I am writing to oppose the MDNS finding and approval of the RUE for this parcel and proposal, for the following reasons:

1. I believe the SEPA application is incomplete. In particular, Section D, questions 1, 2, and 4 are especially pertinent to this proposal to build a structure very close to Lyon Creek. Lyon Creek is a functioning wildlife corridor. Construction in this corridor will increase stormwater impacts to Lyon Creek and affect plants and animals using this wildlife corridor.

2. The project as a whole is proposed to take place in an environmentally sensitive Critical Area, the buffer of Lyon Creek, with steep slopes and saturated soils. More detailed, careful analysis of the proposed project than was provided is needed to correctly determine the impact of this project on the site and on Lyon Creek.

3. The MDNS relies, among other things, on a 10-year stewardship and monitoring plan for buffer mitigation, in a critical area easement, AKA a Native Growth Protection Area or NGPA. While that looks good on paper, the reality is that ongoing stewardship of NGPA's is non-existent, and there is no enforcement effort by jurisdictions. It may sound nice but it will not happen, and the disturbance will result in a rapid overtaking of the NGPA by invasive, non-native plants, negatively impacting the site.

4. Development of this site is not advisable based on its steep slopes and proximity to an important creek. Unfortunately the City seemingly finds itself in the position with its RUE of having to approve some development on any parcel purchased by a developer, whether it makes sense or not. But, the City does have the opportunity via SEPA review to determine that development on this site is not "reasonable".

Thank you for considering my comments.

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Eric Adman
Sno-King Watershed Council
www.snokingwatershedcouncil.org