DRAFT ENVIRONMENTAL ASSESSMENT 1000 RD REALIGNMENT Cover picture: View from east bank of the Chehalis River, looking northwest, showing post-flood Chehalis River and damaged 1000 Road up the eastern bank. TOWN OF PE ELL FEMA-1734-DR-WA SEPTEMBER 2008 FEMA Logo CONTENTS Introduction Purpose of and Need for Action Project Alternatives Alternative 1: No Action Alternative 2: Convert Emergency Road to Permanent Road Alternative 3: Repair Original Road Affected Environment and Environmental Consequences Cumulative Impacts Public Involvement References Appendices Appendix A: Figures Appendix B: Chinook and Coho Salmon Spawning Areas Appendix C: Consultation with State Historic Preservation Officer Introduction In early December 2007, a fierce storm of wind and rain resulted in extensive flooding in Lewis County and other counties in western Washington. During the storm event, floodwaters of the Chehalis River eroded and washed away the slope supporting the 1000 Road, causing failure of a 500-feet-long by 20-feet-wide section (project location). This road provided access to the Town of Pe Ell’s water supply intake from Lester Creek, which is across the Chehalis River by bridge and south-southwest of the project location. It also provided the route by which the water supply lines reached the Town’s water treatment and distribution system. The bridge was also destroyed by the flood. The Town of Pe Ell has applied through the Washington State Emergency Management Division (EMD) to the Federal Emergency Management Agency (FEMA) for funding to make permanent a temporary realignment for the damaged portion of 1000 Road, which is located about 30 to 40 feet above and east of the river. Figure 1 shows the west bank of the Chehalis River, across from the project site. (Figures are located in Appendix A.) FEMA has already provided funding to construct the temporary realignment, a 725-foot- long emergency road upslope of the slide-damaged 1000 Road. A permanent road in this alignment will be necessary to provide for the operation and maintenance of the Lester Creek intake and water lines and replacement bridge construction. The bridge’s replacement will be funded by sources other than FEMA and therefore is not part of the grant application. The project area is located within an easement on Weyerhaeuser Company property. The Town of Pe Ell uses the easement to access and maintain its water supply source and conveyance. The project coordinates are Latitude 46.5464°, Longitude -123.30024°. The project is located in the NE ¼ of the SE ¼ of Section 4, Township 12 N, Range 5 West. Figure 2 shows the project vicinity and location. This draft Environmental Assessment (EA) has been developed to assist FEMA in meeting its environmental review responsibilities under the National Environmental Policy Act (NEPA) of 1969, the Council on Environmental Quality’s implementing regulations (40 CFR Parts 1500 through 1508), and FEMA’s implementing regulations (44 CFR Part 10). FEMA is also using the draft EA to document compliance with other applicable federal laws and executive orders, including the Clean Air Act, Clean Water Act, the Endangered Species Act, the Magnuson-Stevens Fishery Conservation and Management Act, the National Historic Preservation Act, Executive Order (EO) 11988 (Floodplains), EO 11990 (Wetlands), and EO 12898 (Environmental Justice). FEMA will use the findings in this draft EA and resulting public comments to determine whether to prepare an Environmental Impact Statement (EIS). If the action is determined not to significantly affect the quality of the human environment, then FEMA will make a Finding of No Significant Impact (FONSI), rather than prepare an EIS. This document discusses the purpose of and need for the proposed action, the project alternatives, the affected environment and potential impacts to that environment from the project alternatives, cumulative effects, public involvement, and resources consulted. Purpose of and Need for Action Under the Stafford Act, FEMA’s Public Assistance program provides financial assistance to local, state, and tribal governments to restore critical infrastructure damaged in the wake of a Presidentially declared disaster. The Town of Pe Ell needs to ensure the health and safety of its residents by providing key services. A functional, safe, reliable, and cost-effective water supply system is a critical element of this mission. Lester Creek is the Town’s primary water source. During low- flow periods, the Town uses the Chehalis River as a source, but its use is limited. During the high flows of the rainy season, the Chehalis River is turbid (cloudy due to sediment) and difficult to treat to drinking water standards. The silt and debris in the river during the winter can also create challenges to system operation and maintenance and stress the capabilities of the drinking water treatment system. The storm caused damage to existing facilities at both the Lester Creek and Chehalis River water facility locations. From mid-December 2007 to mid-March 2008, the Town had to pump its drinking water from a seasonal, spring-fed creek. The primary water supply system, which serves over 1,000 residents, includes the water intake and reservoir system on Lester Creek, over 10,000 linear feet of 8-inch water line, a pump station, a treatment facility, and a distribution system. All parts of this system must be accessible around-the-clock so it can be operated and maintained on a continuing basis. The 1000 Road furnishes a vital link in providing access to the water source and delivery components of the Town’s water system. The failure of this access road and water line integral to that section of roadway has compromised the Town’s ability to deliver a potable water supply to its citizens. Project Alternatives NEPA requires the evaluation of reasonable project alternatives as part of the environmental review process. This draft EA evaluates three alternatives. Alternative 1 is the no-action alternative, which serves as a baseline by which the other alternatives can be compared. Alternative 2 is the proposed action: to convert the emergency access to a permanent access road for the water supply system. Alternative 3 is to repair the damage to the original road to provide permanent access, and to abandon the temporary emergency access road. See Figure 3 for a site schematic. Alternative 1: No Action Under this alternative, the Town of Pe Ell would use the temporary emergency road to access the raw water transmission line for needed replacement and repairs. Later the road would be used as access for bridge construction and for operation and maintenance of the upper reaches of Pe Ell’s water supply system (reservoir and water line to and across the Tin Bridge). The Town would not make the emergency road permanent, nor repair the existing, originally failed road. Due to the lack of full-depth roadbed design, the temporary road would eventually deteriorate to the point at which it could not be used to access the Lester Creek reservoir supply system, and eventually the water line would not be functional. The Town of Pe Ell would then have to use the Chehalis River as its water supply year round, which would be problematic during the rainy season, as described in the Purpose and Need section above. The abandonment of the temporary road would result in less human intrusion in the area and therefore would likely be beneficial for vegetation and wildlife species. Alternative 2: Convert Emergency Road to Permanent Road (Proposed Action) Alternative 2, the preferred alternative, involves a full-depth design and construction and surfacing of the emergency roadbed, upslope of the damaged portion of the original 1000 Road. The temporary route departs from the original route of the existing alignment a short distance northwest of the junction of 1000 and 1010 Roads and rejoins it just north of the road spur to the bridge. This temporary emergency road is approximately 90 to 190 feet northeast (laterally) of the original road and approximately 70 to 75 feet upslope from the river (at 480 feet elevation), on a natural bench. Construction of the permanent road would require the placement and compaction of materials above the temporary, emergency road base. The material would consist of over 1,400 cubic yards (about 2,100 tons) of 24-inch-thick crushed surfacing base course material. Overlying this base would be 8 inches of crushed rock top course (400 cubic yards, or 515 tons). The temporary road already includes an 18-inch-wide French drain in its design for subsurface seepage. This design would not be altered with the permanent road. Construction of a permanent road in this location is substantially more cost effective than implementation of Alternative 3. Alternative 3: Repair Original Road This alternative would involve repairing the damage that occurred to 1000 Road as a result of the December 2007 storm. This 500-feet-long by 20-feet-wide stretch of repaired road would then provide access to the water intake at Lester Creek, and to the transmission line that conveys the water to the pump station at 6000 Road. The site is bounded by a steep upward slope to the east and a steep downward slope to the west, which leads to the east bank of the Chehalis River. Under this alternative, the upslope temporary road would be abandoned and restored to its original condition. The newly laid pipe under the temporary road would also be abandoned, and a new section of pipe laid under the repaired road. The work would consist of removal of an estimated 15 feet (11,000 cubic yards) of unsuitable earthen fill down to structurally stable soil and installation of downslope support (a mechanically stabilized earthen [MSE] slope). A geotextile material would be placed underneath a road base, which would be constructed of 15 feet of compacted earthen fill, 2 feet of crushed stone base course, 18 inches of crushed stone top course, and a chip and seal surface pavement (asphalt). The base, or toe, of this slope would need to be constructed below the ordinary high water mark of the Chehalis River. Excavation of such a large slide mass could compromise the stability of the upslope area, according to a geotechnical report prepared for the Town. The cost of repairing the major slope failure is considerably higher than the cost of making the emergency road permanent. Affected Environment and Environmental Consequences This section of the draft EA briefly describes the environment within and surrounding the project area, and compares alternatives based on their projected impacts to environmental resources or parameters. The project site is located about 2 miles south of the Town of Pe Ell, on a relatively steep, forested upland on the east bank of the Chehalis River, near its headwaters. At this location the Chehalis River has cut a deep channel into basalt rock. Within the Chehalis River basin at this location are several tributary creeks, including Lester Creek, which is dammed to form the reservoir that serves as the raw water intake source for the Town’s water supply. The 1000 Road has historically been used by Weyerhaeuser as access to its timber production properties, besides serving as the access road to the Town of Pe Ell’s water source. (Due to the condition of its roads beyond the project site and nearby bridge, Weyerhaeuser is no longer harvesting timber in the area.) The 1000 Road is located about 30 to 40 feet above the river. The road is outside the 100-year floodplain in Zone C, an area of minimal flooding, per Flood Insurance Rate Map 5301020405B for Lewis County (12/15/81). The County is outside the Washington State coastal zone. There are no terrestrial or aquatic wildlife species listed as threatened or endangered under the Endangered Species Act within at least 2 miles of the project site. Chinook and coho salmon spawn in the Chehalis River (see Appendix B). The essential fish habitat (EFH) of these species is protected under the Magnuson-Stevens Fishery and Conservation Management Act (Magnuson-Stevens Act). There are no known historic or archaeological sites or districts in or within ½ mile of the general project area (3.67 acres). FEMA archaeologist Chuck Diters visited the project area on May 13, 2008, and noted no evidence of any occupation of the area. The steep slopes in this area suggest a relatively low likelihood of the existence of any undiscovered archaeological resources in the immediate vicinity. Table 1 shows the intensities of environmental effects for Alternatives 1, 2, and 3, which are categorized as follows: o None: There would be no effect on environmental resources. o Negligible: The effects of the alternative on environmental resources would either be undetectable or if detected, would have effects that would be slight and local. Impacts would be well below regulatory standards, if applicable. o Minor: The effects of the alternative on environmental resources would be measurable, although the changes would be small and localized. Impacts would be well within regulatory standards, if applicable. Mitigation measures would reduce potential environmental effects. o Moderate: The alternative would have both localized and regional scale impacts. Mitigation measures would be necessary and the measures would reduce potential adverse effects. o Major: The alternative would have substantial consequences on a local and regional level. Impacts would exceed regulatory standards. Mitigation measures to offset adverse impacts would reduce potential adverse effects, but long-term changes to the resource would be expected. Table 1. Environmental Impact Intensity of Alternatives Air quality (Clean Air Act) Alternatives 1 and 2: None/Negligible Alternative 3: Minor Water quality (Clean Water Act) Alternatives 1 and 2: None/Negligible Alternative 3: Moderate Environmental justice (EO 12898) Alternatives 1, 2,and 3: None/Negligible Floodplains (EO 11988) Alternatives 1, 2, and 3: None/Negligible Wetlands (EO 11990) Alternatives 1, 2, and 3: None/Negligible Threatened & Endangered species (End. Sp. Act) Alternatives 1, 2, and 3: None/Negligible Essential fish habitat (Magnuson-Stevens Act) Alternatives 1 and 2: None/Negligible Alternative 3: Moderate Cultural resources (National Historic Preservation Act) Alternatives 1, 2, and 3: None/Negligible The following paragraphs discuss the projected environmental effects of the alternatives on salmon habitat, water quality, and cultural (archaeological and historic) resources. Chinook and Coho Salmon Habitat The Chehalis River in the vicinity of the project area provides spawning habitat for Chinook and coho salmon (see Appendix B). Alternatives 1 and 2 would not adversely affect EFH due to the distance of the work from the Chehalis River. The road is on a bench between approximately 90 feet to 190 feet laterally and 50 to 75 feet above the Chehalis River. Alternative 3 might adversely affect the EFH of Chinook and coho salmon, since the toe of the slope repair would be below the ordinary high water mark. Therefore FEMA would be required to consult with the National Marine Fisheries Service (NMFS). The agency consultation process is described in the Magnuson-Stevens Act’s implementing regulations (50 CFR Part 900). FEMA would initiate the consultation process by providing a written assessment of project effects. Depending on the results of the analysis and consultation, the effects to EFH could range from minor to moderate in intensity. The result of the consultation might be implementation of conservation measures to minimize impacts to EFH. Water Quality Alternatives 1 and 2 would have negligible effects on the water quality in the Chehalis River. Stormwater from the temporary road, which is topped with several feet of quarry spalls, would percolate through the unpaved surface rather than run from the surface as sheet flow. Stormwater from the permanent road, which is a base course and top course of crushed surfacing above the quarry spalls, would do the same. The distance from the road to the Chehalis River would also minimize the likelihood of stormwater reaching the river. The French drain from the 1000 Road-1010 Road junction area and constructed under the roadway would convey any seepage from that area onto a riprap pad in the upslope ditch of the original road alignment. This ditch, which was not damaged in the December 2007 slide, flows along the road to the north and away from the project area. Alternative 3 would likely have minor to moderate short-term effects on Chehalis River water quality and minor long-term effects. Before conducting the repair work, the Town of Pe Ell would be required to obtain a Clean Water Act Section 404 permit from the US Army Corps of Engineers because work below the ordinary high water mark of the Chehalis River would result in the discharge of fill to the river. The Corps administers and enforces the Section 404 permit program, whose implementing regulations are at 33 CFR Part 323. Once the Corps received the request for a Section 404 permit, it would likely issue a general, nationwide permit (NWP) to conduct the work. The Town of Pe Ell would be required to comply with the conditions of this permit, which would include, for example, implementation of erosion controls to minimize the project’s effects on the Chehalis River’s water quality. Another regulatory program would be triggered by the project’s effects on water quality. Numeric water quality standards (in this case, turbidity) could be exceeded in the mixing zone during construction. Washington Department of Ecology’s (Ecology’s) water quality regulations at WAC 173-201A-410 allow for the possibility of approving short- term modification of water quality standards “when necessary to accommodate essential activities, respond to emergencies, or to otherwise protect the public interest, even though such activities may result in a temporary reduction of water quality conditions. “ Such short-term modifications must be authorized in writing by Ecology. Cultural Resources FEMA has reviewed the alternatives as required under Section 106 of the National Historic Preservation Act (NHPA), and pursuant to the provisions of a Programmatic Agreement between the State Historic Preservation Officer (SHPO) and FEMA, dated October 14, 2004, and amended April 9, 2007. Alternatives 1 and 2. FEMA determined that there would be No Historic Properties Affected by the action, and the State Historic Preservation Officer (SHPO) concurred (see Appendix C). FEMA contacted the Chehalis Confederated Tribes and the Cowlitz Indian Tribe to solicit their comments. Alternative 3. Alternative 3 is covered by the Programmatic Agreement, which exempts from further SHPO review certain routine activities with little potential to adversely affect historic properties. This action (road repair) is one such activity. It falls into Programmatic Allowance categories I-A, III-A, and III-B of the Programmatic Agreement. Allowance I-1 involves ground disturbing activities related to the repair or replacement of slope stabilization systems. Allowance III-A refers to the repair of roads to pre-disaster geometric design standards. Allowance III-B refers to repairs of road composition with in-kind surface materials to maintain pre-disaster size, traffic capacity, and load class, including compacting of road bed soil. For either alternative, inadvertent discovery of historically or archaeological significant materials or sites (or evidence thereof) would be handled in the same way. In this event, the project would have to be halted and all reasonable measures taken to avoid or minimize harm to the property until FEMA, in consultation with the SHPO and other appropriate parties, determines appropriate measures have been taken to ensure that the project is in compliance with NHPA. Cumulative Effects As defined by NEPA, cumulative impacts are those effects on the environment that result from the incremental effect of the action, when added to past, present, and reasonably foreseeable future actions, regardless of what agency or person undertakes such actions. Cumulative effects can result from individually minor, but collectively significant, actions taking place over a period of time. To assess cumulative impacts of this project, the entire water supply system repair and replacement is considered as a whole. The permanent construction of the temporary road, coupled with vehicular access to the Tin Bridge, may increase vehicle traffic along the permanent road. Due to its poor condition, the pre-storm Tin Bridge was a pedestrian-only bridge for public access (the Town could drive over the bridge in lighter vehicles to conduct water system maintenance). The bridge would be vehicle passable at normal loads once its replacement is constructed. The historic Tin Bridge was one of the only covered bridges in Washington State. Non-FEMA funds are being provided to restore the Tin Bridge, and this restoration could bring renewed interest and visitation to the bridge site. The Chehalis River in the Tin Bridge vicinity is known as a popular swimming area, so increased access could result in more human intrusion along the Chehalis River shoreline. The cumulative impacts of these increases in human use are not expected to have significant environmental effects. Public Involvement The Town of Pe Ell has provided opportunities for the involvement of its citizens and water customers in the decision-making process through town council meetings, which are open to the public. The status, progress, and condition of the water supply system have been made a matter of public record. There will be a 30-day public comment period during which the public, including interested stakeholders, is encouraged to comment. A public notice will be placed in the The Daily Chronicle announcing the availability of the document. A copy of the draft EA will be available at the Pe Ell City Hall, located at 111 South Main Street, Pe Ell, Washington 98572 [phone (360) 291-3543]. The draft EA can also be viewed and downloaded from FEMA’s website at http://www.fema.gov/plan/ehp/envdocuments/index.shtm. Comments may be sent to Mark Eberlein, FEMA Region X’s Regional Environmental Officer, as provided below. Mail: Mark Eberlein FEMA Region X 130 228th Street SW Bothell, Washington 98021 Fax: (425) 487-4622 Email: mark.eberlein@dhs.gov When the 30-day comment period ends, FEMA will review these comments and revise the draft EA as appropriate, then publish a final EA. The Final EA will then be moved to the archives page at: http://www.fema.gov/plan/ehp/envdocuments/archives_index.shtm. References This draft EA is based in part on a site visit of May 13, 2008. FEMA has consulted with the State Historic Preservation Officer regarding the scope of this project. FEMA has also discussed the project scope with representatives of the US Fish and Wildlife Service and National Marine Fisheries Service in regard to potential effects on federally threatened or endangered species or critical habitat, and potential effects to essential fish habitat. Other information sources include the Town of Pe Ell and a news release from the Washington State Department of Health dated March 21, 2008. See www.doh.wa.gov/Publicat/2008_news/08-036.htm http://www.lewiscountybuzz.com/showthread.php?p=43378 http://74.125.95.104/search?q=cache:roR4_2XiZcYJ:whatsinthatkoolaid.blogspot.com/2 007/12/it-exists-car-that-runs-on- greenhouse.html+tin+bridge+pe+ell&hl=en&ct=clnk&cd=8&gl=us Appendix A: Figures Figure 1: West bank of the Chehalis River across from the project site Figure 2: Site vicinity map, a USGS topographic map with an arrow indicating project location Figure 3: New 1000 Road alignment in relation to original road alignment and Chehalis River Appendix B: Chinook and Coho Salmon Spawning Areas in the Chehalis River (Washington Department of Fish and Wildlife’s Salmonscape Database: http://wdfw.wa.gov/mapping/salmonscape/) Fall Chinook: Map denoting that Chehalis River in site vicinity is fall chinook salmon spawning habitat Coho: Map denoting that Chehalis River in site vicinity is coho salmon spawning habitat Appendix C: Consultation with the State Historic Preservation Officer Letter dated 15 May 2008 from FEMA to SHPO: Allyson Brooks, Ph.D. State Historic Preservation Officer Department of Archaeology and Historic Preservation PO Box 48343 Olympia, WA 98504-8343 Re: Section 106 consultation, FEMA-1734-DR-WA PW 912 v 2 Undertaking: Logging Road 1000 repairs (road realignment) Applicant: Town of Pe Ell Determination: No historic properties affected Dear Dr. Brooks: Pursuant to Section 800.4(b) of 36 CFR Part 800 the U.S. Department of Homeland Security’s Federal Emergency Management Agency (FEMA) has taken steps necessary to identify historic properties or other cultural resources within the area of potential affect (APE) for the above referenced project. The purposes of this letter are to: identify the Town of Pe Ell’s road realignment proposal (the undertaking); transmit location and plan sketches; and request your concurrence with FEMA’s Area of Potential Affect (APE) and affects determinations. The Town of Pe Ell has applied through the Washington State Emergency Management Division (WA EMD) to FEMA for funding assistance to repair a portion of the damaged Logging Road 1000, located along the South Fork of the Chehalis River. This road is a Weyerhaeuser Corporation road, which the Town uses to provide access to its water lines, including a crossing of the South Fork (at the site of the now-destroyed Tin Bridge). Additional damage beyond the location of Tin Bridge has rendered the road unusable, and Weyerhaeuser is abandoning it. Repairing the road at its present location is apparently feasible from an engineering standpoint, but relocating approximately 725 linear feet of the roadway, as shown on Map 1, is a lower cost alternative. In addition to being cost-effective, the reroute will reduce the potential of damage from future flooding incidents. Both the old and new alignments are located on Town rights-of-way over Weyerhaeuser Corporation lands. FEMA has determined that the Area of Potential Effect (APE) is a corridor including both road alignments, about 800 x 200 feet in extent, or about 3.67 acres. The surface of the abandoned portion of the road, included within this APE, will provide ample space for staging of equipment and material.. A review of existing data showed no known historic or archaeological sites or districts in or near (within ½ mile) the APE, with the exception of the former Tin Bridge. FEMA Archaeologist Charles Diters visited the project area on 13 May 2008 and walked the flagged route of the proposed realignment. This route departs from the existing alignment a short distance northwest of the intersection of Logging Road 1000 and Logging Road 1010, and climbs onto a relatively steep side slope after crossing Road 1010 and through a small drainage area; it returns to the original alignment at about the location of the access road to the destroyed Tin Bridge. Much of the road will require both cutting and filling. The general appearance of the APE is shown in Photos 1 and 2. Ground visibility along the route was limited, except in the vicinity of some previous Weyerhaeuser ditching near the intersection and along the cut banks above the existing road, as shown in Photos 3 and 4. No evidence of any occupation of the area was noted. The steep slopes in this area suggest a relatively low likelihood of the existence of any undiscovered archaeological resources in the area. FEMA has already determined, and your office has concurred, in a determination that the location of the destroyed Tin Bridge is not eligible for inclusion in the National Register of Historic Places. Accordingly, FEMA has made a determination of “no historic properties affected” for this undertaking, as outlined in 36 CFR §800.4(d)(1). FEMA will include the following as a condition of funding: In the event historically or archaeologically significant materials or sites (or evidence thereof) are discovered during the implementation of the project, the project shall be halted and all reasonable measures taken to avoid or minimize harm to property until such time as FEMA, in consultation with the State Historic Preservation Officer (SHPO), determines appropriate measures have been taken to ensure that the project is in compliance with the National Historic Preservation Act. I request your concurrence with these determinations of APE and affect. Per our Programmatic Agreement, should you not object to this finding within 14 days of receipt of this letter, FEMA will assume concurrence and FEMA’s responsibilities under Section 106 of the National Historic Preservation Act will be fulfilled. Thank you for your review of this project. If you have any questions or comments please feel free to contact me at the above address, by telephone at 425-287-4735, or by e-mail at mark.eberlein@dhs.gov. Sincerely, Mark G. Eberlein Regional Environmental Officer Enclosures Map 1: Project location, Logging Road 1000 realignment, Town of Pe Ell (USGS topographic map) Map 2: Proposed realignment plan Photo 1: Road 1000, view SE; new alignment upslope to left Photo 2: Typical vegetation in realignment area Photo 3: Weyerhaeuser drainage ditching at intersection of 1000 and 1010. New road alignment climbs onto sideslope approximately along arrow Photo 4: Exposed ground at cut bank above current alignment. Primarily broken bedrock and undisturbed forest soils Letter dated 19 May 2008 from SHPO to FEMA: Mr. Mark Eberlein FEMA - Region X 130 228th Street SW Bothell, Washington 98021 Re: Logging Road Repair Project; DR-1734-DR-WA PW 912 v 2; Log No.: 051908-05-FEMA Dear Mr. Eberlein: Thank you for contacting our department. We have reviewed the materials for the proposed Logging Road 1000 Repair Project in Lewis County, Washington. We concur with the professional findings of Mr. Diters and your determination of No Historic Properties Affected. We would appreciate receiving any correspondence or comments from concerned tribes or other parties that you receive as you consult under the requirements of 36 CFR 800.4(a)(4). In the event that archaeological or historic materials are discovered during project activities, work in the immediate vicinity must stop, the area secured, and the concerned tribe's cultural staff and cultural committee and this office notified. These comments are based on the information available at the time of this review and on behalf of the STate Historic Preservation Officer in compliance with Section 106 of the National Historic Preservation Act, as amended, and its implementing regulations 36 CFR 800.4. Should additional information become available, our assessment may be revised, including information regarding historic properties that have not yet been identified. Thank you for the opportunity to comment and a copy of these comments should be included in subsequent environmental documents. Sincerely, Robert G. Whitlam, Ph.D. State Archaeologist (360) 586-3080 email: rob.whitlam@dahp.wa.gov [Received 21 May 2008, FEMA Region X]