City of Centralia Second Notice of Retention - Water Rights SEPA 2024 0003 The City of Centralia, acting as its own SEPA lead agency pursuant to WAC 197-11-926, issued a Mitigated Determination of Nonsignificance (MDNS) for the project described below on February 16, 2024. The City Issued a Notice of Retention of MDNS on March 20, 2024, after considering written comments on that MDNS. Under WAC 197-11-340(2)(f), the City of Centralia is issuing this second Notice of Retention of MDNS and Incorporation by Reference after considering new information relating to comments received on the MDNS. INCORPORATION BY REFERENCE OF ADDITIONAL ENVIRONMENTAL DOCUMENTS 1. Lewis County Countywide Planning Policies (LC CWPP), adopted June 13, 2023 2. City of Centralia Adoption of LC CWPP – Comprehensive Plan Appendix (CP Appendix C) Adopted November 25, 2025 – Ordinance #2571, location CP Appendix, Pages 51-65/224 3. Lewis County Comprehensive Plan, amended September 23, 2025 – Ordinance #1367 4. Centralia Comprehensive Plan Update, including Transportation Plan analysis, land use analysis, and Climate Resiliency Plan, adopted by City Council on November 25, 2025 – Ordinance #2571 – CP Appendix Pages 215-217/224 5. SEPA Checklist and DNS for Centralia Climate Resiliency Plan and Comprehensive Plan Update, dated May 20, 2025 SECOND NOTICE OF RETENTION OF MITIGATED DETERMINATION OF NONSIGNIFICANCE Description of comments: The City of Centralia received four comments on the MDNS, from: (1) the Cultural Resources Department of the Cowlitz Indian Tribe, relating to protection of cultural resources; (2) the Department of Ecology Southwest Regional Office, relating to sites near the Borst Park area with known or suspected contamination; (3) the Lewis County Community Development Department, relating to known or suspected contamination within the time of travel of proposed well sites; and (4) Earthjustice on behalf of the Quinault Indian Nation ("Quinault"), relating to impacts on streamflow, fish, and treaty rights stemming from the Skookumchuck Dam and TransAlta Water Bank, which is the primary source of mitigation for Centralia's water right application. The Department of Ecology also consulted with the City of Centralia regarding these comments and the MDNS. After issuance of the March 20, 2024 Notice of Retention, additional plans and SEPA documents have been prepared and considered by the City of Centralia that are related to comments received on the MDNS, including the documents listed above that are incorporated by reference. SEPA #: 20240003 Date of Second Retention Notice: January 22, 2026 Proponent: City of Centralia, Public Works Department Lead agency: Centralia Community Development Project Permits: SEPA (City of Centralia), Water Right Application (Department of Ecology, Water Resources Section) The City of Centralia SEPA responsible official has determined that the SEPA comments outlined above and the additional documents incorporated by reference in this Notice do not raise any probable significant adverse impacts on the environment. The Mitigated DNS is retained and an Environmental Impact Statement (EIS) is not required under RCW 43.21C.030(2)(c). This decision was made after consultation with Department of Ecology and review of the documents incorporated by reference. In particular: The Quinault comment letter states that climate change is an element of the environment that must be considered in this SEPA process. While climate change is not included in Ecology's environmental checklist, but nevertheless, the Lewis County Comprehensive Plan includes significant discussion and appendices relating to climate change and resiliency, and the City's Climate Resiliency Plan that was recently adopted guides future City planning and decision-making regarding numerous programs, including utilities. The Quinault comment letter contends that the City's water rights application has the effect of inducing growth in the City and that environmental impacts of induced growth should have been disclosed and evaluated. SEPA, at RCW 43.21C.240, contemplates the integrated and phased environmental review of growth management plans and development regulations, typically referred to as non-project actions, with the environmental review of projects, including acquisition of resources and construction of utilities and other urban services. The City analyses and mitigates the effects of urban growth in its GMA comprehensive plan and development regulations, including the recent updates to its Comprehensive Plan that are adopted by reference in this Notice. Compliance with the City's regulations prevents unmitigated significant environmental impacts from urban growth and development, therefore such impacts need not be further evaluated as part of this application for additional water rights. The Quinault comment letter states the City did not take Chinook Salmon runs into consideration when issuing this MDNS. The checklist identified salmon as known on or near the site, which the City took into consideration in issuing the MDNS. In response to the checklist regarding the presence of threatened or endangered species on or near the site, Chinook salmon were not included because they were not and still are not a listed species in this area. Furthermore, the City did review the Washington Department of Fish and Wildlife (WDFW) Salmonscape interactive mapper. The WDFW Salmonscape interactive mapper demonstrates that there are no ESA Listing Units for Spring, Summer, or Fall Chinook in the vicinity. The Quinault comment letter also contends that the City was required to consider alternatives in the MDNS. Recent case law suggests that an alternatives analysis may be required even though an EIS is not required where there are unresolved conflicts concerning alternative uses of available resources. After discussion with the Department of Ecology, the City finds that: (1) there is no unresolved conflict concerning the continued operation of the Skookumchuck Dam or use of the TransAlta Water Bank because those actions were approved by Ecology and not appealed; (2) as a fully mitigated water right, there is no competition for instream flows in the Chehalis River or conflict with other pending water rights; and (3) regarding the City's pending purchase of mitigation credits from the TransAlta Water Bank to offset impacts to instream flows, there is no unresolved resource conflict because there is a significant remaining balance of credits in the TransAlta Water Bank and the City's purchase would not prevent others including the Quinault from purchasing credits. Centralia's local SEPA regulations require no further comment period on this notice to retain the Mitigated DNS. Hillary Hoke, Responsible Official, Asst. Director, Centralia Community Development IPL0308630 Jan 28 2026