10- St Helens SERP 4 Cross Compliance Memo.pdf

Date: 8/26/2024

To: Rebecca Kramer, Project Officer, Clean Water SRF, Oregon DEQ

From: Julie Wirth-McGee, Senior Environmental Specialist

Allison Law, Natural Resource Specialist

Project Name: St. Helens Wastewater Collection System Capacity Improvements Project

AKS Job No.: 10363-04

Project Site: St. Helens, Oregon

Subject: SERP Compliance Memorandum

AKS Engineering & Forestry, LLC (AKS) is working with Consor and the City of St. Helens (City) to help design and permit the proposed Wastewater System Capacity Improvements Project (hereinafter referred to as the Project). The City plans to upgrade and increase the functional capacity of the wastewater management system and has received funding from the Oregon Department of Environmental Quality’s

(DEQ) Clean Water State Revolving Fund (SRF). As part of the funding approval, the City is required to complete the State Environmental Review Process (SERP) to address the environmental impacts of the

Project early in the planning process. This includes complying with applicable environmental laws, consulting with appropriate environmental agencies, and incorporating any required mitigation measures. AKS has been tasked with helping the City navigate the SERP by completing all required documentation as outlined in DEQ’s Applicant Guide to the State Environmental Review Process (SERP

Applicant Guide)1.

The purpose of this SERP Compliance Memorandum is to demonstrate the Project’s compliance with the following federal cross-cutting authorities.

Farmland Protection Policy Act (1981)

Coastal Zone Management Act (1972)

Wild and Scenic Rivers Act (1968)

Safe Drinking Water Act (1974)

After thorough examination, it was determined that due to the location of the proposed Project, it will not result in adverse impacts to these resources, as discussed in further detail below. Documentation showing the Project’s compliance with all remaining federal cross-cutting authorities will be submitted to

DEQ under separate cover.

Farmland Protection Policy Act This federal cross-cutter protects the nation’s productive farmland, and may apply if a project converts farmland to another purpose. The Project area is within the incorporated city limits of St. Helens (Exhibit

1 DEQ. 2022. Applicant Guide to the State Environmental Review Process. Portland (OR): Oregon Department of Environmental Quality. Available at: https://www.oregon.gov/deq/FilterDocs/SERPApplicantGuide.pdf

SERP Compliance Memorandum St. Helens Wastewater Collection System Capacity Improvements Project

August 2024

1) and, therefore, fulfills the criteria in Section 4.4, Step 1.2 of the SERP Applicant Guide. No further consultation to demonstrate the Project’s compliance with this cross-cutter is needed, because the

Project’s location is within the city limits of St. Helens.

Coastal Zone Management Act This federal cross-cutter protects the nation’s coastal areas and applies to projects in counties adjacent to the Pacific Ocean. The Project area boundary lies approximately 10 miles east of the geographical area subject to the Coastal Zone Management Act, as shown in Exhibit 2. Therefore, according to the SERP

Applicant Guide Section 4.5.2, no further consultation is necessary since the Project boundary lies outside of the Coastal Management Zone.

Wild and Scenic Rivers Act This federal cross-cutter protects the character of designated rivers as well as basins of wild and scenic rivers. After reviewing the National Wild and Scenic Rivers System, it was determined the Project is not located within a designated wild and scenic river basin, as shown in Exhibit 3. The closest scenic rivers are the Clackamas River, Eagle Creek, and Salmon River to the southeast and the Nestucca River and Walker

Creek to the southwest, all of which are more than 30 miles from the Project site. According to the SERP

Applicant Guide Section 4.6, Step 2, no further consultation is needed to demonstrate the Project’s compliance with this cross-cutter because the Project lies outside of designated wild and scenic river basins.

Safe Drinking Water This federal cross-cutter protects sole source drinking water aquifers and may apply if the project is located near a sole source aquifer. Although a portion of the Project area is within ±1 mile of the closest sole source aquifer boundary (Troutdale Aquifer System Area SSA), it is not within the mapped aquifer area boundary shown in Exhibit 4 and is separated by the Columbia River. Of note, this aquifer is the only one in the state of Oregon with most of the aquifer located in the state of Washington. Per early coordination with DEQ staff on this cross-cutter, though the Project is located near this aquifer, it is not considered in the vicinity of the aquifer for SRF purposes. Therefore, this Project meets the criteria specified in Section 4.4, Step 3, of the SERP Applicant Guide and requires no further consultation to demonstrate the Project’s compliance with this cross-cutter, because it is not located near a sole source aquifer.

Exhibits

PROJECT AREA

CITY LIMITS MAP 1

SERP COMPLIANCE MEMORANDUM

APPROXIMATE

OREGON COASTAL ZONE MAP 2

NATIONAL WILD AND SCENIC RIVERS MAP 3

SAFE DRINKING WATER SOLE SOURCE AQUIFER MAP 4