PA 10-WA-CLARK-POV-LL-77
             United States
             Environmental Protection
             Agency
Region 10
1300 £!jttfe,
Seattle WA 98101
Alaska
Idaho
Oregon
Washington
             Water
July 1978
EPA 910/9-77-046
             Environmental
             Impact Statement

             Vancouver Lake
             Reclamation Study
             Port of Vancouver
             Clark County
             Washington
            Final

                          .


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 FINAL ENVIRONMENTAL IMPACT STATEMENT

                  FOR

   VANCOUVER LAKE RECLAMATION STUDY
          PORT OF VANCOUVER
       CLARK COUNTY, WASHINGTON
      EPA-10-WA-CLARK-POV-CL-77
             Prepared By

U.  S.  Environmental Protection Agency
               Region X
      Seattle, Washington  98101
     With Technical Assistance By

           Wilsey and Ham
          222 S. W. Harrison
       Portland, Oregon  97201
                         RESPONSIBLE-OFFICIAL:
                            laid r Dubois
                         Regional Administrator
                         Date

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                             PREFACE
On November 4, 1977, EPA released to the public a draft EIS on a
project proposed by the Port of Vancouver for the rehabilitation and
restoration of Vancouver Lake.  The EPA action requiring this EIS is
the approval of grant funds pursuant to Section 314 of Public Law
92-500 for the restoration of publicly owned freshwater lakes.  During
the public comment period, 15 letters were received from Federal, state
and local agencies, and private individuals and groups.  These letters,
and EPA's response, are included in this document in a new Section IV,
Comments and Responses to the Draft EIS.  Where required, changes
have also been made to the body of the EIS.  In addition, EPA held a
public hearing on December 6, 1977 for the purpose of receiving oral
testimony from concerned citizens.  A summary of the hearing can be
found on page 87.

During the response period, significant concerns were raised by the
Department of the Interior, Corps of Engineers and State of Washington
Department of Game and Fisheries.  EPA shares many of their concerns
and has used the time since receipt of their comments to explore with
the agencies and the Port of Vancouver ways of resolving those concerns.
During the various meetings and discussions with these agencies, it
became apparent that many of the critical concerns can not be addressed
without preparation of a detailed operational plan.  As a result, EPA
has decided that the most appropriate approach in this case would be
to approve the project with grant conditions.  These grant conditions,
some of which follow this Preface, contain decisions which will provide
the basis for development of an operational plan.  It is expected that
during the preparation of the operational plan, the final grant
conditions governing construction and operation of this project will
be developed.  No construction funds will be released until EPA
approves the operational plan.  The operational plan will address a
variety of issues associated with the actual dredging and disposal
procedures, including mitigation measures.  It will also evaluate the
design and operation of the proposed flushing channel and other issues
raised by various Federal and State agencies.  Permits, easements or
other rights-of-way necessary for construction of this project will
also be obtained while the operational plan is under preparation.
This will ensure that a/iy special conditions required by such permits
will be integrated into the development of the operational plan.

Upon approval of the operational plan, EPA will make available to the
Port of Vancouver the Federal share of the funds needed to construct
the project to the level of 9 million cubic yards (mcy) of dredging.
Nine mcy is within alternative 2B, 8-12 mcy, discussed in the EIS.
EPA's decision is based on the water quality benefits which could be
expected to occur from implementing this alternative.  It cannot be
shown at this time that dredging more than 9 mcy would provide signi-
ficant additional water quality benefits that would outweigh the
dredging and spoil disposal impacts of a larger project.

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The following discussion summarizes the major concerns of EPA and the
public and private entities which commented on the EIS.  Certain of
the decisions discussed in the following paragraphs will be incorporated
into the grant conditions required for approval of this project.  Those
grant conditions pertinent to this discussion are listed at the end of
the Preface.

One of the major issues raised is the protection of wetland habitat
areas.  At the time of the Draft EIS, EPA had not completed its Wetland
Habitat Evaluation study.  A summary of this study is included in
Appendix A of this document and is available for review at Region X,
EPA offices in Seattle, Washington and EPA's Oregon Operations Office,
522 S. W. 5th Ave., Yeon Bldg., 2nd Floor, Portland, Oregon 97204.
As a result of this study and consultation with other agencies, EPA
has decided to eliminate Site  Va  as a disposal site.  The extent to
which Site Vb could be utilized should be evaluated during the opera-
tional plan.  In addition, at this time, Site VI could only be utilized
to the extent possible under Alternative 7 of the Corps of Engineers
proposed diking project.  Alternative 7 would not cut off the Mulligan
Slough area, nor would it encroach upon the habitat of the Columbia River
Willow or Wapato, two species that are on the State list of rare,
endangered or threatened species (Willow) or the Smithsonian list of
rare, endangered or threatened species (Wapato).  The Corps of Engineers
is currently preparing an EIS on this project.  Final decisions on
Site VI will take into consideration the Corps EIS.  Mulligan Slough
will not be utilized as a spoil site in EPA's project, nor will the
islands at the north end of the lake be disturbed.  EPA will also
ensure that all practicable measures are taken to protect these areas
from construction related impacts.  Under no conditions will areas
containing rare or endangered habitat species be used for dredge
disposal purposes.  In general, dredge spoils will be disposed of in
such a manner, location and depth as to result in minimum loss to
valuable habitat and to provide maximum opportunity for habitat
mitigation and restoration of the aesthetic quality of the area.

Another major issue raised by various agencies concern the impact of the
flushing channel on the anadromous fishery resource.  There is insufficient
data at this time to determine the impacts as the design of the flushing
channel will be part of the operational plan.  The fisheries agencies
have agreed to work with EPA and the Port of Vancouver to determine the
most appropriate design and mitigation measures for this structure.

Several comments were received concerning the ties between the 208
Water Quality Management Plan for Burnt Bridge Creek Basin and this
project.  Some of the expected water quality benefits will result from
the implementation of parts of that management plan.  Therefore, EPA
has decided that no construction funds for the rehabilitation project
will be expended until those parts of the 208 Burnt Bridge Creek Basin
plan necessary to improve water quality in Vancouver Lake are implemented.

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EPA believes that the unresolved issues can be resolved and that the
approach discussed above ensures that environmental impacts will be
minimized or mitigated.  Therefore, the final EIS recommends approval
of the project subject to the grant conditions outlined above.
                                 m

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           RECOMMENDED VANCOUVER LAKE GRANT CONDITIONS
1.   No funds shall be expended until such time as permits, permit commit-
ments and/or formal approvals have been applied for to the appropriate
regulatory and management agencies.  No construction shall commence until
such time as all such permits and approvals have been obtained.

2.   No construction funds shall be expended until such time as the Port
of Vancouver has a legal and valid fee simple title or such other estate
or interest in the disposal sites and flushing channel sites of the
project, including necessary easements and rights-of-way sufficient to
assure undisturbed use and possession for the project purposes as stated
in the EIS and operation plan for construction and operation for the
estimated life of the project.

3.   No construction funds shall be expended until the operation plan
is approved by EPA.

4.   The major purpose of lake dredging for which EPA funds are provided
shall be to improve water quality, recreation and aesthetic values in
and around Vancouver Lake.  Dredging may be permitted for the improvement
of swimming areas, boat launching areas, and movement of small boats
throughout the lake.  The amount of material to be removed from the lake
bottom shall be no more than 9 million cubic yards plus maintenance
dredging and shall conform with the bottom configuration needed to
adequately flush the lake.

5.   Dredge spoils shall be disposed in such manner, location, and depth
as to result in minimum loss to valuable habitat and to provide maximum
opportunity for habitat mitigation and restoration of the aesthetic
quality of the area.  Habitats within proposed disposal site Va have
high relative value (see "Wetland Habitat Evaluation," Vancouver Lake,
November, 1977) and therefore this area will not be considered as a
disposal site.  Area VI can only be used to the extent of alternative
7 of the U.S. Army Corps of Engineers diking project.  Under no conditions
shall areas containing rare and endangered habitat species be used for
dredge disposal purposes.

6.   The island located near the outlet of the lake at Lake River (see
Wetland Habitat Evaluation Report, Figure 6) shall be allowed to remain
in its natural condition for the use of Beaver, Raccoon, etc.  Mulligan
Slough shall remain in its present condition.

7.   Dredging and dredge spoiling operations shall be located and scheduled
such that there will be little or no effects on the reproduction and
rearing processes of fish and wildlife and that recreational, agricultural,
commercial, and industrial activities in the affected area may proceed
without undue interruption.

8.   During spoiling operations, dredge spoils shall be handled in such
manner as to minimize the return of suspended sediment back to the lake.

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Such materials shall be placed or otherwise contained such that resilta-
tion upon recession of seasonal high water around the lake will not occur.

9.   The final dredging and dredge disposal plan and an operating/
monitoring plan and design for the flushing channel developed in coopera-
tion with anadromous fisheries management agencies shall be submitted to
the Project Officer for approval.

10.  Dredging and flushing channel construction should be scheduled such
that improvements in water quality can begin at the earliest possible time.

11.  All construction impacts and activities shall be monitored, inspected
and recorded in accordance with project plans and schedules and be
reported in a manner acceptable to the Project Officer.

12.  In compliance with Section 106 of the National Historic Preservation
Act of 1966, the Port of Vancouver will be required to conduct a site
specific archaeological investigation of the affected areas.  This survey
would be submitted to the Advisory Council of Historic Preservation and
the Washington State Historic Preservation Office for review and accep-
tance.  Any mitigating measures recommended by the State Historic Preser-
vation Officer would be considered by the Port of Vancouver and the
Environmental Protection Agency.  Mitigation measures acceptable to all
three parties (State Historic Preservation Officer, EPA, and the Port of
Vancouver) would be adopted and implemented.

In addition, no funds for construction shall be expended until such time
as the following list of recommendations from the 208 Water Quality
Management Plan for Burnt Bridge Creek Basin are implemented:

     a.   Enact ordinances (City of Vancouver & Clark Co.) which require
          that new development provide for control of stormwater run-off
          such that the rate of runoff after development not exceed the
          rate of runoff before development.

     b.   Enact clearing and grading ordinances (City of Vancouver & Clark
          County) which provide for erosion controls during construction.

     c.   Enact ordinance(s) which prohibits septic tanks in groundwater
          sinks, flood plains, and area with high groundwater tables or
          poor soil or within 200 feet of streams or direct drainage to
          streams.

     d.   Adopt Best Management Practices which include maintenance of
          vegetation buffer areas between streams and cultivated fields
          and which limit high-density livestock access to streams.

     e.   Document significant progress toward implementation of the
          following recommendation:  Require areas with known septic tank
          problems and all existing and new urban density development  (3
          or more d/acre) to connect to sanitary sewers as rapidly ai;

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          possible.   A quarterly report, starting with the first calendar
          quarter of 78, will  be required to document progress.

     f.    Document significant progress toward implementation of effective
          management and funding arrangements for full implementation of
          208 Water Quality Management Plan.  Documentation will be
          provided on a quarterly basis to show progress in attaining
          this goal.

          (1)  Complete "Management Agency Implementation Statements"
               including at a  minimum the information suggested  in the
               September 6, 1977 Federal Register titled "Acceptance
               and Approval of Plans and Designated Management Agencies"
               for all recommended management agencies.

          (2)  Obtain commitments of local  funds for all management
               agencies to initiate recommended actions.

If found to be feasible after  appropriate technical  studies, appropriate
agencies shall as soon as possible, construct and operate first  flush
stormwater diversion facilities at points recommended by 208 plan and
provide  for its treatment.

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                        TABLE OF CONTENTS


PREFACE                                                               i

TABLE OF CONTENTS                                                  vii

LIST OF TABLES                                                        x

LIST OF FIGURES                                                     xi

SUMMARY                                                            xi i

DISTRIBUTION OF FINAL EIS                                         xiii

SECTION I      INTRODUCTION                                           1

     Project Location and Grant Applicant                             1
     Project Objectives and Major Features                            1
     Project History                                                  3
     EPA's Environmental Responsibilities                            4
     Citizen Concerns and Issues                                     4

SECTION II      EXISTING CONDITIONS

     Climate                                                          6
     Air Quality                                                     7
     Topography and Setting                                          7
     Geology                                                         7
     Soils                                                           8
     Hydrology and Flood Hazards                                    10
     Water Quality                                                  14
     Fisheries                                                      23
     Wildlife/Vegetation                                            24
     Significant Wildlife Areas                                     27
     Population Growth and Projections                              29
     Population Characteristics                                     31
     Economic Base                                                  32
     Land Use Plans and Policies                                    33
     Land Ownership                                                 37
     208 Areawide Wastewater Management Plan                        37
     Recreation Plans and Policies                                  33
     Recreation Demand                                              39
     Historical Archaeological Resources                            40

SECTION III    ALTERNATIVES AND THEIR EFFECTS                       42

     Alternative Selection Process                                  42
     Impact Evaluation                                              42
       ALTERNATIVE #1 - NO ACTION
     Air Quality                                                    44
     Topography                                                     44
     Hydrology and Flood Hazard                                     44
     Water Quality                                                  45


                            vii

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              TABLE OF CONTENTS (CONT.)
Fisheries                                                      45
Vegetation/Wildlife                                            45
Significant Wildlife Areas                                     45
Population Growth/Economic Base                                45
Land Use Plans and Policies                                    45
208 Water Quality Planning                                     47
Recreation                                                     47
Archaeological and Historical Resources                        47
Short-Term Resource Use vs. Long-Term Productivity             47
Irreversible and Irretrievable Commitment of
  Resources                                                    47
Mitigating Measures                                            47
  ALTERNATIVE #2 - SCALE OF DEVELOPMENT                        49
  Alternative #2A - Dredging of 12-15 Million
    Cubic Yards                                                55
Air Quality                                                    55
Topography                                                     55
Soils                                                          56
Hydrology and Flood Hazard                                     55
Water Quality                                                  53
Fisheries                                                      55
Vegetation/Wildlife                                            57
Significant Wildlife Areas                                     68
Population Growth/Economic Base                                7Q
Land Use Plans & Policies                                      70
208 Areawide Wastewater Management Program                     70
Recreation                                                     71
Historical and Archaeological Resources                        7j
Mitigating Measures                                            72
Short-Term Resource vs. Long-Term Productivity                 72
Irreversible and Irretrievable Resource
  Commitments                                                  73
  Alternative #2B - Dredging of 8-10 Million Cubic Yards       74
Air Quality                                                    74
Topography                                                     74
Soils                                                          74
Hydrology and Flood Hazards                                    74
Water Quality                                                  74
Fisheries                                                      75
Vegetation/Wildlife                                            75
Significant Wildlife Areas                                     75
208 Areawide Wastewater Management Program                     75
Recreation                                                     75
Archaeological & Historical Resources                          76
Mitigating Measures                                            75
Short-Term Resource vs. Long-Term Productivity                 76
Irreversible and Irretrievable Resource                        76
  Alternative #2C - Dredging of 6 Million Cubic Yards
    and Under                                                  77
Hydrology                                                      77
                      VI 1

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                        TABLE OF CONTENTS


PREFACE                                                              i

TABLE OF CONTENTS                                                  vii

LIST OF TABLES                                                       x

LIST OF FIGURES                                                     xi

SUMMARY                                                            xi i

DISTRIBUTION OF FINAL EIS                                         xiii

SECTION I      INTRODUCTION                                          1

     Project Location and Grant Applicant                            1
     Project Objectives and Major Features                           1
     Project History                                                 3
     EPA's Environmental Responsibilities                            t\
     Citizen Concerns and Issues                                     4

SECTION II      EXISTING CONDITIONS

     Climate                                                         6
     Air Quality                                                     7
     Topography and Setting                                          7
     Geology                                                         7
     Soils                                                           8
     Hydrology and Flood Hazards                                    10
     Water Quality                                                  14
     Fisheries                                                      23
     Wildlife/Vegetation                                            24
     Significant Wildlife Areas                                     27
     Population Growth and Projections                              29
     Population Characteristics                                     31
     Economic Base                                                  32
     Land Use Plans and Policies                                    33
     Land Ownership                                                 37
     208 Areawide Wastewater Management Plan                        37
     Recreation Plans and Policies                                  33
     Recreation Demand                                              39
     Historical Archaeological Resources                            40

SECTION III    ALTERNATIVES AND THEIR EFFECTS                       42

     Alternative Selection Process                                  42
     Impact Evaluation                                              42
       ALTERNATIVE #1 - NO ACTION
     Air Quality                                                    44
     Topography                                                     44
     Hydrology and Flood Hazard                                     44
     Water Quality                                                  45


                            vii

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              TABLE OF CONTENTS (CONT.)
Fisheries                                                      45
Vegetation/Wildlife                                            45
Significant Wildlife Areas                                     45
Population Growth/Economic Base                                45
Land Use Plans and Policies                                    45
208 Water Quality Planning                                     47
Recreation                                                     47
Archaeological and Historical Resources                        47
Short-Term Resource Use vs. Long-Term Productivity             47
Irreversible and Irretrievable Commitment of
  Resources                                                    47
Mitigating Measures                                            47
  ALTERNATIVE #2 - SCALE OF DEVELOPMENT                        49
  Alternative #2A - Dredging of 12-15 Million
    Cubic Yards                                                55
Air Quality                                                    55
Topography                                                     55
Soils                                                          56
Hydrology and Flood Hazard                                     55
Water Quality                                                  53
Fisheries                                                      55
Vegetation/Wildlife                                            57
Significant Wildlife Areas                                     58
Population Growth/Economic Base                                70
Land Use Plans & Policies                                      70
208 Areawide Wastewater Management Program                     70
Recreation                                                     71
Historical and Archaeological Resources                        71
Mitigating Measures                                            72
Short-Term Resource vs. Long-Term Productivity                 72
Irreversible and Irretrievable Resource
  Commitments                                                  73
  Alternative #2B - Dredging of 8-10 Million Cubic Yards       74
Air Quality                                                    74
Topography                                                     74
Soils                                                          74
Hydrology and Flood Hazards                                    74
Water Quality                                                  74
Fisheries                                                      75
Vegetation/Wildlife                                            75
Significant Wildlife Areas                                     75
208 Areawide Wastewater Management Program                     75
Recreation                                                     75
Archaeological & Historical Resources                          76
Mitigating Measures                                            76
Short-Term Resource vs. Long-Term Productivity                 75
Irreversible and Irretrievable Resource                        76
  Alternative #2C - Dredging of 6 Million Cubic Yards
    and Under                                                  77
Hydrology                                                      77
                      vm

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                   TABLE OF CONTENTS  (CONT.)


     Water Quality                                                  77
     Fisheries                                                      77
     Vegetation/Wildlife                                            77
     Significant Wildlife Areas                                     78
     Short-Term Resource vs. Long-Term Productivity                 78
     Irreversible and Irretrievable Resource                        78
       ALTERNATIVE #3 - DISPOSAL MATERIAL PLACEMENT                 79
       Alternative #3A - Land Disposal                              79
       Alternative #3B - Shoreline/In-Water Disposal                81
     Mitigating Measures                                            81
       ALTERNATIVE #4 - DREDGING METHODS                            82
       ALTERNATIVE #5 - DREDGED MATERIAL
                        HANDLING METHODS                            84

SECTION IV COMMENTS AND RESPONSES TO THE DRAFT EIS                  86

PUBLIC HEARING SUMMARY                                              87

FOOTNOTES                                                          127

BIBLIOGRAPHY                                                       132

AGENCY INFORMATION SOURCES                                         137

APPENDIX A                                                         A-l

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                                LIST OF TABLES
Table #     Title                                                           Page  #
  1         Temperature and Precipitation Data for Vancouver Area              6
  2         Soils Characteristics                                              g
  3         Concentrations of Major Ions                                      15
  4         Water Quality Data                                                17
  5         Columbia River Concentrations - Major Ions                        20
  6         Trace Element Concentrations, Columbia River                      22
  7         Population Growth 1960-1970                                       29
  8         Clark County Population Projections                               30
  9         Age Distribution                                                  31
 10         Income Distribution                                               31
 11         Residential Mobility                                              32
 12         Existing Land Use                                              32-33
 13         Land Ownership                                                 36-37
 14         Characteristics of Potential Disposal Sites                       52
 15         Columbia River Nutrient Content                                   62
 16         Phosphorus Loading from Columbia River                            63
 17         Relationship of Mean Depth and Residence Time                     64
 18         Comments Received on Vancouver Lake Draft EIS                  89-90

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                        LIST OF FIGURES

Figure #          Title                             Between Pages
   1              Vicinity Map                           2-3
   2              Topography                             7-8
   3              Soils                                  8-9
   4              Proposed Preliminary Diking
                    Improvements and
                    Existing Floodplains                12-13
   5              Spawning Areas                        18-19
   6              Vegetation                            24-25
   7              Significant Wildlife Areas            28-29
   8              Existing Land Use                     33-34
   9              Vancouver Lake Land Use Plan          34-35
  10              Land Ownership                        36-37
  11              Proposed Recreation Zones             38-39
  12              Dredging and Spoils Disposal
                    Plan                                49-50
  13              Annual Phosporus Loading to
                    Vancouver Lake                      63-64

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                               SUMMARY

               FINAL ENVIRONMENTAL IMPACT STATEMENT

                   VANCOUVER LAKE RESTORATION


1. Type of Statement     Draft ( )      Final (X)

2. Type of Action:     Administrative (X)     Legislative (  )

3. Description of Action:  The EPA administrative action is  the
   award of grant funds to the Port of Vancouver for the rehabilitation
   and restoration of Vancouver Lake.

4. Summary of Impacts:  The project would result in the improvement
   of water quality in Vancouver Lake through construction of a
   flushing channel and dredging in the Lake.  The flushing  channel
   would permit water from the Columbia River to enter Vancouver
   Lake.  Dredging would improve circulation within the lake.
   Disposal of dredge materials constitute the major potential
   for adverse effects.  1 Critical wetland habitats will not be
   used as disposal sites.  Recreational opportunities in Vancouver
   Lake would be enhanced.

5. Alternatives Considered:

            Alternative 1       No Action

            Alternative 2       Scale of Development
                        2A      12-15 Million Cubic Yards of Dredging
                        2B      8-10 Million Cubic Yards of Dredging
                        2C      6 or Less Million Cubic Yards of Dredging

            Alternative 3       Disposal Material Placement
                        3A      Land Disposal
                        3B      Shoreline Disposal
                        3C      Combination of Land and Shoreline Disposal

            Alternative 4       Dredging Methods

            Alternative 5       Dredged Material Handling Methods

6. Comments:  Comments on the draft EIS and EPA's responses  to
   them are included in this document, Section IV.

7. Distribution:  The agencies, groups and individuals on the
   mailing list for this environmental impact statement are attached.

8. Availability:  Date this Final EIS made available to EPA and the
   Public:
                                  xn

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9. Distribution of Final  EIS


                          FEDERAL AGENCIES
   Council on Environmental Quality
   U.S. Department of Agriculture
   U. S. Department of Defense
   U. S. Department of Interior
   U.S. Department of Health, Education and Welfare
   U. S. Department of Housing and Urban Development
   U. S. Department of Transportation
   Federal Energy Office
   National Marine Fisheries Service
   Advisory Council on Historic Preservation
   U. S. Department of the Army
                         MEMBERS OF CONGRESS
   Warren G. Magnuson, U.S. Senate
   Henry M. Jackson, U.S. Senate
                           STATE AGENCIES
   Office of the Governor
   Department of Ecology
   Department of Fisheries
   Department of Natural Resources
   Department of Game
   Department of Social and Health Services
   Department of Commerce & Economic Development
   The State Ecology Commission
   State Parks and Recreation Commission
   State Oceanographic Commission
   State Utility and Transportation Commission
                 LOCAL AGENCIES & INTERESTED GROUPS
   City of Vancouver
   City of Vancouver Public Library
   Port of Vancouver
   Regional  Planning Council of Clark County
   Greater Vancouver Chamber of Commerce
   Clark County Public Works
   Clark County Parks Department
   Port of Richfield

                               xiii

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Diking Improvement District #14
Vancouver Lake Sailing Club
Alcoa
Washington State University
Dames & Moore
National Wildlife Federation
Sierra Club
League of Women Voters
Audubon Society
Southwest Washington Health District
Oregon Bass & Pan Fish Club
                          INDIVIDUALS
John Coop
John DeBenedem
Bob Bottman
Jerry 01 in
Lee Listen
Harley Mays
John Roe
Mr. & Mrs. Donald H. Tilson
Rich Kosterman
John Winther
Ernest Q. Miller - Vancouver Wildlife League
Kit Metlen
Alan Ham
James F. Nelson
Maria A. Shirts
Paul Norman
James R. Meyer
Garland Pittman
Mary Legry - League of Women Voters
Francis J. Mortek
Lloyd H. Kessler
Larry Swatosh
Earl R. Kadow
Don Monbrod
Robert K. Laus
James N. Crane
Gretchen Starke
Kent Anderson
David L. Hickman
John Neel
Nancy Jackson - KVAN
Russ Maynard
Yvonne Viers
H.L. Firestone
Alex Tyrpak
Jim Kosterman
Larry Lange - The Columbian
Glenn H. Hough, P.E.
Norman L. Glenn - DOE
Dept. Natural Resources
Thomas Farr
Merril Firestone
Mary G. Baur
Ernie L. Dyer
Pierre Henrichsen -
  Washington State High Dept.
John Thomas
                             xiv

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SECTION I - INTRODUCTION

Project Location and Grant Applicant

As shown in Figure 1, Vancouver Lake is located adjacent to the City of
Vancouver in southwestern Clark County, within the greater Portland
metropolitan area.  A combination of dredging, flushing and pollution
control measures are being proposed to rehabilitate this 2,600 acre,
eutrophic lake.  Agriculture is the predominant land use adjacent to
the lake although significant recreational  parcels are located on the
west and south shorelines.  Industrial activity occurs south of the
lake, including a large Alcoa plant.  The primary residential  usc-s in the
proximity of the lake occur in conjunction with farming.  Additional
residential areas are located near the southeast corner of the lake and
on high ground along the east shore,

Vancouver Lake drains a watershed of approximately 19,000 acres.   Its
major tributary is Burnt Bridge Creek which enters the lake from the
southeast.  Water from Vancouver Lake flows into Columbia River via Lake
River.  The hydrologic and water quality characteristics of these
waterways are discussed in detail in Section II.

The Port of Vancouver has requested a grant of federal funds to assist
in restoration of the lake as outlined in Section 314 of the Federal
Water Pollution Control Act Amendment of 1972 (PL 92-500).  Section 314
authorizes the Environmental Protection Agency to expend federal  funds
to assist with programs that will restore publicly owned freshwater
lakes.  The Port of Vancouver has requested federal grant assistance to
cover $4,139,000 of the projected $8,278,000 rehabilitation costs.
Additional state funding in the amount of $1,837,500 would be received
through Washington State Department of Ecology's Lake Rehabilitation
Program.  The remainder of the necessary funds would come from local
sources either through direct costs incurred by the Port of Vancouver
or through in-kind contributions from Clark County and Diking Im-
provement District 14.  (A more detailed discussion of project costs
can be found in Section III).  The Port of Vancouver is the imple-
menting agency and would be responsible for project construction
and maintenance.

The restoration of Vancouver Lake has been adopted as a significant
element in the Section 208 Area-Wide Waste Treatment Management planning
program currently being prepared by the Regional Planning Council of
Clark County.  Roughly 30 percent of the total 208 grant is being utilized
for studies to determine the best and most cost effective means to
achieve lake restoration.

Project Objectives and Major Features

Section 314 of the Federal Water Pollution Control Act Amendments of
1972 (PL 92-500) established the Clean Lakes Program, the primary intent
of which is to restore publically owned freshwater lakes which have
experienced historic water quality degradation.  The approach to  the
rehabilitation is defined as twofold:  1) restricting the input of
undesirable materials, and 2) providing in-lake treatment for the removal
or inactivation of undesirable materials.

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The primary objective in the restoration of Vancouver Lake is to improve
the water quality and lake conditions.  Recreation uses of the lake, such
as swimming, fishing, and hunting, will be enhanced by this project.


Gradual pollution and sediment input into Vancouver Lake compounded by
major silt deposition during the 1948 flood, has occurred historically,
to the point that the lake now averages 1 to 4 feet in depth and is
characterized by high levels of bacteriological pollution, excessive
organic and inorganic nutrients, blue-green algae, weeds, sediment, and
other water quality problems.

The grant application prepared by the Port of Vancouver outlines the
following sources of water pollution and sedimentation:

     "Urbanization in the Burnt Bridge Creek drainage basin has sub-
     stantially increased storm water runoff and associated silt loads
     in the creek, which in turn deposits sediments and pollutants in
     the lake.  Subsoils conditions over much of the basin are unsuit-
     able for subsurface disposal of domestic wastewater, so that septic
     tank effluent enters the stream.  Runoff from agricultural crop
     lands into Burnt Bridge Creek also results in a seasonal problem.

     During periods of tidal inflow, the direction of flow in Lake River
     is reversed, and Vancouver Lake serves as a receiving body of water
     for pollutants from dairy farms, crop lands, boat moorages and a
     number of Lake River tributaries.  The largest such tributary is
     Salmon Creek, which carries nutrients and silt load from a develop-
     ing drainage basin characterized by significant agricultural,
     gravel mining and construction activities.

     Non-point waste sources* adjacent to Vancouver Lake consist pre-
     dominantly of runoff from pasture and crop lands.  Drainage from
     roads, railroad facilities, parking lots and lawns may also con-
     tribute pollutants to the lake.  There are no direct municipal,
     storm water or industrial discharges into Vancouver Lake.

     The worst conditions of water quality in Vancouver Lake prevail
     during late summer and early fall, when the potential for water-
     oriented recreation is optimum.  During this low water period, the
     availability of nutrients such as phosphate and nitrates is great
     because of less quantity of water for dilution.  This condition
     coupled with favorable water temperature promotes algae growth,
* Non-point source is defined as a generalized discharge of waste into
a water body which cannot be located as to a specific source.   Conversely,
point source is defined as a specific site from which identifiable and
often measurable quantities of recognizable pollutants derive.

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1 VICINITY MAP

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     which in turn adversely affects other water quality parameters...
     According to the Water Quality Management Plan Summary Report by
     CH2M/Hill (April, 1974), Vancouver Lake does not meet state water
     quality standards and is unacceptable for the following uses:  fish
     and wildlife, drinking, swimming, viewing and boating." (1)

The restoration program recommended by the Grant Applicant has three
major components:  "(1) dredging the lake to remove the most polluted
sediments and enhance recreational use opportunities; (2) construct a
flushing channel to bring Columbia River water into the lake, and (3)
reducing the non-point waste sources which have contributed to the
present water quality degradation." (2)  The applicant believes that all
three efforts are necessary in order to restore the lake's  water quality
and  enhance public recreation use.

Project History

Since the late 1920's, various methods have been proposed for increasing
the use of Vancouver Lake.  Early proposals centered around increased
industrial use of the lake, while later proposals have emphasized recreation
and the necessary water quality improvements to provide an adequate
recreational setting.

In the 1920's local farmers proposed that Vancouver Lake be drained and
used for cropland.  This plan was abandoned, and in 1948 it was proposed
that Vancouver Lake be dredged to a depth that would permit the mothball ing
of Liberty Ships within the lake.  This proposal integrated with Port of
Vancouver desires to use the lake vicinity for industrial purposes and the
Port and Vancouver Chamber of Commerce were the primary agents in support
of that plan.  Recreation was a part of this proposed industrial develop-
ment, but played a secondary role.  In 1966, the Port of Vancouver prepared
a second major development plan for Vancouver Lake which included construction
of a barge channel into the lake and barge loading facilities within the
lake, as well as significant recreation facilities.

In 1968 a new plan for lake use was developed which placed primary emphasis
on recreation use.  Current State of Washington law allows Port authorities
to become involved in recreational facilities only if approved by the
local government having jurisdiction and if consistent with adopted plans
and programs.  Both of these criteria have been met by the 1968 plan,
as revised and currently proposed.

In 1966 the  Port of Vancouver and the Washington Department of Ecology
contracted with Washington State University to prepare a series of water
quality studies for Vancouver Lake and to propose methods for rehabilita-
tion of the  lake.  Since that time, a number of private contracts have
been awarded to study and design various aspects of the proposed restoration
program.

The primary  concern throughout the study and design process has been  the
significant  cost of restoring Vancouver Lake to full public u;e. Even
with the combination of state and  local funds, the necessary financial
resources have not been available at the local level to fully implement
the necessary steps.  When the federal Environmental Protection Agency
was formed,  the Port of Vancouver made initial inquiries into the availability
of federal funding assistance.  Since EPA instituted the Clean Lakes
Program, these efforts have been pursued in earnest.

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 EPA's Environmental  Responsibilities

 The National  Environmental  Policy Act of 1969 (NEPA) Public Law 91-190,
 requires all  federal  agencies to "...utilize a systematic, interdisciplinary
 approach which will  insure  the integrated use of the natural  and social
 sciences and the environmental design arts in planning and in decision
 making which may have an impact on man's environment..."  Section 102
 (2)(c) of that act also requires the agency to prepare an environmental
 impact statement (EIS) on,  "...major federal  actions significantly
 affecting the quality of the human environment..."   This is to be accom-
 plished in consultation with the Council  on Environmental  Quality (CEQ),
 established by Title  II of  the act.

 Through Section 314 of PL 92-500,  EPA has the authority to make grants to
 state or local  public agencies for the restoration  of publically owned
 freshwater lakes.   Concurrent with this authority  is the responsibility
 to assure that federal funds will  produce a project that will  have maximum
 beneficial effects  on the environment and minimum  adverse  effects.

 The public laws quoted above, along  with the  CEQ and EPA regulations,
 constitute the authority and responsibility for  the preparation of
 environmental  impact  statements  on lake restoration programs.

 Citizen Concerns and  Issues

 A variety of  citizen  and special  interest groups have been involved in
 the preparation of the current Vancouver  Lake Restoration  Program.   In
 the early 1970's the  Vancouver Lake  Task  Force was  appointed  by the
 Clark County  Commissioners to prepare  a  specific land use  plan for  the
 project area.   That plan has  been  adopted  by  the county and integrated
 into  the draft  county land use plan  which  is  presently under  review.

 As  part of Clark County  Regional Planning  Council's 208 program efforts,
 a  Vancouver Lake Technical Advisory  Committee was formed to review  and
 comment  on  the  implementation  program.   This  TAC is composed  of local
 agency  personnel, federal and  state  resource  agency personnel,  repre-
 sentatives from the local Park Board,  lake  front property  owners  and
 local business  people.   The  group  meets monthly  to  review  specific
 design  proposals and  has  spent considerable time and  effort on  the
 delineation of  acceptable dredged  spoil disposal areas.  The  Regional
 Planning Council staff feels  that  achieving consensus  among this  group
 on  project features will  insure  general public support  for  the  project.

 Support for the proposed  project appears  to be county-wide and  includes
 a wide variety  of diverse groups including  local business organizations
 as well as recreation   groups.  The Port of  Vancouver  has received
 official project endorsements  from a large  number of  public and civic
 organizations,  and reports that  no one group  has ever publically ex-
 pressed opposition to   the proposal.

 In conjunction with the preparation of this Draft Environmental Statement,
a public information meeting was held  in Vancouver on June 16th.  The
purpose of the meeting was to  review preliminary findings and  to receive

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input from local residents.  Issues which generated the most dis-
cussion at that meeting included:  1) water quality benefits of the
proposed project, 2) cost of construction and maintenance, 3) cost
of providing the recreation facilities, in particular the sailing
course, and 4) the relationship between lake rehabilitation and future
industrial use.
Since publication of the draft EIS, some other concerns and issues
have been raised by Federal and state agencies and local citizens.
These issues are primarily concerned with carrying out the restora-
tion of the lake in the most environmentally sound manner.  Wetlands
protection and impacts on fishery resources were the principle
concerns.  EPA believes these issues can be resolved.  Further
discussions of these, and other, issues raised since publication
of the draft EIS are contained primarily in the Preface to this
document and in the comments section.

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SECTION II.  EXISTING CONDITIONS
Climate

The Vancouver Lake area experiences a predominantly temperate marine
climate, typical of western Washington and northwestern Oregon.  It
is characterized by mild, wet winters and moderately warm, dry summers.
The climate reflects the influence of the Coast Range to the west plus
the Cascade Range and the Columbia River Gorge to the east.   In the
six month period from April through September 25 percent of the total
annual precipitation occurs (see Table 1), while 75 percent of the
precipitation occurs between October and March.

                                TABLE 1

                     Temperature and Precipitation
                        Data for Vancouver Area
Month

January
February
March
April
May
June
July
August
September
October
November
December
  Annual
                    Average
                     Daily
                    Maximum
                  Temperature
44.5<
49.3
55.0
62.8
69.2
73.2
79.8
79.7
75.4
64.
52.
47.
62.7
               Average
                Daily
               Minimum
             Temperature
33.1°F
35.4
38.3
42.4
47.2
51.9
55.1
54.7
51.5
46.0
38.8
36.2
44.2
               Average
                Total
            Precipitation
 5.6
 4.4
 4.0
 2.3
 2.0
 1.9
  .5
  .7
 1.6
 3.6
 5.6
 6.7
39.0
Inc.
                Average
               Snowfal1
5.1  In.
 .8
(4)
(4)
  0
  0
  0
  0
  0
(4)
(4)
(4)
5.9
1.   The annual precipitation was 62.65 inches for the wettest year
       and 25.74 inches for the driest year.  The greatest monthly
       precipitation was 15.04 inches.
2.   The highest temperature on record is 105°F.
3.   The lowest temperature on record is -10°F.
4.   Trace

Source:  Department of Commerce National Oceanographic and Atmospheric
           Administration, 1976.

The average January temperature is 38°F, with an average minimum temperature
of 33°F.  The July average temperature is 67°F, with a maximum daily
average of 80°F.  Total average snowfall for January is 5.1 inches,
while the average yearly snowfall is 8.4 inches.  Annual total precipitation
in the area averages 37 inches.

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Air Quality

The Vancouver Lake area is not specifically monitored for air quality
measurements.  However, there are several stations located to the south
and to the east of the lake.  These stations monitor suspended particulates,
and certain stations in the area have recorded routine ambient air
standards violations.  Primary sources of this type of pollution are
industrial, and Allied Chemical Corporation and the Carborundum Company
have been identified as significant contributors.  Other sources of
suspended particulates are plywood processing, grain handling, and
building activities.  Because of consistent violations of the state and
federal air quality standards, the Southwest Air Pollution Control
Authority (a five county municipal corporation) will closely review any
proposals for expansion within the Vancouver industrial area. All future
development or alteration of industrial  activites in the area must gain
approval from the Air Pollution Control  Authority, to ensure that local
air quality is not further jeoparized.

Other parameters of air pollution, such as carbon monoxide and sulfur
dioxide, are not monitored in the Vancouver Lake area.

Topography and Setting

Vancouver Lake lies to the northwest, and adjacent to, the City of
Vancouver, in the southwestern portion of Clark County,  The lake is
approximately 2,600 acres in surface area, with water depths ranging
between one and four feet.  The lands to the northwest and south are
low-lying flatlands, and subject to seasonal flooding.  The Columbia
River, which flows within one mile of the southwestern shore, has both
tidal and seasonal freshet influence on the lake.  The lowlands lying
between the lake and Columbia River have an elevation of from 10 to 20
feet Mean Sea Level (MSL).  The northeast border of the lake, however,
is characterized by bluffs rising to the Felida-Lakeshore area, with an
average elevation of 200 feet MSL.  (See Figure 2)

The main inflow and main outflow of Vancouver Lake is Lake River, at the
north end of the lake.  Lake River is a slow moving river, experiencing
daily influences of tidal activity from the Columbia River.  Two miles north
(downstream) of the lake, Salmon Creek enters Lake River.  Salmon Creek
drains a watershed that extends beyond Battle Ground to the foothills of the
Cascade Mountains.  Burnt Bridge Creek enters the lake from the east, and is
the only main drainage that flows exclusively into Vancouver Lake.  This
stream drains approximately 17,660 acres of Clark County, for several
miles to the east.

The surrounding lowlands of Vancouver Lake were formed by Columbia River
depositions.  The present location of the lake is believed to have been
the old course of the Columbia.  Most of the low  lying ground is seasonally
flooded, except where dikes now control surface waters.

Geology

Vancouver Lake is believed to have been the old river course of the
Columbia River.  Over the years as the Columbia shifted its course,

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       xtv^r^s
VANCOUVER LA

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substantial deposits of alluvium were left behind.   These alluvial
deposits eventually cut off the lake waters from the main river course,
causing the formation of the current land composed  of mixed sands and
silts.  The Troutdale formation is found to the northeast where the
bluff begins its ascent.  It is a sandstone and conglomerate mix, exposed
almost exclusively along the bluff face. Lying above the Troutdale are
Lacustrine deposits of unconsolidated gravel, sand, silt, and clay, of
detaic origin.  The area south of Burnt Bridge Creek is similar in
origin and nature to the Lacustrine deposits on the bluff, but contain
more substantial gravel components.

Soils

Four principal soil series are represented in the Vancouver Lake area.
The Sauvie soil series predominates in the lands to the west and the
south of the lake, while the Wind River soil series is the principal
soil found south of Burnt Bridge Creek.  In the bluff areas to the
northeast of the lake, the Hillsboro series is the  primary soil type.
Occurrence of the Newberg series is less frequent,  and it is found in
strips along the Columbia River shore.  The general location of each soils
series is mapped on Figure 3.  Map symbols, capability classifications
and slopes are shown on Table 2.

The Sauvie series is the most significant soil group found in the project
area, as it covers the greatest area of land and is the most intensively
formed.  It consists of deep, moderately well drained to poorly drained,
sloping soils.  Formed in river alluvium, the soils are generally loamy
and typical of local bottomlands.  The native vegetation consists of
willows, cottonwoods, ash, and various grasses.  The Sauvie series is
represented by four varieties, ranging in slope from 0 to 8 percent.
All four varieties  (map symbols SpB, SmA, SmB, and  SnA) are considered
to  have high fertility, and a high available water capacity.  Except
when certain soils are wet, tillage is considered easy.  Erosion is
slight, except where the Columbia River floodwaters may scour.  Heavy
winter precipitation, along with spring river freshets, causes a seasonal
high water table.  The soils all have a capability II rating with minor
individual restrictions (see Table 2).  Truck crops, row crops, hay and
pasture are typical uses of these soils.

The Wind River soils series predominates in the Burnt Bridge Creek area,
much of which has been converted from agricultural  to urban uses.  The
soils consist of deep, somewhat excessively drained soils, on nearly  level
to  very steep slopes.  These gravelly soils, of mixed origin, were formed on
Columbia River alluvium.  Permeability is moderately rapid in the upper
part of the soil, but water tends to perch above a depth of 24 inches.
Where the slope is  10 percent or greater, the soil  carries a severe
limitation for septic tank suitability.  Typical native vegetation is
Douglas fir, grand  fir, Oregon white oak, hazel, dogwood, salal and vine
maple.  The soils found in the 0-8 percent slopes  (map symbol WnB) have
the best agricultural capabilities classification  (Hie), and cover the
majority of the Burnt Bridge Creek area.  When  in crop production, the
Wind River series  is used mainly for pasture, tree fruits, nuts, and  row
crops.

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VANCOUVER
  REHABILITATION

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                                TABLE 2

                         SOILS CHARACTERISTICS


                                               Capability
      Soil Name            Map Symbol        Classification

* Sauvie silt loam           Sm A                II w
* Sauvie silt loam           Sm B                II e
* Sauvie silt loam,
    sandy substratum         Sn A                II w               0-3%
* Sauvie silty clay loam     Sp B                II w               0-8%

* Hillsboro loam             HI B                II e               3-8%
  Hillsboro loam             HI E                IV e               20-30%
  Hillsboro loam             HI F                VI e               30-50%
* Hillsboro silt loam        Ho A                 I                 0-3
* Hillsboro silt loam        Ho B                He               3-8
  Hillsboro silt loam        Ho C                III e              8-15
  Hillsboro silt loam        Ho D                III e              15-20
  Hillsboro silt loam        Ho E                IV e               20-30
  Hillsboro silt loam        Ho G                VI e               30-65

  Wind River sandy loam      Wn B                III e              0-8
  Wind River sandy loam      Wn D                IV e               8-20
  Wind River sandy loam      Wn G                VI e               30-65
                             Nb A
* Newberg silt loam          Nb B                 I                 0-3
* Newberg silt loam                              II e               3-8

  Cove silty clay loam       Cv A                 V w               0-3

  Gee silt loam              Ge B                III e              0-8

  Lauren gravelly loam       Lg B                III e              0-8

  Odne silt loam             Oa B                IV w               0-5

  Pilchuck fine sand         Ph B                VI s               0-8

  Fill land                  Fn                  VIII w

  Riverwash (sandy)          Ra

  Rough broken land          Ro
* Considered a Prime Agricultural Soil by the Soil Conservation Service.

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The Newberg soil series is located in bands along the Columbia River
shoreline (see Soils Map, NbA and NbB).  It consists of deep, well-
drained loamy soils that have developed mainly in recent river alluvium.
Located on the floodplains, the slope range is from 0 to 8 percent.
Available water capacity and fertility are high, and there is no erosion
hazard.  The soils have a good agricultural capabilities rating, and
typically produce truck crops, row crops,  hay and pasture.

The Hillsboro soil series covers almost the entire area above the bluff
to the northeast of the lake.  The soils consist of well-drained, deep
soils on terraces formed atop old Columbia River alluvium.  This medium-
textured soils type is among the most productive soils found in Clark
County.  The native floral groups representative of the Hillsboro series
are Douglas fir, grand fir, big leaf maple, dogwood, salal, Oregon grape
and vine maple.  When cultivated, typical crops are pole beans, straw-
berries, sweet corn, cucumbers, and other truck crops, as well as hay
and pasture.  The Hillsboro varieties range considerably in capability
classification (see Table 2), primarily due to slope.

Other soils occurring within the project area are scattered and found
only on small parcels.  They are represented on Figure 3 and their
agricultural capabilities and restrictions are designated in Table 2.

Soils associations and series are rated for generalized agricultural
capability on a scale from Class I to Class VIII.  Class I soils have
few limitations which would restrict their use for agricultural purposes
and are considered to be the most productive soils for crop growing.
Class VIII soils and land forms have limitations that preclude their use
for the growing of any cultivated plants and restrict their use to
recreation, wildlife, water supply or aesthetic purposes.  Classes II
through VII are gradations between those two extremes.  Capability
subclasses are defined as follows and designated on Table 2.

     E -  indicates that the main limitation is risk of erosion unless close-
          growing plant cover is maintained,

     W - indicates that water in or on the soil interferes with plant growth
          or cultivation.

     S - indicates that the soil is limited mainly because it is shallow,
          droughty or stoney.

Within the project area, the majority of the soils fall within capability
Classes II and III.

All soils that drain well, and are on 8% slopes or less, are considered
prime agricultural farmlands in the Vancouver Lake area.  In particular,
all Newberg soils, and all Sauvie and Hillsboro soils with 8% slope or
less have been designated prime farmland soils.

Hydrology and Flood Hazards

     Vancouver Lake

Vancouver Lake covers approximately 2,600  acres and drains a watershed
encompassing about 19,000 acres.  The average shoreline length is about


                                  10

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eight miles.  Along the northeastern shoreline of the lake are high
bluffs which have been developed for residences.  The western shoreline
parallels Columbia River and is separated from the river L>y marshy or
sandy lowlands.  The southern edge of the lake is adjacent to a marshy
area known as Mulligan Slough which appears to have once been a channel
connecting the lake to Columbia River.

The only significant influent stream (other than Lake River during a reversed
flow) into Vancouver Lake is Burnt Bridge Creek, with a mean annual flow
of 20 cubic feet per second (cfs) (3).  Smaller streams that act as
tributaries to Burnt Bridge Creek are Whipple Creek and Flume Creek.  One
very small stream that inflows to Vancouver Lake is Chicken Creek.  The
lake empties into the Columbia River via Lake River.  The reversed flow
of Lake River during tide fluctuations brings significant volumes of water
into Vancouver Lake, both from the Columbia River and Salmon Creek.

The level of Vancouver Lake is determined principally by the level of
the Columbia River, and the mean depth of the lake varies accordingly.
During much of the year (August through April) the mean depth of the
lake is between 3 and 4 feet (4 ).  During this time, the volume of the
lake is approximately 3 x 10^  cubic feet.  Beginning in April, the level
of the Columbia normally begins to rise sharply as a result of upstream
snowmelt. Because the level of the lake is tied to the level of the
river, there is a corresponding increase in the level of the lake, which
reaches a maximum mean depth of about 12 feet in early summer (5 ).  At
this time the volume of the lake is about 12 x 10° cubic feet, or about
four times the volume at minimum level.  During April, May and June, the
flow of Lake River is reversed, bringing a significant amount of Columbia
River water into the lake.  During this reverse flow phase, net inflow
into the lake from the Columbia has been observed to be as high as 200
cfs (6).  In July, August, and September, the level of the Columbia River
falls, and there is a corresponding drop in the level of Vancouver Lake.
At this time, discharge from the lake via Lake River has been observed
to be as high as 150 cfs (7 ).  From late August through April, the level
of the lake is relatively constant, and there is little net flow from
the lake to or from the Columbia.  In summary, under average conditions,
the Columbia River and Vancouver Lake are at a minimum stand during
September and October (less than 6 feet above mean sea level) and at a
maximum during May, June and July (exceeding 12 feet above mean sea
level).  (8).  Clearly, the mean depth of the lake varies directly with
the variation in lake level.  During much of the year (August through
April) the mean depth of the lake is between 3 and 4 feet. (9 ).  The
mean depth of the lake increases with the spring runoff in Columbia River
to a maximum of about 12 feet in early summer.

In addition to seasonal changes in the level of Vancouver Lake, there is
a detectable tidal influence on the level of the lake.  During late
summer and fall (i.e., periods of low flow) the level of the Columbia
River at Vancouver rises and falls as much as two-three feet under the
influence of the Pacific tides.  A tidal variation in the Columbia River
of 2 feet will produce a change in elevation in Vancouver Lake of  1 to
2 inches (10).  A change in mean depth of this magnitude is itself of little
consequence to limnological conditions in the lake; however, these
elevation changes in the lake level imply that Columbia River and Salmon
Creek water are entering Vancouver Lake on rising tides.  Thus, the water
quality in the lake is influenced even though there is little net flow
to or from the lake.


                                   11

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The amount of groundwater flowing to or from Vancouver Lake has not
been documented, although the net groundwater flow to the lake has been
estimated at an annual rate of 20 cfs. (11).  Well water resources in the
Vancouver Lake area appear to be substantial.  Several wells have been
drilled in the north and east areas of Vancouver Lake, with production
ranging from 20 gallons per minute (gpm) to several hundred gpm.  The
range in individual well production is usually due to limited needs for
water (typically domestic or irrigation needs), rather than due to a
lack of water availability south of the lake.  Alcoa Aluminum has established
several wells for industrial purposes and the production of some of these
wells exceeds 3,000 gpm.  West of Vancouver Lake only a few wells have
been drilled and their production ranges between 22 and 750 gpm 02).  Due
to the projected groundwater reserves available around Vancouver Lake,
sufficient supply is considered available for large production of water
resources (13).

In summary, the hydrology of Vancouver Lake consists of two distinct
phases.  During one phase, from August through April, the lake is very
shallow.  During this phase the lake receives water from Burnt Bridge
Creek and other smaller tributaries, and on rising tides from Columbia
River and Salmon Creek.  On a falling tide, flow is out of the lake via
Lake River to the Columbia. During the second phase, from April through
July, the lake level first rises continuously with the rising level of
the Columbia River, and then falls steadily back to a low level in
August.  During April, May, and early June, Columbia River water enters
the lake via Lake River until the volume of the water in the lake has
increased about four fold.  In June the level of the Columbia River
begins to fall, and the lake discharges to Columbia River, falling to
a very shallow level by August.

Due to the influence of Columbia River, Vancouver Lake and Lake River
frequently flood, inundating land along the southern and western lake
shoreline, as well  as land along the western and pastern shore of Lake River.
A partial system of dikes and levees was constructed in the past, but the
Corps of Engineers does not have current data on their functioning and
flood control capability.  The spring-summer flood season in the Vancouver
Lake area reaches the 14 foot contour line on an average yearly basis,
while the fall-winter season reaches the 13.5 contour levels annually.
These Corps of Engineers flood contours would indicate that approximately
2,700 acres of land around the lake experience some degree of annual
flooding.  Every five years the spring-summer seasonal floods reach an
average contour of 18 feet, while the fall-winter flood season reaches the
16 foot contour level.  This represents approximately 3,500 acres of
land which may be vulnerable to inundation every five years.  The above
figures do not estimate the extent to which those lands susceptible to
flooding are protected by the existing dike and levee system.  The existing
levee system was originally constructed to a height of 24-25 feet.  The
Corps of Engineers has indicated that the levees are now considered to
be functional to an elevation of 16 feet, although they have not prepared
estimates of the number of acres that are not flooded as a result of this
levee placement.

The floodplain for Vancouver Lake surroundings is shown in Figure 4.
                                    12

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                                   KINGf
                                   PROV
                                  &FL
                                 '  \_ X Ibp, -TIEAfl FLOty:
VANCOUVER
  REHABILITATION

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Additional diking improvements within Diking District 14 were first proposed
in 1950, and the project has been reviewed intermittently since then.  Most
recently the Corps has been assessing 13 different alternative levee
improvements.  Of those, one alternative (as shown in Figure 4) has appeared
to be the most economically feasible and environmentally practical.  The
levee currently being planned involves two new pump stations and the diking
of up to 3,900 acres.  Specific construction plans and detailed assessments
will be addressed in the draft environmental impact statement which is
presently being prepared.

     Burnt Bridge Creek

Burnt Bridge Creek flows from east to west through commercial and sub-
urban sections of Vancouver, beginning at about N.E. 162nd Street and
emptying into Vancouver Lake.  It drains an area of approximately 27
square miles.  A tributary of Burnt Bridge Creek, Cold Creek, drains a
more rural area north of Vancouver and joins Burnt Bridge Creek near
Vancouver Lake.  Mean annual stream flow is about 20 cfs, but much
higher flows are observed during storms (14).  For example, peak flows
in May, 1976 measured 48 cfs (15).  Because of the extensive urbanization
of the basin, storm runoff is much more rapid than would be the case
under normal conditions.  Burnt Bridge Creek flows are usually 3 to
10 cfs.

The floodplain for Burnt Bridge Creek is shown in Figure 4.

     Columbia River

The Columbia River is the ninth longest river in North America and
experiences an average annual flow at Vancouver of 201,800 cfs.  The
volume is distinctly seasonal, with flows in the late fall as low
as 49,400 cfs, increasing in the spring when snow melt can cause flows
as great as 649,200 cfs.

Because of the variation in flow, there is a considerable seasonal
difference in the level of the river at Vancouver.  Maximum river stage
averages more than 15 feet above mean sea level, while in August river
stage falls to +2 to +6 feet above mean sea level.  Tidal influences are
greatest during low flow months.  Average values of the tidal fluctuation
in the Columbia River are as much as 2.25 feet in August (17).

     Lake River

Lake River connects Vancouver Lake with Columbia River.  The average
depth of the river is 16 feet in July when the level of the Columbia is
high because of spring runoff.  During much of the year, the average
depth of Lake River  is only 3 feet.  Due to tidal effects, a delta
has developed from Lake River into Vancouver Lake.  This tidal flat at
the entrance to Lake River usually prevents Vancouver Lake from dropping
below a surface elevation of 4 feet above mean sea level (18).

The volume and direction of flow of Lake River is directly related to
seasonal and tidal changes in the stage of the Columbia River.  During
April and May, the level of the Columbia River rises sharply with spring
runoff, and during this time Columbia River water flows through Lake
River into Vancouver Lake.  During this phase, flows reach 200 cfs into
Vancouver Lake.   In June and July the level of the Columbia River begins
                                   13

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to fall quickly and the direction of flow in Lake River reverses to
discharge from the lake into the Columbia.   At this time, from late June
to mid-September, net outflow falls from about 150 cfs to less than 50
cfs (19).

During much of the year, approximately August through March,  the level
of Vancouver Lake is at its minimum, so that the direction of flow in
Lake River is influenced by Pacific tides.   On rising tides,  water from
the Columbia River flows into Vancouver Lake and on falling tides it
flows from Vancouver Lake into the Columbia River.

Tlie extent of Corps floodplain mapping for Lake River is shown in Figuro 4

Water Qua!ity

     Vancouver Lake

Because of its extremely shallow depth, Vancouver Lake does not stratify
and the temperature of the lake is generally determined by ambient weather
conditions.  Winter temperatures as low as 4°C. (39°F.) and summer
temperatures as high as 26°C. (79°F) have been observed (21).

Due to the shallowness of the lake and the lack of stratification, fine
bottom sediments are resuspended into the lake by wind induced turbulence.
When the  lake is very shallow, boats also cause noticeable turbidity
while plankton cause additional turbidity in the summer months (22).
Turbidity has been observed to range from 4 to 70 Jackson Turbidity
Units.

     o Major Ions

The concentrations of major ions (Na+, K+, Ca++, Mg++, C1-, S04, HCOo) in
Vancouver Lake are low to moderate.  The available data indicate that
the water of Vancouver Lake is more diluted than the average for North
American  rivers (23).  The total concentrations of all ions, and the
relative  concentrations of individual ions, imply that the minerals dissolved
in the lake stem largely from atmospheric precipitation, with additional
ions derived from rock weathering (24).

There  is  some evidence that concentrations of major  ions vary seasonally
in response to the hydraulics of the lake.  This evidence  is summarized
in Table 3.

Clearly,  the lake  is more  diluted  in July  and  August,  and  more  concentrated
in December.  Mean  values  reported  for  the  Columbia  River  for chloride  and
bicarbonate  ions are 4.3 mg/1  (ppm) and  26  mg/1  (ppm),  respectively.
Evidently,  the major ion concentrations  in  the lake  in  July  and  August  re-
flect  the  intrusion of  Columbia  River water  into  the lake  during the  late
spring,  while the  higher values  observed  later in  the  year indicate that  the
water  chemistry  is more  dominated  by water  and stagnation  of  the lake  itself.
                                   14

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                                TABLE 3
 July,  1967

 August,  1967

 December,  1967
    CONCENTRATIONS OF MAJOR IONS
                mg/1

        Vancouver Lake

   Cl-                 HC03

2.5-3.5            37-40

2.5 - 4.5            30 - 39
4.5 - 5.0
                 Lake River

              Cl-          HCO

           1.5 - 3.0     33 - 40

           2.0 - 4.0     25 - 35
67 - 120   5.0 - 6.0
                                              71  - 103
 Source:   From  Bhagat and Funk, 1968.


 The range of pH observed in the lake is from 6.7 to 9.3 units.  Higher
 pH values occur when there are algal blooms in the lake, and lower values
 occur in the winter, reflecting the acid (pH 4.5) rainfall  of the Pacific
 Northwest (26).

     o Metals
Detectable levels of copper, mercury and zinc are present in the sediments
of Vancouver Lake (27).  During the pilot dredge monitoring program
undertaken by Dames and Moore in 1976, sediments were analyzed for seven
trace metals including arsenic, cadmium, chromium, copper, lead, mercury
and zinc.  Of these, only mercury was found in the dredged sediments in
concentrations considered hazardous to organisms (greater than 0.05 ug/1).
The atomic absorption method was used by Dames and Moore to detect heavy
metals occurence.
        s done by the Washington btate Department of Ecology on seven fish
from Vancouver Lake revealed that only a carp and a sucker, both bottom
feeders, had detectable levels of mercury (28).   Detection levels were 0.02
micrograms mercury per gram of fish.   No attempt was made to indicate
whether this mercury in the sediments was in the inorganic form or the more
toxic form of methyl mercury.  In one  study undertaken elsewhere, 80 percent
of the mercury in the fish assayed was in the form of methyl mercury; however,
no methylmercury was found in the sediments.  Benthic organisms had 50
percent of the mercury found in their tissues in the form of methylmercury
indicating that the food chain is the manner of uptake of the methylmercury.
Inorganic mercury is converted to methylmercury by bacterial action within
the sediments (29) .

The organic pesticides lindane, aldrin and dieldrin were also found in
the Vancouver Lake sediments (30)-  These pesticides were associated with
the dredged material particulates and have not been reported in fish species.
DDT was detected in the above referenced bioassays, and bioaccumulation
via the food chain was evident.  However, the DDT levels observed were
below the FDA's "Action limit."  (Sample observations reached 0.126 ppm
DDT, while the Action limit has been  established at 5.0 ppm).
                                    15

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     o Nutrients

Inorganic nutrients in Vancouver Lake are rather high and are no doubt an
important ingredient in the high algal productivity observed seasonally in
the lake.  Phosphate has been reported to range from 150 to 1600 ug P04/1
(49 to 552 ug P/l) and nitrate from 20 to 540 ug NOs/1 (4.5 to 122 ug N/l).
Kjeldahl nitrogen values ranged from 280 ug N/l to 8680 ug N/l (31).   Lakes
with more than 30 ug/1 total phosphorus and more than 500 ug/1 total nitrogen
are considered hypereutrophic.  (32).  Clearly, there is sufficent phosphorus
and nitrogen in Vancouver Lake to support extensive algal growth.

For normal growth, plants require 4 to 20 times as much nitrogren as phosphorus
On this basis, there appears to be significantly less inorganic fixed nitrogen
in Vancouver Lake than inorganic phosphorus.  This relative excess of phos-
phate probably favors the development of nitrogen (N2) fixing planktonic algae.

The sources of phosphorus and nitrogen in the lake are from the drainage basin,
and from phosphorus contained in Columbia River water which seasonally enters
the lake.  Additional nitrogen is probably supplied by fixation.  Nitrogen
and phosphorus values reported for Burnt Bridge Creek give an indication of
the significance of the drainage basin in supplying nutrients to the lake.
For Burnt Bridge Creek, total phosphorus values are reported to be from 60
to 170 ug P/l, and total nitrogen (Kjeldahl- N, nitrate=N, nitrite- N, and
ammonia  (NH3) combined) from 800 to 2300 ug N/l (33).  These values are
four times greater than natural background levels, and are characteristic
of watersheds influenced by agricultural activities and urbanization (34).

The phosphorus loading from Burnt Bridge Creek alone is sufficient to supply
the lake with about 0.2 g P/m2/yr.  This level of phosphorus is considered
to be sufficient to cause extensive cultural (human-made) eutrophication of a
lake  (35).  It is believed that additional phosphorus is supplied by other
streams  and assorted non-point sources.

Because  the lake is extremely shallow, sediment supplies of phosphorus must
also  be  considered an active part of the nutrient pool in the lake.  It has
been  shown that much of the phosphorus in the lake sediments may be available
to algae, and there is some evidence that this is the case in Vancouver Lake,
also  (36).

     o Algae

Ths phytoplankton observed in Vancouver Lake are a further indication of
the eutrophic character of the lake.  The diatom species reported
(Fragilaria crotonensis, Stephanodiscus niagarae. Asterionella formosa)
form an  assemblage characteristic of eutrophic waters.  Species of blue-
green algae (Aphanizomenon flos-aquae, Anabaena sp., Oscillatoria  limos.
Spirulina laxa) also indicate eutrophic or hypereutrophic conditions.  Some
blue-green algae including species of Aphanizomenon  and Anabaena are capable
of fixing atmospheric nitrogen  (N2), which probably  contributes  to the
supply of fixed nitrogen in the lake.
                                   16

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                                                TABLE 4
                                         WATER QUALITY DATA
   Parameter

Temperature  °C
pH  Std. units
Turbidity (JTU)
NOTN    mg/1
NO 2-N    mg/1
NH jN    mg/1
Total P  mg/1
Total coliforms
  #/100 ml
  Vancouver Lake
 Ave          Range
            4-26
 7.9        6.7 -  9.3
 33         4-70
          0.005 - 0.12
 0.23     0.05  - 0.52
3000      100,000
Note:  Vancouver Lake Data, Bhagat, 1968.
       Burnt Bridge Creek, KCN-WRE, 1976.
       Columbia River, EPA STORET
   Columbia River
  Ave          Range
  14         4-22
  7.3        6.4 -  8.3
  15         1-29
 0.25       0.01 - 0.60
 0.01       0001 - 0.05
 0.07       0.01 - 0.31
 0.08       0.02 - 0.23
2600         25  - 11600
  Burnt Bridge Cr.
 Ave           Range
 12          2-18
 7.6         6.9 -  8.0
 15          3-70
1.88        0.95 - 3.60
0.02        0.01 - 0.03
0.12        0.05 - 0.38
0.13        0.07 - 0.42
10360       380  - 45000

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The shallowness of Vancouver Lake and the relatively high concentrations
of nutrients indicate that the growth of phytoplankton is not restricted
by nutrient supply.  The relatively high turbidity, from resuspension of
bottom sediments, may tend to reduce algal  growth somewhat by light limita-
tion.  (37).

       Dissolved Oxygen

Dissolved oxygen values have been observed to range from 5.7 to 14.8 mg/1.
Dissolved oxygen reflects the eutrophic conditions and the shallowness of
the lake.  Oxygen concentrations are sometimes well above saturation (e.g.
14.8 mg/1 in August, 1967) probably as a result of photosynthetic production
of oxygen by phytoplankton (38).  At other times, oxygen is less than saturation
(e.g. 5.7 mg/1), presumably because of respiration by algae and bacteria.  (39)
No oxygen values below 5.7 mg/1 have been reported, in spite of the highly
eutrophic conditions of the lake.  The shallowness of the lake prevents
stratification and permits reaeration from the atmosphere.


     o Biochemical Oxygen Demand

The enriched state of the lake is also shown in the BOD values.   BOD
values range from 2.5 to 25 mg/1; which is  quite high for natural  waters
(40).

     o Bacteria

The enriched condition of the lake also provides organic nutrients which
support bacterial growth.  Total bacterial  counts as high as 100,000 per
100 ml have been reported. (41). Ten to 40 percent of the total  coliform bacteria
found in Vancouver Lake were fecal coliforms, indicating the presence of
warm blooded animals, birds, mammals or humans.  Bacteria counts have
been observed to exceed standards set for recreational activities. (42).

     o Fish

Most of the fish in the lake are warm-water species such as large mouth
bass, crappies, bluegills, carp, perch and brown bullheads (see Figure 5
for spawn areas).  Some of the deeper areas have juvenile sturgeon, and adult
sturgeon were reputedly fished from the lake in the past (43).  Coho,
Chinook, cutthroat trout, and steelhead have been found in Vancouver Lake,
all of which presumably use the lake as access to Burnt Bridge Creek (except
Chinook, which don't spawn in that creek).   The warm temperatures of the
lake (20°C+ during summer periods) are not conducive to salmonids and
sturgeon; therefore these species are not found in significant enough numbers
to warrant a fishery.

     o Sediments

Test borings of Vancouver Lake indicate that the sediment on the bottom
of the lake consists of a variety of sediment types, including clay,
silt and sand (45).  Lake sediments, particularly in shallow productive
lakes, often contain significant reservoirs of nutrients such as nitrogen
and phosphorus.  Analysis of shallow cores from Vancouver Lake revealed
measurable quantities of these nutrients with somewhat higher concentrations
in the top six inches of sediment.  Bioassays indicate that some of the
nutrients in this surface sediment are available to algae,  and can
     lat? algal growth (4fj


                             18

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frn i  f *- + •  •
V A
-i

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     Burnt Bridge Creek

The temperature of the water in Burnt Bridge Creek varies seasonally.
Temperatures sometimes exceed 20°C (68°F) in July and August, and fall
below 10°C (42°F) during November to March.   The upper reaches of the
stream are unshaded and as a result the water becomes quite warm during
the summers. Seasonal  average temperatures for three years ranged from
7.9 to 9.1°C for winter, 12.3 to 16.2°C for spring, 15.8 to 18.0°C
for summer and 8.0 to  10.8°C for fall.

Turbidity in the stream reflects land use within the drainage basin.
Urban storm water runoff, agricultural  activity and natural fluvial
processes all contribute to the turbidity levels.  Turbidity was observed
from 3 to 70 Jackson Turbidity Units (JTU) during 1975, but ran as high
as 200 JTU during storm runoff in May,  1976 (47).  Total suspended solids
data is not available  for Burnt Bridge  Creek.

Observations indicate  that dissolved oxygen in Burnt Bridge Creek remains
rather high, and is above the minimum required for aquatic organisms.
Concentrations "from a  low of 8.4 mg/1 in August to a high of 14.0 mg/1
during a cold spell in January have been reported (48)-  Observations also
indicate that pH remains within a range acceptable for aquatic life.  In
general, pH in Burnt Bridge Creek is between 6 and 8 units.  Relatively low
pH values measured during 1974 were evidently related to highway construction
(pH 6 to 7) (49).

Inorganic nutrients in Burnt Bridge Creek are considerably higher than
would be observed in a natural stream.   Total phosphorus is highly
variable, ranging from 50 to nearly 1000 ug P/l (50).  Concentrations of
phosphorus are somewhat higher during the winter, perhaps because of septic
tank intrusion, and again in late spring at a time when fertilizers are
applied in the basin (51).  Nitrate (N/l) has been observed in concentrations
from 900 to 2300 ug/1; nitrite from 3 to 20 ug/1; and ammonia from 40 to
180 ug/1 (52).  All of these nutrients  are chronically present at concen-
trations sufficient to support nuisance algal blooms in Burnt Bridge Creek.
In addition, Burnt Bridge Creek is an important source of nutrients to
Vancouver Lake.

Bacterial count data from Burnt Bridge  Creek show a great deal of fluctuation.
Total coliform counts  in Burnt Bridge Creek range from 380 to 45,000/100
ml.  (53).  At the mouth of Burnt Bridge Creek total coliform levels
have been measured from 2,000 to 43,000/100 ml., while fecal coliform counts
have ranged from 700 to 19,000/100 ml.  (54).  The Washington State
Standard for Class AA Watercourses (which includes Burnt Bridge Creek)
is less than 50/100 ml. with less than  10 percent above 230/100 ml. if fecal
contamination is present.  Thus, the bacterial counts in Burnt Bridge Creek
exceed the State standards.  Septic tank intrusion and use of manure
fertilizers in the drainage basin are probable sources of bacteria.

A  biological survey of Burnt Bridge Creek was carried out in March and April
of 1976  (55).  As  part of this survey,  data were collected on the distribution
of benthic organisms, macrophytes and periphyton.  The results of this work
indicate that there is a distinct zonation of organisms in the stream.  In
the upstream reaches, periphyton  is dominated by diatoms.  Species of Melosira
                                    19

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and Navicula were abundant, and species of Fragilaria, Tabellaria, Dlatoma,
Synedra, and Gomphonema were observed.  There were also moderate to heavy
growths of macrophytes in the upstream reaches.  Potomogeton was the dominant
macrophyte.  A wide variety of insect larve were collected in upstream benthic
samples, including some forms (alder-flies and caddisflies) which are charac-
teristic of clean water.

In downstream reaches, there was a distinct shift to more pollution resis-
tent species of periphyton.  Filamentous green algae were more common while
diatoms were less common than in the upstream areas.  Some blue-green algae
were also observed.  Macrophytes were largely absent in downstream reaches and
the benthic organisms collected were forms more resistent to pollution (i.e.
sludge worms.).

The general pattern that appeared is evidence of the cumulative impact of
increasing levels of pollution from point sources and non-point sources on
the downstream reaches.  The change in species present was probably the re-
sult of a moderate degree of nutrient enrichment and possibly the influence
of turbidity or some toxic compounds.  However, nowhere in Burnt Bridge Creek
did there appear to be evidence of heavy pollution by organic or toxic wastes.

Sculpins and trout were observed at various locations throughout the length of
the creek.

      Columbia River

 The concentrations of chemicals in the Columbia River also show considerable
 annual variation.  Conductivity data indicates that there is  a  distinct
 bimodal pattern in the concentrations of the major ions  (56).   Con-
 ductivity is highest in the spring (148 - 208 umhos/cm)  and  fall  (165  -
 200 umhos/cm) and lowest in the winter (71  - 178 umhos/cm)  and  in  the
 summer (100 - 120 umhos/cm) indicating a similar pattern in  the concentrations
 of the major ions.  Alkalinity values show a similar pattern, with
 values of 29.6 to 56.8 ppm (as CaC03) in January,  48.1  to 64.9  ppm  in
 April, 37.7 to 44.3 ppm in June and 55.6 - 67.4 in December.  The  range
 of the major ion concentrations is indicated in the table below:

                                 TABLE 5
                             COLUMBIA RIVER
                        CONCENTRATIONS-MAJOR IONS
                                  mg/1

                     ION                      Mean  Value

                     Ca++                     17.30
                     Mg++                      1.92
                     Na+                       5.71
                     K+                        1.07
                     S04--                    13.08
                     Cl-                       4.29
                     HC03-                    25.97

      Source:   EPA STORET, 1974
                                    20

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The total of these averages indicates a mean salinity of about 70 mg/1,
which is about one half the average for North American rivers (57).

Water temperatures of the Columbia River are distinctly seasonal, with
winter temperatures near 4 C°(39°F) and summer temperatures near 20°C
(68°F).  The average pH of the Columbia is 7.3 units, with a range of
6.4 to 8.3.  The highest pH is observed in the early fall (58).

Suspended sediments in the Columbia River are primarily inorganic,
crystalline material resulting from rock weathering.  At Vancouver,
Washington, the estimated particle size composition of the 1963 total
sediment discharge which reached 6.3 million tons was 35 percent sand,
50 percent silt and 15 percent clay.  The average suspended sediment
content at Vancouver is 25 ppm (59).  This amount is highly variable,
generally increasing with flow and is, therefore, particularly high
during winter floods.   For example, a daily average concentration of
 2660  ppm was measured during the flood of December 25, 1964.  Con-
centrations during the normal low flood of August through October gene-
rally range between 5 ppm and 10 ppm (60).

Nutrients are present in sufficient amounts to support algal growth at
all times.  The range of total phosphorus (P/l) concentrations is from
28 to 231 ug/1, with a mean value of 78 ug/1.  Nitrate is present in
concentrations of 10 to 600 ug N/l, with a mean of 254 ug N/l; and ammonia
is between 5 and 310 ug N/l, with an average of 70 ug N/l (61).  Total phosnhorus
concentrations in lakes of 10 to 30 ug P/l and total nitrogren concentrations
of 500 to 100 ug N/l are sufficient to cause eutrophic conditions (62).
Total phosphorus concentrations above 30 ug P/l give rise to hypereutrophic
conditions.  The inorganic phosphorus concentrations in Columbia River do
not fall below algal requirements at any time (63).

Trace metal concentrations appear to be quite low and well below con-
centrations which could be expected to cause problems to aquatic organisms
(64)

Phytoplankton density in Columbia River varies strongly with the season.
Total cell counts fall below 10 x 10^ cells during winter months, begin
to increase sharply in March and April, and reach a maximum of about 150
x 105 cells/1 in July. Populations decline swiftly in the fall to reach
winter 1ows (65).

Increasing phytoplankton populations are correlated with increases in
discharge, water temperature and incident solar radiation.  The avail-
ability of solar energy is probably the most direct cause of changes in
the phytoplankton density.  The Columbia River is thoroughly mixed from
top to bottom, and, since Secchi disk transparency is only about one
meter, the available light is "diluted" (66).  Since nutrients are
always present in concentrations sufficient to support additional algal
growth, it aooears probable that population densities of algae are
limited by light availability.

Diatoms are the most abundant division of phytoplankton throughout the
year, in terms of number of taxa and, also, in terms of population
densities. Dominant species of diatoms are Asterionella formosj^, Sjte^h_ajiodiscus
a_strea, Me]_os_i_r_a i tal ica, Fragilaria crotenensis, and Melosira ampj
Tnese secies indicate eutrophic conditions  (67).  Most non-diatom

                                   21

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                                       TABLE 6

                           TRACE ELEMENT CONCENTRATIONS
                              COLUMBIA RIVER, ROOM 84
Trace Elements (ug/1)
Arsenic,
Arsenic,
Cadmium,
Cadmium,
Chromium,
Chromium,
Copper,
   Dissolved
   Total
   Dissolved
   Total
    Dissolved
    Total
  Dissolved
Copper, Total
Iron,
Iron,
Lead,
Lead,
Zinc,
Zinc,
Dissolved
Total
Dissolved
Total
Dissolved
Total
Selenium, Dissolved
Mercury, Dissolved
Mercury, Total
                         Mean
1,669.33
     .00
     .00
     .00
     .83
     .50
   13.69
    5.78
  143.15
  605.29
   24.85
   25.97
   68.78
   23.70
   60.00
    1.78
    1.40
Maximum

5,000.00
    5.00
    1.00
    1.00
   35.00
    9.00
  233.00
   10.00
  450.00
2,410.00
  280.00
  100.00
  730.00
   50.00
   60.00
    5.00
    2.70
                                     Minimum
2.
5.
1.
1.
2.
2.
1,
3.
   .00
   .00
   .00
   .00
   ,00
   .00
   .50
   ,50
 50.00
105.00
   .60
   .00
 10.00
 12.00
 60.00
   .60
   .50
2.
2.
Major Ions (mg/1)

Calcium
Sodium
Potassium
                          43.19
                           5.70
                           1.07
                    95.00
                    15.00
                     2.10
                     18.00
                      3.50
                       .50
Source:  EPA STORET, 1974.
                                          22

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species of the phytoplankton belong to the Chrysophyceae and Chlorophyta
(68).  Blue-green algae were most common in the late summer and fall,
but were never very abundant.

Changes in the population densities of zooplankton are quite similar to
changes in phytoplankton.  Populations are low in mid-winter (500 to
100/P3) and increase to maximum values (10,000 - 20,000/m3) in July and
August, and then decline rapidly.  A few taxa dominate the zooplankton.
Common rotifers are Brachionus and Asplanchna, and common cladocerans are
Bosmina and Daphnia.  Remaining zooplankton was mostly cyclopoid copepods (69)

     Lake River

Water quality conditions in Lake River are similar in character to
either the Columbia or to Vancouver Lake depending on the direction of
flow.  In addition, Lake River receives discharge from Salmon Creek.  The
Salmon Creek drainage is predominantly rural  in character, however, there
is some suburban development and a variety of agricultural activities.
Salmon Creek receives nutrient enrichment and bacterial  pollution from
agricultural runoff, boat moorages, septic tank seepage and street
runoff.

At the outlet of Lake River, water quality conditions are similar to
those in the Columbia River.  Turbidity is relatively low.  Algal populations
are predominantly diatoms and temperatures are lower.  At the inlet end
of Lake River, conditions are more similar to Vancouver Lake.   In late
summer, the river contains significant populations of blue-green algae
(Aphanizomenon flos-aquae).  Temperature, turbidity, and bacterial
counts are higher.   In general, water quality is higher when Lake River is
under the influence of the Columbia and poorer when it is under the
influence of Vancouver Lake.

Lake River sediments are predominantly silts and clays near Vancouver
Lake.  Sand content increases downstream, and the sediments are pre-
dominantly sand at the mouth.

Fisheries

Lake Vancouver is a popular fishing area for regional residents, supplying
a considerable resource of spiny rayed (warm water) fishes. Due to the
excessively warm water, salmonids are not recognized residents of the lake,
but are known to migrate up Burnt Bridge Creek.  The spiny rayed fish
are not native to Washington, but have been established in areas such as
Lake Vancouver for many years.

The predominant spiny rayed fishes are the yellow perch,  large mouth
bass, bluegill, brown bullheads, carp, black crappie and the white crappie.
These fishes are found in considerable numbers in the lake, particularly
in Mulligan Slough during spawning season.  The slough area is a prime
spawning location, and draws numerous fishermen into the backwater
sites.  Due to habitat type, Mulligan Slough experiences the heaviest
spawning activity of the spiny rayed fish in the lake since it
offers a preferred aquatic vegetation  and adequately warm temperatures
(above 55 F).  Other spiny-ray spawning areas occur at the mouth of
Burnt Bridge Creek.  Although they have not been specifically identified,


                                   23

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it is believed that a few, smaller spawning areas occur in Lake River
and Mulligan Slough.

Though the numbers of fish in the lake are considerable, recent catches
indicate a lack of full sized fish available.   Most of the fish caught
are somewhat stunted, which is either caused by the low water levels of
recent seasons, or possible over-population of the aquatic environments.
Although toxic substances can cause stunted fish growth, fish exposed to
toxic materials usually show abnormal behavior and/or deformities in
addition to their stunted growth.  Neither of these conditions has been
observed in fish caught in Vancouver Lake.  More likely, the stunted
growth is a result of population pressure, since the fish caught from the
lake are uniform in size per species and appear normal in all other char-
acteristics.  There have been no detailed surveys or studies undertaken
to determine the present, and near future conditions of the fish populations.

Native fish include the sturgeon, trout, and salmon.  Juvenile sturgeon
have been caught in the lake, with an occassional adult occurrence.
These fish are usually found in the deeper areas, such as the Pilot
Dredge Study hole in the southwest corner of the lake.  Trout (cutthroat)
have been netted at the mouth of Burnt Bridge Creek, presumably caught
prior to an upstream spawning run.  Steel head and salmon make native
runs up Burnt Bridge Creek using Lake River and Vancouver Lake as access
routes.

The Washington State Department of Fisheries does not maintain an active
management program  in Vancouver Lake.

Wildlife/Vegetation

The Vancouver Lake  area is primarily comprised of floodplains and agri-
cultural lands, except for the urbanized areas of Burnt Bridge Creek and
areas to the northeast of the lake.  The low-lying lands, however, are
predominantly agricultural and riparian.  Agricultural lands have been
diked off in an effort to inhibit periodic inundation by floodwaters.
Most lands that are not in agricultural use have primarily water related
floral assemblages.  Vegetation communities are shown on Figure 6.

     Agricultural Land

Approximately 5,000 acres of  land  are currently used for the production
of truck crops, row crops, hay and pasture.  Wildlife and natural vegetation
is limited in these areas, as the human controls imposed upon the  land
have greatly restricted the natural  influences and processes.  Mammalian
representatives found in these areas include the insectivores (shrews and
moles), rodents (mice, voles and squirrels), and rabbits.  Field birds
(sparrows and meadow larks), raptors (hawks and owls), and game birds
(pheasant and doves) use the farmlands for feeding.  The field perimeters
provide emergency cover and breeding habitat for fauna where shrubs are
allowed to establish.  Much of the farmlands becomes  inundated by winter
and spring high water, which provides excellent habitat for  great numbers
of migrating waterfowl.  Mallards, pintail, widgeon,  Canada  geese, and
sandhill crane and  whistling swan use flooded fields  for feeding and
loafing purposes through the migration and winter seasons.
                                   24

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     Wetland

The wetlands are found primarily on the south end of Vancouver Lake.
Mulligan Slough, a shallow channel that meanders down to the Lower River
Road dike, is the most extensive wetland in the project area.  Much of it
is under water for parts of the year, fluctuating in water depth according
to precipitation, Columbia River flow, and tidal variations.  Wetlands
exist along the more established channels.  The size and extent of wet-
lands within the Vancouver Lake area have been mapped and discussed
in the Jones and Stokes wetland evaluation study.  A summary of that
report is provided in Appendix A.  The immediate areas surrounding these
freshwater wetlands have thick stands of green ash and willow.  The
Mulligan Slough area is an important water fowl area, since it has a good
food source, and provides excellent protection.  It is used extensively
for breeding and nesting purposes, and is a popular hunting area in
the fall.  Nesting fowl include cinnamon teal, mallards, and woodducks.
Shorebirds using the area include snipe, yellowlegs, and dowitchers.
The protected waters in the slough also act as important spawning
areas for many of the lake fish.  The surrounding willow and ash thickets
make much of the area inaccessible to humans, which further enhances
the area for wildlife.  This area is one of the more important biologic
communities in the project area because of its natural protection and
marshland characteristics.  It is further discussed below in the
Significant Wildlife Areas section.

     Riparian

Riparian biota is very important in the Vancouver Lake area, with healthy
stands occurring at the south and north end of the lake.  Riparian ground
in moist areas is comprised of Oregon ash and willow.  These thickets
are not tall (3-13 feet), but grow in great densities.  They do not harbour
great numbers of fauna, primarily due to their lack of floral diversity.
However, they do act as excellent coverage (for land mammals and birds
feeding on the water), buffer zones (for waterfowl  activity), and
nesting sites (for woodducks and warblers).  Amphibians are found pri-
marily in these zones, including the spotted, tree, and bull frogs and
the northwestern, Pacific giant, and ensatina salamanders.   Reptiles found
in the riparian areas include the racer, garter and gopher snakes, and
the painted turtle.  Mammals using these areas include nutria, bats, raccoons,
and rabbits.  The winged seeds of the ash provide foodstuffs for certain
seedeaters (grosbeaks, etc.), and provide insect feeding conditions for
flycatchers and vireos.  The willow provides food in its bark for mammals
(cottontail squirrel, woodrats, and meadow mice), and insect food for
perching birds much like the ash does.

Cottonwood, another typically riparian tree species, is found in scat-
tered groups throughout the project area.  It is usually located on
drier lands behind the thick belts of willow and ash.  Wild rose, black-
berry, and elderberry are often found in the understory.  Mammal species
are the same as for the willow-ash communities, but the avifauna is more
diversified.  Woodpeckers and towhees, along with the other riparian
species,  readily use these areas.  The raptors and perching birds use the
                                   25

-------
tall cottonwoods for nesting and feeding purposes.  These raptors include
the red-tailed, sharp-skinned, rough-legged hawks, osprey, marsh hawk,
kestrel (American), bald eagle, barn, great-horned, screech and pygmy
owls.  Such prominent perches are especially important to the raptors,
as surrounding open fields and water provide favorable hunting conditions.

     Open Grasslands

Limited areas within the vicinity of Vancouver Lake are characterized by
a grass-scotch broom vegetation community.  These areas typically represent
land that was cleared at one time, but was not maintained for domestic
purposes. Grasses and shrubs have claimed the area, and the land is now
fairly open, inhabited by cottontails, wood rats, voles, and mammals
moving from one eco-type to another.  These areas act as important
feeding grounds for local hawks and owls, and typically harbor local
goldfinches.

     Coniferous Forest

Conifers exist on the northeast bluff of Vancouver Lake.  These trees,
predominantly Douglas fir, have been cut back over the years to what are
now only thin stands of trees.  Found at the edge of the bluff, and
along the short drainages in the immediate area, the trees represent the
basic vegetal community of western Washington.  Other species found in
the community include red cedar, big leaf maple, dogwood, red alder,
thimbleberry, salal, red-flowering current, and various ferns.  Squirrels,
voles, shrews and moles are the usual mammalian residents.  Avifauna
include wrens, kinglets, grosbeaks, thrushes and owls.

No  studies have been conducted to determine the extent of aquatic vege-
tation within Vancouver Lake.  Species, numbers and locations of the
macrophytes and other in-water flora are not presently known.

The Washington State Department of Game manages designated areas within the
project vicinity.  The upland game bird season runs from October 15 to
December 11 and pheasant and chuckar are planted throughout the season,
particularly in the area between Shillapoo Lake and Caterpillar Island.
The rabbit season occurs from mid-October until the end of February and
is quite popular in southwestern Washington.  Duck hunting is extremely
popular around Vancouver Lake and the season extends from mid-October to
early January.  Woodducks and teal are the primary game species and
Vancouver Lake and its associated wetlands are considered to be one of
the best duck production areas in southwest Washington.

     Rare and Endangered Flora and Fauna

Endangered animal species within the Vancouver Lake area include the bald eagle
and the white-tailed deer.  Five to six eagles use the general Sauvies
Island-Vancouver Lake area during the winter and spring seasons.  White-
tailed deer have been sited in the Ridgefield Wildlife Refuge area and
are suspected of ranging as far as Vancouver Lake.  However, populations
and movements of this species are not known.

Peregrine falcons appear in the area during migration, but the specific
species has not been identified.  The southern race (Falco peregrinus)  is
                                   26

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considered to be rare.   Two northern races, the Peale's (Falco peregrinus.
pealei) and the tundra  (Falco peregrinus tundris),  do appear in the general
area regularly during migration and winter seasons.  These races are not
considered to be endangered.   American osprey appear in the area during
spring; a species considered "comparatively rare"  in Washington which is,
therefore, protected.

Rare and endangered plant species of the project area include the Columbia
River willow (Salix fluviatilis) and Wapato (Sagittaria latifolia).
Columbia River willow is included in Washington State's list of rare, endan-
gered or threatened species (Denton, et al., 1977)  and is a candidate for
threatened on the Smithsonian List of Endangered and Threatened Plant
Species of the United States, (1974).  This species of willow occurs at
scattered locations throughout the Mulligan Slough  wetlands and at several
locations west of Mulligan Slough.  Those locations of Columbia River willow
shown on Figure 7 represent sizable thickets of this species.  Wapato is
also in the 1974 Smithsonian list of endangered and threatened plant species.
Wapato occurs at several locations in Mulligan Slough and at the mouth of
Rurnt Bridge Creek (Figure 7) (Jones & Stokes, 1977).

Significant Wildlife Areas

n variety of significant wildlife areas exist within the project area.
Each is mapped on Figure 7 and discussed below.

     o Mulligan's Slough is a particularly important wildlife zone in
the Vancouver Lake area, as it provides essential  habitat for some
important members of the biologic community.  The  extensive channels and
marsh areas that spread down to Lower River Road provide the most important
spawning areas for the  spiny rayed fish that inhabit the lake.  This
habitat offers adequate plant life that supplies protection (cover from
predators) and food (micro-organisms and invertebrates existing in the
plant communities).  The spiny rays (perch, crappie, bass, etc.) often
become stranded in the  channels and ponds as the waters recede, thus
offering a good feeding opportunity to raptors (hawks, osprey), waders
(heron, egrets), and mammals (raccoon). This stranding activity may also
play an integral role in the regulation of the population, as many
adults and juveniles are lost each year to this process.

Important loafing, feeding and nesting areas for waterfowl are available
in Mulligan Slough.  The marsh-related slough flora provides good food
for the pond ducks (mallards, pintails, teal, woodducks and widgeon),
and substantial protection due to the thick willow-ash growths.  Perching
birds (such as warblers, flycatchers, vireos and swallows) find excellent
feeding in such wetlands because of the insect populations produced  in
the warm, still waters.  The extensive willow-ash thickets that surround
the entire wetland area offer excellent over-all protection and substantial
nesting sites.

     o The Shillapoo Lake - Vancouver Lake area provides important
wintering grounds and migration stopover habitat for various waterfowl
and related bird species.  The Shillapoo Lake area  is an old lake bed
which is now in agricultural  use, and is inundated  with water during
nigh water seasons.  This area combined with Vancouver Lake, offers
comparable habitat to that found at Ridgefield Wildlife Refuge to the

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north and Sauvies Island Game Refuge across the Columbia River.  These
three areas are linked together in their role as major stopover grounds
for thousands of migrating birds.  The Vancouver Lake area hosts grebes,
whistling swan, Canada geese, mallard, pintail, widgeon, shoveler, teal,
wood duck, scaup, and bufflehead, among others during various parts of
the migration season.  As Ridgefield Refuge and Sauvie Island experience
heavy hunting on certain days, the Vancouver Lake area provides important
resting sites for weary birds.  The farmlands around Shillapoo Lake
provide good feeding habitat, as local farming activities will often
leave large quantities of foodstuffs available to dabbling and grazing
waterfowl.  The Vancouver Lake area is a popular waterfowl hunting area
for regional residents, and the lake has an open season (no closure days
during the waterfowl season). Due to its size, Lake Vancouver can still
provide adequate resting areas for fowl, given that the numbers of
hunters on the lake at one time is not too great.

 Vancouver Lake also acts  as  an  important feeding ground for great blue
 heron, who use the  lake regularly  and  in significant numbers.  It is
 suspected that these herons  come down  from  the Bachelor Island rookery,
 a  colony of some  500 herons  that nest  as a  group seven miles  to the
 north.   The herons  wade through the shallow waters  preying on fish,
 amphibians, and  invertebrates.  The heron, because of its peculiar habits
 and aversion to  human disturbance, has been used as an indicator species
 for determining  the relative state of  certain eco-systems.  The bird  is
 considered one of the more  significant faunal species found in the
 northwest.

      o A woodduck/teal  nesting  area exists  on the west shore  of Vancouver
 Lake.  The thick  stands of  willow  and  ash,  combined with  the  various
 channels of Buckmire Slough provide good nesting habitat  for  these two
 birds.   They have used the  area for a  number  of years, and presumably
 many of  the birds raised  in the area  return to nest in the same locale.
 Such habitats are declining in  abundance due  to  human disturbance.

      o Just north of the  woodduck/teal nesting area exists a  good songbird
 habitat, where thickets of  willow/ash, and  cottonwood/blackberry mixtures
 provide  a diversified floral  assemblage.  Warblers, vireos, thrushes,
 sparrows, and chickadees  establish themselves  in this area each year,
 making  full use  of the nesting  and feeding  opportunities.  Because so
 much of  the surrounding area is under unnatural  influences, the perching
 birds are heavily dependent upon these small  ecosystems.

      o  Burnt Bridge Creek acts  as  a  spawning  area  not only for  spiny
 rayed fishes, but also for  some salmonids.  The  spiny rayed fishes spawn
 in the  lower reaches of Burnt Bridge  Creek  where the waters are  slow  and
 ample aquatic vegetation  exists.   The salmonids  migrate  up Burnt  Bridge
 Creek to spawn  in the upper areas  of  the  drainage.  Salmonids have been
 caught  in Burnt  Bridge Creek, but  not in  notable numbers.

      o  Sport fishing areas  of significant  popularity  are  designated on the
 Significant Wildlife Areas  Figure  7.   These sites  have  been  identified
 by state and federal agency representatives as  areas  of the  most inten-
 sive recreational fishing usage, exclusive  of boating  areas.
                                 23

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     o  Wetland areas are generally described as areas that are periodically
inundated by water and are characterized by vegetation that requires water
saturation for growth and reproduction.   The Environmental  Protection
Agency has recently contracted a study to identify existing wetlands in
the Vancouver Lake area and to evaluate the habitat value of those wetland
areas   A summary of the Jones and Stokes wetland evaluation study is pro-
vided'in Appendix A.  Wetlands fall within the jurisdiction of Section 404
of the Federal Water Pollution Control Act Amendments of 1972, which requires
the issuance of a permit by the U. S.  Army Corps of Engineers before  the
discharge of dredged or fill material  may occur.  The Environmental Protec-
tion Agency assists the Corps of Engineers in establishing  evaluation cri-
teria and has veto power over projects which would have an  unacceptable
adverse impact on water quality, fisheries, and wildlife resources.  In
addition, Executive Order 11990, dated May 24, 1977 directs each federal
agency to "provide leadership	to minimize the destruction, loss or
degradation of wetlands." (70).

Population Growth and Projections

Clark County  has experienced steady increases in population growth since
the  1940's, marked by periods of rapid growth such as the influx of workers
for  the shipyards during World War II.  As shown in Table 7, the number of
persons residing in Clark County increased by 36.9 percent between 1960
and  1970.  This growth rate has only been exceeded by the war induced im-
migration of  the 1940's.  Historically, Clark County has shared the population
growth of the metropolitan area; however, this growth has been more pro-
nounced since 1965.  As shown in Table 7, Clark County's growth rate of
36.9  percent  for the period from 1960 to 1970 was substantially higher than
the  SMSA growth rate of 22.5 percent.
                                TABLE 7

                      Population Growth 1960-1970
                              (Thousands)

                                                                  Percent
                                                                  Increase
Area           1930      1940      1950      1960      1970      1960-1970
Clark County   40.3      49.9      85.3      93.8      128.5       36.9

Portland
  SMSA*       455.0     501.3     704.8     821.9    1,007.1       22.5
* The Portland SMSA  (Standard Metropolitan Statistical Area) includes
  Multnomah, Clackamas and Washington Counties in Oregon and Clark
  County, Washington.

Source:  CRAG, Economic Indicators, An Annotated Statistical Abstract
          of the Greater Portland-Vancouver Metropolitan Area, 1972.
                                29

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Local planners have reported that the largest proportion of population
growth in Clark County is due to migration.  Between 1960 and 1970, the
county's population increased by about 35,000.  Of that total, approxi-
mately 70 percent is attributed to migration.  (71)

In 1976-77 Clark County Regional Planning Council contracted with Boeing
Computer Services, Inc. to prepare population and employment projections
for the county.  They prepared three different projections based on the
following three methodologies:  Alternative 1 forecasts the population
of Clark County based on employment in the Portland SMSA and a time
trend.  This relationship from 1960 to 1975 explained 99.5 percent of
the movement in Clark County population.  Alternative 2 forecasts the
population of Clark County based on employment in the Portland SMSA and
employment in Clark County.  This relationship from 1960 through 1975
explained 98.8 percent of the movement in Clark County population.


Alternative  3  forecasts future population based on both demographic and
economic activity within the region and Boeing determined that this
forecast represented the median level.  Table 8 shows the resulting
population projections based on each of these methods.

                                TABLE 8

                  Clark County Population Projections
                              (Thousands)

                         1975           1980           1990           2000

Alternative  1            151.3          167.8          203.0          238.4

Alternative  2            149.1          167.7          198.1          227.86

Alternative  3            142.3          166.3          201.4          250.2

Source:  Clark County Regional Planning Council, Clark County Washington
          Employment, Population and Land Use Forecasts, 1977.


The Boeing report discussed a variety of variables which make projecting
Clark County's growth rate difficult, including the current traffic
congestion on  1-5 and the proposed construction of 1-205.  In conclusion
they reported  that:  "Without the announcement of the 1-205 bridge
corridor opening in late 1981 or early 1982, it is quite likely that the
historic growth rate for Clark County would decline as commute times (on
1-5) increased.  However, with the "still cheap" land prices, it is
likely that  the historical relationships will be maintained and the
growth forecast (in Alternative 3) will be realized".  (72)
                                 30

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 Population Characteristics

     Age

 As  illustrated  in Table 9, Clark County population recorded a definite
 shift  towards increasing numbers of young families between 1960 and
 1970.  In  1960,  9.5  percent of the population was between the ages of  20
 to  29  while  by  1970 that number had risen to 14 percent.  The number  of
 small  children  (ages 0 to 9) fell by 2 percent during this period as  a
 result of the declining birth rate.

                                TABLE 9
                           Age Distribution

                                             Percent
                                   1960                1970

 0-9                               21                   19
 10-19                              18                   20
 20-29                              9.5                  14
 30-39                              14                   11
 40-49                              13                   12
 50-59                              10                   11
 60-69                              8.5                   7
 70-over                            6                    6
                                   100$                  i oo;"
                Bureau  r,'  "ensu-,,  1970
     Income
Family income rose markedly between  1969  and  1974  due  to  a  combination
of factors.  As shown on Table 10, the  largest numerical  increase  occurred
in the $15,000 to $24,999 category which  jumped  from 16  percent of the
total population in 1969 to over 30  percent  in 1974.   All categories
under $15,000 declined in percentage in 1974, while  all  categories above
$15,000 increased.  Although a large portion  of  these  increasing  house-
hold incomes must be attributed  to inflation, a  portion  of  this change
is due to the influx of better educated professional and  technical  workers
into Clark County.
                                 TABLE 10
                          Income Distribution

                                                   Percent
                                   1968                          1974

Under 3,000                         8.0                           2 0
3,000-5,999                        12.0                           9.0
6,000-9,999                        28.0                          19 0
10,000-11,999                      15.0                          12 0
12,000-14,999                      18.0                          17.5
15,000-24,999                      16.0                          30.5
25,000-49,999                       2.0                           8.0
50,000 & over                       1.0                           2.0
                                  100.0%                        100.0%
     e.
Housing Market Analysis of Clark County,  Reqiondi  Planning Counci
~~ of Clark County", 1974.
                                 31

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     Mobility

As  shown  in Tab!ell,  little  change  in  residential mobility was  noted  in
Clark  County between  1960  and  1970.  The most  significant shift was a
substantial decrease  in  the  number  of  residents who  had  previously lived
elsewhere in the  Portland  metropolitan area.

                                 TABLE  11
                          Residential Mobility
                              Clark  County
 Residence in 1955
 Same House
 Different House within SMSA
 Different House outside SMSA
 Abroad,  or Moved and Not Reported

 Residence in 1965
 Same House
 Different House within SMSA
 Different House outside SMSA
 Abroad,  or Moved and Not Reported
 Number
 39,303
 30,797
 12,798
  1,060
 83,958

 54,599
 31,596
 21,494
  9.166
1167854
Percent
  46.8
  36.7
  15.2
   1.3
 100.0
  46.8
  27.0
  18.4
   7.8
 100.0
 Source:   Housing Market Analysis of Clark County,  Regional  Planning  Council  of
           Clark County, 1974.

Economic Base

A majority of Clark County's industry is extractive or heavy industry
and is typified by plants with large capital  investments.   Many of
these are clustered around the current Port of Vancouver facilities  or
are located along Columbia River between downtown Vancouver and the  port
docks.  Seventy percent of Vancouver's industrial land is  classified  as
general, while somewhat less than 30 percent of the county's industrial
land is in general usage.  The county has representation from each of
the four industrial classification:  Light (3.0%),  General  (29.5%),
Heavy (32.0%) and Extractive (35.5%) (73).

The Portland SMSA and Clark County both have well diversified industrial
bases which shelter them somewhat from national economic fluctuations, as
reflected by fairly stable unemployment rates in relationship to other
parts of Oregon and Washington.  Economic growth in Clark County has
become more closely tied to growth in the general metropolitan area;
however local business leaders are continuing to work towards increased
economic self-sufficiency.  The Port of Vancouver has been pursuing  an
aggressive economic development policy and is actively seeking to promote
increased industrial activity within and adjacent to their existing
facilities.

The overall industrial land use has remained very stable, and the industrial
sector of the 1944 Land Use Map is in close approximation to current
industrial land location.  New industry has developed and old ones have
grown, but they have remained in the same general strip fronting Columbia
River.
                                 32

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                                 TABLE 12

                             Existing Land Use
                       Vancouver Lake Land Use Plan
RESIDENTIAL*

   Single Family
   Multi-Family
   Mobile Homes

COMMERCIAL

   Retail
   Wholesale

INDUSTRIAL

   Light
   General
   Heavy
   Extractive

COMMUNITY FACILITIES

   School
   Government
   Other Institutions
   Amusement
   Transportation & Utilities

OPEN SPACE

   Agriculture
   Parks
   Wooded & Game Preserves

WATER

STREETS

UNUSED
                               Acres
                               227.9
  188.6
   20.5
   18.8
   49.9
     .8
     .4
  159.3
  274.3
   55.5
    4.1
     .7
   10.3
  109.3
  306.1
5,664.9
  250.0
  398.2
                                50.7
                               489.5
                               430.5
                                   TOTAL
 6,313.1



 5,207.6

   188.0

   533.6

13,440.9
*Includes parts of Vancouver statistics that were not easily separated.

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 Approximately 500 acres within the Vancouver Lake vicinity (primarily south
 of the lake)  are currently being used for industrial  purposes, which
 constitutes about 40 percent of the industrial  activity in Clark County.
 The lowland areas along Columbia River have been an attractive area for
 industry because of the level terrain, proximity to the Portland metro-
 politan area, major rail service and Columbia River deep draft navigation
 channel.  Major industries within the project area are Alcoa (Aluminum
 manufacturer) and Carborundum (abrasives manufacturer).  The Port of
 Vancouver facilities are located south of Vancouver Lake and include
 berthing capacity for three or four vessels, a  roll  on/roll off dock,
 500,000 square feet of warehouse storage and about 75 acres of open storage
 area.  The Port is engaged in diversified trade including the export of
 lumber and wheat, and the import and export of wood chips, paper, fertilizer
 and automobiles.

 Land Use Plans and Policies

      Clark County Comprehensive Plan

 In August 1976, Clark County Regional Planning Council  issued a discussion
 draft of goals and guidelines for the Clark County Comprehensive Plan.
 This discussion draft has been receiving public review and input since
 that time, and adoption by the County Commissioners is expected sometime
 during the winter of 1978.  In keeping with the Columbia Region Associa-
 tion of Governments format, land use is divided into  three separate
 classifications:  urban (including urban intermediate and urban future),
 rural, and natural resource (including both conservation and preserva-
 tion categories).


 The plan includes the following  goals  and  guidelines which  can  be used
 to evaluate the effects of the proposed  Vancouver  Lake  restoration
 project.

 It should be  noted,  however,  that  these  Comprehensive Plan  elements
 provide only  general  guidance for  the  Vancouver  Lake area since  the
 Vancouver Lake Land  Use Plan  discussed below is  the major policy docu-
 ment governing use of the  project  area.

      o  Preservation  Element

           ' encourage the  preservation of  open space, scenic views and
 sites,  historic  and  archaeological sites,

           - encourage and maintain important fish and wildlife habitats,

           - maintain  ecologically  "sensitive areas" such as natural areas
wetlands and excessive  slopes  in as natural a state as possible.

     o Conservation Element

           - encourage the maintenance of agricultural  land uses in those
areas that are agriculturally productive,

          - encourage the maintenance and creation of those farm sizes
                                °f agriculture wh1ch are or could be present
                                   33

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                                             • 'J~vJj  '. LViiSfciS^S^y ;.'j^  • - / ^:

                                                        TiF':
VANCOUVER
  RB&BIUTATI

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     o Transportation Element

          - new and expanded Port facilities should be provided (at locations
designated in the comprehensive plan) for the transfer and storage of goods
that are not adequately provided for by other marine facilities in the area.

     o Economic Element

          - potential tourism in Clark County should be accommodated by
the provision of public park and recreation areas at appropriate points along
the shorelines of lakes and rivers.

     Vancouver Lake Land Use Plan

In December 1974 the Regional Planning Council of Clark County accepted
the Vancouver Lake Land Use Plan included in the report submitted to
them by the Vancouver Lake Task Force.  In 1976 the Board of County
Commissioners of Clark County accepted the Regional Planning Council
recommendation and adopted the Land  Use Plan for Vancouver Lake that was
prepared by the Task Force.

As shown in Figure 8, the existing land use in the project area is pre-
dominantly agricultural, ranging from dairy farming to intensive agri-
culture with high yield crops of cabbage, cucumbers and potatoes.
Industrial activity is concentrated  in the southern portion of the
project area at the Alcoa and Port of Vancouver sites.  Substantial
--c-eational lands arc located along *:he lake shoreline including
Vancouver Lake Park which is operated by Clark County and portions of
Mulligan's Slough which are managed  by the Washington State Game Department
for fishing access and wildlife habitat maintenance.  The Vancouver Lake
Task Force prepared an inventory of  existing land uses for the project
area.  Table 12 includes the acreages for individual types of land use
that were calculated by the Task Force.

Figure 9 shows the land uses designated on the adopted Vancouver Lake
Land Use Plan.  The lake and its shoreline are designated for recreation
and open space use, while agricultural uses are shown for areas to the
west, northwest and southeast.  Heavy industrial uses are indicated for
the southwestern portion of the project area along Columbia River. An
area of light industrial and commercial use is designated at the south-
eastern tip of the project area between the existing residential and
agricultural parcels.  The Task Force felt that the ability of the
lowlands area to support multiple land uses was one of its most important
assets.  For that reason, their land use plan is comprised of co-existing
land uses representing diverse interests that they believed offered a
wide range of choices to the community.

The Task Force report strongly recommended the continued recreation use
of Vancouver Lake.  They established the following policies relative to
actual use of lake shoreline and waters:
                                 34

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 •.. '••••.••
   \m.
VANCOUVER LAKH
  REHABILITATION
,

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          - provide public access to and along shorelines
          - establish recreation and/or park zones
          - preserve the wetlands southwest of Vancouver Lake
          - dredge the lake to the recommended depths for lake restoration
          - continue efforts to reduce the pollutants from the tributaries
              and runoff drainage to Vancouver Lake
          - flush the lake by introducing Columbia River waters through
              a channel  and culverts.

The following policies were adopted relative to land fill and diking
proposals within the project area:

          - land fills along shoreline areas intended for water dependent
              and/or public land uses should be given priority over other
              land fills

          - construct an adequate new dike to the south of Vancouver
              Lake, preserving Mulligan's Slough and its associated
              wetlands.
          - diking should be sought to support the land uses proposed,
              but not more intensive land uses.

In Resolution No. 1976-05-41, adopted by the Clark County Board of
Commissioners on May 24, 1976, the Commissioners attached the following
conditions to their adoption of the Vancouver Lake Land Use Plan:

     - That the Board recognizes that the Task Force report is a general
land use concept which addresses the whole lowlands area generally, but
which does not address the peculiarities and unique aspects of individual
sites or premises; thus, although an individual site may be identified as
a  larger categorization, closer review and further scrutiny, particularly
with respect to the amenities of the proposed use, may dictate that the
site may be more appropriately used for industrial, commercial or other
purposes..."

     - That the proposed implementing amendment...should...permit a re-
viewing body to permit land uses at variance with general concepts if it
can be demonstrated that the proposed use at variance is the appropriate
use of the particular site or premise at issue and that community needs
require its conversion."

     - "That, as it is established that the needs of the community have
changed, commercial and industrial development should be considered for
expansion into the lowlands area, but only to the extent dictated bv the
needs established."  (74).

On May 26, 1976 the Clark County Board of Commissioners adopted a 2M-H
zone for much of the agricultural/recreation land adjacent to Vancouver
Lake.  Agricultural and recreational land uses are permitted outright in
the 2M-H zone.  Certain other uses -- primarily those allowed in the heavy
manufacturing zone (M-H) -- are to be allowed only by permit.  Such a per-
mit may only be granted if the Board finds, among other things, that:

     (1) Surrounding agricultural and recreational land uses will not
be adversely affected by the granting of the permit;


                                35

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     (2)  The proposed use is in conformance with the controlling land
use plan.

Shoreline Management Master Program

The statewide adoption of the Shoreline Management Act in November 1972
established a cooperative management effort between local government and
the Washington State Department of Ecology.  This placed three significant
responsibilities on local government:

     1.  Establishment of a system for the administration and enforcement
          of a permit requirement for shoreline developments;
     2.  Completion of a comprehensive inventory of shorelines falling
          under jurisdiction of the act; and
     3.  Development of a master program for the regulation of shoreline
          uses.

With the assistance of the Regional Planning Council, the Clark County
Citizen Advisory Committee for Shoreline Management prepared a Shoreline
Management Master Program which was adopted in August, 1974.  Vancouver
Lake and its ponds, sloughs, lakes, channels, streams and islands are
defined as "shorelines of statewide significance" within that program.
As such, these shorelines must be managed  in a manner which:

          - recognizes and protects the statewide interest over local
               interest,
          - preserves the natural character of the shoreline,
          - results in long term over short term benefits,
          - protects the resources and ecology of the shoreline,
          - increases public access to publicly owned areas of
               the shorelines, and
          - increases recreational opportunities for the public in the
               shoreline.

The Shoreline Management Act further states that the management of shorelines
and shorelines of statewide  significance is not limited to the water areas
or to  the underlying  beds, but  includes wetlands associated with those
lakes  and streams.  Wetlands are defined in the act as follows:

     "Wetlands or wetland areas mean those lands extending land-
     ward for 200 feet in all directions as measured on a horizontal
     plain from  the ordinary high water mark; and all marshes, bogs,
     swamps, floodways,  river deltas, and  floodplains associated with
     the streams, lakes  and tidal waters which are subject to the
     provisions  of these chapters; the same to be designated as to
     location by the  Department of Ecology."

The Clark County Shoreline Management Master Program contains the following
goals  which are  relative to the evaluation of the proposed project:

          - Public Access Element:  To improve the quality of existing
            points of public access and promote the acquisition or de-
            signation of additional shoreline areas for public access,
            while assuring that all such sites are appropriate and safe
            for  public use, and that improvements and utilization will
            not  result in detrimental effects on these natural sites
            or adjacent  properties.

                                36

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VANCOUVER
  REH1VBIUTATI

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                              TABLE 13

                           LAND OWNERSHIP
                    VANCOUVER LAKE LAND USE PLAN
PUBLIC                                                       ACRES

  Port of Vancouver
  Clark County
  Washington State Department of Game
  U.S. Government
     TOTAL
PRIVATE (Parcels over 100 acres)

  Esther Dugan Estate                                          314
  Pacific Coop. Supply                                         103
  Elmer Rufener                                                279
  Alcoa                                                      1,558
  Scherruble Brothers                                          186
  Egger Family                                               1,303
  Grant Wiley, et al.                                          281
  Chris Herzog                                                 233
  John Mettler                                                 204
  Fazio Brothers                                               803
     TOTAL                                                   5,264
Source:  Vancouver Lake Task Force Report

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          -  Recreational  Element:   To promote  the  continued  public
            acquisition of appropriate shoreline  areas  for recreational
            opportunities and to influence development  of these  sites  in
            a manner which will  preserve the natural  characteristics of
            the shoreline.

          -  Conservation Element:   To provide  for  management of  natural
            resources in shoreline areas by means  that  will  insure  the
            preservation of nonrenewable resources,  including unique,
            scenic and ecologically sensitive  features, while allowing
            sound utilization of renewable resources  in a manner consis-
            tent with the public interest.

          -  Shoreline Improvement Element:  To encourage the restoration
            of degraded shoreline areas to conditions of natural  environ-
            mental quality, and promote the revitalization of abandoned
            shoreline facilities for practical and productive activities.

Four shoreline environmental designations are  provided  for in the master
program:  urban environment, rural environment, conservancy  environment
and natural  environment.  These designations provide  a  uniform basis for
applying management criteria within different  shoreline areas and with
different objectives regarding their use and development.  Portions of
Vancouver Lake have been designated urban, rural  and  conservancy,
generally as follows:

          -  Urban:  South of Burnt Bridge Creek.
          -  Rural:  All of Vancouver Lake, Lake River and associated
            wetlands north of urban boundary except for east bank of
            Vancouver Lake, Lake River and Lower Salmon Creek between
            mouth of Burnt Bridge Creek and Burlington  Northern  rail
            line crossing of Salmon Creek, an  easterly  portion of Lake
            River inside city limits of Ridgefield.
          -  Conservancy:  Easterly bank from mouth of Burnt Bridge  Creek
            northerly to Burlington Northern rail  line  crossing  of  Sal-
            mon Creek.


Land Ownership

Table 13 lists the major  property owners within the  project area and
Figure 10 illustrates the general distribution of public, private and
corporate lands.  Many of the parcels within  the project area are over
200 acres in size, reflecting the need  of  the  existing  agricultural and
industrial  land  uses  for  large  land  areas.  This largeness  provides a
future  potential  for  conversion to other  uses.

208 Areawide Waste Water  Management  Plan

Regional Planning Council of Clark County is  currently preparing a
Section  208 Areawide  Wastewater Management Plan which  has three  basic
work elements:   1)  restoration  of Vancouver Lake, 2) reduction  of  point
source  pollution from Burnt Bridge Creek,  and 3)  reduction  or elimination
of future pollutants  from non-point  sources.
                                  37

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The restoration plans for Vancouver Lake represent approximately 30
percent of the effort being expended within the 208 program.  Dames and
Moore recently completed a Master Plan for the Rehabilitation of
Vancouver Lake which outlines specific lake restoration and maintenance
measures.  The Clark County Regional Planning Council adopted the
Master Plan in December of 1977.

The Burnt Bridge Creek Management Plan was also adopted in December
of 1977.  The report outlines measures to reduce or eliminate future
pollutants due to non-point sources.  Of primary concern in that report
are animal wastes resulting from agricultural activities, urban drainage
resulting from residential uses and new construction activities.

Recreation Plans and Policies

A variety of recreational opportunities currently exist in the project
area, ranging from limited hunting in the Ridgefield Wildlife Refuge
to sailing on Vancouver Lake.  There are approximately 1,200 acres  owned
by Federal, State or County government and used for fishing, hunting,
sailing and canoeing.  In early 1973, Clark County purchased the 234
acre Vancouver Lake park site from Alcoa Corporation.  This long, linear
strip of park land covers approximately two and one-half miles of shore-
line on the southwestern and western side of the lake, and is currently
undeveloped.  The park lies between Vancouver Lake on the east and State
Highway SR 501 on the west, extending from the Mulligan Slough marsh-
lands on the south, northward to Buckmire Slough and then along the slough
to within one mile of the lake outlet into Lake River.  The area presently
provides fishing access to the lake, which hosts a large spiny rayed
fishery.  Other popular recreation facilities within the project area
    •re Frenchman's, Tena's and Davis Bar on the Columbia River which
      •e access to salmon and steelheau fishing.

in i9/3 a Master Plan Study for Vancouver Lake Park was prepared for the
Clark County Parks and Recreation Department with funding provided  by  the
Port of Vancouver.  The master plan proposed the creation of the recreation
zones and construction of the specific park facilities shown since  that
time is the elimination of power boat use (other than small engine  fishing
boats) in the lake, and a proposal for an Olympic sailing course to be
established in the south central portion of the lake.  The site and facili-
ties at Vancouver Lake have been designed to accommodate 12,000 to  15,000
park users per day, with approximately 5,000 people using the site  at  any
one time.  Consistent with the design philosophy, automobile parking is
limited to 50 percent of the potential demand, or 650 cars.  In 1973,  con-
struction of the proposed facilities was estimated to approach $1.4 million.
Present parking facilities comprise 1.75 acres, and accommodate 158 cars.
                                  38

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                              P
                              RECREATION
                                 , ZONES
       t S hi i I a po o Lake
                          T.' '^-'/T^i    ' '  '
                          tip    . AUTO access ANO PACING-.--
                          ilr*Jfefii',    .^i^'^f	
            PICNIC SWIMMING

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                               Af-?&....•-  SI
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^k\^K.  4- 4  y-W:
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        d^F t^ • rv ^>N     4?:  ; ;"• *   J^-z^^

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 Implementation of the water improvement program is  projected to have the
 greatest potential  to improve the recreational  use  of the park by pro-
 viding:   1)  sufficient water depth for  small  boats, 2)  the opportunity
 to upgrade the aquatic life so that the lake  can support increased
 numbers  and types of species for improved  sport fishing, and 3) clean
 water for swimming and other water sport activity.   In addition, the
 Master Plan states that creative use of the dredged materials resulting
 from lake restoration measures could enhance  the useability of the lake
 by creating additional  shoreline property  and raising some of the existing
 land above flood levels (75).

 In 1971  the Columbia Region Association of Governments  published a re-
 creation report entitled The Urban Outdoors:   A New Proposal  for Parks
 and Open Spaces.  In that report,  the CRAG staff suggested that Vancouver
 Lake offered a unique opportunity  for water based recreation since it is
 the region's second largest lake.   However, they noted  that it was
 currently too shallow and that the water quality had deteriorated due to
 silting  and pollution.   Therefore, a costly rehabilitation program would
 be necessary in order to realize the lake's recreation  potential.

 In addition to the preparation of  the Vancouver Lake Park Master Plan,
 Clark County Park and Recreation Department has also prepared plans  for
 a greenway system linking Burnt Bridge  Creek,  Vancouver Lake,  Lake River
 and Salmon Creek.  The primary purpose  of  this  system is  to link the
 urban areas  with existing and future park  sites and to  preserve public
 access to area waterways.

 Recreation Demand
 Only limited facilities  are  available  in  Clark  County  to  serve  the  still
 water/lake recreationist.  Lake  Merwin is  the largest  such  facility
 and is privately owned,  but  available  for  public  use.  Three other  faci-
 lities are available  in  the  metropolitan  Portland area, one each  in
 Multnomah, Washington and  Clackamas  counties.

 The demand for water-related recreation sites is  based primarily  upon
 three major factors:


           -  the  population of the recreation area of influence,
           -  recreation user  preferences within the recreation area of
             influence, and
           -  the  availability of water-related recreation sites within
             the  recreation area of influence and nearby areas.

Nationally,  the  demand for all types of recreation areas continues to
grow  rapidly due to increased leisure time and disposable income,  as well
as people's desires to increase their recreational activities.   Past
trends have  indicated that participation in outdoor recreation in  the
United States is growing 25 percent faster than the adult population,
and these trends are expected to continue for the immediate future.
Projections also indicate that water-related recreation activities will
make  up three of the five fastest growing recreation activities between
1972  and 1978 (76).
                                 39

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Because of Vancouver's role as an integral part of the CRAG region and
its proximity and similarity to Oregon features, it is assumed that
Oregon recreation projections can be applied to Clark County recreation
demand.  In Oregon, water-related recreation activities continue to be
among the most popular.  The rate of growth of boat ownership has far
surpassed the population growth as indicated by the 52 percent increase
in boat registration from 1967 to 1972, compared with a 6 percent increase
in population for that same period (77).  In general, Oregon boaters
prefer lakes to rivers as favored recreation areas, and fishing is the
most widely participated in boating or boating related activity (78).

The Clark County Parks and Recreation Department has indicated that
demand for water-related recreation sites within the county has not been
evaluated.  The recent experience of a new reservoir facility in Washing-
ton County, Oregon, however, may provide a point for comparison.  Scoggins
Reservoir in Washington County was opened in the summer of 1975, for re-
creational use, even though only 20 percent of the proposed recreational
facilities were completed.  Projections had indicated that approximately
100,000 visitors would use the lake during the first full recreation
season; however, actual attendance reached 180,000 -- almost double the
intended use.  Washington County Parks Department surveyed a portion
of the recreationists at Scoggins Reservoir to determine where they came
from and what type of recreational facilities they were using.  It was
found that the majority of users, 68 percent, lived in Washington County,
while 18 percent lived within 40 miles of the reservoir.  Swimming and
picnicking were the most favored activities, followed closely by boat
fishing and motor boating (including water skiing.)

Recreation projections by both the Oregon State Highway Division and the
Pacific Northwest River Basins Commission indicate a strong overall  need
for water-related recreational facilities in the Portland metropolitan
area.  In addition, the Scoggins Reservoir 1975 attendance figures
indicate that recreation demand for swimming, boating, fishing and
picnicking is sufficiently high to draw large numbers of visitors to
a site even though the recreation facilities are not completed.  At the
present time Scoggins Reservoir is the only metropolitan area regional
park that provides quiet water-related recreational facilities.  A
review of federal, state and local recreation plans indicates that no
plan exists to significantly increase the supply of water-related re-
creation sites within the near future with the exception of Vancouver
Lake.

Historical and Archaeological Resources

During the study investigations for this report, both the Wasington State
Historic Preservation Officer and the Washington Archaeological Research
Center (Washington State University) were contacted to determine the
presence of historical and archaeological resources within the project
area.  The Washington Archaeological Research Center identified over
40 Indian relic sites that have been identified by both professional and
amateur archaeologists.  These sites are scattered along most portions
of the lake shoreline and north along the banks of Lake River.  Little
information is available describing either the characteristics or the
significance of these sites.
                                  40

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The Washington State Historic Preservation Officer identified only four
sites within the project area.   All  of these were Indian relic sites
that were included within the sites  identified by the Research Center.
There are no sites within the project area that are included on the
National Register of Historic Places.

Implementation of any of the alternatives  described in Section III
(exclusive of Alternative 1, the "no-action" alternative)  would require
the Port of Vancouver to conduct a site specific archaeological  investi-
gation of the affected areas.  This  survey would be submitted to the
Washington State Historic Preservation Office for review and acceptance.
Any mitigating measures recommended  by the State Historic  Preservation
Officer would be considered  by  the Port of Vancouver and the Environmental
Protection Agency.  Mitigation  measures acceptable to all  three  parties
(State Historic Preservation Officer, EPA  and the Port of  Vancouver) would
be adopted and implemented.
                                  41

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SECTION III  ALTERNATIVES AND THEIR EFFECTS

Alternative Selection Process

The basic proposal for lake restoration, including construction of a
flushing channel and dredging of lake bottom sediments, was first pre-
sented in a Stevens, Thompson & Runyan report of 1973.   In the studies
undertaken in the current 208 planning program, Dames and Moore has
suggested some revision to those features, but their basic character-
istics remain the same.  In addition, completion of the Pilot Dredge
Study allowed analysis of lake bottom sediments for reuse, various
methods of dredging and techniques for placement and handling of the
dredged materials.  Based on the above studies EPA selected the following
alternatives for consideration in this Draft Environmental Statement:

     ALTERNATIVE 1             No Action

     ALTERNATIVE 2             Scale of Development
                 2A            Dredging of 12-15 million cubic yards
                 2B            Dredging of 8 -10 million cubic yards
                 2C            Dreding of under 6 million cubic yards

     ALTERNATIVE 3             Disposal Material Placement
                 3A            Land Disposal
                 3B            Shoreline Disposal
                 3C            Combination of Land and  Shoreline Disposal

     ALTERNATIVE 4             Dredging Methods

     ALTERNATIVE 5             Dredged Material Handling Methods

Impact Evaluation

In this section, possible environmental impacts associated with each al-
ternative are discussed following a brief description of the alternative.
Environmental impact may be categorized as adverse or beneficial, primary
or secondary, and short term or long term.  Any number  of combinations
of these categories are possible depending on the type  of project involved.
For each alternative, impacts on the natural and social environments are
discussed in terms of these categories, where the categories can be applied.
Elements of the natural and social environments are discussed in an order
corresponding to Section II, Project Area Existing Conditions.

Most of the terms used to describe environmental impact are self-explanatory.
However, for the purpose of this discussion, several need further clarifi-
cation.

     Primary Impacts include short term impacts occurring during con-
     struction, and long term impacts related to construction and op-
     eration of the facilities.  Examples of primary impacts include
     traffic disruption, disruption to vegetation, etc.


                                42

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     Secondary Impacts are essentially those associated with growth
     and development.  These impacts could include potential increases
     in air contaminants and traffic as a result of increased recrea-
     tion use, need for increased public services, and other effects
     of growth related to lake restoration in general.  Cumulative
     impacts will  be discussed where applicable.

In addition to environmental  impact, short term uses and long term pro-
ductivity will be discussed,  as well as any irreversible and/or irretriev-
able resource committments.   The proposed alternatives will  be analyzed
in relationship to their effect on future options, and the availability
of future resources.  Resource committment is primarily a discussion
of the environmental and monetary resources which would be committed
to the project, and thus would not be available for future use.

Mitigating measures for each  individual  alternative must also be con-
sidered.  Mitigating measures may be technological  means to  avoid and/
or minimize adverse environmental  impact, or policy methods  to mitigate
the impact of growth.  For the purposes of this report, mitigating mea-
sures will emphasize means of reducing short term construction impacts
of the project.
                                43

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                     ALTERNATIVE 1 - NO ACTION


Alternative 1 is the "no project" alternative and assumes that EPA
would not provide grant funds for the proposed lake restoration project.
The no action alternative is used as a base line from which to evaluate
impacts associated with action alternatives.  The non-point
source pollution control programs in Burnt Bridge Creek would continue
as part of Clark County's 208 Areawide Wastewater Management Plan Program.

Air Quality

Projected trends for the Vancouver Lake area indicate that the U.  S.  En-
vironmental Protection Agency and Washington Department of Ecology Ambient
Air Quality Standards will be naintained in most instances.   However,  total
suspended particulate levels will continue to be violated in the area
just south of the lake if the Carborundum Company plant does not im-
prove its pollution control efforts.  The Clark County Air Quality Ana-
lysis prepared in 1976 projected continued violations of suspended par-
ticulates by Carborundum Company until new pollution controls are under-
taken.  An agreement concerning those pollution controls has been reached
between the Southwestern Air Pollution Control Authority and the Carbor-
undum Company.

Topography

No changes in the local land topography would be expected as a result
of the pursuit of the no action alternative.  Over a long period of time,
however, the configuration of the lake bottom would be expected to change
significantly due to continuation of the natural  filling process.   It  has
been estimated that since 1948, a foot of sediment deposition has occurred
within the lake.  This rate of deposition could be expected to decrease
somewhat in the future due to less intensive home building and other
construction activities in the adjacent drainage basin and increased
control over urban runoff and erosion.

Hydrology and Flood Hazard

Selection of a no action alternative would suggest that no steps would
be taken to change the flushing or circulation patterns within the lake.
This would result in continued deposition of sediments throughout the
lake, eventually creating marshlands in the shallowest areas.  Although
it must be pointed out that these processes occur over many years,
eventually the circulation patterns would change slightly to accomodate
increasing shallowness and a shrinking water surface area.

Pursuit of a no action alternative would have no effect on the flood
hazard potential within the project area.  Construction of the proposed
diking improvements by the Corps of Engineers would provide flood pro-
tection to the agricultural land owners within the project area.
The Corps is presently" preparing" a draft EIS  concerning  their favored
diking alignment.  The Vancouver Lake diking  improvement program  has
been under consideration since early  1950.  Recent  questions  have
been raised as to its cost-benefit ratio,  and  the project's  future is
undertain at this point.  Further discussion  of  the diking  improvement
plans can be found under Alternative  2A.
                                 44

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 Water Quality

 Current total and fecal coliform levels within Vancouver Lake substantially
 exceed the acceptable standards for a Class AA Waterway (Lake Class).  Although
 coliform levels are expected to decrease in Burnt Bridge Creek as a result of
 a variety of plans and programs, the decrease is not expected to be sufficient
 to lower the coliform levels in Vancouver Lake to within the acceptable Class
 AA levels.

 The trophic status of a lake is determined  by  the residence time of water
 in the lake, the mean depth of the  lake,  nutrient loading  of the lake
 from the drainage basin,  and a variety  of other  limnological  parameters.
 The single most important parameter in  determining lake  trophic  status
 is phosphorus loading.  Lakes can be defined as  oligotrophic,  eutrophic
 or hyper-eutrophic.   In general, oligotrophic  lakes  have very  little
 phosphorus, while eutrophic lakes are high  in  phosphorus content.   Hyper-
 eutrophic lakes, by definition, evidence  exceedingly high  levels of
 phosphorus.  Sedimentation and, to  a certain extent, eutrophication
 are natural processes in  the history of lake development,  particularly
 in a lake which receives  only marginal  amounts of freshwater inflow.
 However, human activity can cause substantial  acceleration of  the pro-
 cess.  Cultural  eutrophication is the result of  increasing the nutrient
 loading of a lake due to  conditions and activities within  the  watershed.
Any human activity which  causes an  increase in nutrient  flow to  a  lake
will  cause cultural  eutrophication.  Common causes of cultural eutro-
 phication include sewage, increased erosion from agriculture or  con-
 struction activities, or  use of plant fertilizers.  When culturally
 derived nutrients are added to existing supplies  in  a lake,  the  lake
 becomes correspondingly more eutrophic.

 Natural lake processes move on a continuum  from  oligotrophic to  highly
 eutrophic,  which are dependent upon a variety  of watershed and config-
 uration conditions.   Although Vancouver Lake is  not  yet  considered hyper-
 eutrophic,  it is at the upper end of the  eutrophic scale.   If  no action
 is taken, it is expected  that Vancouver Lake will  eventually reach hyper-
 eutrophic conditions.  In the long  term,  coupled with continued  sedimen-
 tation, the lake will eventually fill and convert to marshland.

 Pursuit of other 208 Areawide Wastewater Management  Plan elements,
 including reducing both point and non-point source pollution reaching
 Vancouver Lake,  would decrease the  amount of cultural eutrophication
 occurring within the lake.  This would  decrease  the  overall  rate of the
eutrophication process, but would not prevent  the eventual  occurrence
of hyper-eutrophication and in-filling.

 Fisheries

Over the long term,  selection of a  no action alternative would result in
Vancouver Lake becoming increasingly shallow,  which  would  further limit
 the aquatic environment.   Turbidity problems would continue and  would
 likely increase in magnitude.  The  lake fisheries would  probably exper-
 ience stunting,  as biotic competition began to take  its  toll  on  the
 fish species.  Over the long run, fisheries would probably be  eliminated
and the lake would evolve into a marshland, and  much later,  a  terres-
trial environment.
                                 45

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                     ALTERNATIVE 1 - NO ACTION


Alternative 1 is the "no project" alternative and assumes that EPA
would not provide grant funds for the proposed lake restoration project.
The no action alternative is used as a base line from which to evaluate
impacts associated with action alternatives.  The non-point
source pollution control programs in Burnt Bridge Creek would continue
as part of Clark County's 208 Areawide Wastewater Management Plan Program.

Air Quality

Projected trends for the Vancouver Lake area indicate that the U.  S.  En-
vironmental Protection Agency and Washington Department of Ecology Ambient
Air Quality Standards will be maintained in most instances.   However, total
suspended particulate levels will continue to be violated in the area
just south of the lake if the Carborundum Company plant does not im-
prove its pollution control efforts.  The Clark County Air Quality Ana-
lysis prepared in 1976 projected continued violations of suspended par-
ti cul ates by Carborundum Company until new pollution controls are under-
taken.  An agreement concerning those pollution controls has been reached
between the Southwestern Air Pollution Control Authority and the Carbor-
undum Company.

Topography

No changes in the local land topography would be expected as a result
of the pursuit of the no action alternative.  Over a long period of time,
however, the configuration of the lake bottom would be expected to change
significantly due to continuation of the natural filling process.   It has
been estimated that since 1948, a foot of sediment deposition has occurred
within the lake.  This rate of deposition could be expected to decrease
somewhat in the future due to less intensive home building and other
construction activities in the adjacent drainage basin and increased
control over urban runoff and erosion.

Hydrology and Flood Hazard

Selection of a no action alternative would suggest that no steps would
be taken to change the flushing or circulation patterns within the lake.
This would result in continued deposition of sediments throughout the
lake, eventually creating marshlands in the shallowest areas.  Although
it must be pointed out that these processes occur over many years,
eventually the circulation patterns would change slightly to accomodate
increasing shallowness and a shrinking water surface area.

Pursuit of a no action alternative would have no effect on the flood
hazard potential within the project area.  Construction of the proposed
diking improvements by the Corps of Engineers would provide flood pro-
tection to the agricultural land owners within thejpj-oject area.
The Corps  is presently" preparing a draft EIS  concerning  their favored
diking alignment.  The Vancouver Lake diking  improvement program  has
been under consideration  since early  1950.  Recent  questions  have
been raised as to its cost-benefit ratio,  and  the project's  future is
undertain  at this point.   Further discussion  of  the diking  improvement
plans can  be found under  Alternative  2A.
                                  44

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 Water Quality

 Current total and fecal coliform levels within Vancouver Lake substantially
 exceed the acceptable standards for a Class AA Waterway (Lake Class).  Although
 cohform levels are expected to decrease in Burnt Bridge Creek as a result of
 a variety of plans and programs, the decrease is not expected to be sufficient
 to lower the coliform levels in Vancouver Lake to within the acceptable Class
 AA levels.

 The trophic status of a lake is determined  by  the residence time of water
 in the lake,  the mean depth of the  lake,  nutrient loading  of the lake
 from the drainage basin,  and a variety of other  lintnological  parameters.
 The single  most important parameter in determining lake  trophic  status
 is phosphorus loading.  Lakes can  be defined as  oligotrophic,  eutrophic
 or hyper-eutrophic.   In general, oligotrophic  lakes  have very  little
 phosphorus, while eutrophic lakes  are high  in  phosphorus content.   Hyper-
 eutrophic lakes, by definition, evidence  exceedingly high  levels of
 phosphorus.  Sedimentation and, to  a certain extent, eutrophication
 are natural processes in  the history of lake development,  particularly
 in a lake which receives  only marginal  amounts of freshwater inflow.
 However, human activity can cause  substantial  acceleration  of  the pro-
 cess.  Cultural  eutrophication is  the result of  increasing  the nutrient
 loading of a  lake due to  conditions and activities within  the  watershed.
 Any human activity which  causes an  increase in nutrient  flow to  a lake
will  cause  cultural  eutrophication.  Common causes of cultural eutro-
 phication include sewage, increased erosion from agriculture or  con-
 struction activities, or  use of plant fertilizers.   When culturally
 derived nutrients are added to existing supplies  in  a lake,  the  lake
 becomes correspondingly more eutrophic.

 Natural  lake  processes move on a continuum  from  oligotrophic to  highly
 eutrophic,  which are dependent upon a variety  of watershed  and config-
 uration conditions.   Although Vancouver Lake is  not  yet  considered hyper-
 eutrophic,  it is at the upper end  of the  eutrophic scale.   If  no action
 is taken, it is expected  that Vancouver Lake will  eventually reach hyper-
 eutrophic conditions.  In the long  term,  coupled  with continued  sedimen-
 tation, the lake will eventually fill  and convert to marshland.

 Pursuit of  other 208 Areawide Wastewater  Management  Plan elements,
 including reducing both point and  non-point source pollution reaching
 Vancouver Lake,  would decrease the  amount of cultural eutrophication
 occurring within the lake.  This would decrease  the  overall  rate of the
 eutrophication process, but would  not prevent  the eventual  occurrence
of hyper-eutrophication and in-filling.

 Fisheries

Over the long term,  selection of a  no action alternative would result in
Vancouver Lake becoming increasingly shallow,  which  would  further limit
 the aquatic environment.   Turbidity problems would continue and  would
 likely increase in magnitude.  The  lake fisheries would  probably exper-
 ience stunting,  as biotic competition began to take  its  toll on  the
 fish species.  Over the long run,  fisheries would probably  be  eliminated
and the lake  would evolve into a marshland, and  much later,  a  terres-
trial environment.
                                 45

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Vegetation/Wildlife

Selection of a no action alternative would have no marked effect on the
vegetation and wildlife of the project area.  Marsh areas would probably
expand over time, and riparian vegetation would continue to spread along
the shorelines.  These processes would be extremely slow, and thus would
not alter the present wildlife activity.

Significant Wildlife Areas/Environmentally Sensitive Areas

Selection of a no action alternative would have no noticeable effect on
the present significant wildlife areas.  Existing wetlands would be
maintained in their natural state as mandated in Executive Order 11990
and Environmental Protection Agency's Wetlands Policies, and would con-
tinue to provide valuable wildlife habitat.  Increases in agricultural
activity around the lake could result in a depletion of wetlands and
marsh areas if those lands were converted to more intensive pasture usage.
It is doubtful that individual land owners would be allowed to do this
under current federal regulations.


Population Growth/Economic Base

No changes in project area population growth would occur as a result of
selection of a no action alternative.  It is expected that agricultural
use of the area could potentially increase over the long term as a
result of continued deposition of sediments in the marshlands.   This
increase would be extremely slow.  Selection of a no action alternative
would have no effect on the continued industrial  expansion that is fore-
cast in the Vancouver Lake Task Force Land Use Plan.

Land Use Plans and Policies

The Vancouver Lake Task Force report and the accompanying adopted land
use plan both endorse and recommend plans for the restoration of Van-
couver Lake.  Selection of a no action alternative would be contrary
to the goals and policies outlined in that report and adopted by the
Clark County Commissioners.  If restoration of the lake did not occur,
the recreation shoreline uses shown in the plan would not be implemented;
however, industrial and agricultural use patterns could proceed as
defined on the adopted land use map.

208 Water Quality Planning

The restoration of Vancouver Lake is a significant portion of the Section
208 Areawide Wastewater Management Plan currently being prepared by the
Regional Planning Council of Clark County.  In addition, the remaining
two work elements --  drainage management in Burnt Bridge
Creek and control of non-point source pollution around the lake -- are
closely tied to the eventual cleanup of Vancouver Lake.  If the no
action alternative were selected, the goals of the 208 work program
would not be fully realized.  Significant public funds have been pre-
viously committed and spent on this project, and a fairly high  level
of public interest has been generated in the project.  The future
availability of Vancouver Lake for recreational use appears to  be a


                               46

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 popular  local  issue  and adverse public reaction could be expected  if
 the  project were  abandoned.

 Completion of  the two remaining 208 Program work elements would decrease
 the  amount of  nutrient inflow reaching Vancouver Lake, but this decrease
 would probably not be noticeable in relationship to overall lake quality.

 Recreation

 Selection of a no action alternative would be expected to result in  the
 abandoning of  county plans to improve their 234 acre Vancouver Lake  Park.
 A major  feature of the proposed park facility is water contact and access
 for  swimmers,  sailors and fishermen.  Group and family picnic areas  and
 a youth  camp would be built to capitalize on the water access and use.
 The  existing lake quality conditions are not adequate for this type  of
 use, therefore the projected plans would be expected to be abandoned.
 Existing and future demand for water-related recreation areas would
 remain unmet,  unless alternative sites were constructed or improved.

 Archaeological and Historical Resources

 No effects would  be expected upon the existing archaeological  sites  if
 the  no action  alternative were selected.   Amateur and, occasionally,
 professional archaeologists would continue to search the area for Indian
 artifacts and  remove them from the project area.

 Short-term Resource Use vs. Long-Term Productivity

 Selection of a no-action alternative would not require any committment
 of additional  monetary resources, nor would it change the environmental
 factors  currently at play within the lake and its environs.  The long-
 term productivity of the lake would be lost as the lake continued to
 in-fill, however, for the long-term the lake would be preserved as  a
 valuable wetland  habitat for waterfowl and other wildlife.   Eutrophi-
 cation represents the increasing nutrient enrichment of a body of
 water, and from that standpoint the lake would become increasingly
 productive.  However, human use of its surface and shoreline would  be
 extremely limited.  Eventually, over the  very long-term,  the lake
 bottom would fill, creating marsh and swamp areas.   These habitats  are
 highly productive, but would replace and  eliminate the existing
 aquatic habitat and species.

 Irreversible and  Irretrievable Commitments of Resources

 If a no action alternative were selected, Vancouver Lake would be
 committed towards eventual hyper-eutrophication and in-filling over
 the long-term.   The existing aquatic habitat would be replaced by
wetland and marsh habitat, and eventually by upland vegetation.
 Increasing amounts of land area would be  available for agriculture  or
other dry land uses.

Mitigating Measures

Although the implementation of point and  non-point source pollution
controls within the Vancouver Lake drainage basin would result in a
                                 47

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decrease in nutrient input into the lake, it would not be sufficient to
reverse the existing trends.   There are no mitigating measures which can
be suggested to achieve the project purposes under a no action alternative.
                               48

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                 ALTERNATIVE 2 - SCALE OF DEVELOPMENT

In order to restore Vancouver Lake to the depth and water quality level
that will allow more extensive human activity on and around the lake,
the Master Plan proposes three major work efforts:  1) flushing the lake
with relatively clean Columbia River water,  2) dredging the lake to pro-
vide for increased recreational usage, and 3) control of pollution enter-
ing the lake 'from non-point sources.  Each of these major work
elements is described below and illustrated  on Figure 12 - Dredging and Spoils
Disposal Areas.

     1.  Flushing Channel:   The flushing channel would extend from Columbia
     River at Blurock Landing to Lower River Road,  adjacent to the lake.
     A culvert system would extend the flushing channel below the highway
     corridor and would discharge into the lake through four 96" diameter
     culverts.  The culverts would be equipped with sluice gates on the
     Columbia River side and with flap gates on the lake side.  The flap
     gates would prevent reverse flow out of the lake through the culverts.
     The sluice gates could, if necessary, be used  to prevent inflow into
     the lake during periods of high turbidity in the river, to isolate
     the lake from migrating salmonids, and  for lake maintenance.  An unlined
     channel with the bottom width of 50 feet at elevation -8MSL and 3:1
     (horizontal to vertical) side slopes is recommended in the Master Plan
     (79).

     2.  Dredging of Lake Bottom Sediments:   Figure 12 defines the areas
     within the lake which are expected to be dredged and the depths to
     which dredging would occur.  Three purposes are expected to be achieved
     through selective dredging of the lake: 1) enhancement of lake flushing
     by creating channels on the east and west banks to aid in circulation
     and provide a short circuit for the nutrient rich Burnt Bridge Creek
     water, 2) removal of nutrient rich bottom sediments which may be pro-
     viding phosphorus in quantities sufficient to  promote or assist algal
     growth, and 3) deepening of the lake to allow  increased recreational
     activity.  The configuration of the proposed dredging includes a channel
     along the west shore to bring Columbia River water past the county
     park, an east channel  to direct the flow from  Burnt Bridge Creek out Lake
     River, a boating (sailing) basin in the south  central portion of the
     lake, sediment basins at the flushing channel  at the outlet and Lake
     River entrance, and a substantial undredged area in the north central
     portion of the lake and near most shorelines where the flats or sloughs
     are major spawning areas.  The Master Plan states that this pattern of
     dredging will result in better water quality and more recreational poten-
     tial than the same amount of dredging spread evenly over the entire lake
     (80).

     Various levels of dredging have been proposed  within the Master Plan.
     Total dredging evaluated in the study plan was 15.4 million cubic yards.
     However, the Master Plan concludes that reducing all dredged depths by
     one foot would decrease the total dredging to 12.9 million cubic yards
     with little effect on the recreation potential of the lake.  The Master
     Plan states that approximately one-half of the above dredging is for
     development of the sailing area, which although it may provide the greatest
                                   49

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 benefit in economic terms,  is the least critical  for achievement for a
 clean lake.  The Master Plan indicates that only about 20 percent of
 the sailing area dredging is actually critical  to achieve good water
 quality in the lake.   This  would reduce the above figures to 9.6 and
 8 1 million cubic yards, respectively.  The 8.1  million cubic yards
 is believed to be the minimum dredging that would be required to provide
 acceptable water quality (81 )•

 The Master Plan for Vancouver Lake rehabilitation also outlines a
 program for lake maintenance.   Columbia River flushing water and
 the continued flow of Lake  River and Burnt Bridge Creek would
 continue to transport sediment into Vancouver Lake.   The dredge
 plan includes zones specifically designed  to collect these sediments
 and it is estimated that approximately 50,000 cubic  yards of
 sediment would be deposited in the lake each year.   In addition,
 annual maintenance dredging of between 3,000 and  6,000 cubic yards
 of material would be  required within the flushing channel  itself.
 Methods of dredging,  and disposal areas, will be designed during
 the development of operation plans.


 In order  to remove  the  bottom  sediments  from  Vancouver Lake, adequate
 sites  for  the  disposal  of those materials must be found.   The
 Master Plan for  Rehabilitation of  Vancouver Lake  identifies  the
 potential  dredge  sites  delineated  in  Figure 12.  Since the availability
 of disposal  sites has not been finally settled, the Master Plan  found
 it necessary to  identify more  potential  fill  areas than would be ulti-
 mately required  (82).   Table 14 presents the  possible fill areas and
 volume in  each of those  sites  for  alternative fill elevations ranging
 from  20 feet above  MSL  to 32 feet  above  MSL.  If all  of these sites
 were  used,  there would  be more than  sufficient capacity to implement
 the 15.5 million cubic yard dredging  plan without filling  any site
 above  the  20 foot elevation.   Since  the  availability of these sites
 is not yet  known, the Master Plan  proposes that the following criteria
 be utilized to guide the ultimate  selection of the disposal  areas  and
 fill  elevations:

     A.   "Proximity of  disposal area  to  dredged site,
     B.  Suitability of dredged material for  intended future use of
           site,
     C.  Irreversible commitment of  resources due to filling,
          e.g., loss of wetlands or  prime agricultural lands,
     D.  Potential  damage to fish  or wildlife habitat,
     E.  Suitability of on-site material for  dike construction,
     F.  Potential  damage to archaeological sites,
     G.  Potential  disturbance to  existing structures, and
     H.  Potential  ground water pollution  (83)."

 It  should be noted  that each of the above criteria emphasizes a  differ-
 ent set of  values, whether it  be engineering  feasibility,  future
 land use, cost considerations or environmental protection.   Selection
of the  specific disposal areas may  require that trade-offs  be made  between
 those  varvinq sets of values.

 The following paragraphs basically describe each of the potential  fill
 areas  based on information provided  by the Regional Planning Council
 of  Clark County.

                               50

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Site 1  Northwest Shoreline Hest of Buckmire Slough:  This 65
acre tract includes pasture land and vacant highway right-
of-way.  Compared to other pasture land in the lowlands,
this area is not highly productive.  In addition, it does
not receive significant wildlife use.  The site is well
located for use for the west channel and Lake River sedi-
ment trap dredging.

Site 2 Northern Undeveloped Portion of Vancouver Lake Park:
This 47 acre site is now used for pasture but is designed
for future group picnic facilities and playfields in the pro-
posed Vancouver Lake Park Plan.  It is within normal pumping
range for the west channel dredging.

Site 3 West Central Area West of Lower River Road to Buckmire Slough:
This 71 acre tract is owned by Alcoa and zoned for heavy in-
dustry, although it is presently used for pasture and has numerous
low lying areas.  The Vancouver Lake Land Use Plan calls for
agricultural use, but with possible conversion to heavy in-
dustry if conflict with surrounding land uses can be mitigated.
The Regional Planning Council recommended use of this site for
filling based on two considerations:  1) the narrow site is
located adjacent to Vancouver Lake Park and thus would be diffi-
cult to develop for heavy industry without adversely affecting
the park and, 2) since it is not among the most productive
pasture areas, it was thought that the temporary loss of pro-
ductivity might not be unacceptable to the owner.  The site
is well situated for use in conjunction with dredging both the
west channel and the flushing channel sediment trap.

Site 4 Southwest Area West of Lower River Road:  This 33 acre
strip is characterized by two low lying areas which provide
water fowl habitat.  There is little existing agricultural
use.  The area is zoned for heavy industry and Alcoa, the pre-
sent owner, may be unwilling to allow non-structural fill.
Without booster pumps, the site could be used only for dredging
the flushing channel sediment trap.

Site 5 Southwest Embayment and Shoreline:  The southwest embay-
ment is very shallow -- one foot or less most of the year.  It
is a spiney ray spawning area, and provides seasonal bank fishing
access.  The embayment is surrounded by a county park and would
be filled to create an addition to the park.  It is intended to
create a rolling landscape with native plant materials and
to encourage only limited access, thus essentially allowing the
area to grow wild again with the few nature trails and view points.
The upland area includes a willow swamp, grassy marsh and open
meadow.  The Regional Planning Council recognizes the wildlife
habitat provided at this site, but believes that use of the site
would allow other more valuable fish and wildlife areas to be
preserved or enhanced.
                            51

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                                                TABLE  14
CHARACTERISTICS OF POTENTIAL DISPOSAL AREAS
Volume in Cubic Yards When Fil
to Elevation (MSC)
Site Designation
1
2
3
4
5a
5b
6
7
Description
Northwest Shoreline
West of Buckmire Slough
West-Central Shoreline
East of Lower River Road
West-Central Area West
of Lower River Road
Southwest Area West of
Lower River Road
Southwest Embayment
(Surface Elevation
below +6)
Southwest Shoreline
(Above Elevation +6)
South Shoreline
Northeast Shoreline
Area (acres)
65
47
71
33
65
83
650
112
+20
350,000
300,000
500,000
300,000
1,650,000
1,350,000
8,100,000
3,200,000
+25
900,000
700,000
1,100,000
450,000
2,200,000
2,050,000
13,350,000
4,100,000
+30
1 ,400,000
1,000,000
1 ,700,000
700,000
2,750,000
2,750,000
19,000,000
5,000,000
lied
+32
1,650,000
1 ,100,000
2,000,000
800,000
2,950,000
3,050,000
20,800,000
5,200,000
Note:   Areas and volumes are approximate

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          Site 6 South Shoreline:  This 650 acre area is made up of
          productive wetlands and farmlands, State Game Department
          land, low lying sink holes, and a few vacant fields near
          the lake.  The lakeward boundary of the area conforms to
          the line ac'opted by the Clark County Commissioners  01 a
          proposed dike,   me Vancouver Lake Land Use i-'lan  desiynates
          agriculture and open space as the future use for  this area.
          The provision of flood  improvement dikes along this area  is
          closely  tied to the use of the area for spoils disposal.
          If flood protection is  not provided, the property owners
          may decide not to make  any land available for fill.

          Site 7 East Shoreline of the Lake:  This area of  112  acres
          would provide for deposition of up to 5 million cubic yards
          of dredged material and would open up a major portion of  the
          east side of the lake to public access.  It would connect
          the Burnt Bridge Creek and Salmon Creek Greenways thus pro-
          viding fishing access to this entire shoreline (84).

      3.   Non-Point Source Pollution Control Measures:  As
      discussed previously, the 208 Program currently being  prepared
      by  the Regional Planning Council of Clark County is aimed at
      reducing the  flow of non-point source pollution from the
      drainage basin into Vancouver Lake.  The major interceptors
      serving the Burnt Bridge Creek drainage area have been
      constructed and collectors are now being built to serve individual
      neighborhoods.  The Regional Planning Council has proposed the
      establishment of a drainage district to control the storm runoff
      generated in  the drainage basin, including a diversion of "first
      flush" storm water to sanitary sewers.  In addition, efforts to
      control erosion, septic tanks, construction erosion and agricultural
      runoff have also been proposed for adoption.

 Although construction of improvements to Vancouver Lake Park are not
 part  of  the proposed project, completion of lake rehabilitation would
 serve as the impetus to begin those park improvements.  Because of the
 close tie between the proposed lake rehabilitation and the  proposed park
 development, the park will be evaluated as a secondary impact of the
 proposed program.  Specific park programs are discussed in  Section II
 and outlined on Figure 11.

Cost Estimates

The grant application  submitted  by the  project  sponsor (Port of  Vancouver)
in April  1976,  estimated  the  cost of the project  to  be $8,278,000    Of
that total,  federal participation represented  some $4,139,000.   Since
that time,  however, completion of the pilot dredge study  and the Master
Plan for  the Rehabilitation of Vancouver Lake  have altered  the projected
                                    53

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costs.  Estimates made in the Pilot Dredge Study indicate that dredging
and disposal of lake bottom sediments is expected to cost about $1.25
per cubic yard.  Thus, the total cost of the project would vary greatly
depending upon the amount of material to be dredged.  The Port of Vancouver
is currently exploring a variety of dredging options in order to minimize
those costs.  The following cost-estimates are taken from the Master Plan
and reflect estimates prepared in May, 1977.   The estimate does not include
the cost of engineering, administration, legal services and contingencies.
Land acquisition costs and costs associated with park improvements or
vegetative cover of dredged material have also not been included.


     Dredging and Dike Construction for
     removal of 8,100,000 cubic yards
     of sediment -                                $ 10,400,000

     Dredging and Dike Construction for
     removal of 15,400,000 cubic yards
     of sediment -                                $ 19,500,000

     Flushing Channel Construction                     430,000

     Culvert Construction                              520,000

          TOTAL                    $ 11,350,000 —$ 20,450,000

The Port of Vancouver and Regional Planning Council of Clark County have
proposed the above package of work elements in order to restore Vancouver
Lake to public use by improving its water quality.  The proposal presented
by these two agencies requires dredging of approximately 12-15 million cubic
yards of lake bottom sediments.  The entire package of aquatic improvments,
including dredging of 12-15 million cubic yards of material, are included with-
in Alternative 2A and represent the project sponsor's proposed project.
The impacts discussion included within Alternative 2A will evaluate the
total package of proposed improvements.

In order to fully evaluate the proposed project, the Environmental Protection
Agency selected two alternatives which would affect the scale of the entire
development.  Alternative 2B will evaluate the dredging of 8-10 million cubic
yards of material, while Alternative 2C will evaluate the dredging of under
6 million cubic yards.  Other project features will remain the same for each
of these alternatives; therefore, the effects discussion will be limited to
the impacts of decreasing the quantity of material to be dredged and disposed.
                                     54

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                     ALTERNATIVE 2A - DREDGING OF
                      12-15 MILLION CUBIC YARDS

Alternative 2A represents the dredging of 12-15 million cubic yards of bottom
sediments from Vancouver Lake.  This is the amount of dredging that
would provide for the sailing course while maximizing water quality benefits.
The remainder of the project features are as discussed in the previous pages.
The effects of this alternative are discussed below.

Air Quality

     Short Term

The air effluents created by the dredging machinery would have a negligible
effect on the Vancouver Lake airshed.  No significant adverse impacts are
anticipated; however, specific projections cannot be made until the machinery
and methods to be used have been identified.

     Long Term

Secondary impacts would occur primarily due to an increase in vehicular
traffic around the lake.  The dredging of the lake would significantly
increase the recreational use of the lake, particularly for sailboating
and swimming, thus bringing more vehicles into the area.  However, pro-
jected increases in vehicular traffic are not expected to significantly
decrease current air quality conditions.  Industrial  development in Clark
County, specifically as it affects particulate levels, will  be closely
monitored by the Southwest Air Pollution Control Authority.   Guidelines have
been adopted by that body which will require that any new industrial
developments be thoroughly analyzed to determine their short and long
term effects on the regional airshed.

Topography

The disposal of dredged materials would alter present topographic conditions
along the lake shore.  Proposed disposal sites may experience an elevation
increase of from 10 feet to 22 feet.  The maximum total increase proposed
would bring the Mean Sea Level elevation up to 32 feet, from a present 20
feet.  This change in topography may have effects on certain upland vegeta-
tion types, but any such effects are expected to be negligible.

The configuration of the lake bottom would be that portrayed in Figure 12
if the study plan of 15.4 million cubic yards were to be dredged.  Configura-
tion for 12 million cubic yards would be depths lessened by one foot through-
out the lake bed.  The differential configuration described in the previous
section would be maintained to assist with the flushing characteristics.

Construction of the proposed flushing channel would create a 4,300 foot
long, 15 foot deep and 100 foot wide channel through presently level
ground.  In addition a 100 foot wide cross dike would extend outward from
the inland portions of these channels.  Although the construction of the
flushing channel would change the land configuration, no adverse impacts would
be expected.
                                  55

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The Clark County Park and Recreation Department hopes to use some of the
dredged materials to create topographical variety within the proposed
park areas, providing a range of park and recreation experiences and
vistas.

Soils

     Short Term

Soils would be affected when they are either removed, or covered over
by land disposal activity.  The dredged materials would take up to a year
to dewater and settle, thus making the disposal sites unusable for at least
that time period.  The structure of the underlying soils would be suffi-
cient to handle the disposal materials  and local soils could be used for
diking purposes for disposal cells.  If existing soils were not removed
(particularly the top 4 to 6 inches of organics), good top soil would
be permanently lost.  If they were removed from the site, either for
relocation or eventual return to the site, the impact would be temporary.

     Long Term

The long term effects that may occur at the disposal sites would depend
upon the re-use of the lake soils.  Lake soils are of a substandard
quality, both for building purposes and agricultural purposes.  The
physical and chemical characteristics of the lake soils must be enhanced
and properly managed before the soil characteristics could attain
existing dry land soil conditions.  If the lake soils were placed on the
land and were not conditioned and enhanced, the soil would experience
shifting and settling, and could not support traffic or a diverse vegetation
for a few years.  If the soil were conditioned to attain uniform dewatering,
settling, and compaction, the site could be developed for vehicular and
certain structural functions.  The re-use of the soils for agricultural
purposes would require enhancement with fertilizers and other amendments.

Revegetation of disposal sites as soon as is practicable would alleviate
any long-term increase in erosion potential.

Hydrology and Flood Hazard

The implementation of Alternative 2A would result in significant changes
in the hydrology of Vancouver Lake, through the combination of dredging
to change the lake circulation patterns and construction of the flushing
channel to allow an inflow of Columbia River water.

During low flow periods the flushing channel would introduce approximately
500 cfs into Vancouver Lake from Columbia River.  The flushing flow would
be one-directional into the lake since the flap gates would prevent reverse
flow back into Columbia River.  During the summer, Lake River would continue
to flow in both directions, although the flow to the north would be increased
by about 35 percent.  The circulation model prepared by Dames and Moore  in
the Master Plan indicates that during the summer a tidal amplitude of approxi-
mately 0.7 foot would occur in the lake.  Although this variation is several
                                  56

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      the present amplitude, it is still quite low.  In it's present state,
Vancouver Lake responds to elevation changes in Lake River.  With the flushing
connection, lake levels would also be influenced by the Columbia River at
River Mile 101, resulting in a slight increase in water elevation (0.2 to
0.3 foot) (85).

During low water nonsteady-state periods, the existing flow in Lake
River is two-directional with approximately the same flow rate in each
direction.  The introduction of flushing flow would reduce the southerly
flow of Lake River and increase the northerly flow.  The decrease in
the level of inflow is expected to be about 65 percent of the preflushing
flow, while the increase in the outflow is expected to be 140 percent of
the preflushing flow.

During high flow periods in Columbia River, the flow in Lake River would
be essentially one-directional to the north.  At the southern extreme,
the rate of flow would be essentially the same as the flushing channel
inflow. During high flow periods, the average water level  in the lake
would be increased about 0.5 foot over present levels, while during low
flow periods it would be increased about 0.2 foot (86).

In the past, rapid flooding in the Columbia River has resulted in south-
ward progressing flood surges in Lake River.  The construction of the
flushing channel should lessen the impact of this surge due to the
northward progressing flow through the flushing system (87).

The circulation and velocity model cited in the Master Plan for the
Rehabilitation of Vancouver Lake indicates that the proposed dredging
plan would result in increased water circulation throughout the lake.
Of primary importance is the flushing action that would increase the
flow along the park beach, placing Columbia River water in close proximity
to the shoreline, and the channel along the east shoreline which will
divert Burnt Bridge Creek water directly to Lake River.

The 500-700 cfs flushed from Columbia River through Vancouver Lake
represents approximately .3 percent of the average Columbia River flow.

'•'rivate property owners around the lake have encouraged thp Corps of
Engineers to proceed with the proposed diking improvements in order
to remove additional lands from the floodplain.  Agricultural lands
may be available for placement of dredged materials if diking and flood
control is provided.  Specific placement of the proposed dikes
is presently being  addressed in the Corps draft EIS for the project.
The diking alignment favored by the Corps is shown in Figure IV.

The proposed project is not expected to have any effects on the down-
stream floodplains of Columbia River and Lake River.  During extensive
                                  57

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flooding conditions, the flow from Columbia River into Vancouver Lake
can be controlled so as not to increase the flow in Lake River above
existing flood levels.

The Corps of Engineers Floodplain and proposed levee plans  are shown in
Figure 4.  Dredge disposal areas exist both inside and outside the diking
perimeters.  In flood prone areas the disposal sites will  be individually
diked to protect the materials from flood hazards.  Effects on floodplain
water retention characteristics cannot now be fully assessed.

Water Quality

A variety of techniques have been employed to improve water quality in
lakes.  Nutrient removal or diversion, dredging or flushing have sometimes
proven effective in reducing algal growth and associated water quality
problems (88).  In the case of Vancouver Lake, three separate alterations
in the lake and its drainage basin are included within the proposed lake
rehabilitation program.

1.  Land use patterns and sewage handling practices are expected to change,
which will have an impact on the quality of water and the amounts of algal
nutrients and other contaminants transported  into the lake.

2.  The proposed dredging program would increase the mean depth of the lake
and might alter the character of the sediments at the sediment-water interface.

3.  The proposed diversion of Columbia River water would alter the residence
time and circulation pattern of water in the  lake, and would change the
concentration of algal nutrients in the lake.

Each of these modifications is considered separately in the following dis-
cussion, and finally all are considered simultaneously (since there is some
interaction among them) in an attempt to anticipate their potential impact
on water quality.  It is not possible to predict precisely what the con-
sequences of each of these actions might be.  However, the application
of selected theoretical models and comparisons with other lakes, makes it
reasonable to predict the general pattern of  response to be expected.

     208 Wastewater Management Program

The water quality of Vancouver Lake is directly influenced by the pattern of
land use in its drainage basin.  Extensive urbanization in the Burnt Bridge
Creek drainage basin has led to the creek transporting increasingly greater
amounts of sediment, algal nutrients, and other materials into Vancouver
Lake,  In addition, agricultural use of land  around the lake also produces
sediment and algal nutrients which are transported to the lake.

The goal of the proposed 208 program in Burnt Bridge Creek is to bring the
water quality within the accepted state and federal water quality standards.
In order to achieve this, a variety of management and land use control
techniques have been proposed.  Studies prepared  during the 208 program
                                  58

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indicated high phosphorus,  septic tank intrusion and heavy metal  levels
reached the stream due to surface storm runoff (89).  In response to
that, the 208 Program proposes that the "first flush" storm runoff should
be diverted to the sanitary sewer system to alleviate that source of
stream contamination.  In addition, a variety of land use, septic tank,
construction and erosion control  measures have been proposed to further
assist in the attainment of existing state and federal  water quality
standards.  Until the proposed Burnt Bridge Creek Drainage Management
Plan has been implemented,  the specific increases in water quality levels
cannot be evaluated.  It is doubtful, however, that the proposed  measures
will totally eliminate the deleterious effects of urban runoff on water
quality in Vancouver Lake.   For that reason, proposed circulation within
the lake has been designed to move Burnt Bridge Creek water directly to
Lake River, allowing it only marginal contact with the remaining  water in
the lake.

It is expected that implementation of the Burnt Bridge Creek Drainage
Management Plan, and the yet to be completed non-point source control
measures, will result in a decrease in the level of nutrients reaching
Vancouver Lake from those sources.  Whether these nutrient sources will
be too low to support further algal growth is unknown.

     Dredging and Removal of Bottom Sediments

Dredging would increase the mean depth of the lake and should improve the
character of the sediments exposed at the sediment-water interface.
The increase in mean depth resulting from dredging would be less  than
three feet; however, the depth would not be uniform throughout the lake.
This increase in mean depth would reduce the tendency for wave action
to resuspend bottom sediment.  At times, Vancouver Lake is noticeably
discolored by fine turbidity, probably largely derived from resuspended
fine sediment.  Since wave induced turbulence declines exponentially
with depth, the proposed dredging may cause a considerable reduction
in the resuspension of sediment (90).

An increase in mean depth would also reduce the average amount of light
available for algal growth throughout the water column.  However, it is
very doubtful that an increase in mean depth of less than three feet could
have a significant impact on algal growth.  The lake would still  be  very
shallow, and in addition, any decrease in turbidity would increase light
availability.

Deepening the lake should, to some extent, alter the character of the
sediment exposed at the sediment-water interface.  Sediment can,  in
some instances, provide a source of nutrients to the overlying water,
and the leakage of phosphorus from the sediment can be considerable  in
shallow lakes (91).  However, it does not appear that the nutrient supply
in Vancouver Lake sediment is particularly high.  The sediment is described
as blue or grey clay, silt and sand and, at least for agricultural purposes,
low in nitrogen and very low in phosphorus (92).
                                  59

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There is some evidence, however, that at least the surface layer of sediment
currently supports algal growth (93).  Removing this surface layer could
reduce the availability of nutrients from the sediment.  Nonetheless,
supplies of nutrients already in the water from the drainage basin are
more than adequate to support algal blooms, so that removing sediment
bound nutrients could have little impact.  In addition, the soil ex-
ploration program carried out during the preparation of the Master Plan
indicated that while the upper few inches of sediment "do generally contain
higher levels of nutrients than lower sediments, there is little variability
in nutrient levels below the upper active layer, and the levels of nutrients
in the lower zone are still significant (94)".  The Master Plan goes on
to conclude that "because the levels of nutrients in the underlying sedi-
ments are significant and because the flushing water itself is expected
to contain substantial amounts of nutrients, it is our opinion that dredging
only to remove the interface soil would be of little lasting water quality
benefit (95)."  Based on that conclusion the Master Plan presented a dredging
plan designed to improve lake circulation and to maximize recreational use
of the lake.

There have been very few studies of the effectiveness of dredging on water
quality in lakes, although there is some evidence that dredging can improve
water quality in certain instances (96).  However, the lack of any extensive
literature and the lack of sufficient data on Vancouver Lake make it im-
possible to anticipate precisely what the impact of dredging Vancouver Lake
might be.

The Pilot Dredge Study and Master Plan for Rehabilitation of Vancouver
Lake evaluated the short-term effects of dredging on the water quality
in Vancouver Lake.  The following discussion is based  on the findings
presented in those reports (97).  Dredging may affect surface water
quality at the point of excavation and in the area were discharge from
the disposal site returns to the lake.  Generally, only minor effects
limited to short-term increased turbidity, occur at the dredge head.  A
monitoring program was carried out during the pilot dredging of Vancouver
Lake to determine the effects of dredging discharge on the lake.  Mercury
was found to occur in significant quantities (0.6-1.1 ug/L) in the dredge
disposal effluent.  Subsequent bioassays of specimen fish, including
bottom feeders found very little incorporation of mercury, however.
The mercury would probably settle to the lake bottom within a relatively
short radius of the effluent discharge from the retention point (98).

Zinc and copper were also detected in significant quantities in the
disposal pond effluent; however, subsequent fish specimen bioassays
indicated that the residues of these metals were comparable to or less than
concentrations found in a limited sampling of the same species from other
parts of the country.  Like mercury, zinc and copper are expected to absorb
onto particulate matter in the disposal pond effluent to a great extent,
hence settling within a short distance of the discharge (99).
                                   60

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     Diversion of Columbia River Vlater  Into Vancouver Lake

Diversion of Columbia River into Vancouver Lake could be expected to
significantly alter the limnological conditions of the lake.  The mineral
composition of the lake could be expected to improve and to closely resemble
Columbia River water, since the volume of flow being considered for flushing
(600 cfs) would greatly exceed the present flow through the lake (approxi-
mately 50 cfs from a combination of stream flow, groundwater flow and
precipitation.)  Flushing water introduced from Columbia River would tend
to deposit coarser sediments as the flow entered Vancouver Lake.  As a con-
sequence the proposed sediment traps located at the inlet of the flushing
channel to the lake would gradually become shallower.   Analysis by Dames
and Moore indicated that about 35,000 cubic yards of suspended sediment
would enter the lake annually.  They further estimated that this sediment
would accumulate in the sediment trap to a thickness of about 2 feet
within ten years.  This rate of sediment accumulation could be reduced
by excluding flushing water from the lake during periods of high sedi-
ment content in Columbia River
The benefits of flushing in reducing the tendency for a lake to become ex-
cessively eutrophic or to produce excessive algal growth stem from two separate
influences.  First, if the water used to dilute a lake is low in nutrients, the
concentration of nutrients will be lowered, which can lead directly to reduced
algal growth rates (101).  Second, if the flushing rate is great enough, algae
may simply be so rapidly washed out that they are unable to develop significant
populations (102).

The diversion of Columbia River water into Vancouver Lake can assist in reducing,
to some extent,  eutrophic  conditions in the lake.   Nutrient dilution has
been shown to be an effective technique for Green Lake, Seattle, Washington
and to be of some benefit for Moses Lake, Washington, where Columbia River was
used as dilution water (103).  However, the Columbia River at Vancouver, Wash-
ington, at times carries relatively high concentrations of algal nutrients
(78 ug P/l for average total phosphorus, and 254 g NO^-N and 70 ug NH^-N/1 average
nitrate and ammonia nitrogen).  These amounts of nutrients are sufficient to
promote rapid algal growth.  Any nitrogen and phosphorus derived from the drainage
basin or bottom sediment would only add to the nutrient supply.  The Control Plan
for the basin will work towards minimizing these supplies.

As shown in Table 15 the nutrient content of Columbia River varies seasonally,
thus flow into the lake could be regulated to minimize the entry of sediment
into Vancouver Lake.  The total phosphorus category is the most relevant to
this analysis since it is the most widely used measure of nutrient enrich-
ment.   Recent sources have stated that it is therefore more relevant to
the question of increasing algal productivity to view the phosphorus
concentrations in terms of total phosphorus, since most of the phosphorus is
bound in the particulate components at any given time (104)."  The majority
of the recent models also use total phosphorus as the major nutrient indicator.
Although nitrogen levels can also be used as an indication of potential
algal  productivity, significant nitrogen-fixing algae currently exist in
Vancouver Lake indicating that the presence of high levels of nitrogen
are not necesseary for algal production.
                                  61

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                               TABLE  15
                    Columbia  River Nutrient Content


                                             mg/1              Total
                              Nitrogen   Ortho Phosphate     Phosphorus

At Bonneville (above Vancouver)

     May - October            0.080          0.029             0.074
     Nov. - April             0.363          0.034             0.084

At Longview Bridge  (below Vancouver)

     May - October            0.163          0.011             0.122
     Nov. - April             0.530          0.060             0.417

Control of algal growth conditions by displacement would require very
high rates of dilution.  Algal growth rates can easily exceed one doubling
every two days; therefore, control of algal growth by washout is effective
only when the entire volume of a lake is replaced in two or three days (105).

It would require a  flushing flow in excess of 1500 cfs to replace the
entire volume of Vancouver Lake in three days at minimum lake volume (mean
depth of four feet).

It has been suggested that diversion of Columbia River water into
Vancouver Lake would drastically reduce algal growth in the lake O06)-
Since the Columbia  River supports a considerable population of algae, such
a prediction is questionable  (107).  In addition, algal growth in Columbia
River is believed to be largely determined by light availability (108).  The
much shallower depth of Vancouver Lake would prevent the light limitation
evident in the Columbia River, and it is expected that algal production
within the lake would continue.


     Combined Effects of Dredging & Diversion of Columbia River Water

Since 1966 a variety of studies have been performed to determine the most
feasible method to  clean up Vancouver Lake and make it available for public
use and enjoyment.  The first full scale study was prepared by the
College of Engineering Research at Washington State University and recommended
three major steps to restore lake water quality:  1) control of pollution
entering the lake,  2) dredging of the lake to remove nutrient rich bottom
sediments and increase recreational potential, and 3) introduce flushing
flow of Columbia River water into the lake.  A subsequent study prepared
by Stevens, Thompson and Runyan further refined these recommendations and
suggested that dredging the lake could also serve to enhance circulation
within the lake (109).  The most recent study, Master Plan for the
Rehabilitation of Vancouver Lake was completed by Dames and Moore.
This report suggests that the same three steps be taken to enhance lake
water quality, but  that the major purpose of dredging be to allow more exten-
sive recreational use and to improve water circulation within the lake (110).
                                    62

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None of these reports suggests that the combined restoration efforts would
convert Vancouver Lake into a pristine, clear body of water, but they all
project that the water quality within the lake would be improved to the
extent that increased recreational use would be possible.

Dredging Vancouver Lake would increase both the mean depth of the lake,
and the hydraulic residence time.  Diversion of Columbia River water into
the lake via the proposed channel would, in turn, decrease the hydraulic
residence time and introduce additional supplies of algal  nutrients,
although at substantially lower concentrations.  All of these alternatives
can be considered simultaneously using the "Nutrient Loading Concept"
developed by R. A. Vollenweider and his co-workers (111).  In developing the
parameters of this model, a range of conditions are considered in order
to assess the predicted impact of a variety of alternative procedures.
These alternatives are outlined in the following Tables 16 and 17 and
then presented graphically in Figure 13 to compare with Vollenweider's  model


                          TABLE 16

           PHOSPHORUS LOADING FROM COLUMBIA RIVER

                              Added Flow
                            from Columbia         Phosphorus Loading
                                 River               (gP/m2/yr)

Assumed phosphorus            100 cfs                  0.339
concentration in
inflow of                     600 cfs                  2.035
40 ug P/L*
                            1,000 cfs                  3.395
Assumed phosphorus            100 cfs                  0.764
concentration in
inflow of                     600 cfs                  4.578
90 ug P/L*
                            1,000 cfs                  7.640

*Representative values for high and low concentrations  of  phosphorus
observed in Columbia River (Beak 1977).
                                 63

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   1O-
O)

5
(0
o



o

a

o
£
a.
    .1 -
            EUTROPHIC
                                                          90 pg P/l
                                                           40>jg P/l
                                               OLIGOTROPHIC
1 — •—• ' ' 	 1
1
— 	 I 	 1 — -
10
1 • ""I • • •
100
            13'Annual  Phosphorus Loading to Vancouver Lake using
                Columbia River water for flushing at various rates.

                (Adapted from Vollenweider and Dillon 1974).

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                               TABLE 17

             RELATIONSHIP OF MEAN DEPTH AND RESIDENCE TIME

                Added Flow         Residence
               From Columbia          Time        Depth/Residence
                River (cfs)           (Year)            Time

Mean Depth of
1 Meter
(Before dredging)   100              0.118              8.5

                    600              0.0193            51.8

                  1,000              0.0118            85.5

Mean Depth of
3 Meters
(After dredging)     100              0.353              8.5

                    600              0.0589            50.9

                  1,000              0.0353            84.8

Volume at one meter depth =  1.052 x 107 m3

Volume at three meter depth  = 3.156 x 10? m^


The results of these calculations are presented in Figure 13, which
includes lines indicating admissible and dangerous levels of phosphorus
loading.  The shaded area in the figure represents the expected status
of the lake due to nutrient  loading from the proposed addition of
Columbia River water alone.   It is clear from this graph that the greater
the addition of Columbia River water, the more eutrophic the lake may be
expected to become.  When existing sources of phosphorus loading (from
the existing drainage basin  and from sediment in the lake) are included
in the nutrient budget, the  Vollenweider model predicts that Vancouver
Lake would remain a eutrophic lake, with or without dredging, and with
or without the addition of flushing water.

The pattern of dredging and  the position of the proposed flushing channel
are designed to promote "short circuiting" of the flow from Burnt Bridge
Creek directly to the outflow, Lake River, and also to provide a flushing
current of Columbia River water along the swimming beach at the park.
This flow pattern would help reduce bacteria populations in the rest of the
lake and provide the cleanest possible water along the swimming beach.
The Master Plan indicates, however, that in order to increase water
quality to the level required for water contact sports, it may be necessary
to provide a supply of cleaner water (preferably from a groundwater
                                  64

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source) along the swimming beach (112).  The reduced residence time of
water in the lake could prevent the accumulation of a large standing popu-
lation of algae.  Since the inflowing Columbia River water would be some-
what cooler, it would tend to flow into the lake on the bottom and could
displace or prevent major surface accumulations of algae out of the
lake.  Thus, although nutrient supplies would support rapid algal growth,
the additional flow could reduce any deleterious impacts by temperature
influences and surface water flushing.


Vancouver Lake can be expected to remain a eutrophic body of water after
dredging and with the addition of Columbia River water because there would be
a sufficient supply of nutrients, sufficient residence time (15-20 days)
and  sufficient light availability to ensure significant algal production.
However, the shorter residence time of water in the lake would reduce the
tendancy for large standing crops of algae to develop.  Although the
lake would still be considered eutrophic (30-100 ug P/l), the proposed
restoration procedures would reduce its movement towards a hypereutrophic
condition (in excess of 100 ug P/l).  As Columbia River water quality is
improved and nutrient sources from the watershed are eliminated, the nutrient
levels are expected to continue to decline.

It is important to note that neither eutrophic conditions, nor the presence
of algae render a lake unusable for recreation purposes.  In fact, many
of the most widely used recreational lakes in both Washington and Oregon
are  characterized by both conditions.

The  State of Washington has not established specific standards of coliform
levels for water contact recreation.  However, within the State's Lake
classification total coliform levels are not to exceed 240/100 ml with
20 percent not to be greater than 1,000/100 ml if fecal coliform is
present  (113).  Present conditions in Vancouver Lake indicate that maximum
coliform levels approximate 100,000/100 ml total coliform, while 10-40
percent of the total coliforms are fecal coliforms.  The coliform bacteria
counts in the Columbia River, while far better than the existing conditions
in Vancouver Lake, sometimes approach marginal levels for water contact
recreation  (mean is 2,600-1,000/100 ml) 014).  On the basis of
those estimates, the Master Plan for Rehabilitation of Vancouver Lake
recommends that water quality in the vicinity of the swimming beach be
enhanced during swimming season by the discharge of ground water to the
swimming area (115).  The Master Plan estimates that a single well with a
capacity of about 1,000 gallons per minute (gpm) could be used to pump
water to the surface where it could be directed to two discharge points
along the beach.  "The flow of well water would act both to dilute and
displace the lake water.  Since the well water should have very low concen-
trations of coliform bacteria, it should significantly increase the quality
of water at the beach (116)."  Water quality and coliform levels along the
beach would be monitored and groundwater would be diverted to the beach as
necessary.

Fisheries

     Short Term

The  construction of the flushing channel would cause considerable turbidity
both at  Columbia River and Vancouver  Lake.  The increased turbidity could


                                  65

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adversely affect Columbia River fish runs and nearby downstream fishing.
However, these effects would be temporary and the extent of the impacts
would be dependent upon the time of year of the construction activities.
Maintenance dredging of the flushing channel  sediment trap within the
lake would be required every 10 years (117).  No estimates have been prepared
for maintenance dredging within the flushing  channel itself.

In-lake impacts would occur where the dredging takes place (at the pipe-
line head) and at certain disposal  sites.  The effects of the actual
dredging are expected to be slight,  although the spread of turbidity
would be greatly affected by specific wind and current conditions.  The
disposal of dredged materials in Mulligan Slough, the south embayment and
along the northeast shore would have adverse  impacts upon the fisheries.
Disposal in these areas would destroy feeding and spawning areas.  If
disposal in wetland areas of Mulligan Slough  occurred in spring or early
summer, it would destroy considerable numbers of fish.

Return waters from the dewatering process would have a short term impact
on the lake fish, but this is expected to be  minimal.  Removal of the lake
bottom sediments would eliminate certain toxics from the fish environment
which should have a favorable impact on local populations.

Washington State University conducted surveys in 1967-68 that involved
bottom sampling in various parts of the lake.  The benthic organisms
collected included Naididae, Chironomid and Nematoma worms.  No other
epifaunal or infaunal organisms were collected.  The most common organisms
were worms of the family Naididae which characteristically inhabit shallow
and turbulent waters.  Dredging would eliminate such organisms from specific
areas of the lake during the short-term.  Repopulation would be expected.

Columbia River water is expected to warm at the rate of approximately
1°C. per day upon entering Vancouver Lake.  Thus in six days time, the
water is expected to warm 6°C. (10°F.).  It is anticipated that this  warming
factor would be sufficient to increase the Columbia River waters to
meet the spawning needs of the spiny-rayed fishes in the lake.

     Long Term

The flushing channel could permanently alter  nearby Columbia River shore
contours, which may affect immediate area fisheries.  This effect should
be minimal, however.  The Washington State Department of Fisheries believes
that the flushing channel will lure migrating salmonids, which would
disrupt their natural migration processes.  Juvenile salmonids, if allowed
to enter the lake, would probably fall prey to resident spiny-rayed fishes.
The Department of Fisheries has indicated that screening of the flushing
channel would be necessary in order to prevent juvenile salmonids
from entering the lake during their fall downstream migration.  Screening
criteria for water diversions typically require that screen openings  should
not exceed 1/8 inch in the narrow direction,  and approach velocities  should
                                  66

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not exceed 0.5 feet per second as measured at the gross area of the screen.
These screens would be placed at the entrance to the flushing channel, where
the Columbia River water entered the channel.  The construction of these
fish screens would entail considerable engineering design, impacts or
costs of which cannot now be determined.  Screens would be self-cleaning,
and effective at Columbia River levels ranging between +2 and +16 msl.


The deepening of the lake may enhance the over-all fir.h habitat, increasing
the carrying capacity of the lake and diversifying available niches.
Where a pilot dredge study hole was dredged in the southwest corner
of the lake, it was found that a marked number of lake fishes soon moved
into the deeper waters.  Deeper waters, thus an increased total environment,
may encourage an increase in size of resident fishes.

If the spiny-ray fish population in Vancouver Lake were enhanced due to lake
rehabilitation, the Washington State Department of Fisheries believes that
an adverse impact upon the salmon fisheries of Lake River could occur (118).
During the spring season juvenile salmon migrate down Salmon Creek and
through Lake River on their way to the Columbia River.  These small finger! ings
would be susceptible to predation by larger spiny-ray fishes, primarily bass.
An increased spiny-ray population in Vancouver Lake could result in an in-
creased spiny-ray population in Lake River
The placement of dredged materials in Mulligan Slough or its surrounding
wetland areas, would have a significant adverse impact on the lake fisheries.
Disposal in these areas would permanently destroy the most important
spawning areas of the entire lake.  There are few areas in Vancouver Lake,
Lake River, or Burnt Bridge Creek that have comparable conditions, and
none offer so large an area.  The specific role played by Mulligan Slough
will be more evident after completion of the on-going wetlands inventory.

Vegetation and Wildlife

     Short Term

Alternative 2A would have varying effects on the local vegetation and wildlife.
The construction of the flushing channel would destroy vegetation and
habitat, but should not cause significant losses.  The channel would
primarily cut through pastureland and open areas.  Vegetation loss would
be minimal, and though some mammals would be lost, most of them could
easily relocate.

The dredging of the lake should cause minimal effects on waterfowl, given
that dredging activities were not undertaken by several dredges at once.
The lake is large enough for visiting waterfowl to stay away from, and
thus not be disturbed by, the dredging.

The disposal of dredged materials in Mulligan Slough and other recognized
important wildlife areas would cause immediate disturbance to local wild-
life species.  The destruction of nesting and feeding areas would seriously
impact waterfowl and songbirds, as these species would be forced to relo-
cate.  Relocation may be difficult, as surrounding habitats are near carrying
capacity now.  Limited nesting areas are available to such waterfowl as woodducks,

                                   67

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thus the destruction of any nesting areas could severely impact area populations.
Raptors and mammals would be affected by loss of habitat, but relocation
would be possible for predator/prey relationships.  Most invertebrates
in the area would be lost, as would all  wetland vegetation communities
in the areas of disposal.

     Long Term

The flushing channel may affect seasonal mammalian movements in the area,
as the channel would present a very real barrier to certain species.  The
channel would be too great for small  mammals to circumvent (mice, squirrels,
oppossums, rabbits, skunks, and possibly raccoons).  Although deer should
be able to swim the flushing channel, its presence would create a barrier
restricting their habitat.

The dredging of the lake should cause no significant problems for waterfowl,
except that feeding may be restricted for the "dabblers".  Since the
pond ducks (dabblers) do not diver, they are restricted in the depth of
water available to them for feeding purposes.  However, the deepening
of the lake may prove to be advantageous to the diving ducks, as they
prefer deeper waters in which they can actually dive  for invertebrates
and small fish.  Available feeding areas for the great blue heron would
be reduced, but adequate feeding would still be present along the entire
shoreline of the lake.

Increased recreational use of the lake,  particularly in terms of boating,
would have an adverse impact on wildlife usage of the lake.  Waterfowl
and waders would be more constantly disturbed by human activities, thus
inhibiting their use of the lake.

The long-term effects of dredged material disposal would be most marked
at Mulligan Slough, and on the west side of the lake.  The inundation of
these areas would permanently destroy wetland habitat, which is important
to waterfowl, invertebrates, and certain flora.  Nesting areas for wood
ducks, teal, and mallards would be lost.  Favorable habitat for swallows,
warblers, vireos and flycatchers would be destroyed.  These losses must
be considered significant because similar habitat is rapidly decreasing
in the urban regions.  The diversity of the regional environment is
commensurate with the stability of that environment.  (Evaluation of
the specific disposal sites is included within Alternative 3.)

Significant Wildlife Areas

     Short Term

The construction of the flushing channel would result in short-term
adverse effects on the nearby fishing areas of the Columbia River noted
on the Significant Wildlife Areas Map, Figure 7.  These areas, parti-
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cularly the site immediately adjacent to the channel area, would experience
excessive turbidity.  These turbidity problems would occur until construction
in the area was completed.

The dredging of the lake would cause some adverse impacts on the lake
surface migration activity if dredging occurred during the migration
season.  As long as several dredges were not working concurrently, the
impact should not be significant.  The size of the lake should allow for
adequate space between waterfowl and dredge to minimize disturbance.

The disposal of dredged materials would cause adverse impacts on certain
areas of the lake shore.  Mulligan Slough would be affected by the
destruction of various invertebrates and some small mammals (shrews,
moles, etc.).  If disposal took place during the spring or early summer,
significant numbers of spiny rayed fish would be destroyed while they
were attempting to spawn or rear their young.  Nesting songbirds and
waterfowl would lose their nests, and the riparian and aquatic vegetation
would be destroyed.  The disposal of dredged materials in the Buckmire
Slough area would also destroy songbird and waterfowl habitat, with the
most adverse impacts occurring in the spring and early summer.  Some
spawning areas may be destroyed in the northern portion of Buckmire
Slough.

     Long Term

The deepening of the lake may change the migratory use of the lake by
waterfowl, but not to a significant extent.  Dabblers may do more feeding
in the Shillapoo Lake area, because of difficulties in feeding in the
deeper lake waters.  Divers, on the other hand, may find the deeper waters
more favorable.

The disposal of dredged materials in a portion of Mulligan Slough or adjacent
wetlands would seriously impact the wildlife characteristics of the area.
Spawning, nesting, and feeding for many and various species of vertebrates
and invertebrates occurs within these wetland areas annually.  The area
must be considered the single most important eco-type within the entire
project area.  It is the most important spiny rayed fish spawning area
and has the largest area of relatively undisturbed marshland and wetland.
It contains the thickest belts of riparian vegetation, which provide
important waterfowl and songbird nesting habitat.  Also, the wetland
habitat produces vast amounts of mico-flora and micro-fauna that ultimately
plays an integral role in the life-processes of the entire lake eco-
system.  The filling of a portion of this area would destroy an irreplaceable
biological resource of the Vancouver Lake environment.

Disposing of dredged materials adjacent to the Buckmire Slough area
would destroy wood duck and teal nesting grounds, as well as songbird
habitat and fish spawning areas.  These areas are fairly heavily used
by the wildlife groups because there are not many alternative areas avail-
able in the vicinity.  The spawning grounds are primarily located in
the northern part of Buckmire Slough.  The avifauna habitats are shown
on the Significant Wildlife Areas map.
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Population Growth/Economic Base

The restoration of Vancouver Lake is not projected to have any significant
long-term effects upon local population growth.  Creation of a more pleasant
lake environment could enhance the property values of those residential areas
that either view the lake or are within walking distance.  However, this would
only result in a minor shift of population within the general western portion
of Vancouver.

The creation of a widely used recreation facility in close proximity to
the City of Vancouver could result in an increase in tourism to the area.
Local gas stations, grocery stores and convenience restaurants would benefit
from the recreationists visiting the lake during the summer months.  The
Olympic sailing course could also be expected to draw large numbers of
spectators who would frequent local  commercial  enterprises.

By 1980 it is projected that approximately 1,705,000 recreation occasions
would occur annually at Vancouver Lake Park if lake restoration efforts were
undertaken.  This would result in recreation benefits of approximately
$4,000,000 (120).  In addition, the construction of adjacent recreation
facilities such as a marina, golfcourse or baseball/softball  facility would
expand the local economic base and generate additional  revenues.

A previous plan for the flushing channel was designed to allow barge traffic
and a barge loading facility, or marinas and other related activities along
the channel.  These plans have been abandoned and the present flushing
channel design would not accommodate such uses.

Land Use Plans and Policies

Selection of the 2A Alternative is consistent both with the adopted Vancouver
Lake Land Use Plan and the preliminary Clark County Comprehensive Plan Goals
and Guidelines.  Both documents have designated this area for a mix of high
intensity recreational, agricultural and industrial activities.  At the
present time, the agricultural activities within the project area specialize
in income-producing row and specialty crops.  As long as these crops remain
profitable, conversion to more intensive uses would probably not occur.  Both
the preliminary comprehensive plan and the Vancouver Lake Task Force report
outline strategies to be instituted by the county for preservation of agricul-
tural land.  If these strategies are implemented, the intensification of
recreational activity within the area should not adversely affect the mainten-
ance of agricultural activities.  Placement of dredged materials on currently
productive agricultural land would be contrary to the Vancouver Lake Land  Use
Plan since it would remove that land from productive use for a period of time.

The sediments dredged from the lake are not expected to be of sufficient quality
for use as structural fill material.  Therefore, placement of materials on
areas designated for future industrial use would render the land unusable  for
that purpose and would be in contradiction to the intent of the Vancouver
Lake Land Use Plan.

208 Areawide Wastewater Management Program

Alternative 2A is the alternative recommended by the Regional Planning Council
of Clark County in its 208 planning program.  In combination with the control
of non-point source pollution, they believe this alternative would best achieve
Clark County's water quality and land use goals.

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Recreation

The restoration activities outlined in Alternative 2A would support
the recreation plans developed for Vancouver Lake by the Clark County
Park and Recreation Department.  These plans include construction
of an Olympic sailing course in conjunction with the Vancouver Lake
Sailing Club, as well as development of a number of facilities at
Vancouver Lake Park including swimming, picnicking, play fields,
nature areas and a youth camp.  The park has been designed to provide
a variety of both passive and active recreational options and it
appears that the planned facilities recognize the value and limita-
tions of the various habitats existing within the park boundaries.

Clark County Park and Recreation Department has indicated that they
expect that the Port of Vancouver would be involved in the implemen-
tation of the park master plan, but that the county would be respon-
sible for the operation and maintenance of the facilities once they
were constructed.

Selection of the 2A Alternative would allow both shoreline and in-
lake recreational activity.  Dredging under this alternative would  be
sufficient to allow the establishment of an Olympic sailing course  in
the south central portion of the lake.  The current county plans do
not call for motor boat use of the lake, which, if it were to occur,
would conflict with both sailing and fishing use of the lake, due to
the lake's rather uniform shallow depths.  Some conflict between sailing and
fishing use of the lake could be expected to occur since the pilot  dredge
study indicated that the fish moved quickly into the deeper dredged areas
of the lake.  If the fishermen and sailing enthusiasts both wish to utilize
the same areas of the lake, some conflicts could be expected.  However, these
could be minimized by the creation of use zones within the lake water areas.

Dredging of a deeper channel along the western shoreline and placement
of sand materials in that area would create an adequate swimming beach
for a large number of recreationists.  Quiet water swimming areas are
much in demand in the metropolitan area, and the easy access to Vancouver
Lake should make it a popular warm weather picnicking and swimming  area.

The Vancouver Lake Park Master Plan outlines recreation facilities
capable of accommodating a large number of recreationists.  The park's
proximity to the Portland metropolitan area and the continually
increasing demand for water-related recreation areas support those
plans.  If the case of Scoggins Reservoir is applicable to
Vancouver Lake, then initial use may surpass early estimates.
Park planners have been careful to provide parking facilities in a
manner that may limit the chance of over use of the facility.

Historical and Archaeological Resources

Before the placement of dredged materials can occur, an archaeological
inventory of the project area must be undertaken.  Evidence of over
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40 archaeological sites within the area was determined by the Washington
Archaeological Research Center.  The condition and significance of
these sites is currently unknown.  In addition to the disposal of
dredged materials, increased recreational use and wave action along
the shorelines could have adverse impacts upon these sites.

Mitigating Measure

Measures to mitigate the short-term effects on dredging and the disposal
of the dredged material are discussed under Alternatives 3, 4 and 5.
Placement of screens on the flushing channel culverts to prevent juvenile
salmonids from entering the lake has been proposed by the Washington
State Department of Fisheries.

Short-term Resource Use vs. Long-Term Productivity

Economic, social and environmental systems are seldom static, but can
usually be viewed as a continuum moving from what they were in the past,
to what they will be in the future.  A significant concept in the evalua-
tion of effects is:  What effect does a potential project have upon those
trends?  Does the project slow down, or speed up the trend, or does it
move the trend in another and different direction?

In the case of Vancouver Lake, we are faced with two distinct trends —
a natural system trend and a human trend.  Over the past years Vancouver
Lake has evolved from an integral part of the Columbia River system, to
a highly eutrophic lake characterized by high levels of nutrients and
bacteria.  The lake has continued to become shallower and if left in
its natural state would eventually infill to a greatly increased extent.
Although extensive wildlife habitat is available in the wetlands and
sloughs surrounding the lake, human use of the lake is very limited due
to its poor water quality.  The lake's eutrophication process has been
encouraged by the extensive growth that has occurred within the Vancouver
area over the past 20 years.  Increasing construction activity, storm
runoff and inadequate sewage disposal has added to the natural processes,
resulting in a decreasing level of lake water quality.  In addition, the
population growth in Clark County and the Portland Metropolitan area
has created a clear demand for increased public facilities, including
recreation.  Vancouver Lake's proximity to the urban area and under-
utilization has made it a focal point for future recreation plans.

The federal government through the implementation of the Environmental
Protection Agency's Clean Lakes Program has determined that public monies
should be expended to restore lakes such as Vancouver Lake.  Thus federal
policy actively supports changing the natural systems in some lakes, when
those natural  systems have been degraded by human activities, to improve
their water quality and, hence, their usability.  In the short-term, the
restoration of the lake would result in localized decreases in water quality
as a result of the proposed dredging activity.  Short-term losses of pro-
ductivity and wildlife habitat use would also be associated with the place-
ment of dredged materials on the lands surrounding the lake.
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The proposed restoration program and its maintenance would increase the
future usability of the lake for local and metropolitan area residents.  By
decreasing the lake's long-term production of nutrients and its coliform
levels, future recreation uses can be greatly enhanced.  The only major,
long-term adverse effect of the proposed project would result from the
destruction of significant wetland habitat through inundation with
dredged materials.  The results of an on-going study are intended to
identify Class I and other significant wetland areas.  Placement of
dredqed materials on those lands would not support the President's
Executive Order concerning wetlands, as well  as to EPA's wetlands policy.

The selection ororess for determining specific dredqed material disposal
sites would be closely tied to a direct understanding of the tradeoffs and
relative values associated with a variety of land uses.  Placement of
materials on Class I wetlands would not be supported by federal policy,
while placement of materials on productive farmlands or designated indus-
trial land would not be supported by the Vancouver Lake Land Use Plan.

Irreversible and Irretrievable Resource Commitments

The major resource commitments involved in lake restoration would be
the inundation of the disposal sites with lake bottom sediments and the
funds spent during the dredging and construction activities.  If wetland
areas were covered with dredged materials, a significant habitat area would
be lost to the local and regional ecosystem.   The placement of dredged
materials on other lands around the lake would result in short-term losses
of productivity and use, until the soils were settled and prepared for a
new use.  The commitment of the approximate $15,000,000 necessary to
complete the proposed project must be weighed against the benefits in
both enhanced water quality and recreation opportunities that would result
from the proposed program.
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                    ALTERNATIVE  2B  -  DREDGING  OF 8-10
                          MILLION CUBIC YARDS
Alternative 2B suggests that 8-10 million cubic yards of material be dredged
from Vancouver Lake, as opposed to the 12-15 million cubic yards outlined
in Alternative 2A.  This dredging plan would allow maximum dredging for
circulation, but would not include dredging of the Olympic sailing course,
which would result in decreased spoils disposal near Site 5 and 6.  The
remainder of the dredging and spoils disposal  would occur as outlined in
Alternative 2A.  Only those areas in which impacts would differ between
Alternatives 2A and 2B are discussed below.  The estimated cost of
Alternative 2B would be approximately $12,500,000.

Air Quality

The dredging of 8-10 million cubic yards  of lake bottom sediments would
have the same general impacts as would occur if the project involved the
dredging of 12-15 million cubic yards. The total  emissions would be slightly
less, due to less operating time required by the dredge machinery,
and possibly less vehicular traffic due to the elimination of the sailing
race course.  However, these differences  would probably be negligible.

Topography

The dredging of 8-10 million cubic yards  would lessen the total amount of
fill material that would be deposited on  Sites 5 and 6.  Thus, the topo-
graphic change from existing conditions to post-disposal conditions
would be less marked.  No significant effects should be anticipated.

Soils

The same relative effects could be expected from Alternative 2B as were
outlined in Alternative 2A.  Where the native soils were buried, they
would be permanently lost.  If scraped to the side for reuse or reloca-
tion, the impact would be temporary.

Hydrology and Flood Hazards

The general hydrological effects that are discussed in Alternative 2A
would apply under selection of this alternative.

There would be no impacts on the flood hazard potential.

Water Quality

Because the hydrologic conditions within  the lake would remain as they
were with Alternative 2A, no change would be expected from those pre-
dicted for that alternative.  Sufficient  sediments would still be removed
from the lake to possibly decrease the existing nutrient load, and the
channels along both shorelines would provide increased circulation.
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Due to lessening the volume of water in the lake, it is possible that
the residence time would be shortened somewhat.  However, it is doubtful
if the shortened residence time would be sufficient to provide any
noticeable effects.

Fisheries

There would be very little difference in the impacts experienced between
this alternative and alternative 2A.  A little less deep water habitat
would be available to the fishes and the water could remain slightly
warmer. However, these changes would not be expected to be significant.

Vegetation and Wildlife

Alternative 2B would have less impact upon the vegetation and wildlife
than Alternative 2A due to the reduction by 3-7 million cubic yards in the
amount of lake bottom materials to be dredged and disposed.  This smaller
quantity of dredged material would result in the destruction of less
vegetation and wildlife, particularly in Sites 5 and 6.  Since Site 5
and 6 both contain signficant wetland habitats, disposal of less material
on these sites would greatly decrease any adverse effects that could
result from the destruction of wetland habitat.

Significant Wildlife Areas

Decreased recreational use of the lake, particularly in the southern
portion, would increase the use of the lake by migratory waterfowl. The
large, shallow area in the south central portion of the lake would
provide suitable habitat for migrating waterfowl to use for loafing and
feeding.

If Alternative 2B would eliminate the need to fill significant wetland
areas within Sites 5 and 6, any adverse impacts related to project con-
struction would be significantly lessened.  (A discussion of specific
dredged material disposal effects relating to the individual sites can
be found in Alternative 3.)

208 Areawide Wastewater Management Program

Selection of Alternative 2B would allow implementation of the lake
rehabilitation portion of Clark County's 208 program.  Although the
recreation benefits would be decreased over those to be realized in
Alternative 2A, the water quality benefits for both alternatives would
remain the same.

Recreation

Selection of Alternative 2B would result in elimination of the Olympic
sailing course at Vancouver Lake.  No projections have been prepared to
determine what portion of the recreation visits would be affected by
elimination of that use.  Selection of this alternative would not affect
any other planned uses at Vancouver Lake Park.
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Archaeological and Historical Resources

Selection of Alternative 2B would result in significant reductions in
the amount of dredged materials to be placed along the southern
shore.  This would substantially decrease any potential adverse
effects upon archaeological sites in that portion of the shoreline.

Mitigating Measures

Measure to mitigate the short-term effects of dredging and the disposal
of the dredged materials are discussed under Alternatives 3, 4 and 5.
Placement of screens on the flushing channel is discussed under Alter-
native 2A.

Short-term Resource Use vs. Long-term Productivity

Alternative 2B would maximize water quality benefits, but decrease
by 25% the amount of dredged materials requiring disposal.   This could,
potentially, result in a substantial decrease in the amount of land to
be covered by dredged materials.  Selection of this alternative would
decrease the long-term recreation potential of the lake by prohibiting
the construction of the Olympic sailing course, which was projected to
draw a large number of participants and observers.

Irreversible and Irretrievable Resource Commitments

The selection of Alternative 2B over Alternative 2A would result in
a decrease in the resources that would be committed to the proposed
project.  Elimination of dredging in the south central  portion of the
lake would substantially decrease the amount of dredged materials to be
placed in the vicinity of Mulligans Slough and the south embayment
(Sites 6 and 5).  These areas are believed to contain significant wet-
land habitats, preservation of which is strongly encouraged in federal
policy.
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                    ALTERNATIVE 2C - DREDGING OF 6
                     MILLION CUBIC  YARDS  AND  UNDER


Selection of Alternative 2C would result in the dredging of only 6  or  less
million cubic yards of material from Vancouver Lake, a reduction of 50-75
percent of the amount proposed in Alternative 2A.  No hydrologic,
engineering or recreation studies have been prepared to indicate where
the dredging would occur, or what types of recreation facilities would
correspond to this level of dredging activity.  For the purposes of
this analysis it is assumed that the highest priority for dredging
would be the channels along both shorelines to promote adequate flushing
of the swimming beach area and short-circuiting of flows from Burnt
Bridge Creek.  Only those impacts which would be substantially different
from the impacts expected for Alternatives 2A and 2B are discussed
below.

Hydrology

In the Master Plan for Rehabilitation of Vancouver Lake, Dames and Moore
indicated that 8.1 million cubic yards would be the minimum amount of
dredging that would achieve the circulation and flow objectives they
established (121).  Therefore, it is believed that dredging 6 million cubic
yards  or  less would not be adequate to promote flushing of the swimming
beach and the short-circuiting of the flow from Burnt Bridge Creek.  The
exact hydrologic and circulation changes that would occur as a result of
that dredging level are not known, but they would not be sufficient to
achieve the water quality benefits that comprise the project objectives.

Water Quality

If hydrologic flow conditions within the lake were not altered by imple-
mentation of this alternative, no change in the eutrophic processes of
the lake would be expected  to occur.  This alternative would not provide
for removal of bottom sediments, other than those immediately adjacent
to the west and east shorelines.  Therefore, it would be expected that
substantial nutrient sources would remain in the lake.  If Alternative
2C were selected, it is questionable whether any long-term changes in
Vancouver Lake water quality would occur.

Fisheries

Alternative 2C would represent a shallower lake, and thus a smaller
aquatic environment available to the fishes.

Vegetation and Wildlife

Selection of Alternative 2C represents a significant reduction in the
amount of land necessary for the disposal of dredged material, and  hence
a significant reduction in  the amount of vegetation and wildlife to be
destroyed by the activity.  The specific effects would be determined by
the location of the dredged disposal sites.
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Significant Wildlife Areas

Impacts of the selection of Alternative 2C would be dependent upon the
areas used for the disposal of dredged materials.  If the materials were
placed in areas outlined on the Significant Wildlife Areas map then the
impacts would be similar to those discussed in the Alternative 2A impacts
discussion.  However, if other sites were utilized, then adverse impacts
would be significantly reduced.

Short-term Resource Use vs. Long-term Productivity

Since the dredging of 6 million cubic yards would not provide signifi-
cant water quality benefits, it is questionable whether the long-term
quality and use of the lake would be enhanced.   The Dames and Moore
Master Plan believes that dredging is necessary in addition to the
construction of the flushing channel in order to meet the water quality
and recreation objectives.   Selection of Alternative 2C would probably
not contribute to the achievement of those objectives.

Irreversible and Irretrievable Resource Commitments

The funding costs of Alternative 2C have not been calculated, but are
estimated to be approximately $8,000,000 -$9,000,000.   The commitment of
funds necessary to complete this level  of development must be weighed
against the benefits to be gained, if any.   Any wetland areas covered by
dredged materials would be irretrievably lost to that habitat use.
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            ALTERNATIVE 3 - DISPOSAL MATERIAL PLACEMENT
The Master Plan for the Rehabilitation of Vancouver Lake proposes the
use of seven general disposal sites.  Each of these sites is described
on pages 50-52 of this section.  These disposal areas are very general
in nature since negotiations for use of the sites have not been under-
taken.  The choice of a project alternative (Alternative 2A, 2B or 2C)
would determine the size and location of the necessary disposal sites.
The sites proposed within the Master Plan are a combination of upland,
wetland, shoreline and in-water sites.  The comparative effects of
using such sites are described below.

Alternative 3A - Land Disposal

Land disposal sites comprise both upland and wetland sites.  The speci-
fic lands that would be covered by dredged materials are not currently
known.  However, the effect of placing materials on general sites can
be addressed.  The amount of land to be covered with dredged material
is dependent upon the amount of material to be dredged and the time
frame over which dredging would occur.

Land disposal of the dredged materials could result in increases of land
elevations of up to 22 feet.  The depth of the disposal material would
be primarily dependent upon the topography of the specific disposal
site, and the length of time over which the dredging occurred.  If the
dredging were to occur in increments over 5 to 10 years, it is possible
that disposal depths could be increased, due to compaction of the dis-
posal material.  In other words, a given disposal site can accomodate
more dredged materials if the materials are placed incrementally on
the site so that compaction can occur between placements.  Disposal
of dredged materials on the upland, floodplain and wetland areas adja-
cent to Vancouver Lake would markedly alter the visual aspects of
the land.  Due to the future recreation uses planned for the area,
particularly on Sites 2, 5 and 7, it is expected that these toon-
graphic changes would be scaled to achieve a pleasing aesthetic envir-
onment.

Land disposal will significantly alter the existing soils conditions,
especially where those existing soils are buried.  Impacts would be
lessened in those areas where the topsoil was removed and stock-
piled until it could later be returned to the site.  Lake bottom
soils consist primarily of clayey silt, sandy silt and silty fine
sand.  They are considered from poor to fair for use as structural
fill and from fair to good for use as non-structural fill and
agricultural fill..  However, they are of poorer quality than the
soils on adjacent agricultural land.

Lake sediments have poor soil structure and would be characterized
by poor internal drainage.  In order to be acceptable for agricultural
uses, the soils must be enhanced for root penetration, drainage and
nutrient content.  For structural uses, the soils would require
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compaction for the full depth of the soil and appropriate drying to within
the recommended compaction standards.  Moderate strength and moderate
compressibility could be expected from these soils if properly compacted.

Intended uses and locations must be examined in detail  with considera-
tion given to both the characteristics of the lake soils and the
underlying soils.  Where heavy loads are planned in the future, this
examination is of particular importance.

Sites 1 and 2 are primarily in upland pasture usage and do not receive
significant wildlife use.   Site 2 is a part of Vancouver Lake Park, planned
for future park development.  Placement of dredged materials on these
two sites would be expected to have no long-term adverse effects.   Site
1 could be returned to pasturage after the proper compaction and soil
reconditioning occurred.  The site would be non-productive during  the
short-term, but should return to productive use within  3 to 4 years
after the completion of disposal activities.  Dredged materials placed
on Site 2 would be used to create a varied landscape to accommodate
recreation activities and  enhance the park setting.

Site 3 is currently used for pasture and is predominantly an upland
site.  Numerous low lying  areas occur throughout the site which have
been mapped in the wetlands study.  The property is owned by Alcoa
and could eventually be rezoned for industrial  use.  However, the  Clark
County Regional Planning Council staff believes that such rezoning may
not be feasible due to the site's close proximity to Vancouver Lake Park.
The site's pasture production is not considered to be as important as
other areas around the lake.

Site 4 is characterized by two distinct wetland areas which provide
water fowl habitat.  The class and role of these wetland areas has
been identified in the Wetlands Habitat Evaluation study.  The land
is currently zoned for industrial use and the property  owner may not
wish to have dredged materials placed on the site due to their
inadequacy for structural  use.

Site 5 includes various wetland types, as depicted in the wetlands
study.  This disposal site will not be used in this project, as the
wetland habitats that would be lost are considered significant.

Site 6 includes a large portion of Mulligan's Slough and productive
farmlands.  This 650 acre  area is zoned for agricultural and open  space
uses.  The extent and importance of the wetlands within this site  are
significant.  It is believed that this area contains some of the most
significant wetland and marsh habitat in the Vancouver  area and plays
a significant role in the  local ecosystem.
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If that is the case, filling of portions of Mulligan Slough would result
in significant long term adverse effects.  Future agricultural use would
be curtailed until adequate compaction and soil conditioning had occurred.

The chemical state of the heavy metals and pesticides found in the dredged
material sediments has not yet been fully determined.  The Soil Conser-
vation Service, in conjunction with Dames and Moore, intend to perform
experimental plantings on the existing dredged materials to better det-
ermine any retardation or crop limitations that the spoils may inflict
upon various plant types.

Alternative 3B - Shore!ine/In-Water Disposal

The disposal of materials on the shoreline or in-water would eliminate
fish habitat and possible waterfowl habitat.  Lakeshore vegetation
would be lost, with Site 7 experiencing minimal such losses.  Water-
fowl habitat loss should be minimal at Site 7 and loss of fishery
habitat is not expected to be significant.  The area outlined within
Site 7 is not known as an important spawning area, although migrating
salmonids move through that portion of the lake towards Burnt Bridge
Creek.  However, these migration patterns can be easily altered.

The embayment included within Site 5 is currently a spiny-rayed spawning
area.  Filling of the embayment would convert a water-habitat to  an
upland habitat, and would thus represent a loss in total  aquatic  habitat.

In total, shoreline and in-water disposal within Sites 5 and 7 would
allow substantially increased recreational and public access to those
portions of the lake shoreline.  In the area of Site 7, the width of
the shoreline would be increased by several  hundred feet.

Mitigating Measures

Proposed use of shoreline disposal sites must take into consideration
the biological seasons, as in-water diking projects and outfall may
have significant effects on spawning and migration.

Dike construction must be durable and consist of relatively clean
materials.  The cleanest sands and gravels available from Columbia
River dredging operations exemplify such possible material.  Subsequent
diking stages can consist of dredged materials, depending upon specific
conditions and needs.

Dames and Moore and the Regional Planning Council of Clark County studied
the entire area in and around Vancouver Lake for possible deposition of
dredged material.  The objectives in reviewing each site were:  1) to mini-
mize dredging cost, 2) to complement future planned use for the site, and
3) to minimize adverse environmental impacts.  The sites discussed above
were selected as the most feasible based on those three criteria.  Many sites
were considered and discarded because they were characterized by wetland and
other valuable wildlife habitats, highly productive crop growing soils or
were planned for future industrial use.  The Regional Planning Council
believes that the potential sites listed above are the most feasible for
disposal use.
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                  ALTERNATIVE 4 - DREDGING METHODS
At the present time Vancouver Lake cannot be used for diversified re-
creational purposes due to its shallow depths and poor water quality.
To deepen the lake, thus enhance its recreational functions and appeal
to a broader spectrum of citizens, the lake sediments must be removed.
Based on current technology, dredging appears to be the most viable
method to achieve that goal.  This would involve removal of lake sedi-
ments by means of one of a variety of dredging methods.

The Dames and Moore Pilot Dredge Study explored various possible methods
of dredging that could be applied to the Vancouver Lake conditions.
Excavating type dredges, such as power shovels, drag lines and clam
shells (bucket-type equipment) were considered.  The major advantage
in the use of this type of equipment is the minimized amount of time
necessary for dewatering.  However, these methods cause excessive
turbidity, and would be very costly since the materials would have
to be loaded on barges to be transported to shore.

New types of dredging equipment were considered, particularly the oozer
and the pneuma pump systems.  These methods are especially beneficial
when highly contaminated material is to be dredged.   The bottom sedi-
ments are forced into small  cylinders, then pumped or sucked up a
pipeline and piped to the disposal site.  These methods achieve a
relatively high ratio of solids to water, thus reducing the decanting
process (which in turn reduces the amount of turbidity and pollutants
in the outfall process).  If the lake sediments were found to be
more chemically polluted than expected, these systems would probably
offer the least amount of pollution re-circulation.   Although these
two methods are more expensive to utilize than is hydraulic pipeline
dredging, their use could result in decreased land acquisition costs
since they achieve a higher ratio of solids to water, resulting in
more rapid compaction.  The oozer system in particular, is still
being considered for use by the Port of Vancouver.

The hydraulic suction dredge was determined by Dames and Moore to be
the most suitable method for dredging in Vancouver Lake and they used
it during the Pilot Dredge Study.  This method consists of a pipeline
which scans the bottom of the lake, sucking up the nearby sediments
and piping the material to the disposal site.  An eight-inch (eight-
inch diameter at head of pipeline) hydraulic dredge was used in the
Pilot Dredge Study, though larger dredges are available.  The dredge
used draws 28 inches, requires about that much depth for proper opera-
tion, and can pump the material 3,500 feet horizontally.  Booster
pumps can increase the possible pumping distances, but at considerable
cost.

Hydraulic dredging results in two primary impacts.  First, the dredge
causes increased turbidity in the water during operation.  As the pipe-
line cuts and scans the bottom, fine material becomes suspended in the


                                 82

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near vicinity.  Wind and wave action can spread this turbidity beyond
the actual dredging area.  This increased turbidity would be short term
and is discussed in the Water Qualtiy effects portion of Alternative
2A.  It would cause temporary problems for localized fish and inver-
tebrates, but the impact should be minimal.  Curtains could be used
to minimize the spread of the suspended materials, if that became a
serious problems.  The second major short-term effect of dredging
occurs at the disposal site.  During the dredging process, the hydrau-
lic pipeline draws in considerable quantities of water along with the
bottom sediments.  During the Pilot Dredge Study the ratio of solids
to water was measured at approximately 17 percent by weight.  Thus,
large amounts of water must be removed from the dredged materials,
causing pollution recycling, turbidity and extended decanting times.
Lake sediments must be disposed of carefully, so that the materials
would be properly contained and the dewatering process be managed to
minimize pollution recycling and turbidity.  If well managed, the
effects on water quality and fisheries should be minimal.

Due to the condition of the materials that would be dredged from the
lake, considerable enhancement would be necessary for future economic
use of the materials (agricultural, structural, etc.).  This would
require dewatering of the material to levels applicable for the
various intended uses.  The clam shells, drag lines and power shovels
would require the least amount of dewatering (thus less time, less
return flow, and reduced water quality problems at the disposal  area.)
The pneuma and oozer methods would be more efficient than the excava-
tors at the dredge site, but less efficient at the disposal site.
These methods would require more time to decant than the excavators,
but would be more efficient than the hydraulic system ( 50 percent solids
versus 17 percent solids.)  The hydraulic system would take the longest
time before serious efforts of enhancement of the dredged materials
could take place.  The re-use of the materials for structural or ag-
ricultural purposes would take more than a year.  Given enough time
and work with the dredged materials, they could be used for agricul-
tural and various structural purposes.

Mitigating Measures

The Master Plan for the Rehabilitation of Vancouver Lake suggests a
variety of mitigating measures that could be used to decrease the short
term effects of dredging on water quality.  These include avoidance of
hot weather dredging, lengthening retention periods to allow for minimum
3 day water detention time, creating numerous cells within the storage
areas, use of chemical flocculants, limiting decantation and increasing
aeration.
                                83

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         ALTERNATIVE 5 - DREDGED MATERIAL HANDLING METHODS
Dikes are necessary for containment purposes, for settling purposes to
improve the quality of the outfall water, and for material reclamation
projects.  Dikes may be constructed from local soils, imported materials,
and sometimes from dredged materials.  Native soils are preferred for
construction of initial dikes when the site is on land.  Dikes constructed
in water ( as would be the case for Sites 5 and 7 ) typically function
best if constructed of foreign materials with specified characteristics.

A weir is a simple structure built into the disposal cell, or disposal
pond, that will allow the excess water to drain out (the outfall).  The
weir should be designed to allow only that water which is the least
turbid to enter the outfall, thus causing minimal water quality problems
in the return flow to the lake.  The design of the weir should be site
specific to accomodate existing conditions, with minimal return flow
pollution the major objective.

The construction of the dikes would cause the primary impacts on the
environment.  Soils and existing vegetation would be at least temporarily
lost.  Wildlife losses would depend upon the diversity and depth of the
habitat.  If it is a particularly complex, or extensive habitat, the
environmental impact must be considered to be significant. If the habitat
is small and fairly common, wildlife can presumably relocate without
irretrievable losses.  Vegetation and wildlife can be re-established
within three to seven years, depending upon specific conditions.

If the disposal materials were not physically conditioned for enhancement
purposes, the material would probably require a year's time before it
could support light traffic. The structure of the lake soils would not
support agricultural activities, unless they were conditioned.   Thus,  it
is expected that natural  revegetation would be retarded.  Therefore, to
reduce the environmental  impact of dredged material disposal, the dis-
posal materials should be conditioned to improve their reuse capabilities.

"Casual" uses, such as parkland, playfields, beaches and landscaping,
would require minimal lake soils improvements and care.  Such reuse pot-
entials should not be difficult, given proper planning and a good under-
standing of the soil limitations.  Reuse for structural purposes (roads,
buildings, etc.) would require significant preparation.

Compaction of the material, after proper dewatering, would be necessary
for the full depth of the dredged soil.  Such activity would require a
detailed examination of the specific soil characteristics not only of
the dredged material, but also of the underlying soil as well.   Impacts
of structural reuse of the materials would depend primarily upon the
specific reuse.

For agricultural reuse, the dredged materials would require soil struc-
ture conditioning to improve drainage characteristics and root develop


                                84

-------
ment potential.  This preparation might be likened to the opening up of
a new plot of land for agricultural use, in that six months to a year would
be spend preparing and enriching the soils.  What impact this would have
on the land would depend upon the prior use.  If this action were not
undertaken within the wildlife areas or thick vegetation zones as mapped
in Section II, the effects would either be minimal or advantageous.

Any in-water or shoreline disposal as in Sites 5 and 7 would be an
irreversible commitment of a natural resource.  Site 7 could possibly
be replaced, through the development of more water area for the lake.
Sites 5 and 6 would be irretrievable commitments of the natural resources,
as the replacement of such habitat types would not be possible.  Both
areas are used extensively for mating, spawning and nesting by various
wildlife species.

If the dredged materials were used for structural purposes, then the
land would be committed to long-term or permanent structural use.  If
agriculture is to be the re-use, then it is an addition to the local
natural resources.

To significantly reduce the adverse environmental impacts of the disposal
of dredged material, alternative sites should be found for Sites 5 and 6.
These areas are vital to the biological mechanics of the lake environment.
Important wildlife areas that occur on the west shore should be avoided
as well.

Construction of the dikes and cells should occur during dry weather to
minimize the impact of the heavy machinery on the wet soils.  Construc-
tion activity during the Pilot Dredge Study occurred during wet periods,
and the machinery caused considerable disturbance to the soils and local
vegetation.
                                 85

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SECTION IV  COMMENTS AND RESPONSES TO THE DRAFT EIS

This section contains comment letters from Federal and State Agencies,
citizen's groups and individuals on the Vancouver Lake Reclamation
Study Draft EIS.  A summary of the Public Hearing begins on page
Those letters which commented directly on the Draft EIS have been re-
produced in this document.  Whenever a response is required by EPA to
the letter, a response page follows that letter.

The following table lists the comment letters received during the
review period, the page on which the letter can be found and general
categories of concern.  Comment categories are shown in an attempt to
indicate the aspects of the proposed action in which the commentors
were most interested.  This may serve to direct the interested reader
to those sections of the document which bear restudy and the support or
opposition to the alternatives is footnoted in the following table.

EPA wishes to thank all those who submitted comments on the Draft EIS.
All letters received by EPA were presented to the Regional Administrator
and were considered by him when formulating the recommendations included
in the "Preface" of this document.
                                  86

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Public Hearing Summary

On December 6, 1977, the Environmental  Protection Agency (EPA) held a
public hearing on the Draft Environmental Impact Statement (EIS) for
the Port of Vancouver's proposed Vancouver Lake Reclamation Project.
The hearing was conducted at the City of Vancouver Council Chambers and
was attended by approximately 40 people.  Because of the length of the
official hearing record, we have not reproduced the hearing record for
the Final EIS.  However, it is available for review at EPA's Oregon
Operations Office, 522 S. W. 5th Avenue, Yeon Building, Second Floor,
Portland, Oregon, and EPA's Region X Office, 1200 Sixth Avenue, Seattle,
Washington.  In addition, a summary of the comments and a table listing
the speakers and their areas of concern are provided in this Final EIS.

Thirteen persons read testimony into the official record.  Nine of the
thirteen persons were in favor of Alternative A.  Among the reasons
cited for this support were:

   • The need to enhance the water quality of Vancouver Lake

   •The need for additional recreational facilities in the Portland/
     Vancouver area

Two persons were directly opposed to Alternative A.  Among their
concerns were:

   • The inadequacy of the proposed 208 plan (which is needed to
     improve water quality in the Vancouver Lake Area) particularly
     regarding nonpoint pollution control on Burnt Bridge Creek

   • The high cost of the proposed 208 program and the proposed method
     of funding; the cost of the Burnt Bridge Creek plans should be
     shared by both city and county, not just the city

   • Using county resident's money to fund a sailing course which the
     county residents would not likely use, particularly since the
     additional dredging was not judged necessary to improve water
     quality.

   •The need to balance recreational as well as preservational values
     in considering the magnitude of this project.

Two of the thirteen persons did not express a preference for any of
the alternatives.  One, however, questioned the project itself, citing
the probable adverse impacts on the wildlife, river banks and pasture
lands of Lake River as reasons for his concern.

EPA wishes to thank all those who participated in the hearing; the
Final EIS will address the issues raised during the hearing.  The
                                 87

-------
hearing record, along with all other comments, were considered by EPA
in formulating the recommendations contained in the preface to this
document.
                                  88

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TABLE 18
Comments Received on
Vancouver Lake Draft EIS

United States Department of
Agriculture - Soil Conservation
<;Prvi rp
Advisory Council on Historic
Preservation
Department of Housing and
Urban Development
United States Department of 5
The Interior
United States Corps of Engineers-
Portland District 1
Washington State Department of
Game
Washington State Department of
Public Health, Southwestern,
Washington
Washington State Department of
Ecology
Washington State Department ot
Fisheries
Washington State
Sportsmen's Council


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TABLE 18
Comments Received on
Vancouver Lake Draft EIS

2
National Wildlife Federation
4
Oregon Bass & Panfish Club
Drainage and Diking 3
Improvement District #14
James R. Meyer
Tom Farr ~
Democratic Precinct Committeeman


1 . Opposes Alt. 2A
2. Opposes Alt. 2A
3. Supports Alt. 2A
4. Supports A t. Zti
5. Opposes Alts. 2A, 2B & 2C


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-------
UNITED STATES DEPARTMENT OF AGRICULTURE

SOIL CONSERVATION SERVICE	
Room 360 U.S. Courthouse, Spokane, Washington 99201

                                                November 9, 1977
        Roger K.  Mochnick
        Environmental  Evaluation Branch,  M/S 443                  -/
        U.S.  Environmental Protection Agency, Region X            ™"   ^^
        1200 Sixth Avenue                                          v<^    
-------
Advisory Council on
Historic Preservation
1522 K Street  NAV
Washington, D.C.  20005
 RECEIVED
KOV 1 4  1977
                                           November 10,  1977
 Mr.  Roger  K.  Mochnick
 Environmental Evaluation Branch, M/S 443
 U. S. Environmental Protection Agency, Region X
 1200 Sixth Avenue
 Seattle, Washington  98101
 Dear Mr.  Mochnick:

 On October 31,  1977,  the Council received the Environmental  Protection
 Agency's  request  for  comments on the draft environmental  statement  (DBS)
 for the Vancouver Lake Reclamation Study, Fort of Vancouver,  Clark
 County, Washington.   Pursuant to its responsibilities under  Section 102
 (2)(C) of the National Environmental Policy Act of 1969,  the Council
 has determined that this DBS does not demonstrate compliance with
 Section 106 of the National Historic Preservation Act of  1966 (16 U.S.C
 470f,  as  amended, 90  Stat. 1320) in accordance with  the "Procedures for
 the Protection of Historic and Cultural Properties"  (36 C.F.R.  Part 800),
 with regard to this proposal.  However, it appears that the  EPA recog-
 nizes  its responsibilities pursuant to Section 106,  as amended,  and
 will carry them out in the future.

 EPA Is reminded that  if future actions Implementing  this  proposal will
 have any  effect on cultural properties not previously Identified which
 may be eligible for or are included on the National  Register of Historic
 Places, it is required to afford the Council an opportunity  to  comment
 on those  actions in accordance with the "Procedures."

 Should this proposal  be approved, the Council looks  forward  to  working
 with the  EPA in accordance with the "Procedures" as  appropriate.

 Should you have any questions or require assistance  in this  matter,
 please contact Brit Allan Storey of the Council staff at  P.  0.  Box
 25085, Denver, Colorado 80225, or at (303) 234-4946, an FTS  number.
                                           Sincerely yo
                                           Louis
                                           Assistant Director, Office of
                                             Review and  Compliance,  Denver
Tkr Cfit»eil ii fn hiJrfriulfnl anil of !hr E\rculirr Rrinch of Ibr FrJrrtl C,ornnmrjit rlargrj hy Ihr Act of
October M, 1966 to iJi-iie tbf fmiJcnl end Conxrm in the fit-IJ of llitforic rrcienatina.
                                  ADVISORY COUNCIL ON HISTORIC PRESERVATION

                                  1.    Response
                                       The grant conditions state that: "In compliance with  Section  ID*)  of
                                       the National Historic Preservation Act of  1956, the Porf  of
                                       Vancouver will be required to conduct a site  specif k  arch.ifoloqic.il
                                       investigation of the affected areas.  This survey would IIP  iiihmitt.eH
                                       to the Advisory Council of Historic Preservation and  the  Washington
                                       State Historic Preservation Office for review and acceptance.   Any
                                       mitigating measures reconmended by the State Historic  Preservation
                                       Officer would be considered by the Port of Vancouver  and  the
                                       Environmental Protection Agency.  Mitigation measures  arcpprahle
                                       to all three parties (State Historic Preservation officer, EPA  and
                                       the Port of Vancouver)  would he adopted and implemented.

-------
                   DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
                                   REGIONAL OFFICE
                        ARCADE PLAZA BUILDING, 1321 SECOND AVENUE
                               SEATTLE. WASHINGTON BB101

                                 November 22, 1977
Office of Community
Planning & Development
Mr. Roger  K. Mochnlck
Environmental  Evaluation Branch, H/S M3
U.S. Environmental  Protection Agency, Region X
1200 Sixth Avenue
Seattle, Washington  98101

Dear Mr. Hochnick:
100 H/S 317
Subject:  Draft  Environmental  Impact Statement
          Vancouver  Lake Reclamation Study
          Port of Vancouver
          Clark  County,  Washington
We have reviewed  the statement submitted with your October 25, 1977 letter.

The proposed  action is the restoration of Vancouver Lake to  Improve water
quality and  lake  conditions to the extent that residents of Clark County
and the greater Portland metropolitan area can use and enjoy the lake for
recreational  purposes.

To the extent that the proposed action Is consistent with the local comprehen-
sive plan, we would support a scale of development that would maximize water
quality and  recreational benefits.  This project Is an exceptional opportunity
to provide the urban population with a wide range of recreational choices.

One element that  we would like to see expanded upon Is the means of access
to the area to assure that traffic congestion would not be a problem for the
city of Vancouver.

We defer  to other agencies to comment on areas not within our expertise and
Jurisdiction.

Thank you for  the opportunity to comment.

Sincerely,

  ?.-.-'/    V "  7 )
I. D. Long, Acting
Assistant Regional  Administrator
                                                                                                                  ro
                                                                                                                  cn
                               HOUSING & URBAN DEVELOPMENT

                               1.    Response
                                    Traffic analysis have not yet been undertaken for the lake
                                    rehabilitation project.  Until facility sizes and user figures arc
                                    qpnerated,  traffic projections will not be possible.
                                   AREA OFFICES
                 PortlNnd. Orrf>n • Srtftle. Wuhlfifton • Anchorife, Aluki
                                   Iniurlni Offlc*
                                 Spokini, Wuhlmlon

-------
          United States Department of the Interior

                      OFFICE OF THE SECRETARY
                      I>A( ll:l(  NOUIIIWI-ST RF.GION
                   REGIONAL ENVIRONMENTAL OFFICER
                   500 NE  MULTNOMAH  ST  SUITE 1692
                   PORTLAND OREGON  vT232
           United States Department of the Interior

                       OFFICE OF HIE SECRETARY
                       I'M II l(  NOKIIITCM Rl (.ION
                  REGIONAL ENVIRONMENTAL OFFICER
                  500 NE MULTNOMAH ST  SUITE 1692
                  PORTLAND  OREGON  97232
 RECEIVED

DF.C27 1977

  EPA-FIS
                                            December 19, 1977
ER-77/983

Mr. Donald P. Uubois
Regional Administrator
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington  98101

Dear Mr. Dubols:                               ''         5  .''v-

This Is In regard to your transmlttal of October  25,  1977, requesting
the Department of the Interior's review and comments  on  the draft en-
vironmental statement for Vancouver Lake Reclamation  Study,, Port of
Vancouver, Clark County, Washington.                  '   '

This Is to Inform you that the Department will have comments but will
be unable to reply within the allotted time.  Please  consider this
letter as a  request for an extension of time In which to comment on
the statement.

Our comments should be available about January 3, 1977.

                                   Sincerely yours,
                                   Charles S. Polltyka
                                   Regional Environmental Officer
                                                limn
                                                 ,o2119
                                                  OfllU  r
                                             December  21,  1977

 ER-77/983

 Mr.  Roger K. Mochnlck
 Environmental Evaluation Branch, M/S 443
 U. S. Environmental Protection Agency
 1200 Sixth Avenue
 Seattle, Washington  98101

 Dear Mr. Mochnlck:

 This Is In response to your request  that  the Department of the Interior
 review and comment on the draft environmental statement for Vancouver
 Lake Reclamation Study,  Port of Vancouver, Clark County, Washington.

 General Comments

 Cultural resources appear to have  received adequate consideration.
 However, archeological sites In the  project area should be evaluated
 for  the "National Register of Historic Places," and, if qualified,  they
 should be nominated.   Progress on  the evaluation should be reported In
 the  final statement.

 The  statement  does not fully describe the mineral resources of the  study
 area.  The only  mention  of mining occurs on Figure 8,  a map of Exlntiiig
 Land Use.   According  to  the  Bureau of Mines'  Mineral Industry Location
 System (MILS), sand and  gravel have been mined in two  locations near
 Vancouver Lake.   The  two deposits are In NE-1/4, SW-1/4,  Sec.  4 and
 NE-1/4,  Sec. 19,  T.2N.,  R.1E.,  W.M.  The reclamation of Vancouver Lake
 Itself probably  would  not  have a direct adverse impact  on either
 deposit.   Disposal of  the  dredge spoils, however, may  affect  the sand
and gravel resources  In  Section 4.  The potential impact  on mineral
 resource availability  should  be examined and  described  In the environ-
mental statement.

Mi lie the draft  statement,  in general, adequately describes the effects
of the proposed  lake  reclamation plan on fish and wildlife, numerous
errors and omissions were  noted.  The area south of Blue  Rock Landing
             cr>

-------
Road drains  to  the  north  through  Buckmlre  Slough.   Construction of the
flushing  channel will  block  this  drainage.   Dredging  of  the Lake River
sump will entail destruction of two  Islands, both  containing beaver
lodges.   Further, no long-range dredge  disposal  plan  for maintenance
of the sumps and the flushing channel has  been included.  Although a
wetlands  study  is referenced,  no  results are presented.  Also, the
Corps of  Engineers'dIking project should be  better explained, parti-
cularly with respect to how  it relates  to  the subject proposal.

There are a  number  of  references  in  the statement  to  areas being zoned
for recreation  or agriculture or  open space. The  entire area, including
the lake  itself, is zoned industrial.   These references, where appropriate,
should be changed to indicate that the  Vancouver Lake Land Use Flan
designated these areas for such uses.   The credibility of the land use
plan may  be  inferred from the Port of Vancouver's  recent approval of the
Lake Rehabilitation Plan  in  which one condition  was that they were still
planning  on  industrial development for  two pieces  of  property which are
located in areas designated  agriculture—open space in the land use plan.

The particular  alternatives  used  are somewhat confusing  and often make
it difficult to determine exact effects.   For example, the major adverse
effects on fish and wildlife are  connected with  disposal of the dredged
material.  But  the  section on Alternative  No. 3  -  Disposal Material
Placement Is quite  short,  with a  brief  discussion  of  the proposed sites
and mitigation  and  does not  follow the  format used in previous alterna-
tives.  Much of the information which should be  covered  in Alternative
No. 3 is  covered in the discussion under Alternative  No. 2A.

This Department's Fish and Wildlife  Service  indicated  in an earlier
letter to the Regional Planning Council that we  are extremely concerned
over the  loss of wetlands  associated with  this project.  Every proposed
disposal  site contains some  wetlands.   Site  5 is almost  entirely wet-
lands, as  Is much of Site  6.   Overall,  we  do not see  any benefits to
either fish  or  wildlife from the  project,  i.e.,  any benefits derived
from deepening  the  lake will be more than  offset by loss of spawning
and nursery habitat.   We are particularly  concerned over any encroach-
ment into  the Mulligan Slough  area.

It appears that this project would result  In a major  adverse environ-
mental impact by destroying hundreds of acres of wetland through disposal
of dredge  spoils.  As  auch It  appears to be  in violation of the President's
Executive Order 11990  on the protection of vetlands.  Although this is
recognized In the draft statement, there la  no direct "finding" pursuant
to Sec. 2(a)(l) and (2) of the Executive Order "...that there is no prac-
tical alternative to such construction, and  (2)  that  the proposed action
includes all practical measures to minimize  harm to wetlands..."  We
strongly urge the Environmental Protection Agency  to develop alternative
and less damaging methods of dredge  spoils disposal.
         This  Department would be willing  to assist  the Port  and  F.PA  in  developing
         a  proposal  that would substantially retain  fish, wildlife, and  recreational
         resources while minimizing wetland destruction.

 8       A  map showing the location of wetlands should be included in  the  FES.

         It should be recognized that there is a possible problem of Juvenile
 9       anadromnus  fish entering the lake through the flushing channel  and
         becoming subject to predation by wannwater  species.

         The proposed project will be subject to permits for which this  Department
         has review  repponsibilities.  Accordingly,  our comments  do not  preclude
         an additional and separate evaluation by the U. S. Fish  and Wildlife
         Service, pursuant to the Fish and Wildlife  Coordination  Act  (16 U. S.  C.
         661,  at seq.), on the permits required from the U. S. Army Corps  of
         Engineers (Sections 9 and 10 of the River and Harbor Act of 1899, and
         Section 404 of P.L.  92-500).  All such permits are subject to separate
         review by the Service under existing statutes, executive order, memoran-
         dum of agreement, and other authorities.   In review of permit applications,
         the Fish and Wildlife Service nay concur, with or without stipulations, or
         object to lie proposed work, depending on specific construction  practices
        which may impact fish and wildlife resources.

         Specific Comments

        Page 111, last par.   It is doubtful If there will be any benefits to
        waterfowl hunting due to the project and  there could be losses as some
10      of the lake area presently hunted would be too deep to allow the type
        of hunting blinds presently in use.   Depending on what areas are filled,
         there could be a significant loss In the  present spring sport fishery.

11      Faee 5.  More Information on the nature of public comments on the overall
        project and on individual  issues would be helpful.

12      Page 11, par.  2.   Whlpple and Flume Creeks are tributaries to Lake River
        not Vancouver Lake.

        Page 11, par.  3.   Winter storms in December and  January often being the
13      Columbia River levels up well beyond the  eight foot stage at  Vancouver,
        with a consequent rise in lake  levels.

14      Page 34.  The proposed dike shown on Map  4 should be explained,  parti-
        cularly as  to its purpose  and probable effect  on the enclosed wetlands.

        Page 18. Flah.   The  Fish and Wildlife Service  has found only  juvenile
15      sturgeon in Vancouver Lake,  not adults.   Juvenile salmon, however, have
        been found  at the southern edge of the lake and  in  Mulligan Slough.

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        Figure 5.  page 23, Fisheries.   Channel catfish are not known to be present
        in Vancouver Lake. Brown bullheads are the moat prevalent catfish species.
        The spawning areas shown are minimal and for the slough and southern edge
        only.   Other spawning areas include the southern edge of the lake, the
16      embayment, the wetlands at the north end of the lake and the willow
        thickets along the western side.  Shallow water areas around the edge
        of the lake and in Mulligan Slough are also very important as nursery
        areas.  The stunting observed in adult fish could be due to overpopula-
        tion or lack of a forage fish such as the treadfin shad.

17      Page 25, par. 1.  Mulligan Slough has limited value for waterfowl nesting.
        Fishery values are much more important.

18      Page 25, par. 2.  Oregon ash is usually found on slightly higher ground
        than most willows.

        Page 27, par. 1.  Columbia River willow (Salix fluviatilia) and wapato
        (Saglttaria latifolta), candidates as threatened species on the Smithsonian
19      list,  are present in the area.  Wapato is found in several places south of
        the lake und at the mouth of Burnt Bridge Creek.  Columbia River willow is
        more widespread and is found mostly on the south and west sides of the
        lake.   The wetland habitat classification study has more exact locations.

        Page 28, and Figure 7.  Sport fishing areas are incomplete.  Areas to be
        added should include:  the lower (northern) and of Buckmlre Slough; mouth
20      of Burnt Bridge Creek; the entire southern edge of the lake; all of the
        area sough of the lake which is inundated by spring high water; and Lake
        River.  These are both boat and bank fisheries.

21      Page 37, Table 13.  Ownership acreage figures should be given also for
        the ownership categories shown on Map 10 and for individual public agencies.

        Page 48 and Figure 12.  Figure 12 indicates that Mulligan Slough is to
22      be dredged to -1  foot.  The slough is not included in the Master Plan.
        The flats and sloughs are major nursery and spawning areas.

23      Fogcs 48-53.  Point sources of pollution should be discussed in addition
        to nonpoint sources.

        Page  49,  second  full  paragraph.  It is implied  that an objective of the
        proposal  is  to  avoid  piling dredging spoils higher than 20 feet.  We
        suggest consideration of an alternative whereby the spoils are used to
24      form  a  landscaped hill or ridge, preferably so  placed as to visually
        screen  recreatlonlsts from nonesthetlc areas.   Such an alternative
        could necessitate temporary storage of spoils to allow dewaterlng.
        However,  Increasing deposit height would eliminate, or at least reduce,
        the Impact on wetlands.
 25      Page  50,  Site  5.   There  is  a  bank fishery on  the  west  side  during  spring
        high  water.

        Pages 58  and 59.   The  statement  should  consider measures  such  as silt
        screens to locally control  the migration  of lake-bottom sediments  dis-
 26      Curbed during  dredging.  Screens  would  minimize resuspenslon of mercury,
        zinc,  and copper that  may be  expected to  absorb onto participate matter
        within the water column.
27



28




29




30


31


32


33


34


35



36
 Page 66,  last  par.   Songbirds would be lost,  rather than relocated,  un-
 less positive  steps are takan to upgrade habitat in nearby areas.   Most
 habitats  are at  carrying capacity and cannot  support additional  indi-
 viduals for more than a short time.   Tills is  particularly true ot
 territorial species.

 Page 67,  next-to-last par.   Favorable habitat for raptors would  also he
 lost.

 Page 74,  Fisheries.   There  could be  a considerable difference  in ImpartH
 on  fish between  this  alternative and No.  2A.   Material  dredged from the
 sailing area would  be deposited  in  Site  6, with  probable adverse effects
 on  fish spawning and  nursery  areas  and the fishery.   The much  smaller
 amount of material  to be placed  in  Site  6 under  Alternative  No.  2B  would
 have considerably less  adverse effect  on  fish habitat.

 Page 78,  par.  3.  Sites  2,  5, and 7  are planned  for  recreational use,  not
 1 and 3.

 Pages 79-80.   The final  statement should  give  acreages  for the disposal
 sites.

 Page 79,  par.   3.  The northern half  of Site 1  is highway  right-of-way
 and  Is not used  as pasture.   It  has  moderate wildlife usage at present.

 Page 79,  next-to-last par.  Site 5 also includes a shallow water area.

 Page 79,  la«t  par, Site  6.  It is our understanding that  the Corps of
 Engineers at present has several designs  for dikes at the southern end
 of the lake.

 Page 80, next-to-last paragraph.   A background explanation of the proposed
 dike construction is needed to make  this  paragraph meaningful.

Pages 81-82.   The discussion of dredging  methods does not really seem
 to constitute  a proposal alternative.  It Is  more a discussion  of the
method to  be used to accomplish the proposed  action.
IT)
(Ti

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37      Page H 1, par.  2.   As  mentioned  nbove,  wildlife will  he lust,  nor relented

        Pag^HJ, last  sentence,  third par.   The statement, that vegetation and
        wildlife can be reestahJ Islied within 3 to 7 years for dredged spoils
38      disposal areas calls  for  considerably  explanation of how the  transforma-
        tion Is to be  carried out and how  the  final vegetation *nd wildlifo will
        r.omp.-iro In numbers and species  with  those present now.


        We appreciate  the opportunity to review and comment  on this document.


                                           Sincerely yours,


                                                      C
                                        Charles S. Polltyka
                                        Regional Environmental Officer
U.S. DEPARTMENT OF  THE INTERIOR

1.   Response
     EPA grant conditions  require  that the Port of Vancouver  conduct  a
     site  specific  archaeological  investigation of the affected areas.
     This  survey would he  submitted  to the Advisory Council of  Historic
     Preservation and  the  Washington State Historic Preservation office
     for review and acceptance.

2.   Response
     The project should have  no effect on  the  mineral  deposits  of Section  19.
     Exact boundaries  of disposal  site 7,  which lies within Section 4, have
     not yet been delineated.  When  construction plans are developed,
     efforts can be made to avoid  impacting the existing  mineral
     resource deposits of  Section  4.

3.   Response
     The construction  of the  flushing  channel  will block  off  some drainage
     into Buclcmire  Slough.  The loss of voter  flow will have  some effect
     on the water regime within the  slough but the degree of  impact  is
     not known due  to  lack of historical drainage  data within the .irea.

     At this time the  project will not  entail  any  action  that will cause
     the loss of the two islands at  the head of Lake River.   Long range
     disposal plans for  maintenance  dredging have  not  yet been  formulated.
     It is anticipated that such plans will be outlined during  the drafting
     of the operation  plan.  The wetlands  study conducted by  Jones *  Stokes
     is summarized  in  Appendix A.  The  Corps of Engineers most  probable
     diking proposal (as of this date)  Is  shown on Figure 4.

4.   Response
     As noted in the text,  the Vancouver Lake  Land Use Plan designates
     substantial  amounts of land around Vancouver  Lake for recreational
     and agricultural use.   On May 26,  1976 the Clark  County  Board of
     Comnissioners adopted a ?H-H zone  for much of the agricultural/
     recreation land adjacent to the lake.  Agricultural  and  recreation
     uses  are permitted outright in  that zone.   Manufacturing/Industrial
     uses  could be allowed on a permit basis.   Such  a  permit  would he
     granted only if the use 1s consistent with the  controlling land use
     plan,  and does not  adversely affei.t adjacent  land uses.
                                                                                                             |
                                                                                                            1i,n f innat  for  the  alternatives d is'.1) '-si on .-n; Ii3r,e'l on the mater
                                                                                                            tn |ir>  covered  in  '••irh  suction.   disposal M?f?ri--)l Placement will
                                                                                                            •wr-p.-l  in  rioLail  1n the required operation pin.
                                                                                                            .
                                                                                                            LPA grant  condition1; require l.hat Mulligan jl-iunh maain in  its
                                                                                                            natural, present  condition.   No disposal will ho allowed on  Site r>.
                                                                                                            Disposal  in  Site  o  will  >>o limited to t'io«p "riM-. i"<-lud<>d in
                                                                                                            Alternative  7  of  the M.'",.  Army Corps of Ennin?^is Dike Improvm-iit
                                                                                                            I'l'in.   This  substantially  -Jocreasea ^tfland  imoa'ls.
10.

11.
                                                                                                         16.


                                                                                                         17.

                                                                                                         18.

                                                                                                         19.


                                                                                                         20.


                                                                                                         21.


                                                                                                         22.
      Response
      EWs' wetland habitat study has identified the critical wetland
      areas.   These areas will not be used for dredge disposal sites.
      All  practical measures will be used to provide the maximum protection
      of the wetland habitats.  Thank you for your  offer of help.  El'A
      is happy to have your assistance in this matter.

      Response
      A complete mapping of the wetland areas is provided in th" Junr-s ^
      Stokes study.  Key wetland areas arp shown in Figure 7 of this F. 15.
                                                                                                            Response
                                                                                                            This has
         been addressed on page 65 (paragraph 6) and  1n othrr parts
of the EIS.

Comment noted.

Response
The transcript of the public hearing is available for review through
EPA.

Response
Text has been changed accordingly.

Response
Comment noted.

Response
See page 13, paragraph 1 for explanation.

Response
Adult sturgeon have been found In Vancouver, though not recently
and not by the U.S. Fish and Wildlife Service.  Text has boon changed
to note Juvenile salmon occurrence.

Response
Figure 5 has been changed accordingly.

Comment noted.

Comment noted.
                                                                                   CT>
Response
Text has
               been  changed accordingly.
      Response
      Text has been changed accordingly.
      Response
      See Table 13.

      Response
      EPA grant conditions require that Mulligan Slough shall remain
      in Its present condition.

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23.   Response
      No point sources of pollution are presently known.

24.   Response
      Alternative dredge material disposal means will be explored in the
      required operation plan.  It is possible that increased quantities
      of materials will be placed in the recreation areas since
      Sites 5 and 6 are no longer available for use.

25.   Response
      Text has been changed accordingly.

26.   Response
      These suggestions will be evaluated 1n the preparation of the
      required operation plan.

27.   Response
      Text has been changed accordingly.

28.   Response
      Text has been changed accordingly.

29.   Comment noted.

30.   Response
      Text has been changed accordingly.

31.   Response
      Acreages are given 1n Table 14, page 51.

32.   Response
      Text has been changed accordingly.

33.   Comment noted.

34.   Response
      Sec page  13, paragraph  1.

35.   Response
      Diking  as  discussed here refers to the diking of  individual disposal
      sites for  retention and control purposes.  Preferred diking materials
      are the actual  dredge spoils.  However, physical  characteristics
      often require  the use of other materials (such  as Columbia River
      sands and  gravels) for  use  in diking construction.

36.   Response
      This section  contains a discussion of available dredging methods.
       It details the  reasons  for  the selection of the proposed method.

37.   Comment noted.
       Response
       RovPOOt ri t ton will  hp  discu^srd  in  detail  in  th*1
       pKin.

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                                                                                                               COMMENTS  ON THE  DRAFT ENVIRONMENT IMPACT STATEMENT
                                                                                                   "VANCOUVER  LAKE RECLAMATION STUDY,  PORT OP VANCOUVER, CLARK COUNTY,  WASHINGTON"
                         DEPARTMENT OF THE ARMY

                     PORTLAND DISTRICT, CORPS Or ENGINEERS
                                  f Q ION 1»<4

                              FOKrtANO. OlttOON fl-IOl
                                                       15 December 1977
NPPKN-ER
Roger K. Mochnick
Environmental  Evaluation Branch, N/S 443
U.S. Environmental  Protection Agency, Region X
1200 Sixth Avenue
Seattle, Washington  98101
Dear Mr. Mochnick•

We have reviewed the draft  Environmental  Impact Statement, "Vancouver
Lake Reclamation Study,  Port of Vancouver, Clark County, Washington,"
and have the  Inclosed consent* to offer on flood control, hydropower,
navigation, and other related areaa of our concern.

The Corpa la  currently studying the potential of levee construction in
the Vancouver Lake  area.  Thli propoaal will be Impacted by the above
mentioned project,

We appreciate the opportunity to coantent  on thli project.

                                   Sincerely youra,
Incl
aa acated
t. J. STEIN
Chief, Engineering Dlvlalon
GENERAL

In general, the P.IS falln to Identify specific  impacts or benefits  to tho
lake from tlie proposed  lake restoration and,  In  fact, repeatedly  ntstoR
that the Impacts and results of  the action on  the  Inke arc  not  known or not
predictable.

In The Federal Register of 10 September 1973,  the  President's Water Renourcon
Council, has published standards  for planning water resource projects.   The
CIS falls to use these principles and standards  or Identify the National
Economic Development or Environmental Quality  Alternatives  as required.   Thin
should be explained and referred to on page 4, paragraph 3.  AI no included
In this section should be a discussion of Federal  and State permits that  will
be required for project implementation.  At a minimum, a U.S. Army  Corps  of
Engineers permit will be required under the authority of section* 10 of the
1899 River and Harbor Act and 404 of the Federal Water Pollution  Control  Act
and amendments (FWPCA) (P.L. 92-500).

SPECIFIC PROVISIONS

Page 111, 3rd paragraph, last sentence - Why was alternative 2C proponed  IT,
as indicated by previous study, that It will not sr.hleve the designed  pur-
pose of the project?

Page 111, 4th paragraph, first sentence - Eutrophlcatlon of a lake  as  a
natural process cannot be halted by any action.  Project construction  may
alter or reduce the eutrophlcatlon rate but not hall It.

Page 111, 4th and 5th paragraph - The stated purpose of the project In  in
enhance water quality for recreational use; however, it would seem  doubtful
from latter discussions that project construction  will actually achieve this
since ground water will itlll have to be pumped along the swimming  bench  to
maintain water quality adequate for swimming.  Further, It  is not clear how
the stated $4,000,000 tn recreational benefits for the project  were derived,
or how project construction will enhance recreational usen, such m hunting,
hiking, and fishing.  These activities currently occur at moderate  to high
levels In the Vancouver take area, end It is doubtful that  enhanced water
quality will Increase thxse uses,  in fact, it would seem that  the  loss of
habitat on the south shore of the lake by dredged material  disposal and the
Incrnanrd human activity on the lake will actually decrease finning Bnrl
hunting use In the area.  In addition, tt would appear that the ma)or dif-
ference Is recreational use of the area between the maximum project  (12.5-15
million cubic yards) and the 8-10 million cubic yards alternative U the
construction of an Olympic sailing course.  It is  questioned whether Che
Increase loss of habitat from the Increased amount of dredged material tn
be disposed of Is worth the construction of a sailing course that will ben-
efit only s miiall segment of the population.  Those dlgcuisions nuod to bo
                                                                                                                                                                                    CTl

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 9


10





11
12
 13
 14
clarified by Including what Increases or loss in user days for which
activities are anticipated by construction of each of the alternatives.
Tills should be done In order that the benefits and losses of each alter-
native can be adequately weighed against each other as required by
Principles and Standards.

Page 1, first paragraph, last sentence - Residential areas are present,
both near the southeast corner of the lake and on high ground along the
east shore.  Both of these areas could be expected to be impacted, either
directly or Indirectly, by project construction.

Page 7, first paragraph - The Southwest Air Pollution Control Authority
had indicated the Vancouver Air Shed Is currently full in regards to
suspended particle emissions, and it's doubtful that any Industry with
suspended particle emission will be allowed to locate in the Vancouver
Lake area.

Page 7, 4th paragraph  - The main inflow into Vancouver Lake Is from the
Columbia River up Lake River and not Burnt Bridge Creek.

Page 8, Soils Section  - This section should Include a discussion of prime
and unique farm  lands  in the project area as required by CEQ guidelines.

Page 13, first paragraph * This Is not an adequate  statement of our proposed
project in the area.   In our Phase I studies, we are considering 10 poten-
tial project alternatives  that provide flood protection to from 310-3,900
acres  of the Vancouver Lake  lowlands with various  levee alignments.   The
alignment  shown  In  figure  4  is similar to the Corps' Vancouver Lake Diking
Project alternative 4, but our alternative includes all of the area between
lower  River Road and  the Columbia  River  from  the ALCOA Plant, east to high
ground near the  Port  of Vancouver.   It Is suggested  that you contact  the
Portland District for a complete description  of  the Corps' project at
Vancouver  Lake.

Page IS,  3rd  paragraph - Methyl mercury  can also be directly absorbed from
the water,  as well as taken  up  through the  food  chain.  A  discussion  should
also be provided of how the  0.02 micrograms of mercury per gram of fish
relates  to state water quality  standards  and  the toxicity  level for humans.

Page  18,  5th  paragraph - Data  is  available  from  the USFWS  on fish  species
present  in the  lake,  and this  Information should be included in the EIS,
as well  as an estimate of what  proportion are warm-water gameflsh  and what
portion  are cold-water gamefish.   How  does  the  20  C apply  to Vancouver Lake,
and  in what way Is Vancouver Lake  not  conducive  for trout  and  other salmonoids.
Salmonotds,  as  well as steelhead  trout have  been collected near  the mouth of
Burnt  Bridge Creek and also  near  the Mulligan's  Slough  area.

Page  26,  5th  paragraph,  4th  sentence - This  statement  is not  true  and is
contradictory to the  2nd sentence,  above.
        Page 45, 2nd paragraph,  last sentence - It is doubtful that this will occur
        to any extent.   Some wetland or marsh areas may be converted during low-
 15      water years; however,  during normal-water years, the areas would have to
        be diked or filled  in order to be used as productive agricultural land.
        It is doubtful  that Individual land owners would be allowed to do this
        under current federal  regulations.

        Page 46,  paragraphs 5  and  6 - It Is doubtful that the lake would become
        hypereutrophic,  particularly in light of  the 208 programs  for Burnt Bridge
 16      and  Salmon  Creeks currently being conducted in the watershed.   A further
        discussion  Is needed here  on what impacts these programs will  have  on
        water quality in the  lake  without the proposed project.

        Page 49,  2nd paragraph - It Is stated that  from 53,000 to  56,000 cubic
        yards of  material will be  dredged for annual maintenance requirements.
 17      This section should discuss the  methods that will  be  used  to do  this,  as
        well as what disposal areas,  both for short range  and long range, will he
        used.

 18      Page 52,  first paragraph -  Again, it  should be indicated that  this  levee
        alignment is  only one of the  alternatives being  considered  by  the Corps.

        Page 53,  first paragraph -  The cost estimates  should  Include total  costs,
        including administration, engineering, legal services, and  contingencies,
        as well as the current estimate of Federal  participation.  Also,  since lake
19      restorations  are generally  temporary, unless they are constantly maintained,
        some  estimate of maintenance cost for dredging, disposal of dredged mate-
        rial, and operation and maintenance of the  flushing channel should  be  In-
        cluded.
O
O
                                                                                                    20
                                                                                                    21
                                                                                                    22
       Page 54, last paragraph - Construction of the flushing channel will have
       an adverse impact on transportation.   No discussion Is present regarding
       foot or vehicle transportation over the flushing channel.

       Page 55, 2nd paragraph,  2nd sentence  - The dredged material would take up
       to 3-4 years to dewater  and settle as stated earlier;  and,  then depending
       on the thickness of the  material and  whether it was agitated,  it would only
       have a 18-24 inch crust  underline by  the original unconsolidated material.
       This would limit the suitability of the material for dike  construction or
       other purposes.

       Page 57, 2nd paragraph,  first  sentence - The Corps has  mapped  the Vancouver
       Lake flood plain,  and  this  Information Is available from Portland District's
       Flood Plain Management Section.

       Page 59, 2nd paragraph,  last sentence;  page  61,  3rd paragraph,  last  sen-
       tence;  and page  63,  2nd  paragraph,  last sentence - These statements  seem
       to reflect the  character of the  project In general.  They  Indicate that both
       the impacts of  the proposed project,  as well as  its benefits are not  well
       known.   It is anticipated that additional Information in these  areas  will
       be needed in order to obtain required permits.

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        Page 64,  1st paragraph, 2nd sentence - It Is not apparent how colder
23      Columbia River water flowing in on the bottom will displace surface algae
        blooms.   This needs further explanation.

        Page 64,  2nd paragraph - Again, enactment of the proposed project would
        not halt eutrophlcatlon of the lake.  With the improvement of both the
        water quality in the Columbia River and in the Vancouver Lake Watershed,
24      it Is doubtful that the lake will become hypereutrophic without the pro-
        posed project.  The lake, however, will continue to fill in with sediments,
        even with the proposed project, unless a maintenance dredging program is
        conducted.

        Page 65, 1st paragraph, last sentence - Maintenance dredging requirements
25      and siltatlon rates for the flushing channel should be discussed in the
        final EIS.  It is conceivable that siltatlon rates at either the Columbia
        River side or the Vancouver Lake side of the channel may be significant
        enough to make the channel inoperative without considerable maintenance
        dredging.

        Page 65, 5th paragraph * This statement is misleading and assumes that all
        water entering the lake will heat uniformly.  The colder water entering
26      from the Columbia River will tend to sink and remain on the bottom and may,
        In fact, lower the bottom water temperature In the Mulligan's Slough area
        due to its proximity to the flushing channel.

        Page 66,  1st paragraph - Information should be supplied on the screening
27      devices and their acceptability, both for project operation and blocking
        downstream migrants from entering the lake.  This Information will be
        necessary for any federal permit required.

        Page 78 - The discussion of disposal sites should also evaluate such alter-
28      natives as island creation and barging and indicate why these disposal
        methods are or are not acceptable.

        Page 79,  last page, 3rd sentence - Again, the Corps diking project represented
29      in the EIS Is only one of the alternatives being considered and not neces-
        sarily the proposed project.

30      Page 80,  2nd paragraph - It is doubtful that such a study would show much,
        since much of surface contaminants will be leeched out by rainfall.

        Page 82,  2nd paragraph, 2nd to the last sentence, and Page 83, 4th paragraph,
31      1st sentence - Again dewater time would require from 3-4 years if not con-
        ditioned and then would probably not support traffic since only the upper
        18-24 Inches of crust would be dewatered and consolidated.
CORPS OF

 1.    Response
      EP/Vs riean L.V'e^ Program is not subject, to the ref
      and standards.
                                                                  |§r inciple<;
      Only after the .ma lysis cninpliHiM  in  l.hr;  Vancouver  Lak"  Mister Plan
      and the DEIS was  it. known  that AH"ruativnt.  Fish inn IPS?
      is expected to increase due to enhanced wotor quality and  improved
      access.

 5.   Response
      EPA will not fund construction of the sailing course since there  is
      no direct link to improved water quality.  Flip grant renditions
      state that no more than 9 million cubic yards of material  shall lie
      removed from the Like bottom.

 fi.   Response
      EPA's Clean Lakes Program is not -,'ihjrrt to (he ivfcrenrwl l-v in.: ipl<>s
      and Standards.

 7.   Response
      Text has been changed accordingly.

 ft.   Response
      The SACC/V wi 11  still  review any applications for industry  loc.it inn,
      though the lirshod dons pose very real limitations.

 9.   Response
      Ipxt has h"pn rhangprl accordingly.

li.   Response
      Prime  farmlands  have  been noted in  text on page fi.

11.   Response
      Figure -1 liss h'vn revised l.o depict  the probable alignment  of tlic
      dikes  fiat -.Mill  he assessed in t'\c  Draft  Environmental  Impart
      Stitemsnt that  is now "vim) prepared by the Corps.

-------
1?.    Response
      Stat° standards apply only tn inflowing streams to lakes.   A
      .005mg/l total  mercury for a 100 cfs stream is the maximum level.
      Toxicily to humans is contingent on several parameters, which is
      difficult to assess at this time.

13.    Response
      Text has been rhanqed accordingly.

It .    Response
      text has been changed accordingly.

15.    Response
      Text has neon changed accordingly.

16.    Response
      llyporeutrophic is used as  the advanced stage of the existing eutrophic
      condition.   It is assumed  that  this could occur even within  the
      natural processes, due to  the lake's physical  setting  and character-
      istics.  The imparts of the 200  study cannot he adequately discussed
      because existing  data is  insufficient.

17.    Response
      EPA  grant  conditions  require  that an operation plan  for the  construction
      and  operation  of  the  project  be prepared prior to expending  any
      construction funds.   This  operation plan must  cover  the estimated
      life of  the  project  and must  be approved by EPA.   Annual  maintenance
      dredging  requirements will be addressed  in  that plan.

10.   Comment  noted.

10.   Response
      This information  will be  included in  the  operation plan  to  he
      prepared by the  Port of  Vancouver and  approved by EPA.

?1.   Response
      Foot and vehicle transportation will  be provided  via Lower  River
      Road.  That road will be relocated to accommodate construction nf
       the flushing channel.

 ? 1 .    Response
       Vancouver Lake Master Plan and Pilot Dredge Study indicate that
       i|r'?d<|0il material's would take up  to one year to dewater.   Further
       discussion  of this will be included in the operation plan.   Drudge I
       m.itirl.ili are not proposed to be used for  dike construction.
23.   Response
      Text has been changed  to clarify  tiie  process.

24.   Response
      Text has been changed  appropriately.

25.   Response
      Maintenance dredging requirements will be discussed  in detail  in
      the required operation plan.

26.   Comment noted.

27.   Response
      Design criteria for the screening devices will be included in the
      reguired operation plan.   These criteria will be developed jointly
      with the state and federal fisheries management agencies.

28.   Response
      Island creation was evaluated in the Vancouver Lake Master Plan.
      It was determined not to  be feasible based on the characteristics
      of the dredged material.   Barging has not received detailed
      evaluation.

29.   Comment noted.

30.   Response
      The proposed study is intended to determine the vegetation growth
      capabilities and limitations of the dredged materials.

31.   Response
      Methods of  conditioning the dredged materials will  he evaluated
      in the  operation plan.
       Rpspoiv.'1
       Klomlpi i In  do] innit ions are  shown pn Figure 1.

-------
STATE OF
WASHINGTON

Dixv I.pr* R*y
                           DEPARTMENT OF GAME
                           A*»t N-*t!i Op="J Wav ntanpA. WadvngiQ-i W
December 5, 1977
Mr. Donald f. Dubois
Regional Administration
U.S. Environmental Protection Agency
1200 6th Avenue
Seattle, WA 98101
Mr. Dubois,
                                                             L;-,.:-
                                                                             r
                                                                           J <-T
                                                                     • 'HAL [.VALUATION
                                       DRAFT EIS:  No. EPA-10-HA-CLARK-POV-CL-77
                                                       Vancouver Lake Reclamation Study
                                                       Clark County
Your document has been reviewed by our staff as requested.  Comments follow:

1.  Section  II. Existing Conditions.  Your EIS, in combination with the Draft
    Wildlife Habitat Analysis for Vancouver Lake Restoration Project prepared
    by Jones and Stokes Associated, Inc., provided adequate baseline information
    on existing wildlife habitat.  Figure 7, which outlines significant wildlife
    areas, is generally accurate although it does not Indicate stands of Pacific
    willow,  on the existing islands at the north end of the lake and on the north-
    east lakeshore, which we feel are valuable wildlife habitat.

2.  Section  III, Alternatives and Their Effects.

    a.  Alternative 12, Scale of Development.

        (1)  The selection criteria for spoil disposal sites (page 49), are ade-
             quate but we oppose any pHofitlzation of these criteria which would
             subordinate fish and wildlife resources to the proximity of disposal
             sites or the suitability of dredged material for intended future use
             of the site.

        (2)  Although we have no problems with the brief discriptlons of potential
             spoil disposal sites (pages 50 and 52), we disagree with the idea of
             filling in Site 5 to preserve or enhance other more valuable fish
             and wildlife areas.

    b.  Alternative 2A. Dredging of 12-15 million cubic yards.

        (1)  We do not oppose in principal the creation of a year-around sailing
             area in Lake Vancouver.  We do oppose 1n principal the use of valuable
             lakeshore fish and wildlife habitat as convenient spoil disposal sites
                                                                                               page 2
                                                                                               Donald P. Dubois
                                                                                               December 5, 1977

                                                                                                       for the tremendous amount of material which would be dredged to create
                                                                                                       such a sailing area.

                                                                                                  (2)  We agree with the statements on page  66-68 that the disposal of dredged
                                                                                                       materials in Mulligan Slough (in Site VI) would permanently destroy
                                                                                                       recognized important wildlife habitat and seriously impact the wildlife
                                                                                                       characteristics of the whole area.  He also agree that disposal adjacent
                                                                                                       to Buckmire Slough would destroy valuable fish and wildlife resources.

                                                                                                  (3)  We agree with the statement on page 72 that a significant habitat area
                                                                                                       would be lost to the local and regional ecosystem if wetland areas were
                                                                                                       covered with dredged materials.

                                                                                              c.  Alternative 3. Disposal Placement Material

                                                                                                  (1)  In general, we favor a project that would result in shallower dredging,
                                                                                                       less dredge spoil material, and relatively deep deposition of spoil in
                                                                                                       those areas most acceptable for spoil, so as to reduce the overall sur-
                                                                                                       face area of land, and wildlife habitat blanketed by spoil.
                                                                                en
                                                                                o
                                                                                       10
(2)  The habitat evaluation  done  by  Jones  and  Stokes  as  a  supplement to this
     EIS states, on page  19, that all  disposal  sites  and portions of the lake
     to be dredged contain valuable  wildlife habitat.  We  agree with this
     assessment.  We feel, however,  that there  is  a lot  of room for discussion
     of imaginative solutions to  spoil  disposal-solutions  which are economically
     feasible but do not  result  in unacceptable losses to  fish and wildlife
     resources.   We would not object,  for  instance, to the creation of an is-
     land in  the undredged portion of  the  lake.  If designed properly, a new
     island could be used as additional beach  area for boaters and need not
     interfere with prevailing winds needed  for sailing.

(3)  We oppose any use  of Sites  5 and  6 for  spoil  disposal, as there areas
     contain  the most valuable wetland habitat at  Lake Vancouver.

(4)  We feel  that, of the remaining  potential  spoil sites, Site 7 would be
     the least detrimental to fish and wildlife.   Relatively deep spoiling
     here would  take care of a tremendous  amount of spoil  material.

(5)  Of the sites on the  northwest shore of  the lake, we think that Site 2
     night be most advantageous  for  deep spoil  since  vistas could be created
     to enhance  the adjacent park.

(6)  There are valuable wildlife  habitats  in Sites 1, 2, 3, 4,  and 7 which
     might be at least  partially  protected If  imaginative, selective spoiling
     were done.   If these areas are  selected for spoiling, we would  insist
     on a serious discussion of measures to  protect such vegetative  cover

-------
page 3
Donald P. Dubols
December 5, 1977

         types as reed canary grass, and as many  large  deciduous  trees  as  possible.

He think that this draft EIS, 1n combination with the wildlife  habitat  analysis,
Is generally adequate In describing the environmental resources and  direct en-
vironmental Impact of the proposed Vancouver Lake Reclamation project.   As we said
before, we feel that there 1s still a  lot of room for discussion  of  creative
methods of spoil disposal to protect existing  fish and  wildlife resources.

Sincerely,

THE DEPARTMENT OF GAME
             Tourrette, Applied Ecologlst
Environmental Management Division

JEF:bj
cc: Agencies
    Regional Manager
STATE OF UA'HIKGTOf) QEP/WrHEFir OF GAME

  1.   Text has bec-n changed accordingly.

  2.   Response
      Final sites will be chosen based on wrtland  and wildlife protection
      criteria (refer to grant conditions for  further discussion of
      acceptable disposal sites).

  3.   Response
      Site 5 has been eliminated from further cons Her .if Hn .•>•; i disposal
      site.

 4.   Response
      The lake Mill  not  be  dredged to the deeper depths  required  for  the
      sailing  course,  since habitat  and  water quality considerations  do
      not warrant  deeper dredging.   As outlined in  the grant conditions,
      no more  than 9 million cubic yards (plus maintenance dredging)  shall
      be removed  from  the lake bottom.   The  dredging shall conform with
      the bottom  configuration needed to adequately flush  the lake.

 5.   Comment  noted.

 6.   Comment  noted.

 7.   Comment  noted.

 3.   Response
      The grant conditions  state  that:  "The  final dredging and dredge
      disposal  plan  and  an  operating/monitoring plan and design for the
      flushing channel developed  in  cooperation with anadromous fisheries
      management  agencies shall be  submitted to the Project Officer for
      approval."   Representatives  of the Department of Game will  be
      consulted during the  preparation and review of those plans.   Island
      creation  was evaluated early  in the Master Plan process.   It was
      determined not to  be  feasible  due  to the character of the dredge
      materials.

 9.   Response
      The grant conditions  state  that: "Dredge spoils shall be disposal
      in such  manner,  location and depth as  to result in minimum  loss to
      valuable  habitat and  to  provide maximum opportunity  for habitat
      mitigation and restoration  of  the  aesthetic quality  of the  area.
      Habitats  within prooosed disposal  sites Va and Vb  have hiqli  rH.itive
      value  (see "Wetland Habitat  Evaluation," Vancouver Lake,  November,
      1077)  and therefore thc-se areas will not be considered as disposal
      areas.   Area VI can only be used to the extent of  Alternative 7
      of the U.j.  Army Corps of Engineers diking project."

10.   Response
      Such  ine.isures will  be  developed during the preparation of the
      operation nlin referenced above.

-------
 December 16,  1977
EPA  Region X
1200 6th ave.
Seattle, Washington 98101
 Dear Sirs:

 In  my brief and Incomplete review of  the  Vancouver Lake Reclam-
 ation Study draft E.I.S. I found a few errors  that should he
 brought to  your attention:

 Page 11, 2nd paragraph, 2nd sentence, states that Whljtple and
 Flume Creek empty Into the lake ( Vancouver ).   However, those
 creeks flow Into the Lake River not Vancouver  Lake.   The only
 named creek flowing Into Vancouver Lake,  other than  Burnt Bridge
 Creek (BBC), 1s a rather Insignificant drainage, aptly named
 Chicken Creek,

 Page 13, 2nd paragraph under the heading  of Burnt Bridge Creek
 states that no flood  plain or flood  flow data for BBC Is available
 as  Indicated by personal comnunlcatlon with the Army Corptof
 Engineers,  1977.  However, In our files,  as well as  at Regional
 Planning, we have the"Spec1a1 Flood Hazard Information , Burnt
 Bridge Creek, In the Vicinity of Vancouver, Washington" ,
 U.S.  Army Engineer District, Portland, Ore.  ,  February, 1977.
 This contains both the flood plain and flood flow data.

 Page 14, 3rd paragraph, a similar  statement about Lake River
 may or may  not be accurate as a recent  Army Corps of Engineers
 draft report on the Salmon Creek  drainage basin  (  Barker,  Tamara
 1977)  reports that USGS had recorded water discharge data on
 Salmon  Creek from October, 1943 to September,  1975.  Possibly,
 this  data,  Including the maximum flow of  Salmon  Creek recorded,
will  reflect on Lake River flooding.

 I hope  these corrections  will  be helpful.
                n77
                                             Sincerely,
Thomas A. Newman
Chemist
Southwest Washington
Health District
llf'SJi'lir."
1Tir> n

                                                    I ,ll;i« IdV'l, lull.  Ill  l.ll'lir I'lVI". ""'' ""' '.llfl If |r-Mt.  .>nni|i|l| t'l ,l'l'''|'l ll,"

                                                    rll'fi'lllllw1  I l"'irl  r.ll,)rn( l"l Ijl I' '..

-------
                        DEPARTMENT OF ECOLOGY
                        Oh™r»». Wiwhirxnon 98504        20S/753-MB
December 21, 1977
Mr. Roger K. Mochnick
Environmental Evaluation Branch
Mall Stop 443
U.S. Environmental Protection Agency, Region X
1200 Sixth Avenue
Seattle, Washington  98101
Subject:
          Review of Vancouver Lake Reclamation Study
          Environmental Impact Statement
Dear Mr. Mochnick:

Thank you for providing us with a copy of the draft environmental impact
statement for our review and comment.

The graph in figure 13 shows a very interesting relationship, about
which the statement Is made:  "... the greater the addition of Columbia
River water, the more eutrophlc the lake may be expected to become."
This is the key statement in the EIS which, in effect, reaches the
conclusion that the restoration of the lake, as proposed, cannot succeed.
It is my belief that the above statement is not valid and that flushing
will likely improve water quality, although the lake should remain
eutrophic.

The total phosphorus (TP) concentration in Vancouver Lake is 0.23 mg/1
and the TP concentration in the Columbia River is 0.066 mg/1 according
to Beak's (1977) data for a three-year period.  It is difficult to
imagine how some Improvement would not be obtained when the lake contains
3.5 times as much TP as the flushing water.  The graph in figure 13 does
not consider phosphorus and hydraulic loading from Burnt Bridge Creek.
The model is attributed to Vollenweider and is actually the work of
Michalskl.  The model was verified empirically using data from lakes
which, on the average, were much deeper and less eutrophic than Vancouver
Lake and, therefore, probably received a smaller fraction of their
nutrient income from the sediment.  Another factor which makes Vancouver
Lake atypical is  the great variability in volume and mean depth which
results from the  flow reversal in Lake River.

A significant source of phosphorus in the lake, not given full consider-
ation  In the EIS,  is the lake sediment.  In Western Washington, phosphorus
is generally found bound to iron in  aerobic sediments at the sediment-
water  Interface.  But deeper In sediments, iron is in ferrous form which
                                                                                                       Mr.  Roger K.  Mochnick
                                                                                                       December 21,  1977
                                                                                                       Page two
                                                                                                       is the reduced  oxidation state.    In these  reduced sediments, phosphorus
                                                                                                       is not bound to iron and is soluble.   A  common  event in Vancouver Lake
                                                                                                       is wind resuspension of sediments,  because  of the shallow water over-
                                                                                                       laying them  and the  large lake surface area.  Once resuspension occurs,
                                                                                                       the soluble  phosphorus  previously  trapped below the oxidized sediment-
                                                                                                       water  interface will be released into  the water column and made
                                                                                                       available  for algal  production.  Tills  mechanism is the only explanation
                                                                                                       for the extremely high  total  phosphorus  concentrations found in the
                                                                                                       lake,  because all other possible sources (Columbia River, Lake River,
                                                                                                       and Burnt  Bridge Creek)  contain concentrations  lower than the lake.

                                                                                                       In order to verify the  above  hypothesis, the following calculation was
                                                                                                       made using a mathematical model developed by Dillon and Rigler In 1974.
                                                                                                       This widely used equation is:
                                                                                                                                     [P]
                                                                                                      where  the variables and  their units are defined as follows:
                                                                                                            [P] • the concentration of TP in  the lake (mg/m )
                                                                                                                                                              yr.)
       L - the areal loading of TP to the lake (mg/m

       R - the TP retention coefficient (unit less)

       Z = the mean depth of the lake (m)

       p • the flushing rate or annual inflow/lake volume (1/yr.)

The only variable for which a value is not given in the EIS Is R,  which
in most lakes is between 0.3 and 0.9;  or stated another way,  between 30
and 90 percent of the Incoming phosphorus is  retained  in the  sediments.
Using data from the EIS on Burnt Bridge Creek and Vancouver Lake where:
[P] = 230 mg/m3, L - 200 mg/m2 yr., R = unknown,  Z - 1m,  p  -  Burnt
Bridge Creek flow/Vancouver Lake volume » 2.1/yr., the following calcula-
tion is made:
                                                                                                                          ,2301 u <200>
                                                                                                                          12301
                                                                                                                                   (1)  (2.1)
                                                                                                                                                         -1.42
                                                                                                      The fact that R is negative indicates that in Vancouver Lake here Is a
                                                                                                      net transport of phosphorus from the sediments into the water column.
                                                                                                      This supports my hypothesis that the sediments asre a major contributor
                                                                                                      of phosphorus to the overlaying lake water.   The original  source of
                                                                                                      phosphorus to the sediment may have been the "... major  silt disposi-
                                                                                                      tion during the 1948 flood .  . ."

                                                                                                      The above discussion and calculation shows that the impact statement's
                                                                                                      conclusion, that flushing will increase the  rate of eutrophlcatlon. Is
                                                                                                                                                                                    VO
                                                                                                                                                                                    O

-------
Mr. Roger K. MochnJLck
December 21, 1977
Tage throe
Invalid and observes that the sediments may be one of the primacy sources
of phosphorus to the lake.  Dredging and flushing may produce a signifi-
cant reduction in TP concentration by increasing the mean depth and
diluting the phosphorus released by the sediments.

The last page of the document should read, Washington State Department
of Ecology, rather than Washington Sliate Department of Environmental
QuaJity.

Barbara Rlau from our Lake Restoration Program made the following comments
on the impact statement, referenced by page number.

On page 15 a study was cited which was based on seven fish.  It is
doubtful that seven fish constitutes a representative sample of the
entire fish population.

On pages 48 and 58 the statement is made that dredging will remove
nutrient-rich sediments.  Zt would be useful if the reduction of nutrients
in deeper sediments was supported by data or reference to a publication.

On page 63 the titles to the left of the table are confusing.  It would
be clearer to write:  "mean depth of 1 meter (before dredging)."

Since the Columbia River has sufficient nutrients to support algal
growth, there may be an increase in attached algal growth (petiphyton)
with an increase in flow through the lake.  Periphyton generally grow
better in conditions of greater flow, since there is increased nutrient
supply with increased flow.

It would be informative to discuss the value of the dredge spoils for
agricultural uses in light of the heavy metal and pesticide analytical
data.

Miriam Lnukers of our Shoreland Planning Program made the following
observations concerning the project's relationship to shoreline programs.
Vancouver Lake is a shoreline of statewide significance under the Shore-
line Management Act.  The rehabilitation project would further two of
the objectives for shorelines of statewide significance:

     1.   Increase public access to publicly owned arena of tho shoreline.
          and

     2.   Increase recreational opportunities for the public on the
          shoreline.

At the same time, the project would conflict with two other objectives
for shorelines of statewide significance:

     I.   Preserve the natural character of the shoreline, and

     2.   Protection the resources and ecology of shoreline.
         Mr.  Roger K.
         December 21,
         Page four
Mochnlck
1977
         The ETS identifies the lake and its shorelines as valuable habitat for
         freshwater fish and for various water fowl.   It also points out  the
         potential conflict between the natural resources and the proposed projp.ct.
         The anticipated amount of  dredge spoil material in the identified sites
10       will result in loss of future productivity especially if the sites No.  5
         and No. 6 adjacent to Mulligan Slough are utilized.   Alternative 2B with
         dredging of 8-10 million cubic yards would be more consistent with the
         Shoreline Management Act policies than Alternative 2A which would dredge
         12-15 million cubic yards  and need more wetland arr*.as for filling.

         The EIS discusses briefly  the Shoreline Management Act and shorelines of
         statewide significance,  but  does not discuss  in any  detail the local
         shoreline management programs that would regulate the project.   The
11        project would fall under the jurisdiction of  both Clark County's and
         Vancouver's shoreline programs.   The policies in these programs  favor
         fills which minimize damage  to ecological values and do not create
         hazards to fish and  wildlife habitat.

         If  you have any questions  regarding these comments,  please contact me at
         753-6892.   Barbara Blau of our Lake Restoration Program may be reached
         at  753-3886 concerning her comments.   Miriam  Laukers of our Shoreline
         Planning Program may  be  reached  at 753-6871 concerning her comments.
         Sincer
         C.  Jonathan Neel
         Environmental Review Section
         CJN:av

         Attachment
              Barbara Blau
              Miriam Laukers
              Norman Glenn
              Bob  Bottman
                                     References

        Beak Consultants,  Inc.   1977.  Operational Ecological Monitoring Program
             for  the  Trojan Nuclear Plant, Annual Report Volume  1.

        Dillon, P.  J.,  and F. H. Rigler.   1974.  A test of  a Simple Nutrient
             Budget Model  Predicting  the Phosphorus Concentration in Lake
             Water.   J.  Fish. Res. Bonrd Con.   31:1771-1778.

-------
STATE OF WASHINGTON I1FPARTMENT OF ECOLOGY

 1.   Comment noted.
 2.
 5.
      Response
      The model was attributed to Vollenwcider because Hie current  1 it-pral.ure
      cites it as Vollenwpider's, and because all practical applications
      of the model used in this study were developed by Vollenweidcr.

      Response
      Lake sediments have been considered as a primary source of phosphorous
      In the lake (page 16, paragraph 5).  Phosphorous sources could he
      several, with each source adding proportionately to the already
      excessive levels within the water column.  At issue is the fact that
      excessive levels do in fact exist, and all sources (and to what degrees)
      have not been researched to date.  Estimates in this study have bnen
      conservative.

      Dredging may produce a reduction in total phosphorous concentration
      of the lake by meansof removal of phosphorous containing sediments,
      but anticipated flushing characteristics will not necessarily
      eliminate phosphorous availability to eutrophic conditions.
      Phosphorous sources are suspected of being diverse and plentiful
      enough to continually replenish high levels of concentration.  In a
      static body of water the phosphorous content can be expected  to be
      used up by resident biological processes.  But in a flushing  system,
      this typically will not occur.
      Response
      Text Hal
               been changed accordingly.
 7.
Response
Avallable data included bioassays of only seven  fish.  This sample
is not projected to be representative of the whole system, but
merely a sample of the data presently available.

Response
lext on page 53 states that "dredging...should  Improve the
character of the sediments exposed at the sediment-water  interface.
However, it does not appear that  the nutrient supply  in Vancouver
Lake sediment  is particularly high."  Reference  is made to the
Vancouver Lake Master Plan and Pi hit Dredge Study; both prepared
by Damn-; 4 Moor? and the Port of  Vancouver.

Response
Text has bppn  channed accordingly.
 3.   Response
      Significant increases in periphyton ore not n*pprl.n<| tn occur,  as
      tliij alg.ie requires a stable surface on which to .iita<~h ll.srlf.
      Vancouver Lak° has a sind and mud bottom, which is not  the preferred
      substrst0 of uoriphyton.  The lako is also subject to turbidity,  which
      causes r,3dim<>nt problems for this type of algae.

 9.   Response
      The Pilot Dredge Study conducted by Damps ?< Him-p (1977)  concluded
      that the greatest concern for aoricultural reuse of the dredqe  spoil";
      would be soil  structure.  Heavy metals and pesticides are not pxpeclrd
      to cause agricultural problems.

10.   Response
      Grant conditions substantially minimizing the alteration  of wetlands
      and other natural habitats  will  reduce the identified conflict1;.
      Grant conditions will  limit the  amount of material to he  removed  from
      the lake bottom to 9 million  cubic yards.  Since hahit.it:. in proposal
      disposal sites Va and Vh have high relative value, these  areas  will
      not be considered as disposal areas.   Area VI can only  be used  for
      disposal to the extent of Alternative 7 of the U.S. Army  Corps  of
      Engineers diking project.   Mulligan Slough and the island located
      near the outlet of the lake at La!: relationship of thn Clark County
      Shoreline Mitngement Program  to  Vancouver Lakp.   Plan ohjnrtivr"",  and
      d«siquations are discussed.
                                                                                                                                                                                        CO
                                                                                                                                                                                        o

-------
        SI ATE OF
        WASHINGTON
DLPAKTMENT OF FISHERIES
December 22, 1977
Mr. Roger K. Hochnick
Environmental Evaluation Branch
U. S. Environmental Protection Agency,
 Region X
1200 Sixth Avenue
Seattle, Washington  98101

Dear Mr. Hochnick:

           Draft Environmental Impact Statement - Vancouver
           Lake Reclamation Study - Port of Vancouver,
           Washington, Clark County      	WRIA E-28

We have reviewed the above referenced statement and offer the following
comments.

In past communications, and in particular, our letter to the Department
of Ecology (attached) regarding the referenced project, we noted that a
flushing channel will have an impact on both upstream and downstream
migrant salmon in the Columbia River.  In our opinion, your Draft EIS
does not adequately address this impact.  For instance, on page 65 it
is indicated that the Department of Fisheries believes that the flushing
channel may lure migrating salmonlds which would interrupt the natural
migration process.   We believe that the proposed flushing channel
carrying 500-700 cfs of water, not only "may" lure but will attract
both downstream and upstream migrants into Vancouver Lake.  It is our
professional judgement that downstream migrants originating from up-
stream spawning and rearing areas will enter Vancouver Lake through the
flushing channel  and that adult salmon destined for spawning areas up-
stream from Vancouver Lake could be attracted into the mouth of Lake
River and would migrate into Vancouver Lake where they could be lost
to production.  These impacts need strong emphasis in the final CIS.

In 1977, approximately 75 million juvenile salmon originating from
Washington streams  upstream from Vancouver and including the Snake River,
migrated seaward.   This figure does not include salmon production from the
State of Oregon nor other important species such as steelhead or shad.
                                                                                                 Mr. Roger K.  Hochnick
                                                                                                 Page two
                                                                                                 December 22,  1977
                                                                                                 On page 65 you noted  that  the  WDF  "would  probably"  require  screening
                                                                                                 to prevent juvenile salmon  from entering  the lake.   Based on  our  present
                                                                                                 knowledge of the  project,  I  can assure you  that  the Department of Fisheries
                                                                                                 will require adequate screens  to prevent  the entrance  of fish into Vancouver
                                                                                                 Lake.   This should he stated in the  final EIS.   We  take  this  position on  the
                                                                                                 basis  that downstream migrants  entering Vancouver Lake will be subjected  to
                                                                                                 predation and possible other adverse environmental  conditions existing  in
                                                                                                 Vancouver Lake and Lake River.

                                                                                                 For many years, fisheries  agencies of the Northwest and specifically those
                                                                                                 involved with management of  the Columbia  River salmon  resource, have had
                                                                                                 to seek solutions to  fish  passage  problems  occurring as a result  of dam
                                                                                                 construction on the upper  Columbia River  system.  Adult fish  losses are
                                                                                                 known  to occur between the dams, and downstream  migrant losses occur due
                                                                                                 to turbine mortalities and  from nitrogen  supersaturation during high flow
                                                                                                 and spill conditions.   The  fisheries agencies have  worked with the Corps
                                                                                                 of Engineers and  other power producing entities  on  the Columbia and Snake
                                                                                                 Rivers in conducting  a variety  of  research  programs designed  to reduce  the
                                                                                                 impact of power generation projects  on both upstream and downstream migrant
                                                                                                 salmon.  Hundreds of  millions of dollars  have been  spent for  fish passage
                                                                                                 facilities to increase survival  of salmon and steelhead on  the Columbia
                                                                                                 River.  In view of the value of the  salmon  resource and the financial
                                                                                                 commitment made to maintain  the upstream  fish resources, we could not approve
                                                                                                 the Vancouver Lake project with its  associated potential impacts  on the
                                                                                                 salmon resources  unless adequate facilities were provided for the protection
                                                                                                 of these fish.

                                                                                                 The following comments refer to specific  items in your Draft  EIS.

                                                                                                 1.  Long Term (p. 65)  - The  last sentence refers to screen  and approach
                                                                                                     velocity requirements.   This sentence should be changed to read as
                                                                                                     follows:  "Screening criteria developed by the  Washington Department
                                                                                                     of Fisheries  and  Department of Game for water diversions  require
                                                                                                     that screen openings should not  exceed  1/8"  in  the narrow direction,
                                                                                                     and approach  velocities  should not exceed 0.5 feet per  second as
                                                                                                     measured at the gross  area  of  the screen."

                                                                                                     Further it should be noted  that  these requirements pertain to self-
                                                                                                     cleaning screens,  which  we  would require In  this particular case.

                                                                                                     Effective screen  operation  would entail special screen  design and
                                                                                                     placement.  The screening  facility must be effective at Columbia
                                                                                                     River levels  ranging between approximately +2 and  +16 HSL.
                                                                                                                                                         en
                                                                                                                                                         o

-------
Mr. Roger K. Mochnick
Page three
December 22, 1977

2.  Long Term (p. 66) - In the first paragraph you  note  the  possibility
    of closing the culvert gates at key  times during  the salmon  runs  In
    order to prevent their entry Into  the  lake.  We do not consider this
    a viable alternative to an adequately  designed  and constructed screen
    Installation.  The reason for this 1s  that downstream migrants of
    many species are present in the Columbia River  at virtually  all times
    of the year and it is our intention  to protect  the entire  resource,
    not just major segments, as this possible alternative implies.

3.  Fisheries (p. 23) - Carp were not mentioned  1n  the discussion of  fish
    in Vancouver Lake despite the fact that they are  very abundant.  The
    large carp population 1s actually a  key factor  1n the present lake
    environment.  Some local recreation  effort is directed at  this species
    during the spring spawning season.   In addition,  limited commercial
    harvest has occurred 1n the past.

In summary, we feel that certain portions  of the Draft EIS are seriously
deficient in addressing fishery related  Items.   The statement  does not
adequately describe adverse Impacts to salmon and other  Important Col-
umbia River fish species, nor has there  been sufficient  review of
possible measures to mitigate these Impacts.

We hope these comments are helpful  in  further consideration  of this study.

Sincerely,
     Claude Stoddard,  WDG
      WDG,  Olympia
      DOE
      Vancouver Lab
                                                                                                   STATE OF  WASHIIIfiTOH DEPARTMENT OF FISHERIES
1.     Response;
      It is agreed  that the total impacts are not fully known.   EPA's grant
      coiiriilioiis  require that an operation nlan for construct.ion anil
      operation must b» completed prior l.o expending construction fund1..
      This  operation plan  must cover Hie estimated life of the  project,
      and must bo approved by EPA.   EPA and the Port of Vancouver will
      work  closely  with the Dep.ir1.mcnt  of Fisheries during thp  preparation
      of the operation  plan.

 1.    Response
      Text  has Iiren rhnmied accordingly.

 5.    Response
      The Department of fisheries will  he asked for input duriivi f'ic>
      formulation of operation plans for the project.   At that  time,
      specific conditions  can be outlined and formalized.

 Ij.    Response
      Carp  have been added to the. list  of resident fish r.|>ecie-, (|>a
-------
,O"N U STONF PRESIDENT ELECT
 B U BOX 35f
 CLEAR LAnE. WA «SZM


'.ORFN -KAY- MORSF 1ST VICE PflfS
 •V 24JB LIBERTY
 SPOKANE. WA
                                     KEN ucLEoo HONORARY SECRETARY
                                     WASHINGTON STATE
1 NICHOLAS A 7HTFI SECRFTARY

  TACOMA  WA W4H


 OFFICE OF  SECRETAnv
  PO BOX  W7M
  TACOUA  WA M499
  |20A| »4-M<0
                     COOROINATEP CONSCBVAIION AFMLIATFO WITH NATIONAL WILDLIFE FFD£HATION
                                        January  16,  19?8
                                                                                                                   (Page 2-Vnncouver Lake Inpnct Statement.)
     It is most interesting  that the areas on both sides of Alcoa Aluminum Comp-
     any and west of the Lower River Road were not noted as possible spoils area.
     A review of that area will reveal that there would be less  environmental impact
     in these areas than those suggested for Areas1-2-3-'*-5-6.   Area Ho. 7 could be
     a disposal area without too much impact.

            In short summary,  I fpel that a more definite plan with a closer dollar
     estimate be presented and a more acceptable spoils disposal areas bp designated
     before this or any lake rehabilitation plan be decided upon.   There are many
     other points that seem  to me are not fully addressed.

                                        Respectfully yours.
           Mr. Roger K.  Hochnick,
           Environmental Evaluation Branch, H/S Wj,
           0. S. Environmental Protection Agency, Region X,
           1200 Sixth Avenue,
           Seattle,  WA.  98101

           D»ar Mr.  Kochnick:

                   Reference the "Draft Environmental  Impact  Statement for VANCOUVER LAKE
           RECLAHATIOH STUDT, PORT OF VANCOUVER, CLARK COUNTY,  WASHINGTON, November, 1977-
           I certainly appreciate an extended opportunity to make a response to theabove
           mentioned statement.  The statement was brought to my attention late last week
           with the  extended due date.  There are several important points should be an-
           swered.

                  The EPA should hold up any funding  for the project until firm commit-
           ments and decisions are made as to where the  spoils  will be placed.  There are
           seven possible areas mentioned in the report  but  nothing definite.  To make a
           commitment and expenditure of federal funds no large as mentioned in the report
           should have a definite plan or cost estimate  for  such a loren expenditure.  It
           serans to  me that as it is cited in the plan would be an excellent example of
           fipcal irresponsibility.

                  The map facing page W shows spoils dlspossl  area Number 6.  In view of
           the Presidents'  Executive Order relative to saving wot lands,  it la hard to see
           how this  area could be spoiled.   For the moat  part,  it is an excellent wet land
           area, used by a great number of resident and migratory waterfowl and other water
           oriented  birds and animals.  Certainly this area  cannot b« considered as a dis-
           posal area.
                  Disposal areas 1-2-3 a" in f*lr cr°P land Bnd  presently used for graz-
           ing and  other  agriculture activities.  How much contact  with the land owners
           was made to suggest these areas for spoils disposal?
                                           (Con't)
     c:  EPA,  Washington D. C.
                                         HOWARD E. NELSON
                                         National Affaire
        National Wildlife Federation
        1'»12 16th Street, N. W.,
        Washington,  D. C. 20036  V/attach-
w/\.iiinr,!UN
               F. c.i'np, i SMF ir s  LOIINCIL
      Rf':.pnnj;i!
      As -i n.'Iult of  HIP  DEIS  and the Met. lan? usi'd  tn t'io oxtonL lit All°rn( Hie U.S. Army Tnips of Enninpprs dikinn project.  The  isl.md
      ii'.'iir t!ie oiit lot nf  HIP lnk° at Lakn River  and Hulliqan Slnnqh  shall
      remain in Ihplr prpscnt  cnndition.
         "it-il.pd  in Uie fibovp  response,  SitP 6 will receive a suhsl.int.ially
      r"f|'irod quantity of drndypd  material, limited primarily to  Hie
      pion-v/p| l.ind portions of  HIP  site.

      Resgons;
      THe Fort of Vancouvpr has  made preliminary contact with all  nronorty
      o\vi\p.rs affi'i tid by  tiio  proposed disposal.

      Response
      Tltn subject sites werp  eliminated from revi»w in the Vancouver  Lakfi
      Master Plan since t.hp dredijud matnrlals are not suitable  for future
      structural use.  They may  he reconsidered in the operation  plan that.
      will  bo completed prior  to project approval.
                                                                                                              5.   Comment

-------
          National  Wildlife  Federation
112 16TH 5T, N W., WASHINGTON, DC. 200V>
   Me.  Alex Smith, Chief
   Environmental  Review Branch
   U.S. Environmental Protection Agency
            Region X
   1200 Sixth Avenue
   Seattle, Washington    98101
                                        January 20, 1978
                                                   i u
JAN
  row MI
      FVA;UMIUH
                  Re:  NWF Comments on the Vancouver Lake "Clean
                      Lakes Project" DEIS	


   Dear Ms.  Smith:

          Per our  telephone conversation of a few weeks ago,  you  stated
   that EPA  would  take into consideration any comments which  reached you
   by early  in the week of January 23 on the subject DEIS.  Our comments
   are attached.

          Among our principal conclusions and recommendations are the
   following:

             1)  The use of "Clean Lakes" grant funds under  Sec. 314 for
   dredging  and spoil disposal associated with deepening of a lake to
   create a  sailing course or otherwise enhance recreational  boating, seems
   highly questionable, where such lake deepening will have little if any
 1  positive  effect on the lake's water quality.  Since about  half of the
   dredge spoil requiring disposal in the proposed project  is attributable
   to such non-water quality-related purposes, deletion of  Sec. 314 funding
   for this  part of the project will (at least) correspondingly reduce the
   adverse environmental impacts associated with spoil disposal.   The Final
   EIS should fully address this issue and its implications.

             2) It is far from clear that the remaining dredging  to be
   done will have  a sufficient positive effect on water quality to justify
   the proposed grant, particularly in relation to such non-dredging
 2  measures  as (a)  reducing non-point source inputs of nutrients,  (b)
   groundwater flushing of the bathing area, and possibly (c)  flushing the
   lake with water from the Columbia River (although this may just add to
   the nutrient inputs to the lake).  The Final EIS must, clearly, devote
                             Ms. Alex Smith, Chief
                             January 20, 1978
                             Page Two
greater attention to  the  issue of maximizing water quality (not  total
recreational)  benefits, while minimizing the amount of dredging  and
dredge spoil disposal required.

          3) From a substantive project standpoint, our principal
concern, not surprisingly, is to keep at an absolute minimum the
quantities of  dredged material which roust be deposited in
ecologically valuable wetland areas.  Indeed, EPA is itself under  an
affirmative legal mandate to "provide leadership and— take action to
minimize the destruction, loss or degradation of wetlands, and to
preserve and enhance  the  natural and beneficial uses of wetlands ...."
Executive Order  11990 (May 24, 1977).  In this regard, the Final
EIS should give  careful consideration to each of the following:

            a)  regarding as grant-eligible only that dredging which
can reasonably be expected to significantly enhance water quality
and as to which  there are no environmentally acceptable alternative
means of accomplishing this objective;

            b)  to the extent dredging must be done, maximizing  non-
wetland disposal of the dredged material, including use of the material
for creation of  artificial "spoil islands" within the lake;

            c)  to the extent wetland deposition is unavoidable,
spoil deposition should be limited, to the maximum extent possible,
to the least ecologically significant wetland areas.  The Wetland
Habitat Evaluation Study  prioritizes the wetlands adjacent to the lake
as to their fish and  wildlife value.  The results of this Study  should
be integrated  into the Final EIS, with a matching of the least
important wetland acres against the irreduceable minimum quantity  of
dredge spoil requiring wetland disposal.

       We trust  that  EPA's final decision on this project, as well
as the Final EIS, will give these concerns the attention they
deserve and require.

       The opportunity to express these views is appreciated.

                                     Sincerely.
                                                                  Kenneth S. Kamlet
                                                                  Counsel      .
                                                                                                                          Har/ey R.  Spiegel
                                                                                                                          Legal Assistant
                                                                                     Attachment

                                                                                     cc:   See following page

-------
Ms. Alex Smith
January 20,  1978
Page 3
     Hon.  Donald P. Dubois
     Joan  Bernstein, Esquire
     Mr.  Ken Mackenthun
     Mr.  Bob Johnson
     Mr.  Roger  K. Mochnick
     Mr.  Howard E. Nelson
     Mr.  Carl N. Grouse
     Mr.  P.K. Schneider
National  Wildlife  Federation
                                                                            1412 16TH ST., N.W., WASHINGTON, DC. 20036
    COMMENTS OF THE NATIONAL WILDLIFE FEDERATION
    ON THE DRAFT ENVIRONMENTAL IMPACT STATEMENT
        FOR VANCOUVER LAKE RECLAMATION STUDY
                                                                                      The Port of Vancouver is applying for an EPA grant under § 314

                                                                                of  the 1972 Federal Water Pollution Control Act Amendments to

                                                                                rehabilitate and reclaim Vancouver Lake, in Clark County, Washington.

                                                                                The proposed project calls for several steps to be taken to restore

                                                                                the lake:

                                                                                         1.  Dredging the lake (the spoils to be dumped largely

                                                                                on  adjacent wetland areas);

                                                                                         2.  Construction of a flushing channel to bring Columbia

                                                                                River water into the lake;

                                                                                         3.  Pumping ground water into the lake at the swimming beach.

                                                                                The project assumes the full implementation of a proposed 208 plan

                                                                                to  reduce non-point sources of pollution in the lake.   This program

                                                                                is  primarily concerned with pollution caused by agricultural activities

                                                                                and urban drainage. Efforts to reduce non-point sources in the

                                                                                proposed plan include diversion of first flush storm water into

                                                                                sanitary sewers in the Burnt Bridge Creek discharge basin,  and control

                                                                                of  erosion, septic tank leakage, and agricultural runoff.  The extent,

                                                                                nature, and adequacy of these controls are not sufficiently discussed

                                                                                in  the DEIS for critical comments.  Hopefully, the Final EIS will

                                                                                elaborate on these critical points.
                                                             ro |
                                                             JZI

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                                -2-
                                                                                                                 -3-
       The first section of these comments questions whether EPA may
lawfully fund a project which will result in very little benefit to
water quality. Part A of this section reviews the project's probable
effects on water quality.  Part B discusses the scope and intent of
5 314 and whether this project is appropriate for EPA funding under
this section.
       The second section of these comments describes deficiencies in
the Draft Environmental Impact Statement  ("DEIS") and the underlying
project design and suggests necessary remedial measures.

I.  Legality of Proposed EPA Grant
    A. Effects of proposed project on water quality
       Except for the reduction of non-point sources of pollution  under
the 208 program, the proposed project is  not designed to improve water
quality in Vancouver Lake.  Rather, the stated purposes of the project
are to increase recreational benefits, without regard to water
quality, by  (1)  increasing the depth of the lake for boating and  (2)
diluting a portion of the  lake with groundwater to make it safe for
swimming.  This  conclusion is supported by the discussion throughout
the DEIS :
           1.  The  introduction of Columbia River Water  into the lake
will  have  little or  no  positive  impact on water quality in the lake.
The river  water  has  sufficient nutrient levels to  itself promote
rapid algal  growth or  "eutrophication."   DEIS, at  60.   The DEIS
states  that  "the greater the  addition  of  Columbia  River water, the
more  europhic the  lake  may be expected  to become."  At  63.  The DEIS
concludes  that  continued alqal production is  expected.  At 61.
        Flushing the lake with water from the Columbia River will
 increase the circulation of water within the lake.   It is suggested
 that the increased  flow would reduce the tendency for large standing
 crops of algae to develop.   DEIS, at 64.  However,  the DEIS admits
 that the flushing ratio is  far too slow to wash out algal population
 At 61.   The  DEIS does  indicate that the "additional flow could  reduce
 any deleterious impacts" from the introduction  of additional nutrients.
 The suggestion seems to be   that  the introduction of the Columbia
 River water  will be a  break-even  proposition.   If in fact greater
 benefits to  water quality will  result,  the DEIS should  clearly  state
 this.
        The primary reason for introducing  Columbia  River water  into
 the lake, seems to be  to reduce the  bacterial count along the
 proposed swimming beach.  DEIS, at  63.   The river water  has  a
 significantly  lower bacterial count, and will be channeled  along the
 swimming beach to produce a  safe  swimming  area.  The DEIS does  note
 that this water may have to be further diluted with croundvater to
 provide  a safe swimming area.  In short, it appears that  the sole
 reason for introducing river water is to dilute the bacterial
 contamination along one section of the lake, with no additional
 benefit  to overall  water quality.
          2.   Dredging of Vancouver Lake will not significantly
 improve water quality.   Although the DEIS is ambiguous in this regard,
 the conclusion seems to be that the material to  be dredged does not
 contribute significantly to the nutrient base of the lake.  DEIS at
 58.  In fact, phosphorus and nitrogen levels in  the  sediment to
be removed are low.   DEIS at 58.
       The increase  in  mean  depth  of the lake will not significantly
reduce the amount of light available for algal growth ( — in fact,  it

-------
                                -4-

might increase it).  However,  it will  certainly  increase the
residence time of water  in the lake, which  should  tend  to encourage
large standing crops of  algae.  DEIS,  at 64.  Any  positive  effect
will, of course, be counteracted by  the increased  flow from the
Columbia River Channel.
       Approximately half of the proposed maximum  of  15.4 million
cubic yards  to be dredged has  absolutely no relationship to improving
water quality.  This dredging  is for the purpose of developing a
sailing area.  DEIS, at  48.  Only  8.1  million cubic yards of dredging
is  even arguably required to provide "acceptable water  quality."
DEIS, at 49.
          3.  Summary  of Water Quality Improvements.
              The DEIS makes the unsupported and dubious assertion
that the lake's water  quality  "would be improved to the extent that
increased recreational uses would  be possible."  At.  62.  Whereas
water quality enhancement may  contribute to recreational benefits
 (e.g., improved fishing  and swimming opportunities),  it seems obvious
that enhanced recreational benefits  do not  necessarily  mean improved
water quality (e.g., more boat docks and increased water depths may
both improve boating opportunities without  benefiting water quality
"at  all—or affecting it  only negatively).
       The few positive  effects of the project on  actual    water
quality are  summarized at p. 64 of the DEIS.  The  most  that can be
said for the project is  that it may  halt movement  from
eutrophic toward hypereutrophic conditions,  although  the lake will
remain eutrophic.  Actual reductions in nutrient levels in  the lake
                                 -5-

 will  come about only if there are improvements in the water quality
 of  the Columbia RJver.  DEIS, at 64.
       The increased depth of the lake may increase available fish
 habitat.  DEIS at 66.  However, the destruction of fish spawning
 areas through disposal of dredge material would probably result in
 a net harm to the fish population.  DEIS at 68.
       In sum, the project's principal objective is improved
 recreational opportunities—principally boating.  Effects on water
 quality are clearly incidental to this objective and are likely to be
 marginal, at best.

      B.  The scope of section 314.
         Section 314 of the 1972 Federal Water Pollution Control Act
 Amendments ("FWPCA") provides that EPA may grant up to 70% of the
 funds needed to  "restore the quality" of fresh water lakes that are
 classified as eutrophic.   The question that concerns us is whether
 such  funding may be granted solely to increase a lake's recreational
 potential.   We have concluded that a fair reading of the statute
dictates that S 314 funds should be granted only to control and
reduce pollution in lakes, not to build parks, swimming pools, or
 sailing courses in polluted lakes.   This is not to say that
 increasing recreational benefits is not an important goal of any  lake
restoration project.  We  only suggest that pollution control  is  the
primary goal of the act,  and that any project funded under  it should
be designed principally to reduce a  lake's pollution level  and enhance
its water quality.

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                                -6-


       The TWPCA as a whole, and S 314 specifically, clearly indicate

that their paramount purpose is to reduce pollution.

       Section 314(a), in its entirely, reads as follows:

          "Sec. 314(a)  Each state shall prepare or establish,
          und submit to the Administrator for his approval—
             (1) an identification and classification
            according to eutrophic condition of all publicly
            owned fresh water lakes in such State.
             (2) procedures, processes  and methods
             (including land use requirements), to control
            sources of pollution of such lakes) and
             (3) methods and procedures in conjunction with
            appropriate Federal agencies, to restore the
            quality of such lakes.

       Eubparagraphs  (1) and (2) clearly indicate that the purpose

of the section is to deal with pollution problems in the nation's

lakes.  The phrase "restore the quality of such lakes" should be

interpreted in the same way.  EPA should fund only those projects

that are intended to  restore the water quality of lakes.

Section 314 should not be interpreted to allow EPA  to fund lake

dredging projects  that in fact will have little impact on overall

water quality.

       The legislative history, of  S  314, although sparse, likewise

indicates that the purpose  of  the section was to address pollution

in the lakes.  The Senate committee report cites "eutrophication,

accumulated  sludge and other pollutants, reduced flow and severe water

level  fluctuation, and  heavy sedimentation"  as  factors contributing

to the critical  condition of lakes.   Comm. on Public Works, S. Doc. No.

414,  92 Cong.,  1st Sess.  68 (1971).   While this statement does

indicate  that sedimentation is a  problem that  section 314 should deal

with,  it  does not suggest  that deepening is  grant-eligible under

S 314  unless removing such  sediments  will benefit water  quality.
                                                                                                                 -7-
       The response that  is  appropriate  in a case involving heavy

 sedimentation in a lake should be determined by the effects of a

 particular action on water quality.   Sedimentation does not ruin

 a lake for all uses.  Nor does restoration of a lake require that it

 be capable of handling any particular  kind of boat.

       The Conference Committee report of the 1977  Amendments

 admonishes EPA to give "special attention" to "restoring lakes which

 offer the potential for high utility  as  recreation areas."  H.R. P-ep.

No,.   3199 (1977).  EPA has apparently interpreted this comment as

 giving it the power to approve projects  such as the Vancouver Lake

 Reclamation Project.  This clearly is not the case.  Suggesting that

 EPA restore lakes that have potential as recreation areas does not

mean that EPA should or may fund projects designed solely to enhance

 recreational benefits.  The key factor which must be used by EPA to

 select its projects is improvements in water quality.  If "recreational

 benefits" were the criterion used, EPA could end up funding the

 building of boat ramps or ski jumps or sailing courses.  Such

projects are clearly beyond the intended scope of S 314.

       The Conference Committee report emphasizes that the clean

 lake program is intended to lead to lake pollution control.   The

comment regarding lakes with high potential as recreation areas is

merely intended to guide EPA in determining which of the  many

polluted lakes in this country should receive priority in funding.

Thus, if there are two polluted lakes, both of which can  be  restored

by a 314 program with one having greater potential for recreational

use, that lake should receive priority funding.

-------
                                -8-
       In evaluating the proposed restoration of Vancouver Lake,


EPA must find that the project will improve water quality and that


its grant funds will be spent toward that end.  As noted in Part A,


such a finding is questionable in the case of the Vancouver Lake


project.


       At the very least, one thing is clear: that the additional


dredging required to build the sailing course will have no positive


impact on water quality.  As such, EPA should, at minimum, deny


funding for this portion of tha project.  If the remainder of the


project can be shown to meet the threshhold requirement of benefitting


water quality, it should then be determined whether the environmental


benefits outweigh the environmental costs.   (i.e., notably the adverse


impacts on wetlands).  In this respect, also, this project seems


highly dubious.  The Final EIS should explore in detail the water


quality pros and cons of the project, as well as the Impacts of a


project which deleted the sailing course component.


       The project calls for radical surgery on a body of water that


is both highly eutrophic and heavily sediroented.  The project would


seem to offer very little benefit to overall water quality.  The DEIS


is ambiguous as to whether algal population will be reduced in the


lake.  The project will cause extraordinary disruption of the entire


lake ecosystem due to the dredging and disposal   operations.  Since


the benefits seem so tenuous and the disruption so great, EPA should


seriously consider the possibility that the best plan for this lake


is to concentrate on reducing the flow of pollutants [notably nutrients]


into it.  Allowing the lake to remain as is will not promote the
                                 -9-



recreational goals the project intended, but  it will preserve  a


lake that is probably less polluted than that proposed by  the  plan,


and, in different ways, a lake that is no less productive  and


beneficial.



II.  Deficiencies in the DEIS.


       The DEIS is deficient in  the following specific respects which


must be rectified in the revised version:


          1.  The DEIS does not discuss the effects of dumping dredged


material containing concentrations of mercury (and other chemicals)


"considered hazardous to organisms,"  (at 15) onto wetland  areas.


A complete analysis should be made of levels of toxic substances in


the sediments to be dredged.  The effects on fish and wildlife of


dumping toxic dredge spoils on wetlands should be thoroughly discussed.


Elutriate tests, as recommended  in EPA's S 404 guidelines, should be


performed.


          2.  The DEIS does not adequately discuss alternatives to


dredging the lake as a means of upgrading its water quality.   The


DEIS should stipulate that improved water quality is the primary goal.


The following alternatives should be discussed to determine their


relative impacts on water quality.


            (a) A more extensive program under 5 208 to reduce the


flow of nutrients and sediment into the lake.  While the DEIS does
                \

discuss the 208 program in a number of places throughout the report,


that discussion needs to be consolidated and elaborated upon.

-------
                                  -10-
               (b) Construction of. a flushing channel to the Columbia
   River without any dredging within the lake itself.  While the effects
   on water quality of this alternative will probably be no greater than
   those of Alternative 2C, it is unclear whether 2C is rejected solely
   because it will not meet minimal recreational objectives.  Discussion
   of each alternative roust be in terms of whether it will improve water
   quality.
               (c) Mechanical harvesting of algae.

6            3.  The DEIS does not adequately discuss the extent to
   which the lake in its present condition may be used for recreational
   purposes.  The DEIS should fully discuss the extent of present
   recreational activities in the lake area.  The possibility of in-
   creasing the recreational benefits without dredging the lake should
   be thoroughly discussed.  For example, it may be possible to create
   water safe for swimming by simply pumping groundwater into the lake
   at the site of the swimming beach.
7            4.  The DEIS does not discuss the expected rate of deter-
   ioration of the lake after all 208 measures to reduce non-point sources
   of pollution and all of the measures proposed in the present project
   have been implemented.  The DEIS does  indicate that sedimentation and
   eutrophlcation would continue.  However, it does not say anything
   about whether  significant deterioration would occur over a period
   of years or decades or  centuries.  This information would be
   significant if  in  fact  the  lake may  be used for recreational benefits
   in its present condition.
                                                                                                                     -11-
00
          5.  The DEIS does not adequately discuss alternatives
to the proposed dumping sites for dredged material.  Only on-land
dumping is seriously considered.  A significant alternative would be
in-water "disposal" to create one or more artificial islands within
the lake.  Naturally the final EIS should weigh the extent to which
fish habitats are destroyed by the creation of islands against the
harm resulting from dumping of dredge spoil in fish spawning areas.
          6.  The DEIS does not discuss the possibility that continued
dredging may be required to remove sediment as it accumulates in the
lake in the future.  The DEIS states that 50,000 cubic yards of sediment
per year will enter the lake after the project is complete.  DEIS at
49.  35,000 cubic yards of the sediment will enter into the lake
through the proposed flushing channel.  This sediment would accumulate   ^~
in sediment traps to a depth of 2 feet in 10 years.  DEIS at 60.
The DEIS does not address the possibility that periodic dredging of
the lake will be required to remove this accumulated sediment.  This
issue should be addressed along with the impacts of the dredging
and disposal operation.  The DEIS does note that annual dredging of
the flushing channel would be required to remove between 3,000 and
6,000 cubic yards of material.  DEIS at 49.   We question whether the
probable need for periodic dredging is in agreement with EPA's
apparent policy against funding of projects  requiring periodic
maintenance.  (Guidance for the Preparation  of Lake Restoration Grant
Application, U.S. Environmental Protection Agency (1976)  at 11).
          7.  The DEIS does not Indicate what the water quality
objectives are that will only be obtained by dredging 8.1 million
cubic yards.  DIES at 76.   Are these objectives recreational or are

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                                    -12-
                                                                                                                       -13-
     they related to overall water quality?  In other words, is the
     objective to deepen the lake to improve water circulation and reduce
     algal concentration, or is it to increase the overall depth of the
     lake for boating purposes?
               8.  The DEIS is replete with contradictory or ambiguous
     statements.  Examples include—
10                 'a' Whether sediments contribute to the nutrient base
     in the lake.  The DEIS  (at 18) suggests that nutrient levels in the
     sediment are substantial while elsewhere  (at 58), it states the contrary.
1]                 (b) The DEIS never clearly  indicates whether water
     quality in  the  lake will actually be  improved as a result of the
     proposed project.  The Final EIS should clearly state whether nutrient
     levels and  algal populations will be  reduced by the proposed action.
•jo                 (c) The study does not  indicate whether large standing
     algal populations will remain in the  lake after project completion.
     If they will, the DEIS should discuss the possibility that asthetic
     consideration will reduce recreational benefits of the lake.
]3             9.  The DEIS should indicate the extent to which the Alcoa
     plant adjacent  to the lake contributes to pollution in the lake.
14            10.  The Final EIS must integrate results of the Wetlands
     Habitat Evaluation into its discussion of the proposed action.  The
     alternative prefered by the Wetland study  (i.e., "Alternative I")
     would avoid dumping dredge material at Sites V and VI and would save
     two islands at  the entrance of Lake River that would otherwise be
     dredged.  Wetland Habitat Evaluation, at 27.  If this alternative were
     adopted it would accommodate only 10,750,000 cubic yards of dredged
      material.  This is considerably less than the 12-15 million cubic
      yards to be generated if the full project is implemented.  However,
      Alternative I would adequately handle the minimum proposed dredging
      of 8.1 million cubic yards if that amount is determined to be necessary
      to improve water quality.  The Final EIS should discuss the necessity
      of dredging the two islands and should indicate whether the 8.1
      million cubic yard minimum figure includes or excludes this
      dredging.  The environmental pros and cons of not dredging these two
      islands should also be fully discussed.
                11.  The Final EIS should discuss more fully all the
      present sources of nutrient impacts to the lake and the full range
      of steps which could be taken to reduce such impacts to a minimum.
      If all such steps were taken, would the project be justifiable under
      any rationale?
15              12.  The Final EIS must reach an appropriate balance between
      the competing interest in improving water quality and preserving
      wetland areas.  The DEIS should indicate a paramount concern for the
      preservation of wetlands and lowland areas as mandated by EPA's
      S 404 Guidelines and especially by Executive Order No.  11990
      (directing federal agencies to "avoid to the extent possible"  the
      destruction or modification of wetlands).  Can dredging of any amount
      of material be justified in light  of these mandates?  Can dredging
      of more than the minimum amount necessary to improve water quality
      be condoned,  especially  if  the disposal  of additional dredge material
      will  adversely impact on wetland areas?

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NATIONAL HII.Ol IFF FEDERATION

1.    Response
     HaHon.il S'ilHlifp Federation  is correct  in  its statement nf purpose
     concerning Section 314.  The purpose of  this project is to improve water
     quality of Vancouver Lake.  The project will he funded only to the level
     that can be shown to reasonably maximize water quality benefits and
     minimize other potentially adverse impacts as identified In the KRIS.
     Although much of the evidence on lake restoration is inconclusive about the
     combined effects of dredging/flushing, the following factors clearly support
     water quality improvements:

          in the long-run, dredging will decrease the turbidity of the
          lake,
          significant quantities of mercury, zinc and copper will be
          removed by dredging,
          flushing of the lake by the Columbia River can be seasonally
          regulated and in combination with the proper use of sediment
          traps, can minimize the resedimentation of the lake and the
          introduction of nutrients from river waters,
          as the water quality of the Columbia River improves, so will  .
          the quality of the water being introduced into the lake,
          elimination of point and non-point sources of pollution along
          Burnt Bridge Creek will have a beneficial effect on water
          qua! ity in the lake.

     Specific: grant conditions will include:  1) limiting the amount of
     dredging to 9 million cubic yards,  2) prohibiting placement of dredged
     materials on sensitive wetland areas and 3) requiring implementation
     of 208 measures.

2.    Response
     LPA grant conditions state that "the amount of material to be
     removed from the lake shall be no more than 9 million cubic yards
     pier, maintenance dredging and shall  conform with the bottom configuration
     needed to adequately flush the lake."  The 9 million cubic yards
     of dredging maximizes the water quality benefits realized from
     dredging, while minimizing the amount of dredging and dredged
     material disposal required hy the project.

3.    Response
     EPA grant conditions require that "Dredge spoils shall be disposed
     in such manner, location and depth as to result in minimum loss to
     valuable habitat and to provide maximum opportunity for habitat
     mitigation and restoration of the aesthetic quality of the area."
     Habitats within proposed disposal sites Va and Vb have high
     relative value (see "Wetland Habitat Evaluation") and thus these
     areas will not he considered as disposal areas.  Area VI can only be
     used to the extent of Alternative 7 of the U.S. Army Corps of
     Engineers diking project.  Under no conditions shall areas containing
     rare and endangered habitat species be used for dredged disposal
     purposes.

     The island located near the outlet of the lake at Lake River (see
     Wetland Habitat Evaluation Report, Figure 6) shall be allowed to
     remain in  its natural condition.  Mulligan Slough shall remain in
     its present condition.

     Use of dredged materials for the creation of "spoil islands" within
     the lake was explored in the Master Plan for Vancouver Lake.
     Evidence indicates the characteristics of the dredged materials
     are not suitable for.such use.
     Response
     As  indicated  previously,  dumping  of  dredged materials  onto
     sensitive  wetland  areas will  be prohibited.
 *S.   Response?
      Improved water quality is the primary yoal of EPA's involvement in
      the proposed Vancouver Lake project.  For this reason,  the aiiroiint
      of dredging has been limited to 9 million cubic yards.   Alternatives
      to dredging have been discussed in the Vancouver Lake Master Plan.
      EPA believes that some level of dredging will be required for lake
      restoration and has limited this quantity of dredging to 9 million
      cubic yards.  (See  paqe  3S  for an expanded discussion  of the 208
      program.)

      Construction of the flushing channel alone would not promote the
      necessary circulation patterns.   Dredging will occur in a manner
      which will maximize circulation within the lake.

      Mechanical harvesting of algae has not proven to be a satisfactory
      technique in other area lakes.

 6.    Response
      Recreational activity in  Vancouver Lake is currently limited to  fishing
      and hunting.  Some boating occurs  on the lake but is limited by  depth
      and the presence of algae.   First  phase construction of Vancouver
      Lake Park provides for  limited shorefront recreation.  .Increased
      recreational use would  require better water  circulation,  increased
      lake depth,  increased fisheries, decreased turbidity and algae  and
      increased water  quality.   Dredging "of the lake would be necessary
      to achieve those benefits.

 7.    Response
      Future  deterioration of  the  lake after 208 programs  have  been imple-
      mented  is unknown.   Both  lake  restoration and 2(18  efforts  are fairly
      new in  implementation.  Therefore,  evidence  of their effects  is  limited.
      Without such evidence it  is  difficult to  project  the future of
      Vancouver Lake.   However,  evidence does  indicate  that although the
      lake will  remain eutrophic,  it will  not  reach the  stage of hyper-
      eutrophication.

 8.    Response
      Maintenance  dredging will  be discussed in  detail  in  the required
      operations plan.
9.
10.
11.
12.
Response
Dredging of 3.1 million cubic yards would not enhance water
circulation to the extent that dredging 9 million cubic yards would.
The 900,000 cubic yard difference would be dredged from areas which
would enhance circulation and decrease the early need for
maintenance dredging.  Again, the primary objective being water
quality.

Response
Sediments  do  contribute  to  the nutrient base in  the  lake.  This
contribution,  however, is less than was projected prior  to the
Vancouver  Lake Master Plan  preparation.
      Response
      Refer to comment  1.
      Response
      Large standing  algal  populations  are  not  expected  to  remain  in  the
      lake.

13.    Response
      There is no evidence  to  indicate  that the Alcoa plant contributes to
      lake  pollution.

11.    Response
      The results of  the  Wetland  Habitat  Evaluation have been  integrated
      into  the Final  EIS  and are  reflected  in the grant  conditions.
      The wetland study is  summarized  in  Appendix A of the  FEIS.

15.    Response
      EPA grant  conditions  (discussed previously) adequately address  the
      concerns raised  in  this  comment.
                                                                                   O
                                                                                   OJ

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                     ^^#~  *-*-j- -««P» ,» rw---—   -VW ^•kf.^l^^  -^  ^™-

BASS    6   PANFfSH  CLUB
      Dec'v.ber 10  1971
      U. 3.  Tnvli-onntental Prot;<-t1on  Agency
      Reg lot> X
      Seattle, Washington 9?'l";i

      •Subject:  Draft  Environmental  Impact Statement -
DFC  20 ;n77
                Vancouver Lake Restoration
       ' ntlemen:
                                                            """'' ''MUAIION
                                                            i.. •.•.•! 'I
      We are an  Oregon based organization of 400 members  whose Interests
      encompass  all of the spiny ray  species of fish.

      While  we are basically Oreijonlans, a great number of our members
      fish the waters of Washington also.  During the  spring freshets,
      we fish Vancouver Lake extensively.

      your Impact Statement anrt Its alternatives are therefore of great
      intercut to us.  Wo ha«e studied  the contents with  great concern
      an I  now strongly support the proposals set forth in Alternative ?.-B.

      Thin would provide the necessary  flushing of the  lake and, with
      proper maintenance, allow the lake to remain alive.

      Extensive  disposal  of dredge spoils In Area 5 (Mulligan Slough) on
      Figure 12 would destroy a r.ajor portion of the spiny ray spawning
      grounds and we, therefore,  oppofie any disposition of spolln in this
      area.

      We would appreciate l-einfj placed on your mailing list for future
      documents  i-egardlng thin project.

      Very truly yourn.
                                                                                       HIT BUN n.'.'.'i AND PANFISII CLUli
Iho qr.int cnndillnns prohibit use nf Mulliqnn Slmi'jh for UI
of 'Irnrltio'.l mil.erii] Is.  It st.if.c1; "Mnlliqan Slough shall rnm-iin in
its present roii'litfon."
                                                                                               cvl
      William R, (Jonah 1
      Director at I,nr»;?
      for Oregon Bars * FanfJ.

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               BLAIR, SCHAEFER. HUTCHISON, WYNNE, POTTER, MORTON a JOHNSON
DONALD C BLAIR
ROBERT M. aCHAETTn
DAVID C HUTCHISON
JOHN r WYNNE
HUGH J, POTTER
JAMES D. MORTON
RANDOLPH L. JOHNSON
     IOI4 FRANKLIN STREET
    POST OFFICE  SOX  M4Q
                             December 19, 1977
                       RESOLUTION OF DRAINAGE AND DIKING
                          IMPROVEMENT DISTRICT NO. 14
                                                                             WHEREAS, Dralnigeand Diking Improvement District #14 Is interested In
                                                                  seeing that the land within Its district Is used for Its highest and best use; and

                                                                             WHEREAS, certain flooding has occurred In the lowlands surrounding Van-
                                                                  couver Lake; and
    Ms. Alex B. Smith
    Regional Administration
    U.S. Environmental Protection Agency
    1200 6th Avenue
    Seattle,  Washington  98101
          Re: DRAFT EIS:
    Dear Ms. Smith:
No. EPA-10-WA-CLARK-POV-CL-77
 Vancouver Lake Reclamation Study
 Clark County	
          I called Mr. Dubois' office today and talked to Pam Anderson.  I
    Informed her I had attended a meeting In Vancouver where you had asked
    for comments.  I am submitting those comments In a resolution passed by
    our supervisors.  I was unable to mall It until today since all of the
    supervisors wanted to sign It and one of them was out of town.

          Mn. Anderson assured me our comments would be considered
    and therefore I am sending same for your review.

          Thank you for your consideration in this matter.  If there are any
    questions you would like to ask concerning our Diking  Project,  In relation-
    ship to the lake reclamation, we would be  very happy to answer them.

                                     Very truly yours,

                                     BLAIR, SCHAEFER, HUTCHISON, WYNNE,
                                     POTTER, MORTON &  JOHNSON
     RMS:)sp
     encl
                                             DEC 211977

                                         RNViROIlMLNT'L CVAIUAT'ON
                                                CF,\ iCIl
            WHEREAS, the condition of Vancouver Lake is deteriorating; and

            WHEREAS, Drainage and Diking Improvement District f 14 is the sponsor
for a diking project adjacent to Vancouver Lake which the district feels id an Integral
part of the overall development of the area and the cleaning and deepening of Vancouver
Lake; and                                                                       ,   ,
                                                                              • •   *

            WHFREAS, Drainage and Diking Improvement District #14 is Interested
in seeing both the lake project and the diking  project developed so that they could
complement eadh other and reduce the cost for both projects; and

            WHEREAS, the reclamation of Vancouver Lake is part of the total multiple-
use development concept for the Vancouver Lake/Columbia River lowlands,  Including
the Implementation of the adopted recreation concept around Vancouver Lake and the
construction of dikes In sufficient height to protect the entire lowlands for agricul-
tural, industrial, commercial and recreational activities; and

            WHEREAS, the Lake Reclamation Project as presented to the Drainage and
Diking Improvement District #14 supervisors Is consistent with the total multiple-use
development concept and the diking project;

            NOW, THEREFORE, IT IS HEREBY RESOLVED that the Drainage and  Diking
Improvement District #14 by and through Its supervisors hereby supports the Vancouver
Lake reclamation project and hereby reafflrmsllts position concerning the overall de-
velopment of the area as follows:

   1         1.  That the United States Environmental Protection Agency and the Wash-
ington State Department of Ecology should fund the reclamation of Vancouver Lake.

            2.  That the I Drainage and Diking  Improvement District #14  feels that the
diking project under consideration by the Corps of Engineers is an Integral part of the
overall development of the Vancouver Lake area.

            3.  That a mutual agreement is executed stating that the conditions imposed
by the granting and various regulatory agencies and bodies on the performance  of the
lake reclamation effort are acceptable to the Drainage and Diking Improvement  District
#14, the Port of Vancouver and the affected lowland property owners.

            4.  That the lake reclamation plan Implemented must be compatible with
the diking project and reasonable Industrial development  in the lowland area.

            The forego^ig  resolution was duly  and regularly adopted by the Drainage
                                                                                                                                                        OJ
                                                                                                                                                        rxi

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and Diking Improvement District #14 at Its meeting on December,
., 1977. and
duly signed by Its proper'off leer 3 In authentication of Its passage on said date.
                                      DRAINAGE AND DIKING IMPROVEMENT
                                      DISTRICT #14
                                      By_
                                          Chair.jan of Supervisors
                                          David Scherruble
                                        Supervisor
                                        Jan E. Rosholt
ATTEST:
                                         Hans Egger
Attorney
 Robert M. Schaefer
                                                        December 8,  1977
                                                        5206 nw 169  su
                                                        Ridgefield,.  Washington   98642
                          Roger K.  Mochnick
                          Environmental Evaluation Branch, H/S 443
                          U.S. Environmental Protection Agency, Region X
                          1200 Sixth Avenue
                          Seattle toeshinpton  96101
                          Dear Mr,  Mochnlck:
                                                                                                                                                 If

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     So  esernt In] ].v  during April - May there ic precently a     '
southerly  flow  of  wn'pr In Lake River, during June and July
the flow of  water  Is  reversed to the north, and during Auguct
through  March the  direction of flow IB influenced by tides.
     In  the  alternatives  It Is stated under hydrology and flood
hazards, page  r>5,  paragraph 6, that "during the summer, Lake
Hlvrr would  continue  to flow In both directions, although the
flow to  the  north  would be Increased by 35 percent."  On page 56,
paragraph  2  concerning  low water levels It IB slated that "the
introduction of  flushing  flow would reduce the southerly flew
of Lake  Hlver and  Increase the northerly flow.  'Ihe decrease In
the level  of Inflow  is  expected to be nlout 65 percent of the
preflushlng  flow,  while the Increase 1n the outflow IF expected
to be I'm  percent  of  the  preflushing flow,"  Pare 56, paragraph
3 etnt.ps that "during high flow periods In the Columbia River,
the flow 1 n  Lake Hlver  would be essentially one-direct Inn to
ttu liorth."
     So during  high  flow  periods such VR during April-May the
direction  of flow  of  lake River will be changed from n routhrrly
flow to a  northerly  flow.   Dur'np June-July the flow will re-
main erspnl tally the  rnrne. to the north, and  during August-March
the flow of  wnter  will  continue'to lie In both  directions but  with
an Inerennp  in  a notlierly flow of 35 percent.
     The lump  thnt  thir.  ^inpr to point Is what wi)1 te the    ;
effect of  the  increase  In outflow levfrlfc nnd  the Inarense in a  <
northerly  flow  of  lnk<>  Hlver.on the banks p.lonp Lake River from "
nn rrnslonnl Btnnfl p"lnt.   There bnnks are sut ,1ect to erosion
bv l.nkr  Hlvrr,  rrprrlnlly during times of hiph wattr.  The over
nil chnnre in rtirrction of the flow of Lake River, alone with
nn 1 i'cr' nrffl I'nlfli'w  Jrvr] couJd .".'line an Increorc in erosion
of the tnnks alonr  Lake  Hlver,  especially durlrr hlph flow UVO|F.
Arenr puch an  thone  Jylnr  t.etween  Lake Hlver and S;i 1 mon Crerk
ooiiJrt be ndvcrfelv  effected.  There  Is evidence of erosion
prrf-ently IP thiF ar>'ft ami  It Is possible thnt  a chance In direc-
tion from a southerly flow  to a northerly fjow  could  increase
the rite of erosion, especially that  area of Ip.nd where Salmon
Creek meets Lake River   This Issue on erosion  should be addressed
in the Environmental import statement alonp  with the  VrnpnctB
result !nr from It.  Also mitlpatinp: me;isurrs repnrd Ir.f this
Fintt.PT1 should  to r* 1 PCUT: ned..
     fly Mfh"r pri-n of concern is rejtardlnp- flood hazards r»sult-
1rr from thp project on the Innds  alonp Lake Hlver.  Cn pn/re  12
pnrnprnph 3 the irnvie repnrds "flood  Inudatinf  land nlonc the
southern and wertf-rn Inke rhorpJlne,  as well as land  along the
WpF,ierr, shore of I.nl«- liivpr.1'  There  Is no mention of the effects
of floorMnr on the eastern shore of Lake River, and thlc should
>p nrtdrrpned.  On pape 56 paragraph 3 It Is  stated that "during
hirh flow periods, the average water  level in the lake would  to
irirrered nbout o. •; foot over present  levels, while durlnp Jow
flow periods it woulr) increase about  0.2 foot."  There is no
mpnt l*-in or what the Increase water level in  Lake filvcr will be
Th1r Ifirue of  Inrrenped wnter level In Lnke  Hlvfr should IP
dlpcuspcd nnci  1'r impnet  on the lands  along  Lake Hlvrr.
     On par » f,< paragraph 8 it is  stated,  "the  proimi rd  project
IF not exnecterl to have nny effects on  the down rtrf-am flood
plairr, of Olnml in Hlver nnd L-ike  Hlver."  Yet  on [inge 1't
pnrnprnr-h ~*, it Ir rtnt.ed thnt "no floodplain or flood flow itata
nre Bvnllntle for Ifike Hlver."  So how can the  statement on p/-gr
56 pnrnrmph '  roiirr rninp no impacts  on the  down strinni  llcoil-
lOpins rf cf Inl'p Rivc-r IT made.
CNJ

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      On rtrp-n «;?  n.-'f"• r; -r-h  1,  it  is Kluted that "durinp e

f'l-oniTT cone 1ti'nr ,  the  flow  From Column ><  Hivpr  Into V*no"uvop

L.'-ifcp  nan be  c on t r r. 11 pd FO  ns not  to  incrpnne  the fJow in Lake

Rivr-r t'lovp  pxiPt^np  fln-d levels."   The term "extensive flnodlnr

rrrirt \\ ions"  nr^-dF to  !•<* (Ipflr^d  ro ns tt.- >"-:ow fit whit stare  of

      wwter Kill  th« inflow ir>to  Vancouver Inkp from  the fJushinr

       ] bp controllprt.  Thp impnct durlnp nnn rxtfnslve floorHnp

oonfll tloriF rhntiJ'1 \f  (1 i rr-iiPFcd as to  thp Ir.pRr.t on the lands

-ilonr I..ik» hlv»r n"d  any  mitlfntlnp- measurets  to to taken.

      So in Pinnraary  the tisvironmental  impact  statempnt neFds  to

nflrlrPSE t'v  inrurn  r*p"'-dir.j-  the  imp^ctr on  the Inr.d  alonp lake

liiv^r, from  an  prop'r^n^l  ftsnt'polnt and the  effpct of Increased

ust.r-r levelr in  lake  River durinp hlph watpr  ]eve]s.   Also

any  mitlratlnp  ni'nsurfF concprnlrip these Issues should V:e dic-
                                          Sincerely
                                                    /\  ^/Z/
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If
        /,>/  'v iv   /') l^<  A  ,,
         1 IMMI    y
                                                                                                     UD
                                                                                                     CV1

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                                    FOOTNOTES

 1.   Port of Vancouver,  April  1976.
 2.   Port of Vancouver,  April  1976.
 3.   Bhagat and Osborn,  1971.
 4.   Bhagat et. al.,  1972.
 5.   Bhagat et. al.,  1972.
 6.   Bhagat et. al.,  1972.
 7.   Bhagat et. al.,  1972.
 8.   Bhagat et. al.,  1972.
 9.   Bhagat et. al.,  1972.
10.   Dames & Moore,  1977.
11.   Bhagat et. al.,  1972.
12.   Mundorff, M.  J., 1964.
13.   Personal Communication,  Claire  Title, Clark County PUD.
14.   KCM-WRE, 1976.
15.   KCM-WRE, 1976.
16.   Personal Communication,  U.S.  Army  Corps of Engineers, 1977.
17.   Bhagat et. al.,  1972.
18.   Bhagat & Osborn, 1971.
19.   Bhagat et. al.,  1972.
20.   Personal Communication,  U.S.  Army  Corps of Engineers, 1977.
21.   Bhagat & Funk,  1968.
22.   Dames & Moore,  1977.
23.   Wetzel, 1976.
24.   Gibbs, 1970.
25.   EPA STORET, 1974.
26.   Klein, 1974.
27.   Dames & Moore,  1976.
                                       127

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28.  Dames & Moore, 1977.

29.  Hildebrand et. al., 1975.

30.  Dames & Moore, 1977.

31.  Bhagat & Funk, 1968.

32.  Wetzel, 1976.

33.  KCM-WRE, 1976.

34.  Dillon and Kirchner, 1975.

35.  Vollenweider and Dillon, 1974.

36.  Wilding and Schmidt, 1973; Bhagat et. al.,  1972.

37.  Stoerraer, 1975.

38.  Bhagat & Funk, 1968.

39.  Dames & Moore, 1977.

40.  Bhagat & Funk, 1968.

41.  Bhagat and Funk, 1968.

42.  Bhagat and Funk, 1968.

43.  Personal Communication, Nancy Ellifrit, U.S.  Fish and Wildlife Service,
       1977.

44.  Personal Communication, Nancy Ellifrit, U.S.  Fish and Wildlife Service,
       1977.

45.  Dames & Moore, 1977; Bhagat & Funk, 1968.

46.  Bhagat et. al., 1972.

47.  Washington State Department of Ecology, 1975, KCM-WRE, 1976.

48.  Washington State Department of Ecology, 1974, cited in KCM-WRE, 1976.

49.  KCM-WRE, 1976.

50.  KCM-WRE, 1976.

51.  KCM-WRE, 1976.

52.  KCM-WRE, 1976.
                                       128

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53.  Washington State Department of Ecology, 1975.
54.  Washington State Department of Ecology, 1975.
55.  KCM-WRE, 1976.
56.  Beak, 1977.
57.  Wetzel, 1976.
58.  Beak, 1977.
59.  U. S. Army Corps of Engineers, 1975.
60.  U. S. Army Corps of Engineers, 1975.
61.  EPA STORET, 1974.
62.  Wetzel, 1976.
63.  Beak, 1977.
64.  EPA STORET, 1974.
65.  Beak, 1977.
66.  Tailing, 1960.
67.  Hutchinson, 1967.
68.  Beak, 1977.
69.  Beak, 1977.
70.  Executive Order 11990, May 24, 1977.
71.  Regional Planning Council  of Clark County,  1977-
72.  Regional Planning Council  of Clark County,  1977.
73.  Regional Planning Council  of Clark County,  1977-
74.  Clark County Resolution No. 1976-05-41.
75.  Clark County Parks Department, 1976.
76.  Oregon State Marine Board, 1972.
77.  Oregon State Marine Board, 1972.
78.  Oregon State Marine Board, 1972.
                                     129

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 79.  Dames & Moore, 1977.



 80.  Dames & Moore, 1977.



 81.  Dames & Moore, 1977.



 82.  Dames & Moore, 1977.



 83.  Dames & Moore, 1977.



 84.  Regional Planning Council  of Clark County,  August 4,  1977.



 85.  Dames & Moore, 1977.



 86.  Dames & Moore, 1977.



 87.  Dames & Moore, 1977.



 88.  Ryding and Forsberg,  1976; Oglesby, 1969;  Vollenweider & Dillon,  1974.



 89.  KCM-WRE, 1976.



 90.  Wetzel, 1976.



 91.  Ryding & Fosberg, 1976.



 92.  Dames & Moore, 1977.



 93.  Bhagat et.  al.,  1972.



 94.  Dames & Moore, 1977.



 95.  Dames & Moore, 1977-



 96.  Personal Communication, Spencer Peterson,  EPA,  Corvallis, 1977.



 97.  Dames & Moore, 1976,  1977.



 98.  Dames & Moore, 1976,  1977.



 99.  Dames & Moore, 1976,  1977.



100.  Dames & Moore, 1977.



101.  Welch, et.  al.,  1972.



102.  Dickman, 1969.



103.  Oglesby, 1969.



104.  Wetzel, 1976.
                                    130

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105.  Uhlmann, 1971;  Welch  et.  al.,  1972; Dickman, 1969.
106.  Bhagat et.  al., 1972.
107.  Beak, 1977.
108.  Beak, 1977;  Tallking,  1971.
109.  Stevens, Thompson & Runyan,  1972.
110.  Dames & Moore,  1977.
111.  Vollenweider &  Dillon,  1974.
112.  Dames & Moore,  1977.
113.  Washington  State Department  of Ecology, 1974.
114.  Beak, 1977.
115.  Dames & Moore,  1977-
116.  Dames & Moore,  1977.
117.  Dames & Moore,  1977.
118.  Washington  Department of  Fisheries, Letter dated July 12, 1977,
119.  Washington  Department of  Fisheries, Letter dated July 12, 1977,
120.  Port of Vancouver, 1976.
121.  Dames & Moore,  1977.
                                        131

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Regional Planning Council of Clark County,  Clark County-Wide Water Supply
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                                    135

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                                     135

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                    AGENCY INFORMATION SOURCES
Washington Department of Fisheries
      Clint Stock!ey
      Lloyd Rothfus
      Russ Jones

Washington Department of Game
      Claude Stoddard
      Fred Holmes
      Hugh Null (Manager, Ridgefield Wildlife Refuge)

U.S. Soil Conservation Service
      Jim Craig

Clark County PUD
      Claire Tittle

Washington State University Extension Service
      Paul Wesler

Washington State Department of Ecology
      Bob Bottman

U.S. Fish and Wildlife Service
      Nancy Ellifrit

U.S. Army Corps of Engineers
      Larry Anderson
      Kim Larson
      Rob Rotham

Washington State University Archaeological Preservation
      Dr. Daugherty

Environmental Protection Agency
      Al Ewing
      Ed Eldridge
      Spencer Peterson

Clark County Regional Planning Council
      Steve O'Brien
      Vicki Pflaumer

Clark County Parks Department
      Vern Velsey
      Jim Walsh (Mitchell & Associates, Consultants)

Port of Vancouver
      Dick Gorini
                                      137

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                              APPENDIX A


       SUMMARY OF WETLAND HABITAT EVALUATION FOR VANCOUVER LAKE
                                        (Jones & Stokes Assoc.)

The Wetland Habitat Evaluation for Vancouver Lake (Jones & Stokes
Associates, 1977) identifies and describes the wetland and lowland
wildlife habitats surrounding Vancouver Lake, and estimates the value of
these habitats to the dominant fauna! species.  The value of these habitats
to the lake fishery was not evaluated; the seasonally and semi-permanently
flooded wildlife habitats are of considerable but undefined value to the
local fish populations.

The Wetland Habitat report addresses the impact of lake dredging and spoil
disposal on wildlife habitats.  Habitats were compared and evaluated for each
proposed disposal site.  Sites at which spoil disposal avoided or minimized
adverse impacts on the most valuable wildlife habitats were identified, and
the impacts of disposal at these alternative sites were compared to the
impacts associated with the proposed project.  Mitigation measures in the
form of trade-off or "like-kind" (i.e., creating new habitat or enhancing
similar wildlife habitat at another location) compensation were discussed.

Wetland vegetative cover types were classified utilizing the "Classification
of Wetlands and Aquatic Habitats of the United States" (Cowardin et.al.,
1977).  Dominant plant species, water regimes, and soil types were used
to identify all wetland and lowland vegetative cover.  Wetland habitat
descriptions followed the system described by Cowardin et.al. (1977).
Habitat Evaluation Procedures (HEP) developed by the U.S. Fish and Wildlife
Service (1976) to evaluate the impacts of projects on fish and wildlife
resources were used to quantify the non-monetary value of existing habitats
and the losses associated with dredging and spoil disposal.  Habitats of
the project area were compared to similar, "ideal" habitats elsewhere;
different habitat types were not rated against one another.

The capacity of each habitat type to meet wildlife needs was rated on a
scale of 1 to 10; higher ratings were given to sites meeting more wildlife
needs.  Ten wildlife habitat types were evaluated using HEP.  At each
sample site, the habitat type was rated for five functional categories:
nesting habitat, rearing habitat, resting and feeding habitat, transient
use habitat (for migratory species) and degree of interspersion.  Each
site was also evaluated and rated for its capability to support dominant
species of the Vancouver Lake area, occurring in the following ten
wildlife groups:

      1.   Large mammals
     2.   Furbearers
     3.   Small mammals
     4.   Upland birds
     5.   Waterfowl
                                  A-l

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     6.   Shore birds and gulls
     7.   Wading birds
     8.   Raptors
     9.   Passerines and other birds
    10.   Reptiles and amphibians

The wildlife habitats evaluated were:

     1.   Wetland deciduous forest
     2.   Wetland emergent
     3.   Wetland scrub/shrub
     4.   Wetland flat-bed
     5.   Lowland deciduous forest - scrub/shrub
     6.   Lowland grassland
     7.   Lowland cultivated
     8.   Wetland cultivated
     9.   Shallow water/benthos
    10.   Deep water benthos

Certain assumptions regarding the proposed lake reclamation project were
made in this report, as final project sites and figures were not yet
available at that time.  Impacts on wildlife associated with the proposed
dredging and spoil disposal were analyzed for target years 0, 5, 10 and
50 to calculate annual loss or gain of habitat units by habitat type.


                                IMPACTS

Implementation of the full project (the dredging of fifteen million cubic
yards) could eventually result in a loss of between 34 and 69 percent of
the wetland habitat in the study area.  Fourteen to 55 percent of the
lowland habitat would be affected.  Among the wetland habitat types,
wetland emergent is judged to have the greatest individual wildlife
value, of which 61 percent could be lost to project actions.  Overall,
55 percent of the wetland habitat could be converted by project actions.
The 308 acres of cultivated wetland could add to the total unit value of
natural wetlands if they were left fallow for a few years.  When interspersed,
these habitats have significant and irreplaceable values to fish and wildlife
in the study area.  Islands of lowland deciduous forest and scrub/shrub
interspersed among the wetland add significantly to total wetland value
by offering refuges to mammals and reptiles during floods.  High water
during breeding and nesting periods is viewed as the chief limiting factor
to wildlife productivity, especially to avian species, and this accounts
for the relatively low reported Habitat Unit Values.

The Habitat Unit Value of these areas may presently be significantly
greater for fish than for wildlife; however, insufficient information is
available to make an estimate of such value, although one can judge their
fishery importance.  Large numbers of fish occur in the wetland habitats
during periods of flooding and are assumed to be feeding and spawning.
                                  A-2

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The shallow, unstable and relatively barren nature of the main lake
may raise the actual importance of the flooded areas to the maintenance
of productive fish populations.  Fishing is an intensive recreational
activity during high water.  In terms of recreational use, the impact of
wetland losses on the fishery may be much more important than losses to
wildlife.

The wetland areas designated for Special Consideration on Figure 7 are
judged to be the most sensitive in terms of project effects on fish and
wildlife resources and maintenance of the present ecological nature of the
study area.  If extant fish and wildlife values are to be maintained, these
habitats must be given priority and be avoided or fully mitigated in-kind
within the study area.  Any consideration of mitigation must deal with
fish as well as wildlife; presently there are insufficient data to
evaluate fish values.  Avoidance and minimization of project effects on
these sensitive areas appear to be the most practical approaches.

The greatest loss of wetland acreage, habitat units and thus, wildlife
resources, occurs in disposal sites V, VI, and VII and near the entrance
to Lake River, where lake dredging would remove two islands.  Wetland
habitat in disposal sites I through IV has less Habitat Unit Value for
wildlife because of disturbances associated with grazing cattle,  close
proximity to roadways and human uses of the land.  However, there could
still be a significant loss of wetland emergent habitat, i.e., 90 acres,
or about 18 percent of the total.

Wetland habitat in disposal sites V and VII would, in perhaps 20 to 40
years, convert to lowland deciduous forest which has high value for the
wildlife associated with that habitat type.  In disposal site VI, a small
portion of the wetland habitat would be converted to lowland deciduous
forest, while the majority would go to lowland cultivated habitat having
low overall value to wildlife.

Additional possible habitat losses of special significance include the
elimination of eight Columbia River willow groves and two Wapato locations
in disposal site VI, and the removal of the two islands at the entrance
of Lake River, eliminating nesting populations of beaver, nutria and
muskrat.  Deepening the  lake could decrease its value to some feeding
waterfowl and wading birds, but available evidence does not indicate that
this impact is significant.

Available information does not indicate that shallow water/benthos is
very productive for either fish or wildlife, yet it constitutes about
2,140 acres, or 50 percent, of the total study area.  The lack of physical
diversity in topographic relief and substrate type is considered a major
impediment to its productivity.  This probably results from the very
frequent resuspension and redistribution of bottom sediment caused by wind,
                                  A-3

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 resulting in an unstable and unproductive environment.  Changes  in  shallow
 water/benthic habitat  leading to physical diversity or  less sediment  flux
 should increase this habitat type's value for both fish and wildlife.
 The effect of deepening the lake on productivity is difficult to judge
 because relationships  between depth and wind-driven sediment flux are not
 well understood.
                              MITIGATIONS

Two plans which mitigate the level of impact on fish and wildlife are
reviewed as possible alternatives to use of the entire project area.  These
plans are proposed to reduce the loss of the most valuable wildlife habitat,
at the same time providing spoil disposal sites at strategic  locations
around Vancouver Lake.  More specific mitigations can only be accomplished
after a detailed operation and land use plan is developed.  The successional
growth of valuable wildlife habitat over the life of the project was also
considered in the selection of disposal site uses.

Mitigation Alternative I would continue the use of disposal sites I through
IV and VII as proposed in the rehabilitation plan.  Under Alternative I
the use of disposal site V would be avoided.  The filling of areas in
disposal site VI which are considered to be valuable wildlife habitat or
sensitive, and the removal of the two islands at the entrance to Lake
River, would also be avoided (see Figure 7).

Alternative I would substantially reduce the loss in acreage and Habitat
Unit Value of wetland habitat, eliminate the loss of Wapato and Columbia
River willow stands in disposal site VI, and prevent the destruction of
the furbearer populations living on the two northern islands.

In Alternative II, the use of disposal site IV is avoided, while disposal
site V is utilized as described in the proposed rehabilitation plan; all
other disposal and dredging sites are treated as described in Alternative I.
Alternative II would also reduce the loss of valuable wildlife habitat
that would result from the project as proposed, although not by as much
as Alternative I.  Alternative II would increase the acreage of lowland
deciduous forest by more than that created by Alternative I.

One means of compensating for the loss of wildlife habitat is "like-kind"
mitigation.  Compensation can be made by forming new habitat of equal
Habitat Unit Value to that lost or by increasing the HUV of existing
habitat.   These calculations are useful for purposes of comparison but
are not necessarily desirable in terms of the mitigations to be made.
Adoption of Alternative I would result in the lowest compensation
requirement.

Until a restoration project which considers actual dredging and spoiling
operations is described, and until a long-range land use and recreation
plan is developed, detailed in-kind mitigations cannot be planned.
                                  A-4

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Compensation for loss of valuable wildlife habitat can also be accomplished
through trade-off mitigation, i.e., the enhancement or creation of other
types of valuable wildlife habitat.  The planting of lowland deciduous
habitat tree species in disposal sites V, VI and VII is a form of trade-
off mitigation.  More rapid growth of deciduous trees and shrubs on
spoil material could be encouraged through fertilization, drainage
improvements, soil conditioning and planting.  Plant species of greater
value to wildlife, such as elderberry, could be encouraged on disposal
sites.

Another form of trade-off mitigation might be the construction of islands
of lowland habitat within Mulligan Slough that would remain exposed during
high water periods.  Compensation for losses of shallow water/benthic
habitat could be accomplished through propagation of emergent and submergent
aquatic vegetation in remaining areas of shallow water/benthos (Kadlec and
Wentz, 1974) or by encouraging development of invertebrate food sources in
the lake through the formation of solid, stable substrates.  Stumps or
snags could be provided in deep water/benthic habitat for use by wading
birds.

A multitude of trade-off mitigations can be conceived for the project.  It
is assumed that from such an array, feasible trade-offs would be identified,
evaluated and proposed in the final restoration and land use plan.   Decisions
about the value of trade-off mitigations tend to be judgmental and societal
in context, and can best be responded to when the proposed project is
viewed in total as an ecological system designed for human use.
                                  A-5

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