Loading...
HomeMy WebLinkAbout07 Geologist ResponseDonna Frostholm From: Richard Rathvon <rich@rathvonconsulting.com> Sent: Friday, October 11, 2024 3:14 PM To: Donna Frostholm Cc: 'Terry McHugh' Subject: Stratum Group Attachments: McShane comments_Telegin.pdf, MShane comments_Crescent.pdf ALERT: BE CAUTIOUS This email originated outside the organization. Do not open attachments or click on links if you are not expecting them. Donna, In order to facilitate at least a portion of our meeting on Tuesday, I asked Dan McShane to provide his initial impressions of the Geotech related comments from Telegin Law and Crescent Environmental. I have attached the two documents from these firms that include Dan's observations — please see the "electronic sticky" notes embedded in each document and the corresponding Notes pages. Regards, Rich 6 TELEGIN 61�4_bi Law September 27, 2024 VIA E-MAIL ONLY TO dfrostho1m@co jefferson. lva. us Jefferson County Department of Community Development Attn: Donna Frostholm, Associate Planner 621 Sheridan Street Port Townsend, WA 98368 Re; Comments on SDP2023-00020—Type II Land Use Application by Richard Rathvon at 660 Twana Way, Quilcene, Washington Dear Ms. Frostholm I represent John DiMaggio and Michelle Oliver who reside at 161 Twana Way in Quilcene, Washington (Jefferson County Parcel No. 701 153020). Mr. DiMaggio's and Ms. Oliver's property is located approximately 1,000 feet east of Jefferson County Parcel No. 701164005, a shoreline parcel owned by Richard and Renee Rathvon. On behalf of my clients, I ask that Jefferson County consider these comments the Rathvons' pending application for a shoreline conditional use permit to construct a new single-family residence on their property —Application No. SDP2023-00020. A. Overview of the Project The Rathvon parcel is located on the shoreline of Dabob Bay, in an area known to provide ecologically significant habitat for Hood Canal summer chum salmon and Puget Sound Chinook, both of which are listed as threatened under the federal Endangered Species Act. The upland portions of the Rathvon parcel have a shoreline environmental designation of "Natural" under Jefferson County's Shoreline Master Program ("SMP'�. The purpose of this designation is to "protect[] from harm or adverse impact shoreline areas that are intact, have minimally degraded functions and processes, or are relatively free of human influence." Jefferson County Code ("JCC") 18.25.210(3)(c)(i). The aquatic environment adjacent to the Rathvon parcel has a shoreline environmental designation of "Priority Aquatic," the purpose of which is to "protect0 to the highest degree possible and, where feasible, restores waters and their underlying bedlands deemed vital for salmon and shellfish." JCC 18.25.210(3)(a)(i). This area is also known as providing premiere shellfish beds, with Taylor Shellfish located immediately across the bay, and Rockport Oyster just over a mile to the north. Access to the Rathvon parcel is via Twana Way, a narrow, steep, unpaved, primitive road. The surface of Twana Way is only eight to nine feet wide, with some areas as narrow as seven feet — failing far short of the Fire Apparatus Access standards of Quilcene Fire District #2, which require a 12-1oot minimum "all weather" road surface, four -foot shoulder, and 20-foot minimum width clearance. Mr. Rathvon himself has observed that the road does not meet these minimum emergency access requirements and has proposed a detailed road improvement plan. The image below is from a presentation that Mr. Rathvon gave to his neighbors in October of 2023 detailing Telegin Law Nuc 1 175 Parfitt Way SW, Suite N270 I Bainbridge Island, WA 98110 www.teleginlaw.com I bryanLteleginlaw.com 1 (206)453-2884 Jefferson County Department of Community Development Attn: Donna Frostholm, Associate Planner Re: Comments on SDP2023-00020 (Rathvon Application) Page 2 of 8 an extensive road improvement or renovation plan, which Mr. Rathvon represented would be needed to enable safe and reliable access for service and emergency vehicles. ._ - - - 1RACr ! �} i o� Tarr ; MMr r nwr ii iff © + •. e i T A i :rk:• ----1 TwamftVIMpIWWMrft HJWW CW QpWn example i r �r ; � I • n...r...w.+e... .. ��_ � rwortln ---•• -- - idlLesan Below are photographs of Twana Way, known to area residents as the "goat trail." The conditions of the road are so primitive that it is difficult even for everyday vehicles to navigate, let alone large emergency response vehicles, service and delivery vehicles, and construction -related vehicles hauling building materials and equipment. The road is especially difficult for vehicles to navigate traveling uphill, as this narrow, primitive road rises more than 600 feet over an eighth of a mile, immediately adjacent to a steep embankment leading down to Dabob Bay. I I... . .` L=� - ' Jefferson County Department of Community Development Attn: Donna Frostholm, Associate Planner Re: Comments on SDP2023-00020 (Rathvon Application) Page 3 of 8 Near the end of Twana Way, the Rathvons are applying to construct an approximately 3,500 square -foot single-family residence with an onsite septic system and well. Application materials available on the county's online permit database include a site plan. However, no renderings of the proposed home are provided. Nor is any information provided about the proposed construction process, or how building materials and equipment will be transported to the project site. B. Comments on Rathvon Application A primary failing of the Rathvon application is its failure to address details of the proposed construction process. As discussed above, Twana way is a narrow, steep, unpaved, primitive road that is difficult even for everyday vehicles to navigate, especially going uphill. If the Rathvons propose to use this same road for moving construction materials and equipment to and from the project site, then there is a significant risk not only of damage to the road and adjacent hillside, utilities under the road, and interference with other uses (including pedestrian use of the road), there is also a risk of damage to the surrounding environment, including harm to the shoreline environment, infer alia, through increased runoff and sediment transport. In turn, Mr. Rathvon has proposed that the road be significantly improved. Ifthis is still the applicant's plan, then that should be included and evaluated as part of the project application, which may in turn trigger SEPA review. Any proposed renovation ofthe road would clearly raise issues of slope stability, potential damage to downstream receiving waters, and aesthetic degradation of the surrounding area. Nor has the applicant even demonstrated that he would have the legal authority to renovate the road without the prior approval of other landowners. Alternatively, if the Rathvons plan to transport building materials and equipment to the project site via some other route—e.g., via barge or aerial transport —then this, too, needs to be included in the project description and evaluated for impacts on the surrounding environment. Use of water transport would obviously come with a high likelihood of damage to the sensitive aquatic environment. These construction -related issues are directly relevant under JCC 18.25.320(1)(a), which provides that "[t]he location, construction, operation, and maintenance of all shoreline uses and Jefferson County Department of Community Development Attn: Donna Frostholm, Associate Planner Re: Comments on SDP2023-00020 (Rathvon Application) Page 4 of 8 developments should maintain or enhance the quantity and quality of surface and ground water over the long term" (emphasis added). These issues are also relevant under JCC 18.25.590(2)(a) through (e), which require the applicant for a shoreline conditional use permit to demonstrate that the proposal "will be consistent with the policies of RCW 90.58.020 and this program," that it "will not interfere with normal public use of the shoreline," that " the proposed use of the site and design of the project will be compatible with other permitted uses within the area," that the proposal "will not cause adverse effects to the shoreline environment in which it is to be located," and that "the public interest [will] suffer[] no substantial detrimental effect." To remedy the applicants' failure to include details of the construction process in the application, the County should require the applicant to fully disclose how construction materials and equipment will be transported to and from the project site. The County should evaluate the impacts of the construction process. Mitigation measures should be established to protect both the public and area residents, including a requirement that should any damage occur to Twana Way, the applicant shall fully remediate such harm at the applicant's sole expense, returning the road and surrounding area to their original condition as of September, 2024. Next, there are significant errors and omissions in the applicant's February 15, 2022 geologic hazard assessment by the Stratum Group. Attached hereto is a critique of that report prepared by David S. Parks of Crescent Environmental. Mr. Parks is a licensed engineering geologist and hydrogeologist in Washington State with over 35 years of experience evaluating land management effects on hillslope stability, coastal bluff landsliding, hydrogeology and water quality. His attached report concludes that the Stratum Group geologic hazard assessment not only contains significant errors and omissions, but also does not comply with the Jefferson County Code. Among other things: That Stratum Group report failed to consult readily available �iation relevant to assessing slope stability, such z istin a logic assessments i zrrc surrounding area, Jefferson County soil mappin —_ �= s historic shoreline imagery provided by the Washington Department of Ecob, e The Stratum Group report contains unsubstan '_ s claims conce the height of the bluff at the e c,el r� e of the Rathvon propeMff erosion rate potential tsunami inundation lei alQ=:p • The Stratum Group report does not comply with the eleof JCC 18.22.550 requiring identification and mapping of geologically hazard area eluding the requirement that such areas and their buffers be clearly depicted on the applicant's site plan. ■ The Stratum Group report does not attempt to demonstrate that storm water quality, quantity, and flow paths will be comparable to pre -construction conditions —a significant oversight in light of the 9 gical significance of the aquatic environment to the immediate west of the project site Summary of Comments on JeffersonTwanaRathvonsdp023-00020 comments_001_McShane replie.pdf Page: 8 Number: 1 Author. Dan Subject: Sticky Note Date: 10/9/202411:29:17 AM The existing assessments completed in the 1990s by NTi are away from the property and on sites with very different conditions and are not relevant. Number: 2 Author: Dan Subject: Sticky Note Date: 10/9/202411:31:14 AM We provided a description of the soils on the site. The referenced soil map can be added to the report but Is not relevant to ourdirect observations of the soils. Number: 3 Author: Dan Subject: Sticky Note Date:10/9/2024 11:33:11 AM We assessed the stability ofthe slopes and considered groundwater and surface water impacts. It is our opinion that well logs from other properties would provide no relevant information on the stability ofthe slopes. Number 4 Author: Dan Subject: Sticky Note Date: 10/9/202411:35:31 AM We did review the Ecology ob lique photos and stated so. We did not incude the images in the report. Number 5 Author: Dan Subject: Sticky Note Date:10/9/2024 1150:48 AM The height of the bluff was measured in the frefd and can also be derived from fidar data. I rechecked the height using the Iidar data and the height ofthe bluff provided in our description is accurate. Crescent appears to have used elevation to arrive at the height of 45 feet compared to our 40 feet which accounts for the elevated accretion beach fronting the bluff. Number: 6 Author. Dan Subject: Sticky Note Date: 10/9/20241154:12 AM we provided a page and a half supporting our estimation of shoreline bluff retreat (not erosion rate). There has been no bluff retreat atthis site over the past 70 plus years. However, we assume that very rare erosion events will gradually result in bluff retreat and estimate that retreat to have been 1-inch per year. However, we also considered relative sea rise at the site and our projected bluff retreat rate was 2 inches per year and this value was used to provide a setback recommendations from the top edge of the bluff. Number: 7 Author. Dan Subject: Sticky Note Date: 10/9/202411:58:33 AM The DNR map of the area shows the nearby Long Spit (the low area to the north of the property being inundated by about 2 feet by a conservatively large rupture on the Cascadia Fault. We can include this map in the report but our conclusion stands. The home site is on the order of 50 feet above the elevation of Long Spit. The tsunami heights referenced in the Crescent comment are applicable to the outer Washington Coast, but are not applicable to Dabob Bay. Number 8 Author. Dan Sub;ect:5ticky Note Date: 10/9/2024 11:59:34 AM See our Figure 8. Number. 9 Author. Dan Subject: Sticky Note Date: 10/9/202412:02:09 PM We did provide specific recommendations regarding stormwater dispersion and noted that the site soils will readily infiltrate starmwater. Jefferson County Department of Community Development Attn: Donna Frostholm, Associate Planner Re: Comments on SDP2023-00020 (Rathvon Application) Page 5 of 8 • The Stratum Group report does not contain any description or observation of groundwatew and does not contain a description of how the proposal complies with the cl ring, grading, excavation, and stormwater requirements of the Jefferson County Cod Finally, the Stratum Group report fails to include a slope stability and surface erosion assessment of Twana Way. Again, this is a significant oversight given the proposal's proximity to the ecologically significant aquatic environment of Dabob Bay. As Mr. Parks observes in his report: The scope of the geologic assessment completed by the Stratum Group should have included a slope stability and surface erosion assessment of the access road (Twana Way) leading to the project site. Twana Way is a primitive road on a steep slope leading down to Dabob Bay. Portions of the road are within the Critical Areas Buffer of the adjacent stream and will be used by heavy vehicles to deliver equipment and supplies before, during and after project construction. Use of the road by heavy vehicles such as loaded concrete trucks has the potential to cause surface erosion and sediment to enter the adjacent stream, which may then transport the sediment downstream to Dabob Bay. This primitive road should be assessed to determine if it can bear the heavy loads anticipated during truck use without failing and delivering sediment to downstream waters. In light of these many errors and omissions, Mr. Parks concludes that "because of the stated omissions and inaccuracies above and because of the failure to provide the information required by the Jefferson County Code in the geologic assessment (The Stratum Group Report), the geologic assessment should be rejected by Jefferson County Planning and revised." In addition to the problems above, the Rathvon application materials fail to address several important issues and to meaningfully address several questions on the County's conditional use application form. Question 2 on the County's conditional use application form asks the applicant to "[e]xplain how the conditional use is harmonious and appropriate in design, character, and appearance with the existing or intended character and quality of development in the vicinity and with the physical characteristics of the subject property." To this, the Rathvon application answers: "Proposed SFR has been designed to be constructed 160' from the OHWM as such, the home will sit within the existing mature forest creating an in -forest design resulting in a barely -visible footprint." However, no renderings have been provided to show what the proposed single-family residence will look like (either from adjacent uplands or from the water). This is despite that Jefferson County's Shoreline Master Program specifically provides that "[a]ll residential use and development should be planned, designed, located, and operated to avoid adverse impacts on ... aesthetics." JCC 18.25.500(1). The County should require the applicant to provide renderings of the proposed single-family residence to confirm that it will be designed and located to avoid adverse aesthetic impacts. See JCC 18.25.270(3)(b) ("The county shall have the authority to require the applicant/proponent to prepare special studies, assessments and analyses as necessary to identify Page: 9 Number. 1 Author. Dan Subject: Sticky Note Date: 10/9/202412:0&57PM We noted no seepage or plants indicating seepage of groundwater on the bluff. Number. 2 Author. Dan Subject: Sticky Note Date: 10/9/202412:13.45 PM Our report was meantto inform potential development plans regarding geology hazards. Stormwater plans specific to the development plans will need to be developed, but we did provide recommendations for stormwater dipserslon. Jefferson County Department of Community Development Attn: Donna Frostholm, Associate Planner Re: Comments on SDP2023-00020 (Rathvon Application) Page 6 of 8 and address cumulative impacts including, but not limited to, impacts on fish and wildlife habitat, public access/use, aesthetics, and other shoreline attributes.") (emphasis added). Relatedly, there is no discussion of potential cumulative impacts in the Rathvon application. This is despite that JCC 18.25.070(1)(b)(v) specifically requires the County to consider "[i]ndividual effects of the project and the incremental or cumulative effects resulting from the project added to other past, present, and reasonably foreseeable future actions." The County should require the applicant to specifically evaluate and disclose potential cumulative adverse impacts. Question 3 on the County's conditional use application form asks the applicant to describe infrastructure serving the proposed project. In response, the Rathvon application notes that stormwater runoff "will disperse naturally." The County should require the applicant to assess potential impacts of stormwater runoff on water quality. This is especially needed in light of the sensitive aquatic environment and ESA -listed species located just offshore. See JCC 18.25320(1)(a) ("The location, construction, operation, and maintenance of all shoreline uses and developments should maintain or enhance the quantity and quality of surface and ground water over the long term."). The County should also require the applicant to assess potential water quality issues caused by the proposed on -site septic system. Question 5 on the County's conditional use application form asks the applicant to "[djescribe any noise, smoke, dust, fumes, vibrations, odors, outdoor lights or other impacts that will be generated by the conditional use" The Rathvon application answers: "Any impacts such as noise, dust, fumes, etc. should be considered `as typical' for construction and end use of a SFR." This statement provides no "description" whatsoever. The County should require the applicant to provide an accurate and complete description of any such impacts. Question 6 on the County's conditional use application form asks the applicant to "[d]escribe the pedestrian and vehicular traffic and parking area associated conditional use." To this, the Rathvon application answers, in part: "There is no pedestrian use." This is a false statement. Pedestrians regularly use Twana Way and are likely to be impacted by increased traffic, both during construction and after. The County should require the applicant to fully assess such impacts. Question 8 on the County's conditional use application form asks whether there are "any significant adverse impacts on the human and natural environments caused directly by the conditional use? If yes, can these impacts be mitigated." To this, the Rathvon application answers "N/A." No explanation is provided as to why this question is not applicable. The County should require the applicant to provide a full and complete response. JCC 18.25.630(16) specifically requires every application to include "[a] summary characterization of the effects of the project on existing ecological functions and processes in the vicinity of the project. If the project is likely to have adverse effects on shoreline ecological functions or processes, a mitigation plan shall be provided demonstrating measures that will be taken to offset impacts." Similarly lacking is compliance with JCC 18.25.630(12), which requires every application to include "[a] description of the existing ecological functions and processes affecting, maintaining, or influencing the shoreline at/near the project site." Jefferson County Department of Community Development Attn: Donna Frostholm, Associate Planner Re: Comments on SDP2023-00020 (Rathvon Application) Page 7 of 8 Question 9 on the County's conditional use application form asks the applicant to "[d]escribe how granting the conditional use will not be materially detrimental to uses or property in the vicinity of the subject parcel." To this question, the Rathvon application answers: "2 adjacent parcels are currently used in the same manner as our proposal outlines" This is not an answer to the question. The County should require a full and complete response. JCC 18.25.590 specifically provides that "[i]n the granting of all conditional use permits, consideration shall be given to the cumulative environmental impact of additional requests for like actions in the area. For example, if conditional use permits were granted for other developments in the area where similar circumstances exist, the sum of the conditional uses and their impacts should also remain consistent with the policies of RCW 90.58.020 and should not produce a significant adverse effect to the shoreline ecological functions and processes or other users." Question 12 on the County's conditional use application form asks the applicant to describe how the proposed conditional use "complies with all other applicable criteria and standards of the Jefferson County Code (JCC) and any other applicable local, state or federal law; and more specifically, conforms to the standards contained in JCC 18.20 and JCC 18.30" To this, the Rathvon application merely notes that the "septic permit has been submitted to Jeffco EH, and the well permit will be submitted to Jeffco EH at a later date." Again, this is simply not an answer to the question. The County should require the applicant to provide a full and complete response. Question 13 on the County's conditional use application form asks the applicant to "[d]escribe how the conditional use is consistent with all relevant goals and policies of the Jefferson County Comprehensive Plan." The Rathvon application answers: "Our proposal is consistent with zoning and the existing use of properties in the vicinity." As above, this is not an answer. The County should require a full and complete response, including analysis of all applicable goals and policies of the Jefferson County Comprehensive Plan. The Rathvon site plan depicts a stream to the immediate south of the project site, with a proposed 50-foot buffer. This stream buffer must be at least 150 feet pursuant to JCC 18.25.270(4)(e)(iii), which requires a "minimum buffer of 150 feet in all shoreline environments" for all "Stream/River Shores." JCC 18.25.250(1) provides that "[w]hen shoreline development or redevelopment occurs, it shall include restoration and/or enhancement of ecological conditions if such opportunities exist." The Rathvon application fails to state whether such opportunities exist and, if they do, how this project is designed to restore and/or enhance ecological conditions. C. Conclusion The Rathvon application materials fail to demonstrate compliance with Jefferson County's criteria for a shoreline conditional use permit. They do not address the construction process and impacts to Twana Way. The applicant's geotechnical report contains numerous errors and omissions and does not comply with the Jefferson County Code. The conditional use permit application fails to address numerous significant issues. The county should require the applicant to address and correct all of the errors and omissions discussed above. Until that occurs, the county (and the public) is Jefferson County Department of Community Development Attn: Donna Frostholm, Associate Planner Re: Comments on SDP2023-00020 (Rathvon Application) Page 8 of 8 not in a position to evaluate whether the applicant has met its burden to obtain a shoreline conditional use permit. If you have any questions, please do not hesitate to contact me at bryan@teleginlaw.com or (206) 453-2884. Very truly yours, TELEGIN LAW PLLC Bry n Telegin Counsel for John DiMaggro and Michelle Oliver cc: Client Attachments: Crescent Environmental PLLC, Review of geotechnical report and associated documents related to parcel 701164005, Jefferson County, Washington (Sept. 26, 2024) C Crescent Environmental PLLC Environmental Consulting 9/26/2024 John DiMaggio and Michelle Oliver Telephone: (732-241-9776) Email: dimaggiojohnl7@gmail.com RE: Review of geotechnical report and associated documents related to parcel 701164005, Jefferson County, Washington. John and Michelle, Please accept this letter as my review of a geotechnical report and associated documents and information for parcel 7011164005, Jefferson County, Washington. The purpose of this review is to verify that the geotechnical report (Stratum Group Report) is consistent with requirements of the Jefferson County Critical Areas and Shoreline Master Plan codes and further, that the report contains adequate information to support the authors' conclusions. Consistent with our Scope -of -Work dated 9/23/2024, Crescent Environmental PLLC reviewed a geotechnical report dated February 15, 2022 by Stratum Group, Ben Carlson, Licensed Geologist (L.G. #20120123) and Dan McShane, Licensed Engineering Geologist (L.E.G. # 1376) provided for Jefferson County parcel 701164005 as well as other available information (geologic mapping, aerial photographs, LiDAR data, well -logs) related to site geology, slope stability and surface erosion hazards on and adjacent to the subject parcel. I am a licensed engineering geologist and hydrogeologist in Washington State (#533) with over 35 years of experience evaluating land management effects on hillslope stability, coastal bluff landsliding, hydrogeology and water quality. My CV is attached. In conducting this review, I did not perform a site review but relied exclusively on available remote information related to the subject parcel and surrounding areas. General Comments —There are multiple omissions and inconsistencies in the Stratum Group Report as follows: Standard practice for preparing geological assessments for an area is to include previously prepared geologic reports relevant to the subject area being assessed. The Stratum Group report did not include any reference to existing geologic assessments for adjacent parcels. Ar-arl of the Jefferson County planning website showed two available geologic reports relatively m aubject parcel (NTI,1997, NTI 2004). These reports should have been evaluated by the Stratum Group assessment. The following statement on page 6 of the Stratum Group Report does not appear to be consistent with slope measurements derived from the 2019 LIDAR digital terrain model available on the DNR UDAR Portal: Page:13 Number:1 Author Dan 5ubject:Sticky Note Date: 10/9/2024 12:23:06 AM No information on the relevance of these reports is provided. The location of the sites references are well away from the subject property. "The bluff at the property is approximately 40 feet high at its maximum height. The bluff face slopes at approximately 10 degrees on the low, north end and slopes up to approximately 30 degrees toward the south end of the bluff." Slope measurements obtained from the 201Migh Terrain Model (DTM) suggest the slope height of the bluff below the project area is closer to4at its' maximum height and has a maximum slope angle of 45 degrees. The Stratum Group Report does not include a description of how slope heights and angles included In the report were determined. Soil Unit Descriptions: The Stratum Group report does not make reference or evaluate the Natural Resource Conservation Service n�°49 soil mapping (McCreary 1975) for Jefferson County, Washington, completed for the subject parcis omission from the report is consequential because the soil properties analyzed by the NRCS soil survey could directly influence the interpretation of slope stability, infiltration and runoff from the project area and would be important for characterizing subsurface conditions for analyzing ground water conditions and potential flow paths from on -site septic and storm water discharge to receiving waters below the project site. Water well drillers logs from wells on the subject parcel and adjacent parcels were omitted from the Stratum Group Report. Well drillers logs can provide information on subsurface conditions which can be used to infer groundwater flow conditions. Jefferson County Code (see #3 below) requires that geologic assessments include a description of subsurface condition and ground water. The di _ 3 n regarding past and future bluff erosion rates on page 12 should be supported by eviden nless highly sophisticated survey techniques are employed, it is not possible in my experience to measure bluff erosion rates on the order of 1 inch per year. I am not familiar with any bluff erosion study in Washington State that can claim accuracy of 1 inch/ year. When comparing historic survey maps (T-Sheets) to aerial photographs, to on -site observations it is necessary to state the objective accuracy of the maps in terms scale and available survey control datum used to geo-reference the different maps and images. Even with highly accurate terrestrial laser scanners, it is difficult to arrive at an objective accuracy of an inch or two because of the inability to control the location and the elevation of the instrument in the dynamic coastal environment. The authors should justify why they arrived at the stated rates of bluff erosion and provide evidence that estimated rates are accurate Reviewing the oblique shoreline imagery provided by the Washington Department of Ecolo fo he project area between 1977 and 2016, (Photos 1-4) not included in the Stratum Group Repo" is an obvious area on the lower bluff face below the proposed project site that appears to have fai ed in 1994 and in later photos becomes progressively revegetated over time. These photographs should have been included in the Stratum Group Report. Lack of Tsunami Inundation Mapping for the project area: The statement made on page 13 regarding tsunami inundation height ("However, we anticipate this impact to be minor. The proposed building area as indicated on Figure 4 is well above the reach of any earthquake or landslide generated wave heights anticipated for this area") should be qualified by reference to published information or an analysis should be included. As it stands, this statement is without foundation. For instance, the Tohoku earthquake (9.0) in Japan generated tsunami wave run-up heights of 133 feet (40.5 meters). The Washington Department of Natural Resources has calculated that there is about a 10% chance that a 9.0 intensity Cascadia Subduction Zone earthquake will happen in the next 50 years. The Department of Page: 14 Number 1 Author Dan Subject Sticky Note Date: 10/9/202412:36.44 AM This seems petty and is in fact not accurate. The bluff height is 40 feet or less per the lidar derived elevations, It is unclear how [resent derived the heights and slopes. Number. 2 Author: Dan Subject: Sticky Note Date: 10/91202412:37:21 AM McCreay 1975 did not complete a soil map for the property. Soils on the site were described in the report. The soils map referenced by the comment indicates the soils are mapped as Everett sandy loam (McCreary,1975), a soil described as'somewhat excessively well drained'. The soil map is consistent with our description of the upland soil as sand. Number. 3 Author. Dan Subject: Sticky Note Date:10/9/2024 2:10:37 AM Page 11 provides the bulk of the evidence'. Number.4 Author. Dan Subject Sticky Note Date: 10/9/202411.46:24 AM There has bon no.7pprCadtile chAWof she shuellne con "*ns or"welirre "Tuff avereisc hitsmic accord Weed on ouruevtr.. or a..iei pfwtegraphs'laling "ads iG ig5t and hymdc mapsdating bad to IM3: Tho foci M Iha1 there has been no top of bluff reheat over a period of 70 years based on aerial lrsages.The othaeeldence we provided on page 11 through 12 supports a rare of bluff ""Thal is very Yew and our concknIon that the rate of bluff retreat is less than I -inch per year. The purpose of this secllon was to estimate and prgectshoreline bluff retreat. The comment provides has no evidence or rationale supporting a higher rate and Is using measurement accuracy arguments that are not relevant to esumating bluff retreat. Number. 5 Author. Dan Subject: Sticky Note Date:10/9/2024 2:44:20 AM We did review the oblique Ecology photos and can add them to the report. We did note that steeperslope areas will be subject to ravel and shallow soil failures. The area circled on the 1994 photo actually was present in the 1977 photo as well. Natural Resources had published maps of tsunami inundation hazard (WDNR, 201 �jthe coastline of Washington, yet none of this information is included in the Stratum Group Repo —' The scope of the geologic assessment completed by the Stratum Group should have included a slope stability and surface erosion assessment of the access road (Twana Way) leading to the project site. Twana Way is a primitive road on a steep slope leading down to Dabob Bay. Portions of the road are within the Critical Areas Buffer of the adjacent stream and will be used by heavy vehicles to deliver equipment and supplies before, during and after project construction. Use of the road by heavy vehicles such as loaded concrete trucks has the potential to cause surface erosion and sediment to enter the adjacent stream, which may then transport the sediment downstream to Dabob Bay. This primitive road should be assessed to determine if it can bear the heavy loads anticipated during truck use without failing and delivering sediment to downstream waters. Code Compliance: 1. Jefferson County Code 18.22.550 Recording and Disclosure (3) requires that "the limits (or outer extent) of a geologically hazardous area be marked on site as follows:... a. High or moderately high geologically hazardous areas shall be identified and staked by a geotechnical professional." Sub- section (4)(b) of this same rule provides "Geolo icalhazardous areas and buffers shall be shown on a site plan submitted with an application." ' 2 The Stratum Group Report does not indicate that the responsible geologist or geotechnical professional staked the boundaries of the geologically bazar(=rea or buffer, and further, these boundaries do not appear to be shown in the Stratum Group Reporf or on the site plan for the proposal. 2. Jefferson County Code 18.22.550 (5)(di� Ws "The applicant must clearly demonstrate in the geologic assessment that storm water quality, quantity, and flow path post -construction will be comparable to pre -construction conditions. The Stratum Group report on page 13 makes reference to the Washington State Storm Water manual`= p but does not provide an analysis or statement that demonstrates that storm water quantity, quality, flow path post -construction will be comparable to pre -construction conditions. 3. Jefferson County Code 18.22.945, titled "Geologically hazardous area reports," states in part: (2) Project Submittal Standards for Geological Reports. A geological report is required for site development proposals that involve devela ent activity or the installation of structures within a geologically hazardous area;..= otherwise required but do not involve or require engineering design recommendations. The following minimum information is required: (a) Site information regarding the critical areas designations that affect site features; (b) Description of surface and subsurface conditions, Including ground materials, vegetation, surface drainage, groundwater, and a preliminary geologic hazard assessment which includes the locations of structures and the Page:15 Number. 1 Author. Dan Subject: Sticky Note Date:10/9/2024 3:18:42 AM The DNR map of the area shows the nearby Long Spit (the low area to the north of the property being inundated by about 2 feet by a conservatively large rupture on the Cascadia Fault. We can Include this map in the report but our conclusion stands, The home site is on the order of 40 feet above the elevation of Long Spit. The tsunami heights referenced in the comment are applicable to the outer Washington Coast, but are not applicable to Dabob Bay, Number. 2 Author: Dan Subject: Sticky Note Date: 10/9/202412:56:43 AM comment dons not.acwatcy quote 252i, t O,SSo (eHbA - I an.53oi4Hb) Geologically hazardous r ea burr shall be staked on site prior to beginning any clearing, grading, or other Land -disturbing activities. The adminktrator may waive this requlrement if all development activities are wu de of the geologically hazardous aw Wrf rrr. At ine tune of the report, no plans were prepared and no cl�lrr tg planned. We assume that the Ivapowd home will hn W uoe of any geology haaard arse, Per our.ervmmendadon and as illustrated on Figure4 of the report. If the County wan[, the buffer and sesbaclt surfed, we can do 04yhvi given that the proposed harm will be mtsdi of the peeiogy harard .vas It seems to be unnes "wq_ Number. 3 Author. Dan Subject: Sticky Note Date:10/9/2024 2:01:48 AM see figure 4 of the report. Number. 4 Author: Dan Subject Sticky Note Date:10/9/2024 2.03.044 AM There is no 18.22.550(6)(dl. The comment appears to reference 18.22.530(6)(d). This is a stormwater issue and should be covered within the stormwater plan forthe proposed development. We can review the plan. We also made specific recommendations in the conclusion regarding stormwater. Number. 5 Author. Dan Subject Sticky Note Date: 10/9/20241:13:25 AM We did more than simply reference the Manual, ThP repo rl states "Stotmwatcr wllacftd from structures built on the property should be dispersed consistent with the stormwater Management Manual for Western Washington, Soils on the property upland appear rapeble of madly accepting stormwater Infiltration, Slormwater should rat be discharged onto or within approximately 30 feet of the shoreline duff slope.' Number.6 Author: Dan Subject: Sticky Note Date: 10/9/20241:29:03 AM The report is a geology hazard assessment 4f the property and identifies the geology hazardous areas. it is my understanding that the home development will not be located within a geologic hazardous area. identification of the slope and/or coastal processes occurring at the site and factors that contribute to them; (c) Review of available site information, literature, and mapping; (d) Detailed description of slope and other topographic features; (e) Conceptual siting of structures and general recommendations, which include methods and practices that avoid and/or reduce slope and shore impacts. Minimum recommendations should include upland and slope drainage control, groundwater control, site vegetation management, and erosion control; (f) A description of how the proposal complies with the clearing, grading, excavation, and stormwater requirements in JCC 18.30.060 and 18.30.070, and the current version of the Storm water Management Manual for Western Washington; (g) A description of potential effects of the proposal an storm water quantity, quality, and runoff patterns post -construction; (h) A clear statement whether or not the proposal will affect or alter water movement to the geologically hazardous area and its critical areas buffer if the proposal is Implemented; and (I) Identify measures to avoid or minimize alteration of storm water runoff patterns post -construction." The Stratum Group Report does not appear to contain any description or observation of groundwater required by subsection (2)(b) above. ratum Group report does not contain well drillers logs of adjacent water wells in the area or a bole published studies describing groundwater resources of the subject parcel area such as: Grimstad, P. and R.J. Carson,1981. Geology and Ground -Water Resources of Eastern Jefferson County, Washington. Water Supply Bulletin No. 54. Washington Department of Ecology. The Stratum Group report does not appear to contain the analysis required of subsection (2)(f) above although it does recommend compliance with the Storm Water Management Manual for Western Washington on Page 13. The Stratum Group report does not appear to contain the required statement of whether or not the proposal will affect or alter water movement to the geologically hazardous area below the project sit and its critical area buffer if the proposal is implemented, as required by subsection (2)(h) above W In my opinion, because of the stated omissions and inaccuracies above and because of the failure to provide the information required by the Jefferson County Code in the geologic assessment (The Stratum Group Report), the geologic assessment should be rejected by Jefferson County Planning and revised. 4 Page:16 Number. a Author: Dan Subject: Sticky Note Date: 10/9/2024154:33 AM The report noted no water seepage on the bluff slopeandstatedthat 'Sods observed In test pits an a*loa,upWndwererrelldrainedand capableofacceptingaddldonalwater Input contributed by a septic system and saormwatar runoff from the home - The referenced graundsvater resource report and nearby well logs is not relevant to assessing the shoran bluff, shoreline proceses a geomephicprocesses and dope stability at this site. Number. 2 Author. Dan Subject: Sticky Note Date: 10/9/2024159:26 AM The report states "F untw., development within the arm indicated onFigure 4vralnot inuem tdw6ko'txySJdn n-w,, ffthe wit asWrpasthessorsmsertdWnnsofrW,report uCrfogowed, Vie aleo Ha led that-Scilt wr I he propRny uplann appear capable of readily accepr Ong r1 wmvra+rr velYtrsian. stormwala thouw nor be dhcturgrd onrn or witran appra+nvtNy 3p feet of ihr shoMrn.� fx vtf 4opv v!awouldbecantlonaoiean&ingaadding to theseslatemenls spedflcta.quage thalrlur speuFc pnspoul and snarrmvaettpan>regnor dice'' in on the bluff ar irrl2 [sno gea[ogy haurdous -ma, but belpr c the language and eta rvmrnts In t he conclusion co r , , 2?(hl. StnrereIV, M1 L•�•�= f. !f 4 David S. Parks, M. S. Principal Geologist LG, LEG, LHG #S33 Crescent Environmental PLLC 424 East First Street, Box 429 Port Angeles WA 98362 Cell: 360-640-3187 Email: creseentenvironmentai mail.com Website: h s: cMcentenvironmerl.wixsite.com/websit References McCreary, F.R.,1975. Soil Survey of Jefferson County Area, Washington. United States Department of Agriculture, Soil Conservation Service, (National Resource Conservation Service, NRCS). Northwestern Territories, Inc. 1997. Geotechnical Investigation for Tract 5 of Dabob View Tracts, In Section 15, Township 27 North, Range 1 West, W.M., Jefferson County, Washington (Parcel #701-153- 022) Northwestern Territories, Inc., 717 South Peabody, Port Angeles, Washington. 98362 Northwestern Territories, Inc. 2004. Updated to the Geotechnical Report Completed by NTI and Dated August 22,1997, for 1146 Toandos Rd., Located in Section 15, Township 27 North, Range 1 West, W.M., Jefferson County, Washington. Northwestern Territories, Inc., 717 South Peabody, Port Angeles, Washington. 98362 Washington Department of Natural Resources Geology Portal. 2024: https:jfgeylog porlal.dnr.wa.eov Figure 1: Map from Jefferson County GIS Portal showing parcel 701164005 subject to this review (Yellow Highlight). l _ 4,i rnoto z: IVV4 ublique Aerial Photo (WDOE, 2024). '1 6 i' � � i PiLwtuVp i i'A i lot � -1 Photo 4: 2016 Oblique Aerial Photograph (WDOE, 2024). 11