HomeMy WebLinkAbout2017-07-07 404 (b) (1) Alternatives Analysis
CLEAN WATER ACT SECTION 404(B)(1)
EVALUATION
Upper Hoh River Road Project
Jefferson County, Washington
Prepared for:
U.S. DEPARTMENT OF TRANSPORTATION
FEDERAL HIGHWAY ADMINISTRATION
WESTERN FEDERAL LANDS HIGHWAY DIVISION
610 East Fifth Street
Vancouver, Washington 98661
WA JEFF 91420
Prepared by:
DAVID EVANS AND ASSOCIATES, INC.
14432 SE Eastgate Way, Suite 400
Bellevue, Washington 98007
July 2017
Upper Hoh River Road Project i July 2017
Clean Water Act Section 404 (b) (1) Evaluation
Table of Contents
1 INTRODUCTION ......................................................................................................................... 1
2 PROJECT DESCRIPTION .......................................................................................................... 2
2.1 Project Background .......................................................................................................... 2
2.2 Purpose and Need ............................................................................................................. 4
2.3 Project Alternatives .......................................................................................................... 5
2.3.1 No Action Alternative ................................................................................................ 5
2.3.2 Build Alternative (Proposed Project) ....................................................................... 5
2.4 Location and Type of Impacts to Waters of the United States ......................................... 9
2.5 Factual Determinations .................................................................................................. 12
2.5.1 Physical Substrate Determinations ......................................................................... 13
2.5.2 Water Circulation, Fluctuation and Salinity Determinations ................................. 13
2.5.3 Suspended Particulate/Turbidity Determinations ................................................... 13
2.5.4 Contaminant Determinations .................................................................................. 13
2.5.5 Aquatic Ecosystem and Organism Determinations ................................................ 13
2.5.6 Proposed Disposal Site Determinations ................................................................. 13
2.5.7 Determination of Cumulative Effects on the Aquatic Ecosystem ............................ 13
2.5.8 Determination of Secondary Effects on the Aquatic Ecosystem ............................. 14
2.6 Mitigation ....................................................................................................................... 14
2.6.1 Canyon Creek Crossing .......................................................................................... 14
2.6.2 Spruce Creek Culvert .............................................................................................. 14
2.6.3 Lindner Creek Side Channel Engineered Log Jams at MP 6.7 to 7.3 .................... 14
2.6.4 Spruce Creek/Canyon Creek ELJs at MP 9.8 ......................................................... 18
3 CONCLUSION .......................................................................................................................... 18
4 REFERENCES .......................................................................................................................... 20
List of Tables
Table 1 Wetland Summary Report .............................................................................................................. 10
Table 2 Stream Summary Table .................................................................................................................. 11
Table 3 Wetland and Stream Impact Table ................................................................................................. 12
List of Figures
Figure 1 Vicinity Map .................................................................................................................................... 3
Figure 2 Proposed Aquatic Mitigation Concept – Lindner Creek Side Channel Engineered Log Jams at MP
6.7 to 7.3 ......................................................................................................................................... 15
Figure 3 Lindner Creek Side Channel Finger Channels Emerging during Two-year Flood Event, MP 6.7 to
7.3 ................................................................................................................................................... 17
Figure 4 Proposed Aquatic Mitigation Concept – Spruce Creek/Canyon Creek ELJ at MP 9.8 .................. 19
LIST OF ATTACHMENTS
Attachment A Upper Hoh River Bank Failure Risk Reduction Study
Upper Hoh River Road Project ii July 2017
Clean Water Act Section 404 (b) (1) Evaluation
Acronyms and Abbreviations
BMP Best Management Practice
CFR Code of Federal Regulations
CWA Clean Water Act
dbh diameter at breast height
EA Environmental Assessment
ELJ engineered log jam
FHWA Federal Highway Administration
LWD large woody debris
MP mile post
OHWM ordinary high water mark
ONP Olympic National Park
ROW right-of-way
UHRR Upper How River Road
US 101 U.S. Highway 101
USFS U.S. Forest Service
WDNR Washington State Department of Natural Resources
WFLHD Western Federal Lands Division
Upper Hoh River Road Project 1 July 2017
Clean Water Act Section 404 (b) (1) Evaluation
1 INTRODUCTION
The purpose of Clean Water Act (CWA) Section 404(b)(1) (40 CFR Part 230) is to restore and
maintain the chemical, physical, and biological integrity of waters of the United States through
the control of discharges of dredged or fill material. Fundamental to the guidelines is the precept
that dredged or fill material should not be discharged into the aquatic ecosystem, unless it can be
demonstrated that such a discharge will not have an unacceptable adverse impact either
individually or in combination with known or probable impacts of other activities affecting the
ecosystems of concern. This analysis will show that the discharge of dredged or fill materials
related to the Upper Hoh River Road (UHRR) Bank Stabilization Project (project) will not have
an unacceptable adverse impact individually or in combination with known or probable impacts
of other activities affecting the ecosystems of concern.
For projects involving fill in waters of the United States, such as the proposed project, CWA
Section 404(b)(1) requires an evaluation of "practicable alternatives" that would have less impact
on the aquatic ecosystem. In compliance with Section 404(b)(1), this analysis will show that
practicable alternatives that do not involve special aquatic sites are not available or if available,
would not have less adverse impact on the aquatic ecosystem when compared to the proposed
project or would not meet the project purpose and need.
Section 230.10 of Subpart B of the 404(b)(1) guidelines establishes four conditions that must be
satisfied to make a finding that a proposed discharge complies with the guidelines. These
conditions include the following:
a) Except as provided under Section 404(b)(2), no discharge of dredged material shall be
permitted if there is a practicable alternative to the proposed discharge which would have
less adverse impact on the aquatic ecosystem, so long as the alternative does not have
other significant adverse environmental consequences;
b) No discharge of dredged or fill material shall be permitted if it violates state water quality
standards, Section 307 of the Clean Water Act, or the Endangered Species Act of 1973;
c) No discharge of dredged or fill material shall be permitted which will cause or contribute
to significant degradation of the waters of the United States; and
d) Except as provided under Section 404(b)(2), no discharge shall be permitted unless
appropriate and practicable steps have been taken which will minimize adverse impacts
of the discharge on the aquatic ecosystem.
Section 404(b)(1), Subpart A, Section 230.10(a) stipulates that no discharge will be allowed into
waters of the United States if the following is true:
There is a practicable alternative, which would have less adverse impact on the aquatic
ecosystem so long as the alternative does not have other significant adverse
environmental consequences.
When an activity is proposed to occur in a special aquatic site (i.e., wetland fill) and it is not
water dependent, the regulations presume that (1) practicable alternatives that do not involve
Upper Hoh River Road Project 2 July 2017
Clean Water Act Section 404 (b) (1) Evaluation
special aquatic sites are available, and that (2) these alternatives will have less adverse impact on
the aquatic ecosystem.
Adverse impacts may be offset by compensatory mitigation to bring the proposed project into
compliance with the 404(b)(1) guidelines. Impacts must be avoided to the maximum extent
practicable and remaining unavoidable impacts will then be mitigated to the extent appropriate
and practicable by taking steps to minimize impacts and compensate for the loss of aquatics
resource functions and values. Section 230.11 sets forth the factual determinations, which must
be considered in determining whether a proposed discharge satisfies the four conditions of
compliance. These determinations are discussed in the following sections of this evaluation.
2 PROJECT DESCRIPTION
2.1 Project Background
The Western Federal Lands Highway Division (WFLHD) of the Federal Highway
Administration (FHWA), in partnership with Jefferson County, proposes constructing bank
stabilization and bridge and culvert improvements in six locations along the UHRR. Located in
western Jefferson County between U.S. Highway 101 (US 101) and the Hoh Rain Forest Visitor
Center, the UHRR provides access to the Olympic National Park (ONP) and private properties
along the road. The road was built in the 1930s, when ONP was established, and is the primary
western access to the park (see Figure 1).
The UHRR extends in a generally east-west direction north of, and in many places adjacent to,
the Hoh River, an approximately 56-mile-long river originating from Mount Olympus, flowing
through the Olympic Mountains and foothills, and emptying into the Pacific Ocean at the Hoh
Indian Reservation. The Hoh River valley is relatively flat and broad, with a complex channel-
migration zone supporting the braided river channel, gravel bars, side channels, and backwater
areas. The Hoh River has a wide range of seasonal flow rates, with recorded annual peak flows
more than 60,000 cubic feet per second.
The UHRR is within approximately five feet of the Hoh River in many areas, resulting in
unstable banks and slides during high water or storm events. WFLHD and Jefferson County have
constructed several emergency projects in recent years along the road, to prevent road closures
due to unstable slopes on the river side of the road. Repair projects constructed in an emergency
are potentially more expensive, environmentally damaging, and less sustainable in the long run.
The locations WFLHD chose for this project have the highest estimated risk of impending failure
compared to other locations along the UHRR.
Upper Hoh River Road Project
Data Sources: Jefferson County, Washington DNR.
\\Pdxfs1\project\F\FHAX00000226\0600INFO\GS\Maps\Public EA maps\Fig_1-1 Vicinity Map.mxd
Figure 3-1Vicinity Map
HohRiver
Site C4 UpstreamBank StabilizationMP 7.9, RM 23.6
10101
H o h R i v e r
Upper H
o
h
R
i
v
e
r
R
d
Upper Hoh River Rd
Upper Hoh River Rd
Maple Creek Rd
Ow
l
C
r
e
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k
R
d
10101
10101
Hoh Mainline Rd
Culvert ReplacementMP 4.38, RM 19.5
Site C4 DownstreamBank StabilizationMP 7.5 to 7.6RM 23.3
Site C5Canyon Creek CulvertMP 10.2, RM 27.1
Site C1Bank StabilizationMP 3.6 to 3.8RM 18.8 to 18.9
Site C3Tower Creek BridgeMP 7.5, RM 23.3
Site C2Bank StabilizationMP 4.0 to 4.4RM 19.1 to 19.5
Project Locations
Upper Hoh River
Upper Hoh River Road
Local Road
0 0.5 1Mile
WASHINGTONEnlarged Area
T. 27N R. 11WSec. 19, 25, 27, 28 & 30T. 27N R. 12W Sec. 24 & 25
Project Location
10101
10101
Olympic National Park
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Clean Water Act Section 404 (b) (1) Evaluation
2.2 Purpose and Need
The proposed project’s purpose is to develop and implement cost-effective, long-term bank
stabilization solutions at three locations along the UHRR in western Jefferson County,
Washington. The project will also replace three stream-crossing structures (bridges or culverts).
The UHRR at the bank stabilization and stream crossing sites is at risk of washing away in a
large flood event. Key design objectives are to protect the UHRR at certain locations between
mile post (MP) 3.6 and MP 10.2 from erosion, and to provide safe and consistent access to
residents, businesses, and ONP visitors between US 101 and the Hoh Rain Forest Visitor Center.
The UHRR serves as the only access road for the residents and businesses located along this
roadway and for visitors entering ONP from US 101 from the west. In 2014, over 82,000
vehicles entered the park using the UHRR. In August of 2015 alone, 24,000 vehicles entered the
park using the UHRR. Visitor data for recent years indicate that an annual average of 3 million
people visit the park. The UHRR leads to the Hoh Rain Forest Visitor Center, which is one of
four year-round ranger stations in ONP and the only year-round ranger station with access to the
western side of the park (NPS 2016a; 2016b).
Maintaining safe and consistent access along the UHRR has been increasingly difficult due to the
dynamic character of the adjacent Hoh River, a low-gradient river with frequenting-shifting
braided channels. Additional challenges have recently exacerbated the character of the river
corridor. For example, vegetation removal in the Hoh River drainage combined with recent
changes in weather patterns (warmer temperatures and less snow) have contributed to the
magnitude and extent of the river’s channel migration. Often, this has caused flows to be directed
against the road embankment causing significant erosion and instability. Damage to the UHRR
due to flooding has resulted in road or lane closures lasting several weeks in 1996, 1998, 2003,
2004, 2006, 2007, and 2014. A continuing trend of more frequent flooding will increase the
potential for interrupted access to US 101 and ONP for local residents, business owners/patrons,
park users, and other recreationists.
The cost to repeatedly maintain safe access on the UHRR has increased substantially due to the
Hoh River’s character and its proximity to the UHRR. Over the past decade, the County and
WFLHD (through the Emergency Relief Program) have spent over $5 million on 13 projects to
maintain safe access on the 12-mile portion of the UHRR between US 101 and ONP.
Built in 1983, the Tower Creek Bridge is in need of replacement, and does not meet current
seismic and design standards. The Hoh River’s migration toward the UHRR has shortened the
Tower Creek channel length, which has caused the Tower Creek channel to incise and scour the
bridge abutments. In addition to being undersized and requiring frequent maintenance to remove
debris and sediment, the MP 4.38 and Canyon Creek culverts are barriers to fish passage at
certain flows.
Because the purpose and need of the project are intended to stabilize the bank of the Hoh River
and make changes to the in-stream conditions of several tributaries, the project by definition is
“water dependent” as defined under Section 4049(b)(1).
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Clean Water Act Section 404 (b) (1) Evaluation
2.3 Project Alternatives
The following project alternatives were previously described and evaluated in the project
Environmental Assessment (DEA 2017).
2.3.1 No Action Alternative
With the No Action Alternative, the project would not be constructed, and maintenance and
emergency repairs along the UHRR would continue similar to existing conditions, on an as-
needed basis, in response to damage from flood and storm events. This would require ongoing
monitoring along various lengths of bank and riprap revetment to prevent potential future road
closures. Maintenance at the MP 4.38 and Canyon Creek culverts and the Tower Creek Bridge
would continue. Typically, emergency repairs to the riverbank, roadway, or related structures
would need to begin immediately following incidents causing damage, irrespective of the in-
water work window that would normally constrain the timing of construction to protect fish and
fish habitat.
Similar to past emergency repair work, future work would likely require temporary one-lane
closures on the UHRR for staging vehicles, backhoes, cranes, and other equipment during riprap
placement. The amount of riprap would depend on the extent and magnitude of damage resulting
from bank erosion or riprap dislodgement. Some or all of this work could occur below the
ordinary high water mark (OHWM). To the extent Best Management Practices (BMPs) could be
employed on short notice for emergency work, they would minimize water quality impacts from
the release of silt and soils during riprap placement.
2.3.2 Build Alternative (Proposed Project)
The purpose of the Build Alternative is to develop and implement, at six locations, cost-
effective, long-term bank stabilization and stream crossing solutions to lessen the probability of
road washouts and assure safe and consistent access along the UHRR. The need for the project
stems from historic and ongoing damages to the UHRR, and its embankment, from flooding and
erosion along the Hoh River. Such conditions have caused access along the UHRR to be
unreliable for local residents, businesses, ONP visitors, and others traveling this sole route that
connects US 101 with the ONP’s Hoh Rain Forest Visitor Center. The Build Alternative would
accomplish the purpose of and need for the project while providing fish habitat benefits,
including fish passage and in-stream habitat.
The locations WFLHD chose for this project have the highest estimated risk of impending failure
compared to other locations along the UHRR, as determined by the Upper Hoh Road Bank
Failure Risk Reduction Study (study) (WFLHD 2013), included as Attachment A. This
engineering study evaluated the existing bank conditions and considered treatments options and
methods for the bank stabilization locations at Sites C1, C2, and C4 and the Tower Creek and
Canyon Creek crossings. Treatments options considered included continuing maintenance,
relocating the road, stabilizing the existing road embankment, a minor active river channel shift,
and a major active river channel shift.
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Clean Water Act Section 404 (b) (1) Evaluation
Specific methods for stabilizing the existing road embankment were evaluated and included a
complex roughened large rock toe, a complex log crib wall; riprap with roughened tock toe, large
woody debris, and riparian planting; and riprap with stream barbs. Riprap with stream barbs and
engineered log jam groins were considered and evaluated as specific methods to accomplish a
minor active river channel shift.
The study ranked each of these options and methods according to several criteria, including
roadway protection and preservation; cost; and impacts to bank stability, special species and
habitat, wilderness areas, river process and function, safety, and private property. The study also
discussed environmental clearance considerations for each of the options. Ranking highest for
the three bank stabilization locations (Sites C1, C2, and C4) were bank stabilization with
complex roughened large rock toe or riprap with LWD plantings and a minor active river
channel shift using large stream barbs. For Tower Creek, replacing the bridge ranked highest,
and for Canyon Creek, replacing the culvert with a new open-bottom culvert ranked highest.
The study was the starting point for further evaluation of methods, development of the Build
Alternative (Proposed Project), and the evaluation of environmental impacts in the EA. Further
evaluation by WFLHD, including relocation of the UHRR and alternative bank stabilization
measures, are described in more detail below.
2.3.2.1 Road Relocation
Relocating the UHRR north of the existing alignment was initially considered. This preliminary
alternative would have required removal of mature vegetation and critical habitat for the marbled
murrelet, resulted in impacts to undisturbed wetlands, and required excavation on very steep
slopes with geologic hazards. Retaining walls could have been required. Slopes begin at the
UHRR and generally become steeper moving north toward the 3,018-foot summit of Spruce
Mountain, approximately 2.5 miles from Sites C4 and C5. With this alternative, WFLHD would
have had to acquire large amounts of private and public property for conversion to transportation
use. In addition to more extensive road demolition and construction that would have disrupted
traffic for a considerably longer duration and extensive right-of-way acquisitions, substantial
efforts and costs also would have been required to relocate several stream crossing structures
(bridges and culverts) and restore vegetation and the river embankment sections along the
original roadway.
WFLHD documented its examination of the UHRR relocation option in the 2013 engineering
study, discussed in Section 2.3.3 (WFLHD 2013). Major findings for road relocation included
the following:
The required length of the relocated UHRR would have been 3,000 to 4,000 feet; this
option would have required the relocated road cross the 260-foot high terrace slope
immediately north of the UHRR;
Observed slumping on the terrace slope suggested geotechnical instability, meaning that a
relocated road could have caused landslides and debris flows, potentially blocking and
damaging the UHRR;
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Clean Water Act Section 404 (b) (1) Evaluation
Road relocation would therefore have required significant efforts to stabilize the road
foundation, in order to reduce the potential for landslides and debris flows; and
Road relocation would have allowed removal of the existing riprap revetment and
reconstruction of an area of riverbank approximately 80 to 100 feet wide by 1,800 feet
long. Bank stabilization techniques and newly planted vegetation would have been
required on the reconstructed riverbank and upland area to prevent lateral bank erosion
and migration of the channel to the north. Techniques and vegetation would have been
subject to performance monitoring, similar to the proposed project.
More recent evaluation of UHRR relocation considered two main options: (1) relocating the
UHRR to the north between MP 3.0 and MP 11.0, and (2) relocating shorter segments of the
UHRR that are closest to the road, including either the segment from MP 3.0 to MP 5.5, MP 7.0
to MP 9.0, or MP 9.0 to MP 11.0.
Relocating the UHRR for 2.5 miles, between MP 3.0 to MP 5.5, would have moved the road
away from Sites C1 and C2 and required demolition and replacement of two large bridges,
relocation of two to three large-diameter fish-passable culverts, construction of major retaining
walls on the north side of the UHRR, and clearing approximately 20 acres of right-of-way
(ROW). The first bridge would have been approximately 600 feet long and 100 feet above
ground. The second bridge would have been approximately 100 feet long. As the road length
increased and the alignment differences grew, this preliminary alternative would have increasing
risks, including steep slopes and unstable soils on the north side of the UHRR. WFLHD
estimated that the total capital cost of relocating the road, not including addressing erosion and
road washouts at Site C4, would have been ranged from $13 million to $17 million, based on
these two options.
Additional funds could have been required to stabilize the UHRR and surrounding area if
landslides were to occur. Based on the greater magnitude of environmental consequences, a
more extended construction timeline, and higher costs, relocating the UHRR was dismissed from
further consideration.
2.3.2.2 Alternative Construction Methods
Selection of the three bank stabilization sites was based on observations along the river and
UHRR and represent locations most in need of stabilization. Methods considered for stabilizing
banks, other than engineered log jams (ELJs) with dolosse, include riprap, log crib walls, and
stream barbs and groins.
Riprap. Riprap is the most common and highly effective form of bank protection in the Pacific
Northwest. It consists of armoring the bank with large angular rock that deflects hydraulic forces
from treated sites, and is used for long-term erosion control. Using riprap at the three bank
stabilization sites would meet the purpose and need of the project, as it would stabilize the bank
and result in long-term increased reliability and safety along the UHRR. However, riprap can
permanently displace and adversely affect fish habitat, result in erosion at other untreated sites,
and reduce the recruitment of large woody debris (LWD) and sediment recruitment. Riprap not
installed properly tends to (1) create downstream scour at the transition to the natural bank, and
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Clean Water Act Section 404 (b) (1) Evaluation
(2) undermine the toe of the slope downstream of the installed riprap. Existing riprap revetments
along the Hoh River may be responsible for some observable downstream scour and channel
changes, although the dynamic nature of the river’s migrating channel may also be a contributing
factor. The riprap option was dismissed from further consideration due to the risks associated
with improper installation and the long-term potential for adverse impacts related to fish habitat,
LWD, and sediment transport.
Log Crib Walls. Log crib walls are large rectangular log boxes filled with rocks and soil,
oriented parallel to the direction of streamflow. Planting spaces are formed in the wall by
stacking the wall logs in alternating fashion. This solution would meet the purpose and need of
the project—to stabilize the bank and create increased reliability and safety for residents,
businesses, and ONP visitors using the UHRR. These structures are typically used where
streambanks are experiencing mass failure or significant erosion from subsurface drainage. Bank
failure along the Hoh River is caused by river scour at the toe of slope, not by erosion from
subsurface drainage. As vertical structures, log crib walls are susceptible to hydraulic and
gravitational forces that cause undermining and settling of soils within and behind the wall;
therefore, this may not be a sustainable option, given the dynamic and forceful attributes of the
Hoh River flow regime. Installing log crib walls along the banks of the Hoh River could result in
the toe of the structure remaining vulnerable to scour and subsequent undermining, settling, and
collapse. Therefore, log crib walls as a treatment option were also dismissed from further
consideration.
Stream Barbs and Groins. Stream barbs and groins extend from the bank into the flow of a
water body, and are typically constructed of rock, LWD, or a combination of both. They are used
for bank protection, to create lateral sand bars, to divert stream flow in a mid-channel direction,
and to change depositional patterns of sediment. The height of groins usually extend above the
high-flow water surface elevation. This tends to change the cross-section of the stream more than
barbs, by deepening and narrowing the channel. Each type has the potential to provide pool
habitat for fish. Although trees or LWD can be added into barbs or groins to increase habitat
value, they increase the risk of voids in the rock fill, result in poor foundation conditions, and
may cause buoyancy that affects the stability of the structure (NRCS 2013). Groins constructed
of LWD typically allow more water to flow through them, which tends to create less scouring of
the adjoining streambed than a rock groin.
Although both groins and barbs would meet the project’s purpose and need of increasing bank
stabilization and related reliability and safety of the UHRR, they can cause more significant
changes to downstream and upstream hydraulic and erosion patterns. Stream barbs and groins
were dismissed from further consideration because any additional downstream or upstream
erosion they might cause could exacerbate current bank erosion conditions.
2.3.2.3 Alternatives for MP 4.38 Stream Crossing
The water conveyance/stream crossing improvement at MP 4.38 was initially envisioned as a
bridge to minimize the level of disturbance to the UHRR at this site. During the design process,
the Hoh River migrated closer to the existing roadway. Consequently, the anticipated detour
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Clean Water Act Section 404 (b) (1) Evaluation
route planned for construction was no longer feasible because there would be limited area for the
contiguous footings and piers needed for construction. While the bridge option would have met
the purpose and need for the project, the design layout at this site was no longer feasible.
WFLHD, therefore, decided to only carry forward the culvert option for this site.
2.3.2.4 Alternatives for the Tower Creek Bridge
Steel girders were considered as an option at the span length required for Tower Creek.
Replacing Tower Creek Bridge (with steel girders or girders made from another material) meets
the purpose and need for the project, in that a new bridge supports the long-term reliability of the
UHRR. Concerns were expressed that steel girders could require a cast-in-place concrete deck
and that the girders would be susceptible to corrosion and create new maintenance issues.
Therefore, steel girders were dismissed from further consideration for the Tower Creek Bridge.
2.3.2.5 Alternatives for the Canyon Creek Culvert
A three-span bridge arrangement was initially evaluated for Canyon Creek. A three-span
structure would use shorter and more cost-effective bridge girders, yet the cost saving from the
superstructure could be offset by the cost of the additional foundation and piers and the required
in-water work for the intermediate piers. Although the multiple span arrangements would help
minimize the structural depth and reduce the cost of the bridge superstructure, the bridge piers
would have potential problems due to added requirements for dewatering, cofferdams, and
equipment access. The additional piers and shorter spans would combine to catch and retain
debris, and provide another mechanism for scour to form under the bridge. The three-span
arrangement was therefore dismissed from further consideration, even though it would have met
the purpose and need for the project as part of a new bridge, which would have increased the
long-term safety and reliability of the UHRR.
2.4 Location and Type of Impacts to Waters of the United States
Characteristics and classification of wetlands and streams in the project area are described in
detail in the original Wetland and Streams Delineation Report for the project as well as the
Addendum to that report (prepared in 2017). Tables 1 and 2 below summarizes waters of the
U.S. delineated in the study area.
A total of 22 wetlands and 19 streams were mapped within the study area. The wetlands are all
either Category II or III wetlands, and their hydrogeomorphic class is mostly slope. Most of the
wetlands are located on the north side of the Upper Hoh River Road, opposite of the proposed
bank stabilization work. Most of the wetlands are dominated by either shrub or forest vegetation.
Most of the streams are small, high gradient side wall tributaries that drain directly to the Hoh
River. The larger, fish bearing streams in the study area include the Hoh River, Willoughby
Creek, Tower Creek, Canyon Creek, and the unnamed tributary at MP 4.38.
All of the wetlands and streams are assumed to be under the jurisdiction of the Corps based on
direct s
urface water connections to the Hoh River or location in the 100-year floodplain.
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Clean Water Act Section 404 (b) (1) Evaluation
Table 1 Wetland Summary Report
Wetland ID Ecology1
Category
NWI
Classifi-
cation
HGM
Wetland
Class
Total
Wetland
Functions
Score
Water
Quality
Functions
Score
Hydrology
Functions
Score
Wildlife
Habitat
Functions
Score
Jefferson
County
Wetland
Buffer2
Site C1
W4 III PFO Slope 18 6 4 8 150
W5 III PSS Slope 17 6 4 7 80
W6/WC1-A III PFO Slope 18 6 4 8 150
WC1-B III PFO Slope 17 4 5 8 150
WC1-C III PFO Slope 17 4 5 8 150
WC1-D III PFO Slope 17 4 5 8 150
WC1-E III PFO Slope 17 4 5 8 150
W3/WC1-F III PFO Slope 18 6 4 8 150
WC1-G III PFO Slope 17 4 5 8 150
Site C2
W1 III PEM Slope 17 6 4 7 80
W2/WC1-H III PFO Slope 18 6 4 8 150
W12 III PFO Slope 18 6 4 8 150
Site C3
WC3-A III PFO Depressional 16 7 4 5 80
WC3-B III PFO Depressional 16 7 4 5 80
Site C4
WC4-A III PFO Slope 17 4 5 8 150
WC4-B III PFO Slope 17 4 5 8 150
WC4-C III PFO Slope 17 4 5 8 150
Site M1
W7 II PFO Depressional 20 7 5 8 300
W8 II PFO Depressional 20 7 5 8 300
Site M2
W9 III PSS Depressional 20 7 7 6 150
W10 III PSS Slope 20 7 5 8 150
W11 III PSS Slope 20 7 5 8 150
1 Washington State Department of Ecology (2014)
2 Wetland buffer widths in the Jefferson County
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Clean Water Act Section 404 (b) (1) Evaluation
Table 2 Stream Summary Table
Stream Watershed DNR Classification1
Local Jurisdiction
Classification2
Field
Estimated
Classification
Stream
Width (feet)
Buffer Width
(feet)D
Site C1
Willoughby
Creek
WRIA 20 Type F = Fish Type F = Fish F = Fish 15 -20 150
S9 WRIA 20 Not Mapped Not Mapped Ns 2 – 2.5 50
SC1-A WRIA 20 Not Mapped Not Mapped Ns 1 – 1.5 50
SC1-B WRIA 20 Not Mapped Not Mapped Ns 1 – 1.5 50
Hoh River (C1) WRIA 20 Type S Type F = Fish F = Fish 570 - 830 150
Site C2
S8/SC1-C WRIA 20 Not Mapped Not Mapped Ns 1 – 1.5 50
S12 WRIA 20 Not Mapped F = Fish F = Fish 3 - 5 150
S13 WRIA 20 Not Mapped Not Mapped Ns 1 - 2 50
S14 WRIA 20 Not Mapped Not Mapped Ns 2 - 3 75
S15 WRIA 20 Not Mapped Not Mapped Ns 1 - 2 75
S16 WRIA 20 Not Mapped Not Mapped Ns 1 – 2.5 75
S17/SC1-D WRIA 20 Not Mapped Not Mapped Ns 1 - 3 75
S18 WRIA 20 Not Mapped Not Mapped Np 1 - 2 50
Hoh River (C2) WRIA 20 Type S Type F = Fish F = Fish 560 - 590 150
Site C3
Tower Creek WRIA 20 Type F = Fish Type F = Fish F = Fish 30 - 50 150
Hoh River (C3) WRIA 20 Type S Type F = Fish F = Fish 630 150
Site C4
SC4-A WRIA 20 Not Mapped Not Mapped Ns 1 – 1.5 50
SC4-B WRIA 20 Not Mapped Not Mapped Ns 3 – 5 50
Hoh River (C4) WRIA 20 Type S Type F = Fish F = Fish 800 - 1000 150
Site C5
Canyon Creek WRIA 20 Type F = Fish Type F = Fish F = Fish 30 - 50 150
Hoh River (C5) WRIA 20 Type S Type F = Fish F = Fish 720 - 780 150
Site M1
Hoh River (M1) WRIA 20 Type S Type F = Fish F = Fish 400 - 750 150
Site M2
S10 WRIA 20 Not Mapped Not Mapped Ns 2 - 3 50
S11 WRIA 20 Not Mapped Not Mapped Ns 2 - 3 50
Hoh River (M2) WRIA 20 Type S Type F = Fish F = Fish 800 - 1000 150
Upper Hoh River Road Project 12 July 2017
Clean Water Act Section 404 (b) (1) Evaluation
Table 3 describes proposed impacts to waters of the U.S. This information is also listed in the
project JARPA. Most of the proposed fill in waters of the U.S. will occur in the Hoh River, and
will consist of the ELJs and associated materials. The proposed project will have permanent
impacts to approximately 1.5 acres of streams, including the Hoh River, and approximately 2.8
acres of temporary impact to streams. Most of these impacts are due to placement of the ELJs in
the Hoh River. Approximately 0.05 acre of wetlands will be temporarily affected by the
proposed project, and approximately 0.03 acre of wetlands will be permanently affected. All of
the permanently affected wetlands are previously disturbed and in close proximity to the Upper
Hoh River Road.
Table 3 Wetland and Stream Impact Table
Waterbody Impact Type Area of Impact (square feet)
Streams
Hoh River Permanent 58,824
Hoh River Temporary 120,716
Unnamed Tributary at MP 4.38 Permanent 534
Unnamed Tributary at MP 4.38 Temporary 1118
Tower Creek Permanent 5,908
Tower Creek Temporary --
Canyon Creek Permanent 2130
Canyon Creek Temporary --
Total Permanent Impact 65,496
Total Temporary Impact 121,834
Wetlands
Wetland 1 Permanent 765
Wetland 5 Temporary 458
Wetland WC3-A Permanent 339
Wetland WC3-A Temporary 265
Wetland WC3-B Temporary 2
Wetland WC4-A Temporary 18
Ditch DC3-A Permanent 432
Ditch DC3-A Temporary 60
Ditch DC4-A Permanent 55
Ditch DC4-B Permanent 630
Ditch DC4-B Temporary 466
Total Permanent Impact 2221
Total Temporary Impact 1269
2.5 Factual Determinations
Section 404(b)(1), Subpart A, Section 230.11, of the CWA requires that certain factual
determinations be made in order to demonstrate that the project will not cause or contribute to
significant degradation of water of the United States. Each of these determinations are addressed
Upper Hoh River Road Project 13 July 2017
Clean Water Act Section 404 (b) (1) Evaluation
below. In general, information is summarized, and the reader is referred to other existing
documents for more information.
2.5.1 Physical Substrate Determinations
The proposed project will not significantly change substrate in the Hoh River. ELJs will be
limited to addition of dolosse and LWD to mimic behavior of natural logjams in the river. See
section 4.4 (Hydrology and Hydraulics) in the Draft and Final Environmental Assessment (EA)
for more information.
2.5.2 Water Circulation, Fluctuation and Salinity Determinations
The proposed bank stabilization projects are designed to produce a buffering effect along the
existing riverbank and reduce water velocities in order to reduce bank erosion and scour. See
Section 4.5, Hydrology and Hydraulics, in the Final EA, as well as Appendix D of the FONSI,
Hydraulic Report.
2.5.3 Suspended Particulate/Turbidity Determinations
The proposed project will create temporary increases in suspended sediment during installation
of the ELJ/dolosse units. However, these increases will be reduced through use of BMPs and
adherence to the project Water Quality Monitoring Plan, which was an enclosure with the
JARPA application to the Corps. No temporary increase in suspended sediment is anticipated for
any of the tributary projects since all of those will be constructed with complete work area
isolation. No long term changes in suspended sediment or turbidity are anticipated.
2.5.4 Contaminant Determinations
No contaminants will be introduced to the aquatic ecosystem due to the project. All materials
will be either native materials (e.g., logs, slash, nearby bank material, etc.) or pre-fabricated
concrete dolosse.
2.5.5 Aquatic Ecosystem and Organism Determinations
The proposed project will have a variety of effects to the aquatic ecosystem, including temporary
and permanent impacts to the Hoh River, Tower Creek, Canyon Creek, and the unnamed
tributary at MP 4.38. Overall, the project will permanently affect 0.04 acre of wetlands and wet
ditches, and 1.5 acres of the Hoh River due to installation of the ELJs. These impacts to the
aquatic ecosystem and associated aquatic organisms are fully described in the project Biological
Assessment, Biological Opinion (prepared by the U.S. Fish and Wildlife Service (USFWS),
Draft and Final EA, and associated technical reports, including the Wetland Delineation Report
and Addendum.
2.5.6 Proposed Disposal Site Determinations
Location of the proposed in-water work is described in the JARPA application and other project
documents.
2.5.7 Determination of Cumulative Effects on the Aquatic Ecosystem
Cumulative effects to the aquatic ecosystem are described in Sections 4.4 (Hydrology and
Hydraulics) and 4.6 (Fish and Wildlife) of the Draft and Final EA.
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Clean Water Act Section 404 (b) (1) Evaluation
2.5.8 Determination of Secondary Effects on the Aquatic Ecosystem
Secondary (indirect) effects to the aquatic ecosystem are described in Sections 4.4 (Hydrology
and Hydraulics) and 4.6 (Fish and Wildlife) of the Draft and Final EA.
2.6 Mitigation
As a result of the NEPA process, including agency consultation and public comment, WFLHD
concluded that the proposed project would require compensatory mitigation to offset
unavoidable impacts to the aquatic ecosystem. Many mitigation options were discussed with
involved agencies, including mitigation options at Canyon Creek crossing, Spruce Creek bridge,
Lindner Creek side channel at MP 6.7, and Spruce Creek/Canyon Creek at MP 9.8. The options
are described in more detail below.
2.6.1 Canyon Creek Crossing
WFLHD considered proposing the replacement of Canyon Creek culvert with a bridge as
mitigation for the bank stabilization project. Replacing the culvert at Canyon Creek with a bridge
was evaluated in the Environmental Assessment, and it was noted in the Draft EA that at the time
the Draft EA was issued, the Canyon Creek component of the project was under consideration as
mitigation for the bank stabilization components of the project. Since the Draft EA was issued,
WFLHD in coordination with the WDFW, the Hoh Tribe, and the Corps determined that the
Canyon Creek crossing work would not qualify as mitigation.
2.6.2 Spruce Creek Culvert
In 2009, the eastbound lane of the UHRR had been undermined when a debris flow damaged the
Spruce Creek culvert beyond repair. Jefferson County installed temporary riprap to rebuild the
eastbound lane. In 2012, the damaged culvert was replaced with a 24-foot concrete bridge.
Project was self-mitigating because it replaced an existing partial fish passage barrier. Since
2012, much of the material comprising the bank has washed away, and fish passage no longer
exists at Spruce Creek. WFLHD considered rebuilding the bank at this location and restoring fish
passage to Spruce Creek, as mitigation for the bank stabilization work.
2.6.3 Lindner Creek Side Channel Engineered Log Jams at MP 6.7 to 7.3
This mitigation project will be constructed in the area between approximately MP 6.7 and MP
7.3 of the UHRR, west of Site C3 (Tower Creek) (see Figure 2) and owned or managed by the
U.S. Forest Service (USFS), the Nature Conservancy, and the Washington Department of
Natural Resources WDNR. In this area, a large side channel meander of the Hoh River has
formed where the mainstem was formerly located prior to approximately 2010. This large side
channel is adjacent to a stand of mature forest on WDNR and USFS land. Lindner Creek and
several other creeks flow into this large side channel.
Tributaries to the Hoh River, such as Lindner Creek, and the high-water channels that cross the
‘peninsula’ between the Hoh River upstream and the large side channel near MP 6.7 (see Figure
1) provide important rearing and high-water refuge habitat for fish species such as steelhead,
Service Layer Credits:
Upper Hoh River Road Project
Data Sources: USDA 2015 NAIP, Jefferson County
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U p p e r H o h R d
Hoh
River
H o h R i v e r
¶
U p p e r H o h R d
Existing Road
New Road
EngineeredLog Jam (ELJ)
Site C3Tower Creek BridgeMP 7.5, RM 23.3
Site C4 DownstreamBank StabilizationMP 7.5 to 7.6RM 23.3
0 250 500Feet
Figure 1Proposed Aquatic Mitigation Concept -Lindner Creek Side ChannelEngineered Log Jams, MP 6.7 to 7.3
Project Site
Upper Hoh Road
New Road
Existing Road
Engineered Log Jam (ELJ)³
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Clean Water Act Section 404 (b) (1) Evaluation
Chinook salmon, coho, and bull trout. Many of the high-water channels have emerged during
relatively minor flood events (e.g., less than 10-year flood flow) since the 1990s, due to the
increasingly erratic nature of the Hoh River’s migration across the river meander belt. Figure 3
shows the finger- and overflow-channels that emerge on the ‘peninsula’ during a two-year flood
event.
Lindner Creek, the large main channel, and the high-water channels on the ‘peninsula’ comprise
a side channel complex. Long-term preservation of this side channel complex would result in the
following benefits to aquatic and forest resources, which are important to stakeholder resource
managers such as WDFW and the Hoh Tribe:
Preservation and maintenance of vital rearing and high-water refuge habitat for steelhead,
Chinook salmon, coho, and bull trout;
Preservation of nearby priority steelhead spawning areas, which could potentially
undergo modification during the next channel migration event;
Protection of the remaining mature forest stand south of the UHRR;
Encouragement of riparian forest development in the area surrounding the side channel
complex by preventing a future channel migration (this area provides important forage
and cover for Roosevelt elk, particularly in the spring); and
Preservation of the configuration of small overflow channels in the ‘peninsula’ area that
currently exist as small, finger- and overflow-channels, rather than having them develop
into larger channels, or join the main channel, if a river migration occurs.
In order to preserve the side channel complex, approximately 24 ELJs would be installed in an
arc, extending approximately 0.8 mile south and west from MP 7.3 of the UHRR, crossing the
lower section of the side channel complex (see Figure M-1). Each ELJ will consist of
approximately 10 dolosse/log bundles, each comprised of one dolos connected to two or three
logs. Sheet F.8 of Appendix E, Design Plan Set (70%) shows details of the dolosse/log bundle
design. Between the ELJs, the bank would be planted with cottonwood, bank willow, and
emergent willow. In addition, the bank would be stabilized with a mixture of gravel and cobble.
Installation of the ELJs will require limited clearing and temporary improvements to an existing
un-graded side road off the UHRR. This unimproved road, which is currently used for drift boat
access to the river, will need to be sufficiently improved for construction access. It will need to
be temporarily extended beyond its existing terminus with the extended portion replanted with
dense native shrubs and trees once ELJ installation is complete. Up to one acre of clearing will
be required for the temporary access road. Vegetation clearing for the newly extended access
road will be limited to young alders and willows averaging less than 10 inches diameter of breast
height (dbh).
In addition to the side channel benefits listed above, this mitigation project will encourage long-
term preservation of rearing and spawning habitat on the mainstem Hoh River by increasing
channel stability.
Upper Hoh River Road Project
Data Source: FHWA Turner-Fairbank Highway Research Center flume analysis, June 2017
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U p p e r H o h R d
Hoh
River
H o h R i v e r
¶
U p p e r H o h R d
³0 250 500Feet
Figure 2Lindner Creek Side Channel Finger Channels -Emerging During Two-year Flood Event, MP 6.7 to 7.3
Hoh River
¶
Approximate Scale
Upper Hoh River Road Project 18 July 2017
Clean Water Act Section 404 (b) (1) Evaluation
2.6.4 Spruce Creek/Canyon Creek ELJs at MP 9.8
The second proposed mitigation project will involve installing four large ELJs in the Hoh River
adjacent to and upstream of the confluence of Spruce Creek to MP 9.8, in an area managed by
the Nature Conservancy. The ELJs would be placed in front of the existing riprap that Jefferson
County installed as part of emergency repair. They would be similar in design to the ELJ/dolosse
units previously described for the proposed project, and will provide the following benefits:
Preserve the existing riparian habitat at this location, where the river is actively scouring
upstream of the riprap installation;
Improve channel roughness and complexity, which has decreased due to nearby riprap;
Provide additional rearing habitat and cover for salmonids, through decreasing near-shore
flow velocity at this important location near the mouth of Spruce Creek and the mouth of
Canyon Creek (Canyon Creek flows through a large side channel and joins the mainstem
upstream of this location); and
Provide more favorable habitat for juvenile salmonids through (1) the use of the ELJs
itself as cover, and (2) creation of additional channel complexity including scour pools.
(Post-construction monitoring studies of similar ELJ structures installed by WSDOT in
the lower Hoh River and elsewhere have demonstrated this effect.)
3 CONCLUSION
Based on the previous analysis, combined with other relevant project documents, including the
NEPA EA, Biological Opinion, and extensive agency coordination, the WFLHD believes that
there is no practicable alternative to the proposed work, which would have less adverse impact
on the aquatic ecosystem, while still meeting the project’s purpose and need. Other evaluated
options (i.e., riprap) would cost less to implement, but would have greater environmental
consequences. The proposed project will involve extensive BMPs and avoidance measures to
minimize potential adverse impacts to waters of the United States These measures are described
in the Water Quality Monitoring Plan, Section 9 of the FONSI (Mitigation and Environmental
Commitments), the Biological Opinion from the USFWS, and other project documents.
Compensatory mitigation is also proposed that will provide long term habitat improvement for
aquatic habitat in the mainstem Hoh River.
Upper Hoh River Road Project
Data Sources: Google Earth
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³Figure 3Proposed Aquatic Mitigation Concept -Spruce Creek/Canyon CreekEngineered Log Jams, MP 9.8Approximate Scale
Hoh River ¶
U p p e r
H
o h R d
Engineered Log Jam (ELJ)Feet0150300
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4 REFERENCES
David Evans and Associates, Inc. (DEA). 2017. Final Environmental Assessment, Upper Hoh
River Road Project, Jefferson County, Washington. July, 2107.
Natural Resources Conservation Service (NRCS). 2013. Kansas Engineering Technical Note No.
KS-1 (Revision 1). ENG – Design of Stream Barbs. January 23, 2013.
National Park Service (NPS). 2016a. Park Entrance Traffic Counts. https://irma.nps.gov/Stats/
SSRSReports/Park%20Specific%20Reports/Traffic%20Counts?Park=OLYM. Accessed
March 9, 2016.
———. 2016b. National Park Service Visitor Use Statistics. https://irma.nps.gov/Stats/
Reports/Park/OLYM. Accessed January 20, 2016.
Western Federal Lands Highway Division (WFLHD). 2013. Federal Highway Administration,
Western Federal Lands Highway Division, Upper Hoh River Road Bank Failure Risk
Reduction Study. September 12, 2013.
Attachment A
Upper Hoh River Bank Failure Risk Reduction Study