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�CENTURY <br />Xk <br />E N G t N E E R I N <br />• Wetland mitigation design drawings. <br />3.2. FLOOD MITIGATION <br />Issue: The preferred alternative identified by initial flood mitigation alternatives analysis requires <br />construction of drainage improvements outside of the direct study area and within the limits of the 100 - <br />year floodplain. This was determined to be unavoidable as all other on-site improvements that were <br />evaluated resulted in a worsening of downstream flooding. <br />Due to unexpected direct impacts outside the direct study area, additional cultural resources and wetland <br />delineation efforts will need to be expanded to encompass the limits of flood mitigation improvements. <br />Hydraulic modelling of the proposed flood mitigation indicates that the improvements will result in a <br />reduction in downstream flooding between Whiskey and Mercer Creeks by adding additional flood <br />storage infrastructure on the northwest side of the airfield. The added upstream storage and subsequent <br />downstream flooding reduction are likely to affect the current 100 -year flood limits of Whiskey and <br />Mercer Creeks. This revision in flood limits will require additional permitting and coordination with the <br />Federal Emergency Management Agency (FEMA), which was not originally anticipated in the project <br />scope. The County is also in the midst of revising the existing flood conditions shown in the current Flood <br />Insurance Rate Map (FIRM). The proposal of drainage improvements which will further revise the FIRM <br />will require close coordination between the project team and FEMA. A greater level of design will also be <br />required to accurately perforin the "No Net Loss" and mitigation analysis associated with the County's <br />Floodplain Development Permit application. <br />In addition to the anticipated direct floodplain impacts, the Draft Environmental Inventory Memo has <br />identified the potential for summer run steel head trout within the southwestern study area in Whiskey <br />Creek. The Century West project team is unable to make an effects determination without further <br />development of the flood mitigation and stormwater management design. It is likely that a Biological <br />Assessment (BA) will be required during the Individual Permit process to determine effects to <br />downstream federally -listed fish. Additional effort is required for items such as: <br />FEMA coordination and permitting; <br />Further flood mitigation design; <br />• Site assessment and wetland delineations within the limits of flood mitigation impacts; <br />■ Cultural resources assessment within flood mitigation impact zone; <br />• Effects to stream flow and downstream fish habitat related to proposed flood attenuation; <br />0 Further threatened and endangered species investigation and BA efforts as required. <br />Section 4 of this memo, Permit Submittal Requirements, provides a list of the application materials <br />required for the environmental permits, the level of engineering required for those materials and <br />whether the effort required is included in the current scope of services or will require additional effort. <br />The additional effort required to prepare and submit the environmental permits and to complete the <br />NEPA analysis is documented in Section 0 of this memo, The Washington Department of Ecology must <br />Bowers Field Airport Environmental Assessment Page 4 <br />Advanced Design Needs for NEPA Analysis November 27, 2019 <br />