clearwood-SEPA-comments | Stop5ginthebaldhill

Send your comments regarding the SEPA review of the clearwood tower

Dear Neighbor, Thurston county issued their notice of application and we have till the 29th of September to voice our concerns regarding our environmental concerns to the county as part of the comment period for the environmental review. This might be the last chance for you to send your concerns as the county wants to send a Determination of Non significance, which means that the county does not see any environmental impact from this project.

This page is pre-filled so you can use it and modify the template to send an email to the Thurston County project manager responsible for recording the comments. Make your voice heard, this is critical that your comment is received by the county.

If not done already, please go to this first page to send an other email regarding other general concerns.

Yelm Clear Lake / Clearwood
Project 2026101582 | Parcel 23505000000
SEPA 26-107218 XA | SUP 26-107217 ZM
RUE 26-114952 XI | Subtype: Hazardous Slope

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Dear SEPA Responsible Official, Hearing Examiner, and Thurston County Planning Staff,

Please enter this comment in the SEPA and related permit records for the Yelm Clear Lake / Clearwood wireless facility, Project 2026101582, SEPA 26-107218 XA, SUP 26-107217 ZM, and RUE 26-114952 XI, subtype Hazardous Slope, on parcel 23505000000.

I object to a determination of nonsignificance that leaves the material issues below unresolved. Please independently evaluate the current proposal and supporting evidence before relying on a DNS or mitigated DNS for project approval. These objections address specific information gaps and potentially adverse effects, not a claim that every uncertainty automatically requires an environmental impact statement.

[Personal statement inserted here unless you choose to skip it.]

1. Evaluate tower visibility after timber harvesting

Checklist B.10 relies on evergreen forest and terrain to offset altered views, while anticipating harvesting in approximately 25–35 years and proposing a four-foot-wide landscape buffer. That acknowledges logging but does not demonstrate what the 150-foot tower, antennas, and five-foot lightning rod will look like after the screening timber is removed. (Attachment 16, pp. 13–14; Attachment 17, A-4.)

Please identify any post-harvest simulations and their assumptions. Where the existing analysis is insufficient, evaluate current views, reasonably foreseeable harvesting, and the years before replacement vegetation could provide comparable screening. Disclose which trees are assumed to remain, the basis for the harvest timing, the installed and mature dimensions of replacement plants, and any enforceable tree-retention or screening commitments. I am not asking the County to attribute every impact of an independent timber operation to this tower; I am asking it to assess the tower's visibility when the screening it relies on is removed.

Please distinguish screening of the ground compound from screening or concealment of the tower and antennas. The width of a planting strip does not establish its effectiveness at the height of the proposed structure.

2. Evaluate the sunset-viewing location and scenic route to Deschutes Falls Park

The area is used for sunset viewing, with many people reportedly stopping throughout the year. The proposed tower could materially diminish the enjoyment of this location by interrupting the forested horizon and appearing as a conspicuous silhouette against the sunset, especially after timber removal. The scenic approach along Bald Hill Road SE to Deschutes Falls Park also requires evaluation.

Checklist B.12 identifies nearby recreational opportunities but explains that recreational use is not allowed on the applicant's property. That does not address effects on people enjoying views from outside the parcel or travelling along the public road. Please evaluate those off-site scenic and recreational experiences. I am not asserting an established view of the tower from inside the park. (Attachment 16, p. 14, B.12.)

WAC 197-11-444 identifies scenic resources, aesthetics, and recreation as environmental elements. Please identify representative public viewpoints, travel directions, viewing distances, and seasonal sightlines. Require reliable simulations showing the full proposed structure and relevant antenna configuration, including dusk conditions and foreseeable loss of screening. Compare reasonable ways to avoid or reduce the visual impacts, including a different location, height, or concealment design.

3. Resolve wetland identification and the relationship to utility work

Plan A-1.1 depicts County-GIS wetlands and standing-water locations. Checklist B.3.a acknowledges standing water along the access-road drainage ditches and places power and fiber work within the road and drainage side ditches. The revised compliance statement calls certain features potentially non-jurisdictional and recommends silt fencing. (Attachment 17, A-1.1; Attachment 16, p. 6; Attachment 2, p. 5.)

Please identify the field data establishing whether each affected feature is a regulated wetland, another protected water feature, or an excluded ditch under the applicable law. A conclusion about federal jurisdiction does not itself resolve County Title 24 applicability. For confirmed regulated wetlands, identify delineations, ratings, buffers, and distances to every disturbance; for exclusions, identify the rule and supporting evidence.

Evaluate trenching, vault excavation, grading, construction access, sediment, and changes to drainage and wetland hydrology. Please explain how the proposed measures address those pathways rather than relying only on a prediction of no direct filling.

4. Resolve the priority-bird wetland siting issue

Plan A-1.1 contains an approximately 362-foot-2-inch dimension associated with the northern mapped wetland, while the checklist describes more than 300 feet of horizontal separation. Please verify the measurement endpoints and the relevant wetland boundaries. (Attachment 17, A-1.1; Attachment 16, p. 6.)

TCC 20.33.040(A)(1), reproduced in the revised compliance statement, addresses the 1,000-foot separation for wetlands supporting the specified priority or listed birds. Please determine whether the identified wetlands support wood ducks or other birds covered by that provision, using the current biological report, relevant WDFW information, and adequate seasonal evidence. Explain the factual and legal basis for applying or not applying the provision. An intervening road, elevation difference, or general no-impact conclusion is not a substitute for that determination. (Attachment 2, p. 9.)

5. Document the actual survey dates and seasonal coverage

The compliance statement refers to reconnaissance in 2023 and a second review in 2026. Checklist B.5 lists species on or near the site, and A-1.1 maps a gopher area. Please identify what is a verified observation, documented occurrence, habitat assessment, or regional database result, and state the actual dates, methods, and geographic coverage of the field work. (Attachment 2, pp. 4–5; Attachment 16, p. 9; Attachment 17, A-1.1.)

If negative gopher or nesting-bird conclusions still depend on a January reconnaissance, explain how seasonal detectability and breeding-season use were evaluated. An August report revision does not, by itself, establish that another field survey occurred. Please identify any later surveys and the applicable HCP determination for the entire disturbed area. I am not claiming that a winter visit alone is unlawful, or that the latest biological report contains no additional analysis.

6. Reconcile drainage, earthwork, and hazardous-slope mitigation

Checklist B.3.c identifies approximately 247 square feet of impervious surface; plan T-1 identifies approximately 2,500 square feet. Please reconcile the concrete, compacted gravel, road, parking, and compound surfaces and identify the runoff assumptions for the final design. The narrative lists Attachment 24 as a Stormwater Report; please identify the controlling version and its analysis of local slope and wet-feature impacts. (Attachment 16, p. 7; Attachment 17, T-1; Attachment 1, p. 2.)

Attachment 33 describes a selected drilled-shaft foundation, while checklist B.1.e presents spread-footing and directional-bore earthwork scenarios. Please distinguish the operations, confirm the final construction methods and quantities, and identify spoil handling, grading, erosion controls, and drainage outlets. (Attachment 33, p. 1; Attachment 16, p. 4.)

I acknowledge Mark Biever's September 4 geotechnical concurrence on the tower and ancillary structures. It does not replace evaluation of hydrology, habitat, vegetation, visual effects, alternatives, or mitigation of affected buffer functions. Please assess the complete facility and its related access and utilities, not only the pole location. (Mark Biever email, September 4, 2026, p. 1; Attachment 34, pp. 1–2.)

7. Account for stored materials, noise, and the full environmental effect

The plans specify a 30-kW generator, 148 gallons of diesel storage with UL-142 double-wall protection, and batteries. Please reconcile that equipment with the checklist's limited hazardous-material discussion and identify spill, refueling, fire, maintenance, and response measures. I acknowledge the specified double-wall tank and do not allege that containment is absent. Please also identify the noise analysis and enforceable operating assumptions supporting the final equipment configuration. (Attachment 17, A-2.1, GN-5, and D-1; Attachment 16, pp. 10–11.)

Please evaluate the combined effect of vegetation removal, buffer encroachment, drainage changes, habitat disturbance, equipment operation, and loss of scenic quality. The environmental analysis should address the proposed buildout and reasonably foreseeable related effects without speculating about unplanned facilities.

Requested SEPA action and record

Under WAC 197-11-330 and 197-11-335, please independently evaluate the applicant's responses and obtain information reasonably sufficient for the threshold determination. If a proposal continues to have probable significant adverse impacts after appropriate changes or mitigation, apply the EIS requirements in WAC 197-11-330 and 197-11-350. Do not treat the project's communication benefits as eliminating its adverse environmental impacts.

If a DNS or mitigated DNS has already been issued, please identify how these objections affect the supporting analysis and whether correction, additional review, or reconsideration is required under the applicable SEPA procedures. I do not claim that this email, by itself, constitutes a formal appeal or extends any deadline.

For the SUP and RUE, please deny the proposal as submitted if mandatory approval criteria remain unproven. Any denial based on SEPA substantive authority should identify the adopted policies and findings required by WAC 197-11-660, rather than treating an unanswered checklist question alone as proof of an unmitigable impact.

Please include this comment and the cited records in the administrative record, identify the operative reports and mitigation, address these objections in writing, and provide an opportunity to respond to material new information before the relevant record closes. Please acknowledge receipt and provide future notices, determinations, decisions, and applicable appeal instructions.

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Dear SEPA Responsible Official, Hearing Examiner, and Thurston County Planning Staff,

Please enter this comment in the SEPA and related permit records for the Yelm Clear Lake / Clearwood wireless facility, Project 2026101582, SEPA 26-107218 XA, SUP 26-107217 ZM, and RUE 26-114952 XI, subtype Hazardous Slope, on parcel 23505000000.

I object to a determination of nonsignificance that leaves the material issues below unresolved. Please independently evaluate the current proposal and supporting evidence before relying on a DNS or mitigated DNS for project approval. These objections address specific information gaps and potentially adverse effects, not a claim that every uncertainty automatically requires an environmental impact statement.

My connection to the affected area:
[Add your personal statement above, or turn on Skip.]

1. Evaluate tower visibility after timber harvesting

Checklist B.10 relies on evergreen forest and terrain to offset altered views, while anticipating harvesting in approximately 25–35 years and proposing a four-foot-wide landscape buffer. That acknowledges logging but does not demonstrate what the 150-foot tower, antennas, and five-foot lightning rod will look like after the screening timber is removed. (Attachment 16, pp. 13–14; Attachment 17, A-4.)

Please identify any post-harvest simulations and their assumptions. Where the existing analysis is insufficient, evaluate current views, reasonably foreseeable harvesting, and the years before replacement vegetation could provide comparable screening. Disclose which trees are assumed to remain, the basis for the harvest timing, the installed and mature dimensions of replacement plants, and any enforceable tree-retention or screening commitments. I am not asking the County to attribute every impact of an independent timber operation to this tower; I am asking it to assess the tower's visibility when the screening it relies on is removed.

Please distinguish screening of the ground compound from screening or concealment of the tower and antennas. The width of a planting strip does not establish its effectiveness at the height of the proposed structure.

2. Evaluate the sunset-viewing location and scenic route to Deschutes Falls Park

The area is used for sunset viewing, with many people reportedly stopping throughout the year. The proposed tower could materially diminish the enjoyment of this location by interrupting the forested horizon and appearing as a conspicuous silhouette against the sunset, especially after timber removal. The scenic approach along Bald Hill Road SE to Deschutes Falls Park also requires evaluation.

Checklist B.12 identifies nearby recreational opportunities but explains that recreational use is not allowed on the applicant's property. That does not address effects on people enjoying views from outside the parcel or travelling along the public road. Please evaluate those off-site scenic and recreational experiences. I am not asserting an established view of the tower from inside the park. (Attachment 16, p. 14, B.12.)

WAC 197-11-444 identifies scenic resources, aesthetics, and recreation as environmental elements. Please identify representative public viewpoints, travel directions, viewing distances, and seasonal sightlines. Require reliable simulations showing the full proposed structure and relevant antenna configuration, including dusk conditions and foreseeable loss of screening. Compare reasonable ways to avoid or reduce the visual impacts, including a different location, height, or concealment design.

3. Resolve wetland identification and the relationship to utility work

Plan A-1.1 depicts County-GIS wetlands and standing-water locations. Checklist B.3.a acknowledges standing water along the access-road drainage ditches and places power and fiber work within the road and drainage side ditches. The revised compliance statement calls certain features potentially non-jurisdictional and recommends silt fencing. (Attachment 17, A-1.1; Attachment 16, p. 6; Attachment 2, p. 5.)

Please identify the field data establishing whether each affected feature is a regulated wetland, another protected water feature, or an excluded ditch under the applicable law. A conclusion about federal jurisdiction does not itself resolve County Title 24 applicability. For confirmed regulated wetlands, identify delineations, ratings, buffers, and distances to every disturbance; for exclusions, identify the rule and supporting evidence.

Evaluate trenching, vault excavation, grading, construction access, sediment, and changes to drainage and wetland hydrology. Please explain how the proposed measures address those pathways rather than relying only on a prediction of no direct filling.

4. Resolve the priority-bird wetland siting issue

Plan A-1.1 contains an approximately 362-foot-2-inch dimension associated with the northern mapped wetland, while the checklist describes more than 300 feet of horizontal separation. Please verify the measurement endpoints and the relevant wetland boundaries. (Attachment 17, A-1.1; Attachment 16, p. 6.)

TCC 20.33.040(A)(1), reproduced in the revised compliance statement, addresses the 1,000-foot separation for wetlands supporting the specified priority or listed birds. Please determine whether the identified wetlands support wood ducks or other birds covered by that provision, using the current biological report, relevant WDFW information, and adequate seasonal evidence. Explain the factual and legal basis for applying or not applying the provision. An intervening road, elevation difference, or general no-impact conclusion is not a substitute for that determination. (Attachment 2, p. 9.)

5. Document the actual survey dates and seasonal coverage

The compliance statement refers to reconnaissance in 2023 and a second review in 2026. Checklist B.5 lists species on or near the site, and A-1.1 maps a gopher area. Please identify what is a verified observation, documented occurrence, habitat assessment, or regional database result, and state the actual dates, methods, and geographic coverage of the field work. (Attachment 2, pp. 4–5; Attachment 16, p. 9; Attachment 17, A-1.1.)

If negative gopher or nesting-bird conclusions still depend on a January reconnaissance, explain how seasonal detectability and breeding-season use were evaluated. An August report revision does not, by itself, establish that another field survey occurred. Please identify any later surveys and the applicable HCP determination for the entire disturbed area. I am not claiming that a winter visit alone is unlawful, or that the latest biological report contains no additional analysis.

6. Reconcile drainage, earthwork, and hazardous-slope mitigation

Checklist B.3.c identifies approximately 247 square feet of impervious surface; plan T-1 identifies approximately 2,500 square feet. Please reconcile the concrete, compacted gravel, road, parking, and compound surfaces and identify the runoff assumptions for the final design. The narrative lists Attachment 24 as a Stormwater Report; please identify the controlling version and its analysis of local slope and wet-feature impacts. (Attachment 16, p. 7; Attachment 17, T-1; Attachment 1, p. 2.)

Attachment 33 describes a selected drilled-shaft foundation, while checklist B.1.e presents spread-footing and directional-bore earthwork scenarios. Please distinguish the operations, confirm the final construction methods and quantities, and identify spoil handling, grading, erosion controls, and drainage outlets. (Attachment 33, p. 1; Attachment 16, p. 4.)

I acknowledge Mark Biever's September 4 geotechnical concurrence on the tower and ancillary structures. It does not replace evaluation of hydrology, habitat, vegetation, visual effects, alternatives, or mitigation of affected buffer functions. Please assess the complete facility and its related access and utilities, not only the pole location. (Mark Biever email, September 4, 2026, p. 1; Attachment 34, pp. 1–2.)

7. Account for stored materials, noise, and the full environmental effect

The plans specify a 30-kW generator, 148 gallons of diesel storage with UL-142 double-wall protection, and batteries. Please reconcile that equipment with the checklist's limited hazardous-material discussion and identify spill, refueling, fire, maintenance, and response measures. I acknowledge the specified double-wall tank and do not allege that containment is absent. Please also identify the noise analysis and enforceable operating assumptions supporting the final equipment configuration. (Attachment 17, A-2.1, GN-5, and D-1; Attachment 16, pp. 10–11.)

Please evaluate the combined effect of vegetation removal, buffer encroachment, drainage changes, habitat disturbance, equipment operation, and loss of scenic quality. The environmental analysis should address the proposed buildout and reasonably foreseeable related effects without speculating about unplanned facilities.

Requested SEPA action and record

Under WAC 197-11-330 and 197-11-335, please independently evaluate the applicant's responses and obtain information reasonably sufficient for the threshold determination. If a proposal continues to have probable significant adverse impacts after appropriate changes or mitigation, apply the EIS requirements in WAC 197-11-330 and 197-11-350. Do not treat the project's communication benefits as eliminating its adverse environmental impacts.

If a DNS or mitigated DNS has already been issued, please identify how these objections affect the supporting analysis and whether correction, additional review, or reconsideration is required under the applicable SEPA procedures. I do not claim that this email, by itself, constitutes a formal appeal or extends any deadline.

For the SUP and RUE, please deny the proposal as submitted if mandatory approval criteria remain unproven. Any denial based on SEPA substantive authority should identify the adopted policies and findings required by WAC 197-11-660, rather than treating an unanswered checklist question alone as proof of an unmitigable impact.

Please include this comment and the cited records in the administrative record, identify the operative reports and mitigation, address these objections in writing, and provide an opportunity to respond to material new information before the relevant record closes. Please acknowledge receipt and provide future notices, determinations, decisions, and applicable appeal instructions.

Sincerely,
[Your name]

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