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`t`F: ST:17F` pi <br />C Fb mss: r <br />?f• ? <br />n' <br />leas <br />STATE OF WASHINGTON <br />DEPARTMENT OF ECOLOGY <br />1250 W Alder St • Union Gap, WA 913903-0009 • (.509) 575-2490 <br />April 22, 2016 <br />Robert "Doc" Hansen <br />Kittitas County Community Development Services <br />411 N Ruby Street, Suite 2 <br />Ellensburg, WA 98926 <br />Re: P-07-31 <br />Dear Mr. Hansen: <br />Thank you for the opportunity to comment during the optional determination of nonsignificance <br />process for the Palomino Fields preliminary subdivision revision, proposed by Cle Elum Pines <br />East, LLC. We have reviewed the documents and have the following comments. <br />SHORELANDS/ENVIRONMENTAL ASSISTANCE <br />There is no description in the provided documents as to what work will be done in each planned <br />phase and how elements of the original MDNS with its requirements to comply with critical <br />areas protection will be carried forward into the development agreement phases. This <br />information should be made available for public review. No new construction should occur <br />without the environmental reports being completed and made available for review. <br />Locations of critical areas, including floodplain and floodway location, location of wetlands, and <br />depth to groundwater may have changed since original approval in 2008 due to up -gradient and <br />offsite activities. All these critical elements and any previously submitted reports should be <br />updated and made available for public review and comment as part of this action. <br />Both state and federal agencies require new or updated wetland reports for those reports that are <br />older than 5 years. If previously submitted information indicates that there were no wetlands on <br />site, then a new wetland delineation and rating report should be required. It. is highly likely that <br />with one stream on site and one just adjacent to the property, and up -gradient regional <br />application of irrigation waters that there would be areas that would meet wetland criteria. <br />Ecology considers housing densities of greater than one house per one acre to be "high density" <br />with respect to the size of buffer required to protect wetland resources. Ecology recommends <br />that required buffers be outside of private lot lines, and put into permanent "open space" <br />designation in a separate common area. <br />