the Army Corps require initial bridge content testing for contaminants as well as sediment quality testing in Portage and Union Bays, and later, turbidity and air monitoring throughout the demolition process.
Environmentally safer alternatives to dumping and dredging must also be identified, vetted and before allowing any permit change. With the current demolition process, WSDOT held back pertinent information from the public from January 2016 through September 2016 allowing significant waste to handled illegally. For the next phase of theSR520 project, the potential contractor, should provide alternative methods for removing and disposing of all of the existing bridge parts . An off-site, encapsulated facility, such as the one in Tacoma, could offer the real best practice for removing the old bridge. While it may cost a fraction more, getting it more safely out of Portage Bay should be explored and required it is offers protection for in-water users. LCC requests that the Army Corps require that WSDOT provide viable alternatives for the old bridge disposal that could prevent dumping anything toxic into Union or Portage Bays.
4. Ecosystem disturbances and habitat mitigation
Rare bird and protected wildlife reside in Union Bay and Portage Bays (see attached exhibit). Preserving their habitat in this ecosystem, and mitigating for the severe damages inflicted upon their survival, must be delineated, and required. The new bridge has already caused additional daytime shading, and produces glaring night spill onto Lake Washington, and generated excess noise and vibrations which adversely affecting the vitality of
fish, shore birds, and rare bird habitat. Building a park at the University of Washington and creating wetlands miles away at Magnuson Park, do not provide adequate local mitigation needed to correct the loss of existing wetlands that will be destroyed by the building of the Portage Bay section of the SR520 Replacement Bridge in these precious wetlands. In Portage and in Union bays, migrating salmon use the same pathways planned for the proposed dredging, and this will negatively impact their fish journey, and increase their vulnerability to predators. Any permit change should require more local habitat improvement through specific mitigation measures, and provide and maintain clean and safe public access to those recreational waters for humans. The Fishing Rights of the Muckleshoot Tribe must be included before any permit change is granted as this process will occur in their salmon runs.
5. Water Quality Mitigation
The remediation of Portage Bay and Union Bay and the restoration of its water quality is a priority in mitigation. For the 56 years that the old SR520 has been operational, pollutants have dropped into Portage and Union Bay from its storm water runoff . The concrete structure added into these waters when the original bridge was built, has also been a factor in the deterioration of water quality from shading and restriction of water movement. These conditions have contributed significantly to the invasion of milfoil, Brazilian Elodea noxious weeds and a thick cover of non-native water lilies. These plants are taking over the native ones, choking out native plants which promote the health of the fish and wildlife habitats. Salmon need a clear, weed -free and sunlight pathway to migrate through to Puget Sound. In order to reverse the deteriorating conditions, Laurelhurst neighbors, the University of Washington and the Department of Ecology have partnered to treat the invasive water species with good success for the past five years, with excellent, measured results. However, the process of building the West Approach Bridge North (WABN) in 2015 and 2016, has reversed that progress and barges and in-water machinery has re-introduced those weeds again this year into Union Bay. Negative impacts from building the new SR520 bridge, and its construction process should be mitigated in the affected bays.
In summary, the Laurelhurst Community Club asks that the Army Corps extend the comment period by 30 days for the request from WSDOT for a permit change. Further, we request that the Army Corps require WSDOT to notify all agencies and affected stakeholders in the EIS, require site-specific mitigation, require pre-testing of bridge parts and under lying sediment, require ongoing monitoring /testing, ask that WSDOT provide other viable alternatives to dredging and dropping debris into Portage and Union Bays, and contribute meaningfully in the wetland mitigation by the elimination of non-native in-water invasive plants. Thank you for the opportunity to comment, and we appreciate the involvement.
How to stay informed during WABN construction: