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HomeMy WebLinkAboutCA06 Declaration of Attorney Ariel Speser in Support of Jefferson County's Response Brief in Opposition to Apppellant's Motion for Summary Judgment REC IVED JUL 17 2025 JEFFERS.N COUNTY COMMI'StONERS Stephanie Marshall Jefferson County Hearing Examiner 2 3 EXHIBIT •A v( 4 5 BEFORE THE LAND USE HEARING EXAMINER 6 IN AND FOR JEFFERSON COUNTY DECLARATION OF ATTORNEY In re Appeal of Rathvon Shoreline ARIEL SPESER IN SUPPORT OF 9 Conditional Use Permit, JEFFERSON COUNTY'S DCD File No. SPD2023-00020 RESPONSE BRIEF IN 10 OPPOSITION TO APPELLANT'S 11 MOTION FOR SUMMARY JUDGMENT 12 13 I, Ariel Speser, declare as follows: 14 1. I am employed as a Civil Deputy Prosecuting Attorney with Jefferson 15 County. In this capacity, I was recently assigned as counsel for Respondent, 1(; Jefferson County's Department of Community Development (DCD), in the above- 17 referenced matter. I make this declaration based upon by own personal knowledge. 1. For reference and incorporated by reference are Appellant's Supported 19 Documents Exhibits A-H. 20 2. Attached hereto as Respondent's Exhibit I is a copy of the original 21 geological report prepared by Stratum Group (dated February 15, 2022) submitted for the 22 County's review. I retrieved this document via email on July 7, 2025, from Donna 23 Frostholm, associated planner with DCD. 24 25 26 DECLARATION OF ATTORNEY Jefferson County Prosecuting Attorney 27 ARIEL SPESER IN SUPPORT OF 1820 Jefferson Street/P.O. Box 1220 JEFFERSON COUNTY'S RESPONSE t. ; Port Townsend,WA 98368 28 BRIEF IN OPPOSITION TO 360-385-9180 APPELLANT'S MOTION FOR SUMMARY JUDGMENT-Page 1 1 Ms. Frostholm had intended this document to be included in the DCD documents 2 available on the Jefferson County's Hearing Examiner website at 3 https://www.co.jefferson.wa.us/1877/071725-Rathvon-Shoreline. 4 3. Attached hereto as Respondent's Exhibit J is a copy of the preliminary 5 response to the Crescent comments prepared by Stratum Group (received October 11, 2024). 6 I retrieved this document (DCD's Exhibit 07) from DCD documents available on the 7 Jefferson County's Hearing Examiner website at 8 https://www.co.jefferson.wa.us/1877/071725-Rathvon-Shoreline. 9 4. Attached hereto as Respondent's Exhibit K is a copy of the Stratum 10 Group Geology Hazard Assessment Update Report (dated November 14, 2024), 11 prepared in response to the County's request for additional information. I retrieved 12 this document (DCD's Exhibit 08) from DCD documents available on the Jefferson 13 County's Hearing Examiner website at https://www.co.jefferson.wa.us/1877/071725- 14 Rathvon-Shoreline. 15 5. Attached hereto as Respondent's Exhibit L is a copy of Stratum Group's 16 Geologically Hazard Assessment for Twana Way Improvements (dated February 25, 17 2025). I retrieved this document (DCD's Exhibit 09) from DCD documents available on is the Jefferson County's Hearing Examiner website 19 at https://www.co.jefferson.wa.us/1877/071725-Rathvon-Shoreline. 20 6. Attached hereto as Respondent's Exhibit M is a copy of the Jefferson 21 County Substantial Development Permit, Type II shoreline conditional use permit 22 (SCUP), SPD2023-00020, dated April 10, 2025. 23 24 25 26 DECLARATION OF ATTORNEY Jefferson County Prosecuting Attorney 27 ARIEL SPESER IN SUPPORT OF 1820 Jefferson Street/P.O.Box 1220 JEFFERSON COUNTY'S RESPONSE ° Port Townsend,WA 98368 28 BRIEF IN OPPOSITION TO = 360-385-9180 APPELLANT'S MOTION FOR ,, SUMMARY JUDGMENT-Page 2 1 I retrieved this document (DCD's Exhibit 11) from DCD documents available on the 2 Jefferson County's Hearing Examiner website at 3 https://www.co.jefferson.wa.us/1877/071725-Rathvon-Shoreline. 4 5 I declare under penalty of perjury under the laws of the State of Washington 6 that the foregoing is true and correct. / th Dated this 7 day of July, 2025, at Port Townsend, Washington. 9 10 11 Ariel Speser, WSBA#44125 Civil Deputy Prosecuting Attorney 12 Email: aspeser@co.jefferson.wa.us 13 14 15 16 17 19 20 21 .)9 23 24 25 26 DECLARATION OF ATTORNEY Jefferson County Prosecuting Attorney 27 ARIEL SPESER IN SUPPORT OF 1820 Jefferson Street/P.O.Box 1220 JEFFERSON COUNTY'S RESPONSE � Port Townsend,WA 98368 .)s BRIEF IN OPPOSITION TO = 360-385-9180 APPELLANT'S MOTION FOR , SUMMARY JUDGMENT-Page 3 EXHIBIT I 06/27/2024 Jefferson County Community Development STRATUM GROUP PO Box 2546,Bellingham,Washington 98227 Phone:(360)714-9409 February 15, 2022 Richard Rathvon 20 Liberty Knoll Colts Neck, NJ 07722 rrathvon@gmail.com Re: Geologic Hazard Assessment for Proposed Septic System 660 Twana Way Jefferson County Parcel 701164005 Quilcene, WA 98376 This geologic hazard evaluation was conducted to assess the risk of landslide and erosion hazards at 660 Twana Way to determine the feasibility and appropriate locations for the construction of a new home and septic system on the property. The Jefferson County Public Land Records landslide hazard map indicates that part of the subject property is located in a moderate landslide hazard area and part of the property is located in a high landslide hazard area. The shoreline stability map indicates that part of the subject property has unstable slopes and an unstable recent slide is mapped as extending onto the north portion of the shoreline bluff on the property. The shoreline area of the property is mapped as an erosion hazard area and the lower portions of the property are mapped as a potential seismic hazard area. Based on our geologic hazard assessment, construction of a home and septic system can be located on the site outside of any landslide hazards or shoreline bluff retreat from erosion for the next 100 years as long as the home and septic system are located at least 30 feet from the top edge of the shoreline bluff. Furthermore, such construction will not increase the risk of landslides or erosion on or off the subject property as long as the recommendations in this report are followed. This geologic hazard assessment included a field inspection of the subject property and vicinity including the shoreline area and slopes on and in the vicinity of the site. The evaluation also included review of available geologic mapping, historical aerial photographs, historical land surveys, lidar(light detecting and ranging) imagery, and our own notes,photographs, and observations made in the vicinity of the site and at locations with similar geologic conditions. Stratum Group Project: 1.31.22 1 February 15,2022 Jefferson County Parcel 701164005 Geologic Hazard Assessment GENERAL GEOLOGY The Geologic Map of the Quilcene 7.5 Minute Quadrangle, Jefferson County, Washington (Contreras and others, 2014) indicates that subject property is underlain primarily by Whidbey Formation sediments with the lower western third of the property mapped as being underlain by Vashon ice contact deposits, which mantle older glacial and non-glacial formations such as the Whidbey Formation in the area. The map also indicates Double Bluff drift glacial deposits may be present at exposures at the southwest corner of the property. Landslides and landslide scarps are indicated just to the south of the subject property. i ti . „ / 1 . 4$ \ `,,, ---- ty ~' S Qcw i �� � 4\ ;Qa ' \ � QC fLL Qb ` ° ` ', Subject property \ Qgic N i i ) -,_ Qgdp I A r . , Qgdd { • �` Qgic Qc k • ` • , Qls \ • • y`ya Figure 1.Clipped and annotated geologic map showing the subject property. Qb=beach deposits,Qaf=alluvial fan,Qgic=ice contact deposits,Qcw=Whidbey Formation,Qgdp=Possession glacial rift,Qco=Olympia non- glacial deposits,Qgdd=Double Bluff glacial drift,Qc=Pre-Fraser non-glacial deposits,Qls=landslide.Hachures are landslide scarps.Heavy dotted line with query is a surmised potential fault. The Whidbey Formation is a non-glacial deposit that is between 125,000 and 80,000 years old. The Whidbey Formation in the vicinity of the property consists predominantly of sand but also includes units of silt and clay. The formation is dense and hard having been overridden by glacial ice over two separate glacial periods. The Vashon ice contact deposits(Qgic) are a mix of poorly sorted sediments deposited directly by glacial ice during the late stages of the last glacial period between about 14,000 years ago. ,`t P STRATUM GROUP 2 Project: 1.31.22 February 15,2022 Jefferson County Parcel 701164005 Geologic Hazard Assessment Contreras and others (2014) mapped the unit where deposits appeared to be associated with ice wasting and the surface area of the deposits lacked streamlines associated with ice movement. The Double Bluff drift(Qgdd) consists of sediment deposited during a glacial period that is estimated to have taken place between 190,000 and 125,000 years ago. This formation represents a glacial period that occurred three ice ages ago. The basis of the interpretation is from age estimates and map relationships in the larger vicinity than shown on the map; however,this area is geologically complex due to the presence of a fault zone and local offsets and folding. Our observations are generally consistent with the above-described mapping. Soils observed on the property upland and exposed along the shoreline bluff primarily consist of very dense, stratified, sand and gravel with lesser silt lenses (Figure 2). These dense deposits are commonly overlain by a surficial cap of medium dense,poorly sorted, and unstratified, sand, silt, and gravel interpreted to represent Vashon ice contact deposits (Figure 3). A very dense,poorly sorted, and unstratified sand, silt, and gravel unit exposed at the base of the shoreline bluff on the subject property and to the south is consistent with Contreras and others (2014) interpretation of the unit being the Double Bluff drift mapped in the vicinity(Figure 2). 3 Project: 1.31.22 February 15,2022 Jefferson County Parcel 701164005 Geologic Hazard Assessment • .. Whidbey.Fm. Double Bluff Figure 2.Whidbey Formation sand and gravel with Double Bluff drift at the base of the bluff a few hundred feet south of the subject property. rf ,STRATUM GROUP 4 Project: 1.31.22 February 15,2022 Jefferson County Parcel 701164005 Geologic Hazard Assessment 'Y f ' ik '"0�'!yrvT �F — ' a#r ti �.+V¢ yr"y� i' 1./t! ' 7a ` r. t A •." 4: „yam; *":4 r ti '• ^' w. A ,5 '1.# K`r fr-G«- `Y ' .,.�,., A • , -" ✓x"4. "u4' F x a "" tit. . _ • .rr Y,F.; .y . '<f f . r - «^ .. - rr.„ _ f \ . mo`_ }q y ""ma s ,ar' , '.. r- -: *2° 4„ w ......„we:;..,, • da "" t., ,t,...f.. ., t.. . 1 F+ f - i - :y - •."• •rAr �A' ['j`' ray t } Z Y . 7 .9 r. '.,mac+ r xdr Figure 3.Medium dense,poorly sorted sediment consistent with Vashon ice contact deposits on the site upland. SITE SPECIFIC OBSERVATIONS An annotated lidar hillshade image of the subject property and vicinity is provided in Figure 4. The property is accessed by Twana Way, a gravel/dirt road,which crosses through the subject property from the southeast corner to access residential properties to the north. art, STRATUM GROUP 5 Project: 1.31.22 February 15,2022 Jefferson County Parcel 701164005 Geologic Hazard Assessment _ _ Accretionary shore Gentle lowla s -!tea Ridge 01153026 slopes I N.1 au V%al Suitable building b area Val e Dabob Bay T ,,� Bluff erosion ! '' " .,' Figure 4.Annotated lidar hillshade map of the subject property showing key site features.Potential building area outside of any landslide or erosion hazards is outlined with green dashed line. The west edge of the property consists of a shoreline bluff(Figure 5). The bluff is nonexistent to very low at the northwest corner of the property where the bluff descends down to an accretion shore area and steadily rises to the south before dipping down somewhat near the southwest corner where the bluff intersects a valley. 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. The bluff is underlain by compact sand and gravel consistent with pre glacial alluvial sediment and very dense silt/clay with gravel consistent with glacial till. The bluff face is vegetated with Douglas fir, western red cedar, and madrone trees with an understory of mostly grass with some other shrubs. We observed no concentration of hydrophilic vegetation or evidence of springs on the bluff face. STRATUM GROUP 6 Project: 1.31.22 February 15,2022 Jefferson County Parcel 701164005 Geologic Hazard Assessment •4. _ a Slope face y - cy , . • Figure 5.View of the beach and shoreline bluff on the subject property, looking northwest. The beach at the base of the bluff is a gravel and sand beach. Minor past erosion of the toe of the bluff is evident at or very near the southwest corner of the property where the very hard likely Double Bluff glacial drift deposits are exposed at the base of the bluff. The upper part of the beach consists of sand and gravel with driftwood. It appears that water did reach the base of the bluff recently, likely during the recent high tide/storm surge event on January 11, 2022. However, no significant erosion was evident and it appears that erosion occurs on an infrequent basis. A grass-covered accretion beach fronts the northwest end of the property and extends as a long shoreline spit for over a mile to the north of the subject property.No erosion was evident on the accretion shore area ad water did not reach the slope area fronted by the accretion shore reach. The shoreline at the property is located in a transition zone between areas of bluff erosion south of the subject property and shoreline accretion to the north. These observations are consistent with shoreline type designations on the Washington Coastal Atlas and Jefferson County Public Lands Records (Coastal Geologic Services, 2015). STRATUM GROUP 7 Project: 1.31.22 February 15,2022 Jefferson County Parcel 701164005 Geologic Hazard Assessment The upland area above the shoreline bluff slopes up at approximately 10 degrees or less (Figure 6). This gentle slope area is located between two valleys. No water was present in the bottom of the northern valley on the property and the valley area is underlain by well drained sand. The valley on the south is on and/or just south of the property line. There is indication of periodic water flow in this valley, but no water was present at the time of our site visit on February 1, 2022. These valleys appear to be primarily remnant erosional features that formed at the end of the last glacial period when erosion rates were very high on the bare landscape right after ice retreated from the area. 6 a :� •`, 4 I t « t mac, , y 3, �t 0. it ,e: q i t i e ', a � ', Via- id a.-. 1 lR .,: 11 y ;1 � '�� {fir y�,�i �,; � �t� � t M .'�..: • � i� Y' - '. S v >-44'.L .1 4 . , p,,,P, ,7, -.,. 0 ,,, .,1,::.--, ,fel, i 1 it t r-A, '..'et 6" . 4 I ,„ , . ,ciligft • y A I ' 1 ."* r r • ? 1 a a-. ; ° fir. - '*,' '"-•-* * , � '- i ,*• ,. : _, Ott. =!.z i Figure 6.Gentle slopes on the lower(western)upland of the subject property. The eastern portion of the property consists of a plunging ridge between two valleys. The valley side slopes range between 15 and 35 degrees (Figure 7)up to the ridge line and ridge line plunges around 15 degrees to the west-southwest. The south sides of the ridgelines are steeper than the north sides. The Twana Way roadway and a driveway that descend from the road toward the shoreline are cut into the flanks of the slopes of the ridges,which on the steeper south sides of the ridges results in 2-to 4-foot high cut slopes above the road that reach 35 to 50 degrees in slope and 2- to 4-foot tall, 30-40 degree fill slopes below. :..r STRATUM GROUP p O Project: 1.31.22 February 15,2022 Jefferson County Parcel 701164005 Geologic Hazard Assessment tee • 1g • ;, A ' { f jY 3l L - " � Y T'F j ^'� �5✓ Ins _ } ` _ • Figure 7.Moderate slopes descending from the south ridgeline on the eastern portion of the property upland. The upland area is forested with a mix of trees including Douglas fir,western red cedar, western hemlock and big leaf maple. The understory consists predominantly of sword fern and includes bracken fern, salal, evergreen huckleberry and other brush. GEOLOGIC HAZARD ASSESSMENT The upland slope area between Twana Road and the shoreline bluff slope is gently sloping and is outside of any landslide or erosion hazard area. Soils observed in test pits on this lower upland were well drained and capable of accepting additional water input contributed by a septic system and stormwater runoff from the home. The soils are well drained and generally coarse grained and will not be subject to seismic induced liquefaction. The portion of the property outside of any landslide or erosion hazards areas is indicated on Figure 4 above. Shoreline Bluff Slope Stability The shoreline bluff at the site is underlain by dense alluvial sediments consisting primarily of dense sand and gravel consistent with Whidbey Formation and very hard silty glacial till consistent with Double Bluff Drift. These bluff face sediments are capable of maintaining steep slope angles for long periods of time. The glacial drift is very hard and resistant to erosion. The steeper areas will be subject to ravel and shallow surface failures as the upper soil weathers or if STRATUM GROUP 9 Project: 1.31.22 February 15,2022 Jefferson County Parcel 701164005 Geologic Hazard Assessment the slope is undercut by erosion. Currently there is only minimal erosion at the base of the shoreline bluff at the very southwest corner of the site (Figure 8). We observed no evidence of recent sliding other than minor ravel on the shoreline bluff slope. The `unstable recent slide' indicated on the shoreline stability map does not appear in any aerial images dating back to 1951 or within the lidar bare earth imagery. There was an area of bare ground on a slope area to the north visible in the 1976 aerial photograph,but that appears to be associated with land grading and/or mining associated with road construction. We suspect the designation was mismapped. r' .. • Figure 8.View of shoreline bluff from the south.Note minor erosion at hard glacial till located at southwest corner of property. Slopes on Eastern Portion of Site The slopes above Twana Road consist of two valleys with a ridge between. The ridge slopes and valley sides are moderate slopes and no indication of potential landslides is present. Some minor ravel of soil is present on the cut slopes associated with Twana Road. The steep headwall areas of these valleys appear to have had some shallow sliding in the past that sent slides part way down the valleys,but we interpret these landforms to be relict. The upper headwall areas of the north valley appear to be steep enough that shallow slides could take place, but the gradient of the valley, width of the valley and lack of water flow is such that we do not anticipate that shallow slides from the steep headwall of the valley would reach the subject property. �..P STRATUM GROUP 10 Project: 1.31.22 February 15,2022 Jefferson County Parcel 701164005 Geologic Hazard Assessment Beach Processes and Bluff Retreat The beach at the property is located towards the northern end of an approximately 10 mile long drift sector with sediment transported from south to north along the shore. Most of this drift sector is lined with fairly high feeder bluffs (Figure 9) and there is very little shoreline armoring that would reduce the sediment supply. Numerous very large landslides are located along the drift sector including a slide 0.4 miles to the south that covered the entire beach area l Os of feet deep with sediment over a distance of 550 feet in 1998, and there are multiple large areas of high bluffs of exposed glacial sediment that are eroding and raveling onto the beach feeding the beach. moo 1998 large landslide Figure 9.View of eroding bluffs south of property and large 1998 slide area 0.4 miles to the south. There is a slight change in shore orientation and openness to larger fetch along that shore area just to the south of the property. This is likely due to the presence of the very hard glacial till that is resistant to erosion at the base of the bluff at the subject property. The combination of the hard glacial till and the slight change in shore orientation is such that shoreline erosion at the subject property is very low relative to the shore areas to the south. The shore form at the property transitions from a feeder bluff to the south to a transport zone (bluff backed beach on Jefferson County map) to an accretion zone on the north part of the shore at the site. There was no indication of recent erosion having taken place during the very high tide storm surge of January 11, 2022 along the base of the slope on the property. No erosion of the accretion area below the north portions of the site was observed and water did not reach the base of the slope on the northern portion of the site where the trail is located during the January 11, 2022 event. There has been no appreciable change of the shoreline conditions or shoreline bluff STRATUM GROUP 11 Project: 1.31.22 February 15,2022 Jefferson County Parcel 701164005 Geologic Hazard Assessment over the historic record based on our review or aerial photographs dating back to 1951 and historic maps dating back to 1883. Based on the beach conditions, shoreline bluff materials of dense sand and gravel, the very low erosion rate observed over the past 50 years in the oblique aerial imagery, the long term shoreline bluff retreat at the site has been less than 1 inch per year. The top edge of the bluff retreat will be episodic with many years where no retreat will take place at the top edge of the bluff; however, over time the upper bluff will become undermined as erosion and ravel take place on the slopes below and shallow small scale slides should be expected to reach the top edge of the bluff. Consideration of Sea Level Rise While past shoreline bluff retreat has been very slow and the long-term rate has likely been less than 1 inch per year, relative sea level rise projections for the year 2100 are estimated to be between 1.0 and 2.8 feet for the likely range of sea level rise under low to high green house gas levels (Miller et al., 2018). The increase in sea level will result in a greater frequency of high water reaching the base of the slope and hence an increase in erosion rate. However, the increase in erosion will take place along the entire shoreline drift sector and will be even more pronounced at the current feeder bluff areas to the south. The increased erosion to the south will add sediment to the beach fronting the subject property and thus will partially off set the sea level rise increase of erosion at the subject property as the entire shore reach and beach adjust to the change in sea level. Due to the change of seal level,we assume that there will be some increase in erosion rate and a corresponding change in bluff retreat. We estimate that the long term bluff rate accounting for sea level rise over the next 100 years will be 2 inches per year. This corresponds to top of bluff retreat of 8.3 feet over the next 100 years. An additional 20 feet should be added as an addition safety buffer for larger scale ravel or higher erosion rates than what we are estimating or other potential change in conditions along this shore reach. Seismic event considerations Test pits on the site found that the upland area where the home would be located is underlain by coarse well drained sediment. This sediment will not be susceptible to soil liquefaction from seismic events. Given the steepness of the shoreline bluff, small scale slides should be expected on the bluff slope in the event of a large seismic event. We observed no evidence of past seismic induced slope movement such as lateral spread on the uplands of the property on the ground or within lidar bare earth imagery The shoreline at the site could be impacted by earthquake-induced tsunamis or from large waves generated by landslides into the bay. Waves and currents produced by tsunamis or landslide waves could result in erosion of the toe of the shoreline bluff on the subject property that would STRATUM GROUP 12 Project: 1.31.22 February 15,2022 Jefferson County Parcel 701164005 Geologic Hazard Assessment not occur under more typical conditions. 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. CONCLUSIONS AND RECOMMENDATIONS Based on our geologic hazard assessment, it is our opinion that construction of a single-family house and associated septic system on the lower upland on the subject property will not be at risk from landslides or erosion within the expected life of the structure as long as the building and septic systems are located at least 30 feet from the top of the steep shoreline bluff slope. Furthermore development within the area indicated on Figure 4 will not increase the risk of landslides or erosion on or off the site as long as the recommendations of this report are followed. Stormwater management: Stormwater collected from structures built on the property should be dispersed consistent with the Stormwater Management Manual for Western Washington. Soils on the property upland appear capable of readily accepting stormwater infiltration. Stormwater should not be discharged onto or within approximately 30 feet of the shoreline bluff slope. Yard waste and debris: Ground cover vegetation within 20 feet of the top edge of the slope and on the bluff slope should not be disturbed. Trees within the buffer may be thinned or limbed for view purposes. However, if the trees are thinned, trees should be left on at least 30-foot centers. In addition, no debris or yard waste should be placed on or near the steep coastal bluff or other steep slopes on the property. Yard waste can eventually builds up and can form a wet unstable mass that will slide down the bluff damaging the slope and increasing the likelihood of a future slope failure. In addition to our construction recommendations,new construction on the subject property may also be subject to buffer requirements established in the Jefferson County Shoreline Master Program. Final construction setbacks should reflect whichever setback is largest. Stratum Group appreciates the opportunity to be of service to you. Should you have any questions regarding this assessment please contact our office at(360) 714-9409. Sincerely yours, Stratum Group -r ilk �, _ Ben Carlson, L.G., M.Sc. Dan McShane, L.E.G.,M.Sc. Licensed Geologist reo� W ashi�gr Licensed Engineering Geologist �a�g o{ Wash,.,�o o g '1.4*`, ng- :0120123 y %, c13 6gr ..•y ,STRATUM GROUP Project: 1.31.22 Benjamin Carlson DANIEL McSHANE EXHIBIT J Exhibit 7 Donna Frostholm pang 1 of 9R 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 1 Exhibit 7 Pang, 9 of 751 Exhibit 7 Pane of 7R TELEGIN --.�,'-•....__ LAW September 27,2024 VIA E-MAIL ONLY TO dfi•ostholnz@co Jefferson.wa.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.701153020).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"protect[]to the highest degree possible and, where feasible, restores waters and their underlying bedlands deemed vital for salmon and shellfish." 1CC 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— falling far short of the Fire Apparatus Access standards of Quilcene Fire District#2,which require a 12-foot 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 Telegirr Law 'ac I 175 Parfitt Way SW,Suite N270 I Bainbridge Island,WA 98110 www.teleginlaw.com I bryaneteleginlaw.com I (206)453-2884 Exhibit 7 Pang, 4 of 9R 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. . Nana way tmprcvcments nac�r t I."4 HigAir Cat +a k t "t M S y 1 `.0 t 1.. �......I.....f.__ R.. I g+.......o...... w+ J. m.o.I 3 f . &moMs...I= IYl f I.WwWMMlW ... rr :eraser 1 • *....•.-+....+...w !t �' + ( rM+nr.wh /dile smolt •1� rt_ 4 i" • . r ram te. - _111Crs N /AMC►i A ak*4` k MM•4 ...... wa . •:. N ; 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. ,, Exhibit 7 Pan Panp. rf 7R 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, thcn 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,inter alia,through increased runoff and sediment transport.In turn,Mr.Rathvon has proposed that the road be significantly improved.If this 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 of the 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 Exhibit 7 Pane Fi of 7311 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 ' p ation relevant to assessing slope stability, such istin ©logic assessments i�e surrounding area, Jefferson County soil mapping � = historic shoreline imagery provided by the Washington Department of Ecolog • The Stratum Group report contains unsubstan '. .© claims conceit•r• the height of the bluff on the western •e of the Rathvon prope 'ff erosion rat==. potential tsunami inundation level 1;116 • The Stratum Group report does not comply with the eletRenigof JCC 18.22.550 requiring identification and mapping of geologically hazard arealuding 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 - r.4 gical significance of the aquatic environment to the immediate west of the project sit.a Exhibit 7 PanP 7 of 7R Summary of Comments on JeffersonTwanaRathvonsdp023-00020 comments_001 McShane replie.pdf Page: 8 Number:1 Author:Dan Subject:Sticky Note Date.10/9/2024 11:29:17 AM The existing assessments completed in the 1990s by NTT are away from the property and on sites with very different conditions and are not relevant. Number:2 Author:Dan Subject:Sticky Note Date:10/9/2024 11:31:14 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 our direct observations of the soils. Number:3 Author.Dan Subject:Sticky Note Date:10/9/2024 11:33:11 AM We assessed the stability of the 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 of the slopes. Number.4 Author:Dan Subject:Sticky Note Date:10/9/2024 11:35:31 AM We did review the Ecology oblique photos and stated so.We did not include 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 field and can also be derived from lidar data.I rechecked the height using the lidar data and the height of the 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:10/9/2024 1154:12 AM We provided a page and a half supporting our estimation of shoreline bluff retreat(not erosion rate).There has been no bluff retreat at this 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:10/9/2024 11:58:33 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 Subject:Sticky Note Date:10/9/2024 11:59:34 AM See our Figure 8. Number:9 Author:Dan Subject:Sticky Note Date:10/9/2024 12:02:09 PM We did provide specific recommendations regarding stormwater dispersion and noted that the site soils will readily infiltrate stormwater. Exhibit 7 Pang, R of 7R 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 groundwategir and does not contain a description of how the proposal complies with the cl-r: ing,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 toads 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." En 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]11 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 Exhibit 7 Panp A of 7R Page: 9 Number 1 Author Dan Subject:Sticky Note Date:1 0/9/2024 1 2A8:57PM We noted no seepage or plants indicating seepage of groundwater on the bluff. Number:2 Author Dan Subject Sticky Note Date:10/9/2024 12:13:45 PM Our report was meant to 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. Exhibit 7 Pane 1 fl of 9R 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 1 8.25.070(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 18.25.320(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"[d]escribe 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 ofa 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." Exhibit 7 Pane 11 of 9R 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 Exhibit 7 Pano 19 of 9R 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, TELEGTN LAW PLLC Bry n Telegin Counsel for John DiMaggio 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) Exhibit 7 Panp 11 of 9R 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 70116400S, 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 hiltslope 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.A +/1 of the Jefferson County planning website showed two available geologic reports relatively nea ubject 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 LiDAR Portal: 1 Exhibit 7 PanP 14 of 7R Page: 13 Number:1 Author Dan Subject.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. Exhibit 7 Parip, 1 C of 7R "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 2019 r'•" l Terrain Model(DTM)suggest the slope height of the bluff below the project area is closer to 4'-_ igh at 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 ; „s soil mapping(McCreary 1975)forJefferson County,Washington, completed for the subject parc- is 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 did,n regarding past and future bluff erosion rates on page 12 should be supported by eviden-77 niess 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 th-v 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 is he project area between 1977 and 2016,(Photos 1-4)not included in the Stratum Group Repo Wel 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 2 Exhibit 7 Pane 1R of 7R Page: 14 Number 1 Author.Dan Subject:Sticky Note Date:10/9/20241236:44 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 Cresent derived the heights and slopes. Number.2 Author:Dan Subject:Sticky Note Date:10/9/2024 12:37:21 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:1 0/9/2024 11:46:24 AM 'These hat been ha appnbable Change of the Shoreline coruhsront or shoran*bluff over the hstak record hosed on ow review or nese there has been no top of bluff retreat over a poled of 70 htraograortdoblating rabadttio(WO ttuo andhhtnemapsrod o barktolon Mat t e roe our retreat o leas than t•inchper Yesbated on aerial evidence we provided on page 11 throughI supportsaneedblulrnuwu that do..trod out condnbnThat themeof bluff year. The purpose of this section was to estimate and project shoreline bluff retrnt. The comment provides has no evidence or ntlonde supporting a higher rate and is using measurement accuracy arguments that are not relevant to nlimating 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 steeper slope 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. Exhibit 7 Pan= 17 of 7R Natural Resources had published maps of tsunami inundation hazard(WDNR,20 ima the 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:ica © hazardous areas and buffers shall be shown on a site plan submitted with an application." The Stratum Group Report does not indicate that the responsible geologist or geotechnical professional staked the boundaries of the geologically haza =©:rea or buffer,and further,these boundaries do not appear to be shown in the Stratum Group Repo or on the site plan for the proposal. 2. Jefferson County Code 18.22.550(6)(.� s"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 manua 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 dev .. :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 3 Exhibit 7 Pane 1 R of 751 Page: 15 Number.1 Author.Dan Subject Sticky Note Date:10/9/2024 3:18:42 AM The ONR 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:10/9/2024 1256:43 AM Comment does not accuracy quote 2S5.5LS30(4)(bs I n2235o(4)(b)Gedograly hazardous tea been shall be staked on site prior to beginning arty daring,grading,or other land-disturbing esthetes.The adminktrator may waive this tequirtmsent d all development activities are outside of the geologically hazardous area butter. At the time of the report,no poem were prepared and eq(Wong planned.We assume that the papesad home wle be eighth of am geology hazard areas pm our,ecanmendaoon end as Illustrated on Figure 4 of the report If the Countywans the bugerand settees*s aaMed we can do that,but given that the proposed horse win be outside of the geology hazard area It seems to be unneueavry 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::04 AM There is no 1822550(6)(d). The comment appears to reference 18.22.530(6)(d). This is a stormwater issue and should be covered within the stormwater plan for the 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:10/9/2024 1:13:25 AM We did more than simply reference the Manual.The report states*Starnwafacdkcted horn structures built on the property should he ragweed continent with the Stormweter Management Manual for Western Washing ton.Soils on the property upland appear capable ofnadby accepting stamwater(ndleatetn.5torntwater should not be discharged onto or within appronanately 30 feet of the shoreMne bluff slope' Number 6 Author.Dan Subject Sticky Note Date:10/9/2024 1:29:03 AM The report is a geology hazard assessment of 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. Exhibit 7 Pane 1 A of 7R 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.ICC 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 on 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.;=Qtratum Group report does not contain well drillers logs of adjacent water wells in the area or available 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 sitfi and its critical area buffer if the proposal is implemented,as required by subsection(2)(h)above: 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 Exhibit 7 Pang 7(1 of 7R Page: 16 Number. Author:Dan Subject:Sticky Note Date:10/9/2024 154:33 AM The report noted no water seepage on the bluff slope and stated that"So+%ohs.md in raw o to on et*low.,upland were well d..Inod end coswete of accepting additional wait—input contributed by a septic system and sin rmweter runoff from the tome' The referenced groundwater resource report and nearby wel logs is not relevant to assessing the%horene bluff,shoreline proteins a geomophlc processes and slope stabAtty at this site. Number.2 Author:Dan Subject:Sticky Note Date:10/9/2024 15926 AM The report states*f uttnrrmae development within Unary,'Indicated on Figure 4wAi not mceeata he nth o'tondsbdet Or frown.h a OM the ute ss lase Al the retomrseedationt of this report are*Mowed We also%filed that'Sat on thepro✓;erty upland appear capante of readay acteptmq slomwatrr nhtnsuon Stamwate•should not be discharged onto..within We would becomtoetahle attenne a adding to these statements% hc, srimpact thegovaoy ottarowr.Nrx bat bettsr.e pea Ann, that the tFpt:::proposal and itamwatar dean wiK not alter ware.on the bluff a impact the gep(p9Y hyardpy%a,ea.out better c rha ettigtlaga and:Torments In the CauWtwn(eve,r}t(yli Exhibit 7 Panes 71 of 7R Sincerely, t David S. Parks,M.S. Principal Geologist LG,LEG,LHG#533 Crescent Environmental PLLC 424 East First Street,Box 429 Port Angeles WA 98362 Cell:360-640-3187 Email:crescentenvironmental@gmaii.com Website:https:JJcrescentenvironmen.wixsite.comJwebsite 5 Exhibit 7 Panp 77 of 7R 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 S 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://geologyportal.dnr.wa.gov 6 Exhibit 7 Parrs 71 of 7R 4 i -- , ,.,,. :.: is 1 °! n:::. .E. x - ` .. fi y ,lase '\ _ Oh . :7-,:r47:.-,.1,-,cor- --..zerIr —' 1 Mii�.��.` - ors Ate,,' AL h ., '°" Jefferson County,WA wry p.4�. ~ a.�' Bealk 1'1,N6 oar t:r r�o`` w.�.�..lase...sa+�.w a•.....:-..Hula.....•..,u.... .... Figure 1:Map from Jefferson County GIS Portal showing parcel 701164005 subject to this review(Yellow Highlight). 7 Exhibit 7 Panes 7d of 7R -_,^��`'�- "'ems- 'ky,• :`- ti ' { . . a L • d} �• om, T' *4 �} .. . �, +4 wt_y_ ,-' • t s.+.K Photo 1: 1977 Oblique Aerial Photo(WDOE,2024). 8 Exhibit 7 Panes 7ci of 9R F 487.0. Photo 2: 1994 Oblique Aerial Photo(WDOE, 2024). 9 Exhibit 7 Pane 9R of 7R 6!23,203 'CI 15 IV • • s p6 v Photo 3:2006 Oblique Aerial Photo(WDOE,2024). 10 Exhibit 7 Pane 77 of 7R 7/2.M201611.78 AM A'' . 'a•441.: `' ' ," .r++Y.,w.it • , 0 - a > " ?"•; Try .Y.+ _\ j' At Photo 4:2016 Oblique Aerial Photograph(WDOE,2024). 11 Exhibit 7 Pane 751 of 71:1 EXHIBIT K Exhibit 8 Donna Frostholm Page 1 of 66 From: Richard Rathvon <rich@rathvonconsulting.com> Sent: Thursday,January 30, 2025 5:55 AM To: Donna Frostholm Cc: rrathvon@gmail.com; 'Terry McHugh' Subject: Email 1 of 3 Attachments: JC_DCD reply_25_01_final.docx;Attachment A.pdf, Easement referenced in Dabob View Tracts_Attachment B.pdf; SU VS PG 165_Dabob Tracts_Attachment C.pdf;Attachment D.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, I am providing our response to your November request in 3 separate emails due to the size of the 6 attachments. Please let me know if you have any questions or require further information. Thank you. Regards, Rich i Exhibit 8 Page 2 of 66 Proprietary and confidential Exhibit 8 Page 3 of 66 Responses to questions and issues raised in email dated November 5, 2024 1. Question/ Issue 1: A number of the comments DCD received pertained to concerns about Twana Way. The proposal submitted to DCD did not include alteration or expansion of the primitive road nor was there any indication that vegetation would need to be cleared or limbed for heavy equipment to access your parcel. It is my understanding from our meeting a few weeks ago that you are not proposing any improvements or vegetation clearing/trimming. Since then, I have discussed your proposal with building division and it is their understanding that your contractor is expecting to improve the road. Clarify if road improvements or vegetation/trimming is proposed. Answer: a. We are not proposing to alter or expand the road, including "cut and fill" activities or removal of trees. However, road maintenance may be required during and/or after the construction process due to the use of the road by construction vehicles. By way of background, we have easement rights to use Twana Way for ingress and egress generally. in addition, we have specific easement rights pursuant to at least two recorded easements, which includes the authority to upkeep and maintain the road, as follows: (i) Easement 203763 recorded on January 19, 1970, provides a 30-foot-wide easement, and all permitted easement users "agree to share in the upkeep and maintenance of the road. . ."; and(ii) Easement 278885 recorded on July 24, 1982, provides a 60-foot-wide easement for ingress and egress, together with the right to install, maintain and repair the roadway. See: (i)Attachment A—Easement 203763 (initial easement prior to the recording of the Dabob View Tracts survey); (ii)Attachment B—Easement 203763 (easement accompanying the recording of the Dabob View Tracts survey; and(iii)Attachment C— Recorded survey relating to Easement 203763(the Dabob View Tracts survey). Additionally, any maintenance activities undertaken would not be inconsistent with prior maintenance activities, which has been performed by: (i)Glomset(see comments relating to our permit where he stated "I have been working on Twana Way for over 40 years (fixing the road)") (see Attachment D); (ii) other owners in the past, including Hawley and Walker;and(iii) Oliver during 2023 (filling in the severely worn-down grade with rock and gravel on the landward side of the sharp corner just past their driveway). Proprietary and confidential Exhibit 8 Page 4 of 66 Finally, we do not believe that such road maintenance activities would be inconsistent with JCC rules. We are not proposing to engage in clearing of vegetation along the road, including the removal of trees. However, if limbs prevent the safe passage of vehicles, we intend to remove only those limbs that impede safe passage. While we are not presently aware of any such limbs, this necessary and limited activity is permitted under the maintenance rights referenced in the Easements noted above. Additionally, we do not believe that such limited trimming activities would be inconsistent with JCC rules. 2. Question/Issue 2: It is assumed that all materials to construct the house and install the septic system will be trucked to the property and that no building materials will be transported by barge. Confirm that this is correct. Answer: We are not intending or proposing to barge building materials to the site. 3. Question/Issue 3: The Geologic Hazard Assessment prepared by Stratum Group was reviewed by Crescent Environmental (Crescent). Stratum Group responded to comments from Crescent, which you then forwarded on to me. Additional information is needed to show compliance with Jefferson County Code (JCC) requirements and to fully address comments from Crescent. Submit a revised geotechnical report or an addendum to the existing report that is consistent with report requirements in JCC 18.22.905(2) and 18.22.945. This would include, but is not limited to, the following: a. Incorporate existing sources of information (such as documents, maps, photos) that were reviewed and considered to evaluate geologically hazardous areas for your parcel; b. Address the slope failure shown in the Ecology oblique photos in the report; c. Discuss methods used to assess the rate of regression and tsunami hazard in more detail; d. Revise Figure 4 to include the extent of the geologically hazardous areas and buffers on the property so it is clear if the suitable building area is within a geologically hazardous area or a buffer. Answer:See Attachment E. 2 Proprietary and confidential Exhibit 8 Page 5 of 66 4. Question/ Issue 4:JCC 18.25.270(3) and 1CC 18.25.590(3) require a cumulative impact assessment. Submit an addendum to the Peninsula Environmental report that addresses cumulative impacts. Answer:See Attachment F. 3 Exhibit 8 Page 6 of 66 Exhibit 8 Page 7 of 66 Attachment A r :, •, aka • ln�'4 ,. JAN 141 670 I tee... it( �YUI X 7210 ACRW .NT wade end *stared tate this 3ttday of 3 December. 1161, by and between Darold Pederson and !Why h. di tiludsbasisN, husband and vita, Welter A. Pederson and Janet hider . , 'husband and wife, and WWII R. bey and Edith Day, husband mad - d wiG, hereinafter known as the party of the first part. add 1 • Marie Me:7asan, a sridav, hereinafter known as party of the eeooad • 81 . nett. D The first pert!.e are the owners of the following described i 10 Seel estate. to-vitl . . 21, The feat halt of the Southwest quarter el Santee if. . 121 township 27 North, Samos 1 beet. M.R., Jefferson County. 151 The SS OOd party is the owner eft 14 The Worthweet quarter of the Southwest quarter of 15 said section 131 . 16 mach hasty is deaiooa. of .enuring an easement over end ' 17 across the land of the other party as hereinafter sat forth , .sad f =e Is cosaidaratias of smelt party granting to the other respective 19 easements. the parties grant as follows i • m !arty of tie tint part hereby grants to party of the second Si part an sasanast for road purposes by this soot feasib . soot. to 112 eomaset with saluting road which rums is a general Northerly end • • 13 Southerly direction scroes the east ball of the southwest 24) quarter of said section, also as easement to use the existing 25 • reed. Rd Party of the second Part grants unto party of the first•partt 27 as sussent for road purposes over and scroee the northwest quart r 88 of the southwest quarter of said secretes, following the glsasaal Se amts. of an existing road. " SO I The road easements herein granted are thirty (io) teat La . al width. and permanent and perpetual. . 32 She road easements herein granted will be used loistly by tu MUM.VdTAT+< Q••..� `.SUMP„'IMP SALA TAX f► 1 be, i6!:.bI CO TY 'T! .gat/%kit easy wession. penis 19. 1970 - - Exhibit 8 . Page 8 of 66 • t 1 both the party of the first part and party of the second part, 2 and will connect with each other. 3 All parties waking use of the easement agree to share in the 4 Upkeep end maintenance of the road In r p oportion to their one it thereof. t 1 6 Moth grantors and grantees, their anocesuora and assigns • 7 reserve the right to use the said road, 11ND tenements for Magmas 8 and egress to all such properties ae may be owned by the M p respective parties in either Section 15 er 12, Township 27 North, 1 10 Lange 1, West M.K., Jefferson County, Washington. 11 ZN WITNESS MHERZOt, the parties hereto have hereunto • M.12 affixed their signaturesthia _2. day of December, 1l6f. 13 27;7_...t...Z.,_........,I(/s.-J--,-,-.--.r—,----/ 15 le �� 17 • 18 0-0 10 10 21 \ 22 941-11..j. 6::;:;:eli,.....a..cc- L 23 1 24 rim-;,,, ` 1iR il ei4:re g X °> 25 26 27 3 2A 8 rough.. plat of the granted easements, pot drawn to scale, 20 is attached to show the general course of the respective easements herein conveyed. 30 31 32 Siawaawalla. I I tr+...e,Al u• I.eaves Irmo', ' Pe'�M1�.n.ea �--- .. .I 16 . 612 er—.re. Dec. 19, 197C`' - — . CO (.0 - O X 0) W c cm co 0_ • • t7-:•,.r.:••,..`.•• ...•.• :.t..'4..•.-:2 t1•• ••'••":i,ti•.it«• ri. ;x•.: • I!�`ti••Ir.;.1z'' �• �°"t:..� `1�..�••�• .y• yj�y'•::.f 1:t• ! `.tli•;� L•�..(' . • I • .. • [►' • • ..f�•• �t.}r ' • !•fir �R I Ir�� +. ti ••ut +..• - • ,. , • •• - : ^ • • 11441VT • • t� t • i : .• •. r - i11•7 • •• Y „ • • - CC I ••. • 4 _ .S t_ _ _ .•.� 7 %,. - — Cr • • ,▪ ,,• '�, • , • • , .— 1� .a ��I :� . • • ea t • if aim y+`.i , RV le .• • • • 4- w # r • • • % w • • In • • Z ` �' I • - �,r At • c < < � I t•ly a • NI j * • t • (ill e i • .� Exhibit 8 Page 10 of 66 Attachment B Exhibit 8 r, Page 11 of 66 .. .-•. .... tL6.Y • 2 Ar tyMi 3 . CS '-.• •'?, o.,,.I ,,,,.1AO/ Z:SSS54rti, . DNcs k IOU OP lassassN O TN IS DZCLARA?ION OP SAININIXT magi 2 �t- day of 1f II-, by NAROLD T a )CAROL ST111101, his rife. MITNNSOSTN, 1NNRNAS, the above mentio individwls are owners of the following described property, tow �'''.-.2 Government Lot 1, Sec g4i�15 T nehip 27 North, Waage 1 West, N. \)( 1 Situate in the Cor'bf�Jeff'erson, State of Washington; \ /� > NNNRNAS, the Owner fei�fntand to sell portions of said Government Lot 1 tp.,difl4rent-patties and have them share a common easements tlo{ pur ios of ingress, egress and utilities: and Owners also `intend to `benefit appurtenant lands, � NOW Tanaran4i the &Ours do hereby declare and impose the following eaitelent\ 1. Ag “1-' 17;iii for ingress, egress and utilities over under, acroksl\nnd ough, together with the right to install, maintain "rspai-t both the roadways and utilities, 60 feet in width, lity.iiileet on each side of the following described �. er .,s lying in said Government Lot 1, Section 15, Township 2` rt Ridge 1 West, M.N., Jefferson County, Washington, the -cente�ne6 of which are described as follows, to wit, . sage l of 3 16A .::272 idyl 24.1 Exhibit 8 Page 12 of 66 Beginning at the West 1/4 corner of Section 15, Township 27 North, Range 1 West, Willamette Meridian (from which the Northwest corner of said Section 15 lies a distance of 2640.00 feet, North thereof); thence, South 89°-40'-30' East along the East-West Centerline of said Section 15, a distance of 1334.39 feet to the Northeaab corner of said Government Lot 1; thence South 0 -12'-56' \ West, along the Easterly limits of said Govern- ----4 sent Lot 1, a distance of 1240.63 feet, ho the TEOE POINT OF BEGINNING; thence North 68 -2A'-53 West, a distance of 117.76 feet to a Point here- inbfter referred to as Point 'A'; thence North 21 -31.-08' Eagt, a distance of 219.29 feet; `1 thence North 0 -12'-5g' East, a distance of 44.4l� feet; thence North 89 -55'-56' Kest, a distaff of 138.84 feet; thence North 11 -36'-58,' s a�/ ; distance of 296.68 feet; thence South 42o-3 ' 44' West, a distance of 118.52 feet; thence\S h 73 -46'-56' Wes , a distance of. 195.14 ._feet thence North 45 -00'-08' WBst, a distance- f 13.31 feet; thence North 1 -25'-57' EASE, a dis- tance of 162.58 feet to a Point hereinagter re- ferred to as Point '8'; thence South 56 -46'-11' Meet, a distance of 278.42 feet; thence South 26 -24'-44' West, a distance of 302.07 feet; thence North 28 -34'-28' West, a distance of 104.88 feet to a Point ,heteinafter referred to as W 8 Point 'C'; thence Nort9 =41'-34' West a distance of 160.19 feet; thence`Nortb 526-48'-28' West, a distance of 193.22 feet; thence North, a distance of 28.66 feet.; ,thence North 18°-57'-52' East, a distance of 132.99 feat to a Point here- ingfter referred to ea .Point '0'; thence North 46 -54'-23' West, a distance of 73.33 feet, to a Point on the Westerly limits of said Government Lot 1, (being a distance of 580.10 feet South of the West 1/4 corner of said Section 15) and terminus of this described centerline. Also; beginning at -Poi o 'B' as hereinabove de- scribed; not �'E -46'-42' Nest, a distance of tat, to_a Point hereinafter referred to as l4 int •R d.the terminus of this center- line. �° 2. ini;sarMeilr ingress, egress and utilities, over, under, across and. !oygh, together with the right to install, maintain aid epai both the roadway and utilities, being 20 feet in width, /ge fg eet on each side of the following described ) centerl,ltse,�Dy- in said Government Lot 1, Section 15, Township 27 No Far)"i`l i11 Nest, W.K., Jefferson County, Washington, the to\ne>!\pl which are described as follows, to wit: **ginning at Pont 'A' as hereinabove described; t1i1 thence North 68 -25'-19' West, a distance of i 57.73 feet to the terminus of this described i \_____/centerline. Also, beginning at Point 'B' as hereinabove described; thence North 63 -4L'-20' East, a distance of 127.40 feet to the terminus of this described centerline. Page 2 of 3 vs: 164 -4,273 Jun 24,___ _..- _ . _ - 1 - . _ ,- .. •,^SF+-'7D1.11; qw.nT'1T7►'*Rq"Afi•7!•i.t. ..i.....•e.oi• ..•.ram:'?c1T Exhibit 8 Page 13 of 66 Also; beginning at Point 'E' as hereinabove described; thence North 8°-46'-42' Mast a distance of 88.19 feet; thence North 15b-22'-55' West, a distance of 161.83 feet; thence North, a distance of 77.80 feet; thence South 89°-40'-30' East, a distance of 74.10 feet; thence South 49 -06'-53' East, a distance of 253.72 feet; thence North 78 -47'-14' Easb, a distance of 229.12 feet; thence North 52 -31'-47' East, a distance of 180.75 feet; thence South 79 -08'-17' West, a distance of 142.34 feet to the terminus -. of this described centerline. Beginning at Point 'B' as hereinabove desaiibe thence North 88 -34'-01' Wget, a distances 40.00 feet; thence South 1 -25'-57' Weayi • distance of 179.74 feet; thence South 1 0 _ last, a distance of 59.01 feet, to the le a of this described centerline. 3. An Easement for walkway purposes only,bing 10 feet in width, lying in said Government Lot ,,Section Township 27 Worth, Range 1 West, Willamette nei ,1 rl Jefferson County, Washington, the centerline of which i descried as followe, to wits �i Beginning at Point 'C' as herei bode described; '? thence South 66 -10'-49' Nest, a distance of 234.20 feet, thence South 62 -33'-26' West, a distance of 1.0.70 feet, to a point lying 5 feet East of the Westerly limits of said Government Lot 1; thence South, a-long.said line lying 5 feet Easterly of said Westerly limits and parallel to the said Westerly limi said Government Lot k 1, a distance of 170 tLpore or less to the last Shore of Dabob ay. ,' 4. All of the hezallllabov described Easements are as graphically depicted on74,44, recorded under Auditor's Fee Busier , at Volume of surveys Page • 1 This declaration of\easement and all rights of way hereby created and decla au11 be appurtenant to and run with said i Government Lot J. \ 3 1 IH WITNESS the parties have executed this d instrument the daand ear first above written. TaxJ �� ►,o,, fold Steinke Carol Steinke i ♦p 011 t f t``.. ,I S!!4't of-W1165INGTON iO14-; s i----- ii0dpr y- .;34P SON • N' l„ __-_ • . �Tb. 1i•�•ia o certify that on this � day of ..% Ceonally appeared before me Harold Steinke and Carol, ` R inik44,\his wife, to me known to be the individuals described in and rtilp executed the within and foregoing instrument, and ac- k Owledged that they signed the same as their free and voluntary a deed, for the uses and purposes therein mentioned. 4i EN under my hand an official seal this /24' day of . 19t . / 4j ;/�i_ /'it<.i t/i.�. l Notary Public in a of h State of i Washington, residin E ,i,' .77/.�,, i i. Page 3 of 3 V0i 164 ..'74 } J�n 24,19S2 —— — Exhibit 8 Page 14 of 66 Exhibit 8 Pape 15 of 66 Attachment C RECORD OF SURVEY 14C/MTY MAP k,OF GOVERNMENT LOT I, SECT/ON/5,T 27 N,R I WEST W M;JEFFERSON CO, WA. 4 ,___, o 'i• l'' 1\1 I -----, :\ N i Dnbob vQw ..\„., ), . , •-•,.•‘,Is \ '• ,i •, ,I 't. • .'' Ar-- . /-- ri MOOD CANA L Tracts ... 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I,•I akar...a 7;r1"i I.. 7......... : 1,1 liNV,1 k MOM 46.• I r.../..:: 1,,k.I...%.•4 i...re-cr.lor ,-4---—7 • fpod i ,,,:, A"a ,,...---'""-Afr-----'.......„ ..." 01 ke.........MOM . r .....••'. . . t si .......t......... ,. — Ar$1111 %0 , .t.'N.\.........-^.wo i •L.,k. , .0 i • • , •-: .4,..4. 4. ...........-- -7.: \ \it--- • ,----- , 1 •;' 4.1 , ..x•V` 'e /. ?' yes,' • ar 1 , -0, I N * Ne-___ -\\•2-/i.<°°:// 41/ 1 It ACCW FASCAIWOrT 1,.., : s.,.... r........_, , .st/ V •.;, : wet,,f,R Om THAL PR 1 4 N. ....-x-----. it. \ I/ ROO"CEA°ZO-11415 . ',.. ,..• 2 " -/.• ,,i, ct. , ••s 1'.. •••z.;'Ivy 2 --"."...ef #i \ \, + -,„,. 1 ; aua PEE NO,.0 ZAPAE "... :th ft — RECORDS Or rEFFERSOW,O2 ,... ...-''' ....;:0_,V15°.. I t . il ,!--.. ..-.- i • / s.1, ...„ „... TRACT 5 ! TRACT 6 z //9. y • 1 SOe A 5/3 A 4 .., , Ii6; 4 I 11 I t. ,.... . ..c";_;:n.- A.. .,. . -.-..,..., . "'•*,,...":111 . „( I. •1... ••••• •.:OL•••,::,. ..."6.',„., "Ir.: • • 1#. :•••••:., 4. 4•T 14'), e ..,. •;.,.... .,, . k:D '''.•••••-i _e.44 J51 3/0 o 41" ij4.y V 8,9• 50-/S- //2521 1s- .'-' 4 .. .." ..*" I ... ".• '...;" .. •"k..•:'' Q-)N A/LVTOR'S CERT/F/C.4TE SURVEYOR'S CER77F/CATE .4i,urvay Mt=Pm AlCCE. 7r3....11a4CA.1 '4,444.0d....__. .-4. ,...i.q !. --5: :0/1/IECILTIVIIIESVIrtz a Su ref WI SI la cot MCI Ptf 011111CT:011 71 7 1*SURI/In a?AI:Wore 74* :, k.:' '' ' .1%.,::., -, alleC/DRIXT 11T14 71111 111..71/11211DITS assIc iritQ 5 Tn MUTT IISCCM1kG I,C.r/a'II!=NWT Q .1,1a.Wool P••••UV ; •4 2"X S.- IN WWI D STETWE • ,','• k•., ‘.. WM t 01001,11.04.. ...M.. ni..M firtG• Se5.0453 NMI 6111-1.1113 -:?:411.4.0.tt...4 i , ''' .10i'YrAt.'.-.4-A.'' '..‘; '.. . .. . Exhibit 8 Page 16 of 66 Exhibit 8 Page 17 of 66 Attachment D P e r ry►r`f- ( / 15 /20 z dP - o23 -' 000217 14 I PI Y AJ'4/"E is AJILS 6Lo SE r o e ,e.° g rY Ahrx r wa1 rL . 21Gti R/-0 3 ege-0 Po Spa ,4 r- C O 7j ,4-,cJ ift t c2- t Q u I L cF•vz_ cis 3 �6- -Z' •¢ 1,0 v2.4.e. I1E40 fif do v T � T / S 44i o /S s vs c ee Tr L-e To SL/tP-S /l"vE 0eeyti ki012/ 7 C. 0/-I Teti ,elti'9 w , Lr °iQ O (1_ y� yew F/dc f/t f /4-0) w A1---tf/A1E/1.- C 0 tJ 1-4 (2-o 46, RE'CEiIVED SEP 2 5 2G11 Jefferson County Al /C S Community Development e •+, •frt( N 9 /e Sef 6fr 6 ni' Exhibit 8 Page 18 of 66 Exhibit 8 Page 19 of 66 Attachment E .G� STRATUM GROUP PO Box 2546,Bellingham,Washington 98227 Phone:(360)714-9409 November 14, 2024 Richard Rathvon 20 Liberty Knoll Colts Neck, NJ 07722 rrathvon@gmail.com Re: Geologic Hazard Assessment Update 660 Twana Way Jefferson County Parcel 701 164005 Quilcene, WA 98376 This geologic hazard assessment is an update of our previous geology hazard assessment report dated February 15, 2022. Jefferson County has requested additional information based on comments they received per the email below in italics. The additional information that is applicable to the geology hazard assessment and our recommendations are incorporated into this updated report. Summary of response to County Request The County request is present in italics below and our summarized response follows and then is incorporated into the report. 3. The Geologic Hazard Assessment prepared by Stratum Group was reviewed by Crescent Environmental (Crescent). Stratum Group responded to comments from Crescent, which you then forwarded on to me. Additional information is needed to show compliance with Jefferson County Code (JCC) requirements and to fully address comments from Crescent. Submit a revised geotechnical report or an addendum to the existing report that is consistent with report requirements in JCC 18.22.905(2) and 18.22.945. This would include, but is not limited to, the following: a. Incorporate existing sources of information (such as documents, maps,photos) that were reviewed and considered to evaluate geologically hazardous areas for your parcel,; This updated report includes the Washington State Department of Ecology oblique aerial photographs dating back to 1977 and aerial photographs dating back to the 1940s. Stratum Group Project: 1.31.22 Exhibit 8 November 14,2022 Page 20 of 66 Jefferson County Parcel 701164005 Geologic Hazard Assessment Crescent indicated that we should have included in our evaluation NTI reports done on "relatively nearby properties"and the groundwater study of eastern Jefferson County. The two NTI reports are not near the site and are located in areas with markedly different geology and shoreline conditions. There is no relevant information regarding the site slope stability or geology processes in Grimstad and Carson (1981). It has been our experience that doing our own assessment of site soils is a much more appropriate way to assess soil conditions on a given site than simply relying on the USDA soils maps. That said, our finding that the soils are well drained is consistent with the soil map and we have added that to the soil description. b. Address the slope failure shown in the Ecology oblique photos in the report; We provide a more detailed description of the area on the north portion of the bluff slope that has no trees.This location is an old erosion location and is as we noted in our report a site of soil ravel. This feature appears at least as far back as 1977 and may be older per the lower resolution photographs from the 1940s and 1950s. c. Discuss methods used to assess the rate of regression and tsunami hazard in more detail; A detailed analysis of the shoreline bluff retreat history and shoreline processes was utilized to estimate the past long term shoreline bluff retreat as being less than one inch per year and was included in the report.Contrary to the Crescent comment, we did not measure the bluff retreat rate. The value we estimated is based on the evidence that we presented. Likewise our estimated future long term shoreline bluff retreat of 2 inches per year is based on including a consideration of relative sea level rise resulting in an increase of erosion and also considers the shoreline processes along the entire shore reach. Crescent ignored the evidence and rationale we presented and the comment was not applicable to our estimate. That said, we modified the language in the report in hopes of clarifying our rationale for our estimated top of bluff retreat. Regarding tsunami hazard, our assessment of the risk of the site being impacted by a tsunami has not been changed, but we will included the Washington State Geologic Survey maps of tsunami inundation in the area for the Cascadia Fault and the Seattle Fault and we added some further discussion regarding the Dabob Bay Fault which has no tsunami modeling and the potential wave risk from large landslides. In all cases, it is our opinion that the tsunami waves or landslide generated waves do not pose a risk to the proposed building area. • ago (sT�;;$G*ou. 2 Project: 1.31.22 Exhibit 8 November 14,2022 Page 21 of 66 Jefferson County Parcel 701164005 Geologic Hazard Assessment d. Revise Figure 4 to include the extent of the geologically hazardous areas and buffers on the property so it is clear if the suitable building area is within a geologically hazardous area or a buffer. We made a new Figure, Figure 4, to clarify the area of the property that is outside of any potential landslide or shoreline bluff retreat area or buffer. Introduction This geologic hazard evaluation was conducted to assess the risk of landslide and erosion hazards at 660 Twana Way to determine the feasibility and appropriate locations for the construction of a new home and septic system on the property. The Jefferson County Public Land Records landslide hazard map indicates that part of the subject property is located in a moderate landslide hazard area and part of the property is located in a high landslide hazard area. The shoreline stability map indicates that part of the subject property has unstable slopes and an unstable recent slide is mapped as extending onto the north portion of the shoreline bluff on the property. The shoreline area of the property is mapped as an erosion hazard area and the lower portions of the property are mapped as a potential seismic hazard area. Based on our geologic hazard assessment, construction of a home and septic system can be located on the site outside of any landslide hazards or shoreline bluff retreat from erosion for the next 100 years as long as the home and septic system are located at least 30 feet from the top edge of the shoreline bluff. Furthermore, such construction will not increase the risk of landslides or erosion on or off the subject property as long as the recommendations in this report are followed. This geologic hazard assessment included a field inspection of the subject property and vicinity including the shoreline area and slopes on and in the vicinity of the site. The evaluation also included review of available geologic mapping, historical aerial photographs, historical land surveys, lidar(light detecting and ranging) imagery, and our own notes, photographs, and observations made in the vicinity of the site and at locations with similar geologic conditions. GENERAL GEOLOGY The Geologic Map of the Quilcene 7.5 Minute Quadrangle, Jefferson County, Washington (Contreras and others, 2014) indicates that subject property is underlain primarily by Whidbey Formation sediments with the lower western third of the property mapped as being underlain by Vashon ice contact deposits, which mantle older glacial and non-glacial formations such as the Whidbey Formation in the area(Figure 1). The map also indicates Double Bluff drift glacial deposits may be present at exposures at the southwest corner of the property. Landslides and landslide scarps are indicated just to the south of the subject property. �A;» (- 3 Project: 1.31.22 Exhibit 8 November 14,2022 Page 22 of 66 Jefferson County Parcel 701164005 Geologic Hazard Assessment rc. Q Subject propert} Cgic Qgdp • , Qgdd • { )01C: yi * # jy Figure 1.Clipped and annotated geologic map showing the subject property.Qb—beach deposits,Qaf=alluvial fan,Qgic=ice contact deposits,Qcw=Whidbey Formation,Qgdp=Possession glacial rift,Qc.,,=Olympia non- glacial deposits,Qgdd=Double Bluff glacial drift,Qc=Pre-Fraser non-glacial deposits,Qls=landslide.Hachures are landslide scarps.Heavy dotted line with query is a surmised potential fault. The Whidbey Formation is a non-glacial deposit that is between 125,000 and 80,000 years old. The Whidbey Formation in the vicinity of the property consists predominantly of sand but also includes units of silt and clay. The formation is dense and hard having been overridden by glacial ice over two separate glacial periods. The Vashon ice contact deposits(Qgic)are a mix of poorly sorted sediments deposited directly by glacial ice during the late stages of the last glacial period between about 14,000 years ago. Contreras and others(2014)mapped the unit where deposits appeared to be associated with ice wasting and the surface area of the deposits lacked streamlines associated with ice movement. The Double Bluff drift(Qgdd)consists of sediment deposited during a glacial period that is estimated to have taken place between 190,000 and 125,000 years ago. This formation represents a glacial period;that occurred three ice ages ago. The basis of the interpretation is from age estimates and map relationships in the larger vicinity than shown on the map;however, this area is geologically complex due to the presence of a fault zone and local offsets and folding. *tumult cum. Project: 1.31.22 Exhibit 8 November 14,2022 Page 23 of 66 Jefferson County Parcel 701164005 Geologic Hazard Assessment Our observations are generally consistent with the above-described mapping. Soils observed on the property upland and exposed along the shoreline bluff primarily consist of very dense, stratified, sand and gravel with lesser silt lenses(Figure 2). These dense deposits are commonly overlain by a surficial cap of medium dense, poorly sorted, and unstratified, sand, silt, and gravel interpreted to represent as ice contact deposits(Figure 3). A very dense, poorly sorted, and unstratified sand, silt, and gravel unit exposed at the base of the shoreline bluff on the subject property and to the south is consistent with Contreras and others(2014) interpretation of the unit being the Double Bluff drift mapped in the vicinity(Figure 2). ��.. ;; .� a 4 ouhle Bluff g _ 11 ` '. 4*1 Figure 2.Whidbey Formation sand and gravel with Double Bluff drift at the base of the bluff a few hundred feet south of the subject property. [sTRAT GROui. 5 VM Project: 1.31.22 Exhibit 8 November 14,2022 Page 24 of 66 Jefferson County Parcel 701164005 Geologic Hazard Assessment • 't. 3 r A+ 4 ' ,.....a`..{ C'. . : ,•ar, ,a. T -tr4F, a ." 17 ,• -' 1 may_: • •7 •( ... 4 • ^.K� / .,-' -.tom+ ,s' `\ ;�4a A . • y. .y } a Ale• • �i r,�* 1, i t j%..• ,y- J w,. .4 1- ,r.' " �, te .. .. •- - %' ,e, , .. J • •.mac;' _. :4C". e - - , , - m ,r s.�►.. �' '.'", I.igure 3.Medium dense, poorly ,,nrted sediment c<>n,,i tent v.oh \ash,+n iLe contact deposits on the site upland. 'STRATUM GROUP 6 Project 1.11.22 Exhibit 8 November 14,2022 Page 25 of 66 Jefferson County Parcel 701164005 Geologic Hazard Assessment SITE SPECIFIC OBSERVATIONS An annotated lidar hillshade image of the subject property and vicinity is provided in Figure 4. The property is accessed by Twana Way, agravel/dirt road, which crosses through the subject property from the southeast corner to the northwestern portion of the property, { NIL 701199.n1 ,. .a� � l Figure 4.Annotated lidar hillshade map of the subject property showing key site features.Potential building area outside of any landslide ar erosion hazards is outlined with green dashed line. The west edge of the property consists of a shoreline bluff(Figure 5). The bluff is nonexistent to very low at the northwest earner of the property where the bluff descends down to an accretion shore area and steadily rises to the south before dipping down somewhat near the southwest corner where the bluff intersects a valley. The bluff at the property is approximately 40 feet high at its maximum height. The bluff face slopes at approximately !0 degrees on the low, north end and slopes up to approximately 30 degrees toward the south end of the bluff. The bluff is underlain by primarily by compact sand and gravel consistent with pre glacial alluvial sediment but the lower part of the southern portion of the bluff is underlain by very hard, poorly sorted silt with sand, gravel and cobbles that is consistent with glacial till. T`he bluff face is vegetated primarily with Douglas fir trees with an understory of mostly grass with same other shrubs. Limited portions afthe bluff are brush and grass covered. We observed no concentration of hydrophilic vegetation or evidence of springs or groundwater seeps on the bluff face. - t, 7 (SrrtATYN GROUP Project: 1.31.22 Exhibit 8 November 14,2022 Page 26 of 66 Jefferson County Parcel 701 164005 Geologic Hazard Assessment ,r , "''ters0 ` ` :e ' 3 d" et ' till at Hard glacialp r s k base ofslope W t s µ .. Figure 5.View of the beach and shoreline bluff on the subject property,looking northwest. The beach at the base of the bluff is a gravel and sand beach. Minor past erosion of the toe of the bluff is evident at or very near the southwest corner of the property where the very hard, likely Double Bluff, glacial drift deposits are exposed at the base of the bluff(see Figure 5 above). The upper part of the beach consists of sand and gravel with driftwood. It appears that water did reach the base of the bluff recently, likely during the recent high tide/storm surge event on January I I, 2022. However, no significant erosion was evident and it appears that erosion occurs on an infrequent basis. A grass-covered accretion beach fronts the northwest end of the property and extends as a long shoreline spit for over a mile to the north of the subject property. No erosion was evident on the accretion shore area and water did not reach the slope area fronted by the accretion shore reach. 'STRATUM GROUT 8 Project: 1.31.22 Exhibit 8 November 14,2022 Page 27 of 66 Jefferson County Parcel 701164005 Geologic Hazard Assessment The shoreline at the property is located in a transition zone between areas of bluff erosion (feeder bluffs)south of the subject property and shoreline accretion to the north. These observations are consistent with shoreline type designations on the Washington Coastal Atlas(Figure 6)and Jefferson County Public Land. Records(Coastal Geolo is Services, 2015 . mEON oas v Feeder du(e+rardanat reads*W[ Ttempxi Feeder bluff-Taut Aaaeaan shationa Pocket bean Pods beads-aniva No apansgMe drat Milo* at Figure 6.Coastal landforms map from the Coastal Atlas. The upland area above the shoreline bluff slopes up at approximately 10 degrees or less (Figure 7). This gentle slope area is located between two valleys (see Figure 4.). No water was present in the bottom of the northern valley on the property and the valley area is underlain by well drained sand. The valley on the south is on and/or just south of the property line. There is indication of periodic water flow in this valley, but no water was present at the time of our site visit on February I, 2022. These valleys appear to be primarily remnant erosional features that formed at the end of the last glacial period when erosion rates were very high on the bare landscape right after ice retreated from the area. a.r0< jS itAr PI GROUP 9 Project: 1.31.22 Exhibit 8 November 14,2022 Page 28 of 66 Jefferson County Parcel 701164005 Geologic Hazard Assessment ,• �l� A • , 1 ✓p i' T /YY'�'' 'l. . s t fit, fi, _ il 4 t z `-..— - x` iM.. t,�-. f ! • : 1 ! 1\' , Figure 7.Gentle slopes on the lower(western)upland of the subject property. The eastern portion of the property consists of a plunging ridge between two valleys(see Figure 4). The valley side slopes range between 15 and 35 degrees(Figure 8)up to the ridge line and ridge line plunges around 15 degrees to the west-southwest. The south sides of the ridgelines are steeper than the north sides. The Twana Way roadway and a driveway that descend from the road toward the shoreline are cut into the flanks of the slopes of the ridges, which on the steeper south sides of the ridges results in 2-to 4-foot high cut slopes above the road that reach 35 to 50 degrees in slope and 2-to 4-foot tall, 30-to 40-degree fill slopes below. , r r, e$TRA (Inoue — 10 Project: 1.31.22 Exhibit 8 November 14,2022 Page 29 of 66 Jefferson County Parcel 701164005 Geologic Hazard Assessment { ,. c6 k ♦ : R 1101$* '4.eilf .., ,. , . -.4. ,. 1.. . .4,00 .... w a v -- >> _- ' , / :/ r'.. w e 1 Figure 8.Moderate slopes descending from the south ridgeline on the eastern portion of the property upland. The upland area is forested with a mix of trees including Douglas fir, western red cedar, western hemlock and big leaf maple. The understory consists predominantly of sword fern and includes bracken fern, salal,evergreen huckleberry and other brush. ,STRATUM a104 + I Project: 1.31.22 Exhibit 8 November 14,2022 Page 30 of 66 Jefferson County Parcel 701164005 Geologic Hazard Assessment GEOLOGIC HAZARD ASSESSMENT The upland slope area between Twana Road and the shoreline bluff slope is gently sloping and is outside of any landslide or erosion hazard area. Soils observed in test pits on this lower upland were well drained and capable of accepting additional water input contributed by a septic system and stormwater runoff from the home. The soils are well drained and generally coarse grained and will not be subject to seismic induced liquefaction. The portion of the property outside of any landslide or erosion hazards areas is indicated on Figure 9. The slopes and shoreline bluffs and shoreline processes are described below to support our conclusions regarding the geology hazards at the site. ea outside of geologic hazard areas and buffer '_ t 7 v 4 Figure 9.Lidar bare earth image showing area outside of any landslide hazard area and buffer. Slopes on Eastern Portion of Site The slopes above Twana Road consist of two valleys with a ridge between. The ridge slopes and valley sides are moderate slopes and no indication of potential landslides is present. Some minor ravel of soil is present on the cut slopes associated with Twana Road. The steep headwall areas of these valleys appear to have had some shallow sliding in the past that sent slides part way down the valleys, but we interpret these landforms to be relict. The upper headwall areas of the north valley appear to be steep enough that shallow slides could take place, but the gradient of the valley, width of the valley and lack of water flow is such that we do not anticipate that shallow slides from the steep headwall of the valley would reach the subject property. STn Crum GRow Project: 1.31.22 Exhibit 8 November 14,2022 Page 31 of 66 Jefferson County Parcel 701164005 Geologic Hazard Assessment Shoreline Bluff Slope Stability The shoreline bluff at the site is underlain by dense alluvial sediments consisting primarily of dense sand and gravel consistent with Whidbey Formation with the lower portion of the bluff underlain by very hard silty glacial till consistent with Double Bluff Drift(see Figure 5). These bluff face sediments are capable of maintaining steep slope angles for long periods of time. The glacial drift is very hard and resistant to erosion. The steeper areas will be subject to ravel and shallow surface failures as the upper soil weathers or if the slope is undercut by erosion. Currently there is only minimal erosion at the base of the shoreline bluff at the very southwest corner of the site(Figure 10). t ,. - -- - r •44:4- !'fir.-ens; ,• ".�.<;' ". . � �,:_ .. Figure 10.View of shoreline bluff from the south.Note minor erosion at the base of the bluff exposing the very hard glacial till located at base of the bluff.To the north,left side of the picture,the shoreline changes to an accretion shore form with vegetation growing on the accretion area fronting the glacial till bluff slope. The Jefferson County shoreline stability map which is the same as the Washington Coastal Atlas indicates that there is an `unstable recent slide' at the property (Figure 11). We observed no evidence of recent sliding other than minor ravel on the shoreline bluff slope. There is steeper section of bluff on the northern portion of the bluff slope that lacks trees and has lacked trees since at least 1977 (see aerial image below)and possibly since the 1940s(see aerials below—the 1940s and 1951 images are lower resolution that the oblique aerials from Ecology). This small treeless slope may be why the map (which is from the 1970s) indicates a recent slide; however, there is no evidence of recent sliding at this location other than the aforementioned ravel and the extent of the area shown on the map is far larger than the very limited treeless area on the slope and includes upland areas that clearly have shown no slope movement. This treeless area is 'STRATUM GROUP 13 Project: 1.31.22 Exhibit 8 November 14,2022 Page 32 of 66 Jefferson County Parcel 701164005 Geologic Hazard Assessment above the accretion shore line area may have had erosion at the base of the bluff many decades ago when the accretion area did extend to the front the bluff at this location (accretion shores can shift)and the thin topsoil on the lower part of the bluff over very hard glacial till has not been able to support trees. We noted that trees and brush have become established on the accretion shore area fronting this small treeless bluff area, but also note that the accretion shore could be overtopped by very high tides combined with storm surge. The Jefferson County shoreline stability map indicates the bluff to the south of the property is `unstable old slide'; however, the bluffs to the south have multiple recent shallow failures and very active erosion at the base of the bluff is resulting in ongoing sliding (Figure 12). This bluff area is mapped as feeder bluff and feeder bluff exceptional by the Coastal Atlas consistent with our observations. . -._-".-. .s - 'v. qz'....: - •I WMCI.Ir..w UfiY/S .( I sp.a.do.u4As • I 1 CUM MAO... rEIAA Peed Zan.. M;. G.omva Maw tiaiw'1Kra s .f�w" _ v w. wwe.a.v. 1.1.41.13.00 WOG et 4r" ■tim... esr' Figure 11.Jefferson County Shoreline Stability Map • r.s 1s IST ATu«Gawp 14 Project: 1.31.22 Exhibit 8 Page 33 of 66 November 14,2022 Jefferson County Parcel 701164005 Geologic Hazard Assessment • 1. + ¢ _��,� ..fie. ,.lit* y .j ..:..k !' ., , 'em s .. T. ;et..-4--.0.: ,. yk ",xy 9 , f g,_ ,Y iti- , .i''',',,,,011:,..,„lit 24r, ,,._. „.., ,t,..„, . , .. fr_ s .. . .....„.. jpwM, vert' A -. , p r . O A 8 0 8 . . . 1940s(USACOE) 3 . 1951 (USGS) , 14 1 l' k SS TRAtJM GROUR` 15 Project: 1.31.22 Exhibit 8 November 14,2022 Page 34 of 66 Jefferson County Parcel 701164005 Geologic Hazard Assessment ( ' - ,,, , _ ., Mir 1977(Ecology) 1990(Ecology a.1t STRATUM GRouP4 I 1 f, Project: 1.31.22 Exhibit 8 November 14,2022 Page 35 of 66 Jefferson County Parcel 701164005 Geologic Hazard Assessment jai" t 2000(Ecology) - M1 .r0 ' 14 7.'. ..x } r . ; Afar 2006(Ecology) 1..., rreeruN Gam. 17 Project: 1.31.22 Exhibit 8 November 14,2022 Page 36 of 66 Jefferson County Parcel 701164005 Geologic Hazard Assessment 'rya • - f• AIy}Y � SI1 {1 yY •M J. 'AY • • 2016(Ecology) Beach Processes and Bluff Retreat The beach at the property is located towards the northern end of an approximately 10 mile long drift sector with sediment transported from south to north along the shore. Most of this drift sector is lined with fairly high feeder bluffs(Figure 12) and there is very little shoreline armoring that would reduce the sediment supply. Numerous very large landslides are located along the drift sector including a slide 0.4 miles to the south that covered the entire beach area lOs of feet deep with sediment over a distance of 550 feet in 1998, and there are multiple large areas of high bluffs of exposed glacial sediment that are eroding and raveling onto the beach feeding the beach. (SrnwruM G*ouv 18 Project: 1.31.22 Exhibit 8 November 14,2022 Page 37 of 66 Jefferson County Parcel 701164005 Geologic Hazard Assessment 1998 large landslide Figure 12.View of eroding bluffs south of property and large 1998 slide area 0.4 miles to the south. There is a slight change in shore orientation and openness to larger fetch along the shore area just to the south of the property. This is likely due to the presence of the very hard glacial till that is resistant to erosion at the base of the bluff at the subject property. The combination of the hard glacial till and the slight change in shore orientation is such that shoreline erosion at the subject property is very low relative to the shore areas to the south which do not have glacial till at the base of the slope and have a slightly more south oriented aspect. The shore form at the property transitions from a feeder bluff to the south to a transport zone (bluff backed beach on Jefferson County map)to an accretion zone on the north part of the shore at the site.There was no indication of recent erosion having taken place during the very high tide storm surge of January 11, 2022 along the base of the slope on the property. No erosion of the accretion area below the north portion of the site was observed and water did not reach the base of the slope on the northern portion of the site where the trail is located during the January 11, 2022 event. There has been no appreciable change in the location of the top edge of the shoreline bluff over the historic record based on our review or aerial photographs dating back to the 1940s. The specific location of the change over from transport zone to accretion may have shifted slightly in the past such that there have been periods where the bluff area now fronted by the accretion shore form was subject to periodic erosion as the southern edge of the accretion shore area may have shifted. Based on the beach conditions, shoreline bluff materials of very hard and dense glacial till, the very low erosion rate observed over the past 50 years in the oblique aerial imagery, and no change in the location of the top edge of the bluff over the historic aerial photographs record, we �SnuTur�GR ou 1 19 Project: 1.31.22 Exhibit 8 November 14,2022 Page 38 of 66 Jefferson County Parcel 701164005 Geologic Hazard Assessment estimate that the long term shoreline bluff retreat at the site has been less than I inch per year. While no top edge of bluff retreat is evident in the historic record, retreat of the top edge of the bluff should be expected eventually as an episodic event with many years (decades) where no retreat will take place at the top edge of the bluff. Over time the upper bluff will become undermined as erosion and ravel take place on the slopes below and shallow small scale slides should be expected to reach the top edge of the bluff. Consideration of Sea Level Rise While past shoreline bluff retreat has been very slow and we estimate that the long-term rate has likely been less than I inch per year, relative sea level rise projections for the year 2100 are estimated to be between 1.0 and 2.8 feet for the likely range of relative sea level rise under low to high green house gas levels(Miller et al., 2018). The increase in sea level will result in a greater frequency of high water reaching the base of the slope and hence an increase in erosion rate. However,the increase in erosion will take place along the entire shoreline drift sector and will be even more pronounced at the current feeder bluff areas to the south. The increased erosion to the south will add sediment to the beach fronting the subject property and thus will partially off set the sea level rise increase of erosion at the subject property as the entire shore reach and beach adjust to the change in sea level. Due to the change of seal level, we assume that there will be some increase in erosion rate and a corresponding change in bluff retreat. We estimate that the long term bluff rate accounting for sea level rise over the next 100 years will be 2 inches per year. This corresponds to top of bluff retreat of 8.3 feet over the next 100 years. An additional 20 feet should be added as an addition safety buffer for larger scale ravel or higher erosion rates than what we are estimating or other potential change in conditions along this shore reach. Seismic event considerations Test pits on the site found that the upland area where the home would be located is underlain by coarse well drained sediment. This sediment will not be susceptible to soil liquefaction from seismic events. Given the steepness of the shoreline bluff, small scale slides should be expected on the bluff slope in the event of a large seismic event. We observed no evidence of past seismic induced slope movement such as lateral spread on the uplands of the property on the ground or within lidar bare earth imagery Tsunami Hazard The shoreline at the site could be impacted by earthquake-induced tsunamis. The tsunami inundation map for a Cascadia extended 1.,1 magnitude 9.0 earthquake indicates approximately 4 feet of inundation on the higher parts of Long Spit which begins at the subject property(Figure 13). The modeled tsunami event is considered to exceed 95%of the potential tsunami events from the Cascadia Fault(Dolcimasculo and others, 2021). Hence, a Cascadia earthquake will TAArUM GWOU/ 20 Project: 1.31.22 Exhibit 8 November 14,2022 Page 39 of 66 Jefferson County Parcel 701164005 Geologic Hazard Assessment have minimal impact on the subject property with the proposed building site well above any potential inundation and potential erosion at the site being minimal. The Seattle Fault tsunami model indicates an inundation at Lang Spit of less than 4 feet(Figure 14). Localized earthquakes such as an earthquake generated on the Dabob Bay Fault or other fault zones in the area could also generate tsunamis but have not been modeled. These tsunamis may be higher, but are very unlikely to be high enough to reach the upper bluff slopes. Local landslides may also generate waves. The large landslide that took place about 0.4 miles south of the property was reported to have generated a wave of 7 feet per an observation of a property owner on the Bolton Peninsula across the bay from the landslide. Modeled inundation depth (feet) . , DI 8O8 20 ort: .. ,' fit S!f,1ULHTED • i I,Jc 16 r' 12 I Gene , . I' p7 • (+} ,> f Figure 13.Tsunami hazard map from Washington Geologic Survey(2021)showing modeled inundation depth for an extended LI magnitude 9 earthquake on the Cascadia Fault at Long Spit,the accretion shore form that begins at the south end of the property. Sntanm tiaou► 21 Project: 1.31.22 Exhibit 8 November 14,2022 Page 40 of 66 Jefferson County Parcel 701164005 Geologic Hazard Assessment Modeled inundation Dabob . m depth (feet) mope INTLIVATED 20 • • J E'GAUGE 16 - 12 ♦ WAVE ARRIVAL' - ,- FIRST WAVE. PEAK -1 hater 1S minutes t3' Figure 14.Tsunami hazard map from Washington Geologic Surrey(2022)showing modeled inundation depth for a 7.5 earthquake on the Seattle Fault at Long Spit,the accretion shore form that begins at the south end of the property. CONCLUSIONS AND RECOMMENDATIONS Based on our geologic hazard assessment, it is our opinion that construction of a single-family house and associated septic system on the lower upland on the subject property will not be at risk from landslides or erosion within the expected life of the structure as long as the building and septic systems are located at least 30 feet back from the top of the steep shoreline bluff slope. Furthermore development within the area indicated on Figure 9 will not increase the risk of landslides or erosion on or off the site as long as the recommendations of this report are followed. Stormwater management: Stormwater collected from structures built on the property should be dispersed consistent with the Stormwater Management Manual for Western Washington. Soils on the property upland are capable of readily accepting stormwater infiltration and we did not identify any areas of seepage or springs on the bluff slope. Stormwater should not be discharged onto or within approximately 30 feet of the shoreline bluff slope. Yard waste and debris: Ground cover vegetation within 20 feet of the top edge of the slope and on the bluff slope should not be disturbed. Trees within the buffer may be thinned or limbed for view purposes. However, if the trees are thinned, trees should be left on at least 30-foot centers. In addition, no debris or yard waste should be placed on or near the steep coastal bluff or other steep slopes on the property. Yard waste can eventually builds up and can form a wet unstable mass that will slide down the bluff damaging the slope and increasing the likelihood of a future slope failure. STRATYN GROUP 22 Project: 1.3 1.22 Exhibit 8 November 14,2022 Page 41 of 66 Jefferson County Parcel 701164005 Geologic Hazard Assessment In addition to our construction recommendations, new construction on the subject property may also be subject to buffer requirements established in the Jefferson County Shoreline Master Program. Final construction setbacks should reflect whichever setback is largest. Stratum Group appreciates the opportunity to be of service to you. Should you have any questions regarding this assessment please contact our office at(360)714-9409. Sincerely yours, Stratum Group of wash4,h. s`0 7' !o Dan McShane, L.E.G., M.Sc. �� y Licensed Engineering Geologist ` .:! • DANIEL McSHANE • rinwruN Gnaw 23 Project: 1.31.22 Exhibit 8 Page 42 of 66 ATTACHMENT F Exhibit 8 Page 43 of 66 Rathvon Single Family Horn ..;„ Construction Project Cumulative Impacts Assessment ' January 24',2025 Prepared 0 Richard & Renee Rat 20 Liberty Knoll Colts Neck, Ni 07722-13, , Regarding: 660 Twana Way Quilcene. WA 98376 Jefferson County Parcel # 701164005 E S u-i? t7 or SESsNi. MARINE SURVEYS & ASSESSMENTS 2601 Washington Street Port Townsend WA 98368 360-385-4073 info@msaenvironmental.com Exhibit 8 Page 44 of 66 Table of Contents 2 Project Overview 2.I Introduction l 2.2 Resources reviewed prior to MSA conducting fieldwork l 2.3 Habitat conditions observed on site 2 3 Jefferson County Cumulative Impacts Regulatory Code 5 4 Cumulative Effects Assessment 7 5 Conservation Measures to Avoid & Minimize Impacts 12 6 Conclusion 15 7 References 16 List of Figures Figure 1. Rathvon single family home site plans by McClellan Tellone, Architecture Firm 3 Figure 2. Properties in the vicinity of Rathvon proposed single-family home 8 Figure 3.Additional properties north of Figure 2 (north of Rathvon proposed single-family home) 8 Figure 4.Additional properties south of Figure 2 (south of Rathvon proposed single-family home) 9 Figure 5. Dabob Bay Natural Resource Conservation Area I0 Attachments Attachment I. Photo Documentation Rathvon Single Family Home Construction Project--Cumulative Impacts Assessment Report Exhibit 8 Page 45 of 66 l Project Overview 1.1 Introduction Marine Surveys & Assessments (MSA) was authorized by Richard and Renee Rathvon to complete a Cumulative Impacts Assessment to meet Jefferson County Code (JCC)criteria for the permitting of a single-family home construction project located on their 5.47-acre property (parcel # 701164005). In an email dated November 6th, 2024, the Jefferson County Department of Community Development requested additional information after reviewing the Rathvons' shoreline permit application (SDP2023-00020). One of the requests in that email stated, "JCC 18.25.270(3) and JCC 18.25.590(3) require a cumulative impact assessment. Submit an addendum to the Peninsula Environmental report that addresses cumulative impacts." Rich Rathvon reached out to Peninsula Environmental, who had prepared a stream assessment report for the property (Bornsworth et. al. 2022), but they were not available to complete this request due to staffing issues. Thus, MSA was retained to prepare this addendum. To be able to provide an accurate assessment of the project's potential cumulative impacts, MSA biologist Meg Amos visited the site on December 30th, 2024, and completed a habitat survey. Weather conditions during the visit were overcast, windy, and dry with a temperature of 42° Fahrenheit. The habitat survey covered all portions of the parcel located within shoreline jurisdiction, including walking a pathway down to the beach. This report documents the habitat conditions observed on site and assesses the cumulative impacts, only. This report is not intended to be a full impacts assessment. It is MSA's understanding that a full impacts assessment(such as a Habitat Management Plan as defined by JCC 18.22.650) is only required when a project encroaches into a critical habitat area or its associated buffer. A separate stream assessment report has been prepared by Peninsula Environmental (Bomsworth et. al. 2022), and a geotechnical report and update has been prepared by Stratum Group (McShane 2024). 1.2 Resources reviewed prior to MSA conducting fieldwork • 1974 National Wetland Inventory (NWI) maps, United States Fish and Wildlife Service, • Web Soil Survey: National Cooperative Soil Survey. United States Department of Agriculture(USDA),National Resources Conservation Service (NRCS), • Jefferson County Critical Areas Code Chapter 18.22, • Jefferson County Shoreline Master Program Chapter 18.25, • Jefferson County Open Data Portal -critical areas, shoreline permitting, contours, and elevation hill shades layers, • Washington Department of Fish and Wildlife (WDFW) Priority Habitats and Species (PHS) online mapper, Rathvon Single Family Home Construction Project—Cumulative Impacts Assessment Report I M S A Exhibit 8 Page 46 of 66 • Washington Department of Natural Resources (WA DNR)Forest Practices Application Mapping Tool (FPAMT) for viewing typed streams. 1.3 Habitat conditions observed on site The majority of the Rathvon parcel is covered in mature mixed conifer forest, primarily consisting of Western redcedar(Thuja plicata) and big leaf maple (Acer macrophyllum).To the north and south are similar properties that are already developed with single-family homes. The shoreline of Dabob Bay is located to the west, and undeveloped forestland is to the east. There is a non-fish seasonal (Ns)stream located primarily offsite to the south; however, a short segment of the stream (approximately 80-linear feet) is located in the southeast corner of the property. The stream runs from east to west and flows into Dabob Bay.An existing driveway enters the property from the east, then dips back outside of the property line to the south, then back onto the Rathvon parcel running north/northeast, bisecting the parcel and continuing north onto the neighbor's property (Figure I).This driveway is a legal easement for ingress and egress that serves the two properties at the end of the road and is not a public access point. There is a permitted well located to the northeast of the proposed building footprint, on the east/northeast side of the roadway. During the habitat survey, water was observed to be flowing out of the ground in this area and running across the road, with the area around the well fully saturated. The property has been fully surveyed by a licensed Professional Land Surveyor, and a site plan has been created by McClellan Tellone(Figure 1). The proposed building footprint and critical areas buffers (shoreline and stream buffers) are clearly flagged out on-site, including building setbacks. An existing dirt pathway (approximately 18-feet wide) leads to the beach, where the substrate appears suitable for forage fish spawning, with small to medium gravel mixed with sand. From the beach there are visible structures to the north and south; the neighboring property to the north has a beach house and other structures located just landward of the OHWM, and the neighboring property to the south has stairs to the beach. The riparian zone on the Rathvon parcel was observed to be natural and intact with driftwood and gravel up to the beach-upland interface. No wetlands or wetland vegetation were observed while on site. Rathvon Single Family Home Construction Project—Cumulative Impacts Assessment Report 2 1 M S A Exhibit 8 Page 47 of 66 Figure I. Rathvon single family home site plans by McClellan Tellone,Architecture Firm I 1 i g .e- - < , I—— — 11 4 \\ *SO 1 I ii :1 • .‘ ata I Et : 1 istti; • IOW.: * 72'.' ' ! • 1 . •'", II • . 5 oi • ... ,.,,I .‘ . it I 1 • 'toI . I if Yil 4 - lila I! !i f ' ' ri i I 1, 1. 4 P t ' .,, I It ‘''''' ...•''''. 1 '''.. ,I .` •, '‘.V I il 1 /hi IP II . il I , i 11 1. r: i: \ ,t . .4. \. 'i \ Nilil---. ,-- 1 -,. • •••t . \ )\1 # III .71 , , . 1// IN -• 4 ' !Ilt1 I s • ''ily.,. - , ' .."/ •...„'t Ala :// 1 53:11 : ...4 ?„,..0„,,,, ‘.. ......,/ !I ci \ , '‘ • . ‘ -, r 3 i , ,..; , 1 • V / $ s 4 , ‘ •.• ' '"- sll• ,/, I ../ A',E" I./ I eat j -, 4'4 t 's .... • - N'',41 •-•1 ' '''. 1'1 :. ... ,, .- , • •-—__.„...,..„--...0-" I. , ....' ''....••••••Zt 't ,.." . ', „........so- i . , •• ..\- , . , . „-- ,. t_i 1 II ...i.,, ,,, , . II i- ----- ..... -- — • - , , • , , , 8 ' ,, ..„'.. 1_ .. I ... - ••• ,i . I ' Rathvon Single Family Home Construction Project Cumulative Impacts Assessment Report 3 ' MSA Exhibit 8 Page 48 of 66 While on site, the MSA biologist observed the following vegetation species: Herbaceous plants • Dune grass(Leymus mollis) • Foxglove (Digitalis purpurea)—non-native • Miner's lettuce(Claytonia perfoliate) • Piggyback plant(Tolmiea menziesii) • Slender-footed sedge (Carex leptopoda) • Thistle(Cirsium sp.) Shrubs, ferns, and woody vines • Evergreen huckleberry(Vaccinium ovatum) • Nootka rose(Rosa nutkana) • Salal (Gualtheria shallon) • Snowberry(Symphoricarpos albus) • Sword fern (Polystichum munitum) • Tall Oregon grape (Mahonia aquifolium) • Trailing blackberry(Rubus ursinus) Trees • Beaked hazelnut(Corylus cornuta) • Big leaf maple(Acer macrophyllum) • Douglas fir(Pseudotsuga menziesii) • Red alder(Alnus rubra) • Western redcedar(Thuja plicata) Abundant invasive English holly (Ilex aguifolium)was also observed to be present on the property. Some snags with potential nesting cavities were noted on site, but none were observed to be suitable for Northern Spotted Owls, and no trees were observed to have suitable sized limbs for nesting Marbled Murrelets. Notes were taken on all trees within or immediately adjacent to the proposed building footprint to document trees that will require removal for construction. Diameter at Breast Height(DBH) was also recorded for each tree.All of these trees consisted of Western redcedar and big leaf maples, the majority of which had some form of rot or deformities. Additionally, all of the trees noted are located outside of the 150-foot shoreline critical area buffer and 10-foot building setback (160-foot total setback), and well outside of the 50-foot stream setback to the south. These trees are documented below, however the list may not be comprehensive because there were additional trees located outside of the building footprint that may also need to be removed Rathvon Single Family Home Construction Project Cumulative Impacts Assessment Report 4 M S A Exhibit 8 Page 49 of 66 due to proximity.All of these additional nearby trees consisted of the same two species, and all are located outside of the critical area buffers and setbacks. Trees that will require removal for construction: 1. Big leaf maple—34-inch DBH, rotting/diseased, 2. Big leaf maple— 14-inch DBH, 3. Western redcedar—42-inch DB11, very close to building corner. Evidence of use by red breasted sapsucker, 4. Western redcedar—34-inch DBH, rotten/diseased, forked growth pattern, 5. Western redcedar— 13.5-inch DBH, 6. Western redcedar—29-inch DBH, outside of house footprint near east side, 7. Western redcedar—23-inch DBH, outside of house footprint near east side, 8. Western redcedar—34-inch DBH, outside of house footprint near west side, & 10-feet east of surveyed 160-foot buffer and setback boundary, 9. Western redcedar—21-inch DBH, outside of house footprint near west side, & 10-feet east of surveyed 160-foot buffer and setback boundary. Additionally, the MSA biologist noted any wildlife observed while on site, which included the following species: • Bald eagle (Haliaeetus leucocephalus)—visual observation, • Blacktail deer(Odocoileus hemionus columbianus)—visual observation, • Common raven (Corvus corax)—visual observation, • Golden-crowned kinglet (Regulus satrapa)—auditory observation, • Gull (Larus sp.)—visual observation. • Hairy or downy woodpecker(Leuconotopicus villosus or Picoides pubescens)— excavations on trees, • Pacific Wren (Troglodytes pacificus) —auditory observation, • Pileated woodpecker(Dryocopus pileatus)—excavations on trees, • Red breasted sapsucker(Sphyrapicus ruber)--excavations/feeding sign on trees. 2 Jefferson County Cumulative Impacts Regulatory Code The Jefferson County Shoreline Master Program (SMP) states the following code requirements (listed below) regarding the assessment of cumulative impacts for projects located within shoreline jurisdiction. Shoreline jurisdiction extends from the Ordinary High Water Mark (OHWM) landward for 200-feet, and is regulated by the State Shoreline Management Act of 1971. This 200-foot jurisdictional area differs from the County protective shoreline critical area buffer, which is 150-feet (JCC I8.25.270(4)(e)(i)).Although the proposed single-family home and septic development project is located outside of the 150-foot shoreline critical area buffer Rathvon Single Family Home Construction Project—Cumulative Impacts Assessment Report 5 I M S A Exhibit 8 Page 50 of 66 and 10-foot setback, it is located partially within the 200-foot shoreline jurisdiction, thus these additional requirements apply. JCC 18.25.270(3)provides: (3) Regulations—Cumulative Impacts. (a) The county shall consider the cumulative impacts of individual uses and developments, including preferred uses and uses that are exempt from permit requirements, when determining whether a proposed use or development could cause a net loss of ecological functions. (b)The county shall have the authority to require the applicant/proponent to prepare special studies, assessments and analyses as necessary to identify and address cumulative impacts including, but not limited to, impacts on fish and wildlife habitat, public access/use, aesthetics, and other shoreline attributes. (c) Proponents of shoreline use and development shall take the following factors into account when assessing cumulative impacts: (i)Current ecological functions and human factors influencing shoreline natural processes; and (ii) Reasonably foreseeable future use and development of the shoreline; and (iii) Beneficial effects of any established regulatory programs under other local, state, and federal laws; and (iv) Mitigation measures implemented in conjunction with the proposed project to avoid, reduce and/or compensate for adverse impacts. (d)The county shall prohibit any use or development that will result in unmitigated cumulative impacts. JCC 18.25.590(3)provides: (3) In 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. Rathvon Single Family Home Construction Project—Cumulative Impacts Assessment Report 6 I M S A Exhibit 8 Page 51 of 66 3 Cumulative Effects Assessment The Rathvons are proposing to construct a single-family home and septic on their 5.47-acre property.A permitted well has already been installed.No beach structures, such as stairs to the beach, are planned,since none are required for beach access(there is an existing dirt pathway to the beach).Additionally, no expansion or widening of the existing roadway is planned.Only typical maintenance, such as re-gravelling within the existing footprint, is planned to occur. Cumulative effects, which take into account this project as well as future development in the area, are reasonably certain to occur around the larger geographical area. The project area includes many other similarly developed rural residential shoreline properties to the north and south. Cumulative habitat alterations from increased development could impact Endangered Species Act(ESA) listed species and/or their critical habitat areas, as well as other sensitive fish and wildlife species and habitats, human recreational activities and public access, and aesthetics. These potential adverse cumulative effects could be caused by physical obstructions from development, changes in stormwater flow on the landscape, changes in turbidity and pollution levels, and other such factors. Although the Rathvon property was one of the first properties purchased in the vicinity in 1971, it appears to be one of the last 5+ acre parcels in this area(west of Toandos Road)on which a single-family dwelling will be constructed. Beginning in the late 1970's, single-family dwellings were constructed on most of the waterfront and non-waterfront lots in the immediate vicinity not currently owned by the Department of Natural Resources(DNR). See Figures 2 through 4. Rathvon Single Family Home Construction Project—Cumulative Impacts Assessment Report 7 M S A Exhibit 8 Page 52 of 66 Figure 2. Properties in the vicinity of Rathvon proposed single-family home" lib N MIN � . . 111, tttlCUP �t ® j • t t ea 1 i ,[ ' ^.ANer tP111Ht1 # - #�Y��rrrwis i t 1j; I tdr Vriv�le viopertY f—�- Ela (wrrn nOnt/rwr{ ufil ._..-`"""._.—.�.__...— _........ copse ont-v$w own ty' mttvtiq Ela t.vin};dweatrs structum ..-- 15 ..raPmet!dwelling Nnxiure 11:31 _ . _.w.. . ihrit EMU *Dwelling notations are included for properties west of Toandos Road. Figures 2-3 were created by Rich Rathvon using imagery from the Jefferson County Open Data Portal. Figure 3.Additional properties north of Figure 2(north of Rathvon proposed single-family home) . »+Haase ._ 't**not rrimorm € b.t .`*0sr — t cal 1 JittCe102 Private property ' '' ,t,, tmi Government/non-profit - 1 MEM conservancy property � S rat�nelYs+ � 4, Q • Existing dwelling structure µ._ "� rt+-stye. o ,. ,.,\ 731H7Q® a *slid Rathvon Single Family Home Construction Project—Cumulative Impacts Assessment Report 8 I M S A Exhibit 8 Page 53 of 66 Figure 4.Additional properties south of Figure 2(south of Rathvon proposed single-family home) .-_ I '01Yti013• ry 70 11 51 0 0 7 z<� I -a1 70115 4002 'O t 15aU�t 70 1153 00 4 701153005rs 70122 001 701222013 701222011' 701221000 7 01 222 010 amU 1 Dnvdt pn.ty ® e IC;,7?20t2 • Gvue�em 1 non-protn - - ctxrS Y WOPet --••— ti 701722014 1111 L_ eng dweII ,u a +i IMO 701222002 '01224001 All properties located in the immediate vicinity surrounding the Rathvon parcel already contain a single-family dwelling. The only possible exception is the Bennett property (parcel # 701153025), located to the southeast of the Rathvon parcel (Figure 2), which currently has a yurt (according to the Rathvons). Additionally, the terrain near the cliff on the Bennett parcel would likely require that any future proposed structures be built on the north side of Twana Way, and the property may not be developed at all if it is purchased by the Washington Department of Natural Resources (WDNR)or Northwest Watershed Institute (NWT), who have been pursuing the acquisition of properties in the area for conservation. Many of the properties to the north, south, and east of the Rathvon parcel are already owned and managed by WDNR or NWI, with only one entirely undeveloped private property located west of Toandos Road appearing to have the potential of being developed in the future (Parcel # 701094002, Figure 3). WDNR and NWT have acquired, and continue to acquire, property in the area for conservation. This protection of the land will help maintain the ecological conditions of the immediate area and will ensure less cumulative impacts that could be caused by development in the area. Dabob Bay is part of the growing Dabob Bay Natural Resource Conservation Area, which is overseen by the WDNR to ensure the protection of the regional ecology and habitat (WDNR 2024, Figure 5). Rathvon Single Family Home Construction Project—Cumulative Impacts Assessment Report 9 M S A Exhibit 8 Page 54 of 66 Figure 5. F)ahoh Bay Natural Resource Conservation Area* Dabob Bay Natural Resource Conservation Area LEGEND 1 MA x. 1. �4AKa�..., '' , '';/-L` ' L —81111A", ( )) A...M A.-Noun-KW, iy� l mom bane/..-:LIMA YY£/ MIt[..FyyA a� - vw D.K.a.,M Ned KAMM (. 1 . - VS/A,...A14.•L.w.4. ..„,„ A. ,,,,A , .,, . t ..„., / /� . , 13 • .t rralliriliVirliiiirr' A• K...s Fwn���w'.A1 .►.►a..A / tI =hr. s:::::! . f LlN_MAA i—�May Mr�wrrs il- M[►lA�.�1M.AA.M J} , / AINAM LOIN.YNIAM., mMI p-' AitFA114LW1tTAK OtA1- itATURAL .. ,<, RESOURCES *Figure annotations created by Rich Rathvon Additionally, because the Rathvon parcel and surrounding properties are all zoned as RR-5 - Rural Residential, no more than one single-family dwelling can be constructed on each parcel, and only one Accessory Dwelling Unit(ADU)of 1,250 square feet or less is allowed (including garages and basements).This zoning, along with county critical areas code requirements, helps to ensure that the area will not have unmitigated development or significant cumulative impacts from future development. The Revised Code of Washington (RCW)Chapter 90.58.020 discusses preferred uses in shoreline jurisdiction and calls for a balance between private property owner rights, sensitive shoreline ecology, and public interest. This code also supports local jurisdictions in developing and following Shoreline Master Programs, such as the Jefferson County Shoreline Master Program (JCSMP). RCW Chapter 90.58.020 states that, "the shorelines of the state are among the most valuable and fragile of its natural resources and that there is great concern throughout the state relating to their utilization, protection, restoration, and preservation....much of the shorelines of the state and the uplands adjacent thereto are in private ownership; that unrestricted construction on the privately owned or publicly owned shorelines of the state is not in the best public interest; Rathvon Single Family Home Construction Project -Cumulative Impacts Assessment Report 10 0 M S A Exhibit 8 Page 55 of 66 and therefore, coordinated planning is necessary in order to protect the public interest associated with the shorelines of the state while,at the same time, recognizing and protecting private property rights consistent with the public interest. There is, therefore, a clear and urgent demand for a planned, rational, and concerted effort,jointly performed by federal, state,and local governments, to prevent the inherent harm in an uncoordinated and piecemeal development of the state's shorelines." The Rathvons plans for their single-family home construction project have diligently taken into consideration the regulatory code outlined in the RCW and JCSMP, including JCSMP Chapter 18.25.500, which similarly states that: "(a) Residential use and development shall be planned, designed, located, and operated to avoid adverse impacts on shoreline processes, aquatic habitat, biological functions, water quality, aesthetics, navigation, and neighboring uses." The conditional use permit criteria written in the Jefferson County Code(JCC 18.25.590)allows for the construction of a single-family home in a manner that mitigates adverse impacts to the shoreline environment.These provisions are designed to "allow greater flexibility in administering the use regulations of this program in a manner consistent with the policies of RCW 90.58.020."The Rathvons are planning the construction of their single-family home in accordance with the conditional use permit criteria while also abiding by the Jefferson County Shoreline Master Program regulations(Chapter 18.25), the Jefferson County Critical Areas Code (Chapter 18.22), and the County development standards (Chapter 18.30). In accordance with the above regulations, the Rathvons have completed the following planning activities: 1. The proposed development is planned to be entirely outside of all critical areas buffers and building setbacks, and these buffers/setbacks have been clearly flagged out on site. 2. A septic design and permit application has been submitted, received, and approved by the county. The septic system is designed in a way that will avoid groundwater and shoreline impacts to the best practicable extent possible, and the proposed location is outside of all critical areas buffers and building setbacks. 3. A well has been sited and drilled in accordance with Jefferson County regulations. The well is located outside of all critical areas buffers, building setbacks, and outside of shoreline jurisdiction. 4. A survey was completed by a licensed Professional Land Surveyor on the property, and a site plan has been prepared by McClellan Tellone (architecture firm)which shows the proposed building location and critical areas buffers/setbacks overlaid on the topography. Rathvon Single Family Home Construction Project—Cumulative Impacts Assessment Report 11 ! M S A Exhibit 8 Page 56 of 66 5. An additional site plan that outlines all proposed ground disturbing activities was provided by the Rathvons to Jefferson County to satisfy code requirements. 6. A stormwater management plan was prepared to minimize potential impacts to the shoreline and stream habitats and to abide by county code requirements. 7. The home has been designed in compliance with the State Energy Code and county requirements, which mandate that all new single-family homes be built by more energy efficient standards. 8. A geotechnical assessment was completed by Stratum Group and updated after public comments/questions arose. 9. A stream assessment was completed by Peninsula Environmental. 10. A habitat survey was completed by MSA, along with this cumulative impacts analysis. Collectively, adherence to these regulations and policies ensures that the development of this proposed single-family home will be in a in a manner that: a. manages and mitigates any adverse short-term impacts; b. minimizes any adverse long-term impacts (including potential cumulative impacts to the ecology, public use/access, and aesthetics); and c. ensures the protection of shoreline ecological functions. 4 Conservation Measures to Avoid & Minimize Impacts Additional conservation measures presented here include avoidance and minimization efforts that have been considered to ensure that all proposed development is located, designed, constructed, and maintained in a manner that protects ecological functions and ecosystem-wide processes. This section also describes the steps that have been, and will be taken during planning and construction to find the least environmentally damaging practicable alternative to achieve the project goal. It is the opinion of MSA biologists that no additional mitigation, beyond the BMPs described below, should be required for this project, since the proposed construction is located entirely outside of all critical habitat area buffers and building setbacks. The following mitigation sequencing steps, as described in WAC 173-26-201(2)(e) and JCC 18.22.660(2), were considered during project development and site selection: • No action: To avoid the adverse impact altogether by not taking a certain action or parts of an action. o "No Action" would not achieve the project goal. • Minimizing impacts by limiting the degree or magnitude of the action and its implementation by using appropriate technology or by taking affirmative steps to avoid or reduce impacts. Rathvon Single Family Home Construction Project—Cumulative Impacts Assessment Report 12 M S A Exhibit 8 Page 57 of 66 o The proposed single-family home construction project includes the minimum footprint necessary to achieve the goal. Best Management Practices(BMPs) discussed below will be implemented during construction to minimize impacts. Additionally, the house will be constructed in accordance with the recently revised Washington State energy conservation standards, and will be placed outside of all critical areas buffers and building setbacks. The Rathvons are not seeking a buffer reduction or averaging even though they are lawfully allowed to do so pursuant to JCC 18.25.270(5)(b), and their structure will be placed further from the shoreline than neighboring homes'existing placement. • Rectifying the impact by repairing, rehabilitating, or restoring the affected environment. o BMP's will be used during construction, damage to native vegetation will be avoided wherever possible, and any damaged vegetation will be chipped and reused on site. The Rathvons have also stated that they plan to plant additional native plants on their property after the construction is complete. • Reducing or eliminating the impact over time by preservation and maintenance operations. o Opportunities to reduce or eliminate the permanent direct and indirect negative impacts from the project are described below in the list of BMPs. • Compensating for the adverse impact by replacing, enhancing, or providing substitute resources or environments. o Any disturbed ground outside of the construction footprint will be covered in clean woodchips after construction is complete. • Monitoring the impact and the compensation project and taking appropriate corrective measures. o No monitoring is necessary for this project, since the proposed construction is located outside of all critical habitat areas and their associated buffers and building setbacks. To minimize potential impacts to ESA-listed and priority species and habitats that may be associated with this project, as well as potential impacts to the public easement, the following BMPs are recommended by MSA for implementation at the site: • Before any construction work begins, site construction limits for clearing, tree protection, and runoff will be clearly laid out on site, • Prior to any construction activity, a silt fence and straw wattles will be installed between the construction area and the OHWM of the shoreline and stream, • Any disturbed earth resulting from construction activity will be covered with clean woodchips to mitigate sediment runoff, • All staged building materials will be confined to the existing compacted gravel roadways/paths, Rathvon Single Family Home Construction Project—Cumulative Impacts Assessment Report 13 i M S A Exhibit 8 Page 58 of 66 • Any damage to the existing roadway should be restored to its original condition or better. General Best Management Practices for Small Construction Sites • Hand-tools should be used whenever practicable, consistent with standard building practices, • Marking the critical root zone (CRZ)of trees with paint, flagging, or other to avoid running equipment and stockpiling materials in CRZ, therefore limiting soil disturbance and compaction.Additionally, any necessary heavy equipment and/or truck access should entail a layer of clean woodchips, or sufficiently wide and thick steel plates in the vehicle wheel path to avoid rutting and damaging the vegetation, • Construction should not be conducted during heavy precipitation events, regardless of the protection of vegetation. If vegetation is damaged, or rutting occurs, it is recommended that those areas be re-planted with native vegetation. If planting is necessary, a layer of clean woodchips should also be installed around plants at a minimum depth of 3 inches, • Limit the extent of clearing operations and phase construction operations, • The duff layer, native topsoil, and natural vegetation should be retained in an undisturbed state to the maximum extent practicable. Rathvon Single Family Home Construction Project—Cumulative Impacts Assessment Report 14 1 M S A Exhibit 8 Page 59 of 66 5 Conclusion The full scope of cumulative impacts cannot be quantified in this assessment, but with appropriate regulations in place, and the actions described in the above sections, it is unlikely that ESA-listed species, critical habitat areas, or human activities will be significantly affected by the construction of this single-family residence. Significant adverse cumulative impacts are especially unlikely in this area due to the fact that most of the surrounding properties are already developed or protected for conservation, and zoned for one single-family home per parcel. Final jurisdictional authority and permitting on this project will be the responsibility of the appropriate local, state, and/or federal government agencies involved.All information contained in this report should be reviewed by the appropriate regulatory agencies prior to approval or issuance of permits. Sincerely, 11* Jill Co per ' Meg Amos Senior Ecologist , Senior Ecologist c- ssmv. Rathvon Single Family Home Construction Project—Cumulative Impacts Assessment Report 15 M S A Exhibit 8 Page 60 of 66 6 References Bomsworth J., Donadio L,and Sutter K. 2022. Stream Assessment Report for 660 Twana WY,Quilcene, WA 98376. Dated December 19th,2022. Peninsula Environmental. McShane, D.2024.Geologic Hazard Assessment Report and Update.Original report dated February 15, 2022; Update dated November 14,2024. Stratum Group. Washington Department of Natural Resources. 2024.Article titled"Dabob Bay Natural Resources Conservation Area to Expand 3,943 Acres,"dated October 2,2024.Available at: https://www.dnr.wa.gov/news/dabob-bay-natural-resources-conservation-area-expand-3943-acres Jefferson County Municipal Code.Chapter 18.22 Critical Areas. Jefferson County Shoreline Master Program. Chapter 18.25 Jefferson County Municipal Code. U.S. Department of Agriculture(USDA). 2013. Soil Conservation Service.Soil Survey of Jefferson County Area, Washington. December,2013. Accessed December 2024. U. S. Fish and Wildlife Service(USFWS). 2024. National Wetlands Inventory(NWI)website. U.S. Department of the Interior,Fish and Wildlife Service,Washington, D.C.Accessed December 2024. Washington Department of Fish and Wildlife(WDFW). 2024. Priority Habitats and Species(PHS)report. Accessed December 2024.Available at: http://wdfw.wa.gov/mappinglphs! Washington Department of Natural Resources(WDNR). 2024. Forest Practices Application Mapping Tool (FPAMT)for viewing typed streams. Accessed December 2024. Rathvon Single Family Home Construction Project—Cumulative Impacts Assessment Report 16 M S A Exhibit 8 Page 61 of 66 Attachment 1. Photo Documentation Exhibit 8 Page 62 of 66 Twana Way;existing private easement road for ingress,egress �'. '1 i ,44 . . 4, `, ` 4 t.:',- * .. 4 { ` 4@h f, t.. -..*- `ir. . ram„ lif ' 1 ,s cy It i v14 t - ww , � . 4 *.,� r, - - ;y, , fit' of ..f 14 +{. ' •r i OP. , 4.141 _.y .. , s» { it ¢ , ii .., .... , , . 'w rAtlC' ,'. i !f j f , I » � _ tp4 y pry - Exhibit 8 Page 63 of 66 Surveyor's stakes clearly marking proposed building site and setbacks 4 , aa. Ar } e �i ;Iri 'yl 1 yp d w CfS3R� to , it t - • -- 3/ • , 4 _ .4 44. t -. 4.d4,44 ..114 , , , i ' . t- ,, ''....,„, iii ; ' 1y A i w ..p 4� Exhibit 8 Page 64 of 66 Natural riparian shoreline adjacent to the Rathvon parcel ° r . 44 414 4 4.4 Rathvon existing trail to beach �.4► rf • k , . •I �. Ir , ,- Exhibit 8 Page 65 of 66 Rathvon existing trail to beach 5 { ,,-; . �y�• ri 1 ap • Y T b 1.i „, u 74 4, `.n * i jw`,, ;• "�!- tit r g, ; .^ yP,. C..: a. k ' t g • V. A C, .11 .. i A X ,,:' d.: i ' r r Existing structures along neighboring shoreline to the north of Rathvon parcel ....;.: _,...„ e Mg 'w. .� Exhibit 8 Page 66 of 66 Fxisting structures along neighboring shoreline to the north of Rathvon parcel t «t \ f tr, . r #. +`...'..`-�—' - • `,.ram �,7,� ..' + . .+w; gay! � ♦ '�'Xr �. `,, j - ., 41?��-. vf aim_ _ .a.,�.. � ti�. •.. - Existing stairs to beach on neighboring property to the south _ b\, - •+" •• L i yy� ate: , 1�I� ,i /,'w , tw " Ai ter- , -••__. - . 1. aW�t` .. ' U... �" " 4^ sn 2 x✓ �. , iiiielgere , .....*,: f, ' A. f t `r''a ♦ � .. i '� r_ `m *' ,.� _v t �y�. EXHIBIT L Exhibit 9 Donna Frostholm Pane 1 of From: Richard Rathvon <rich@rathvonconsulting.com> Sent: Thursday, March 13, 2025 12:29 PM To: Donna Frostholm Cc: 'Terry McHugh' Subject: Geologic hazard assessment for Twana Way Attachments: Geologic Hazard Letter for Twana Way.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, I had understood previously—perhaps incorrectly—that a letter from our Geotech specialist was sufficient, which has already been submitted to your office. For additional information, attached is a copy of the geologic hazard assessment for Twana Way. Please let me know if you have any questions or require further information. Regards, Rich Exhibit 9 Parra7nfr, STRATUM GROUP PO Box 2546,Bellingham, Washington 98227 Phone:(360)714-9409 February 25,2025 Richard Rathvon 20 Liberty Knoll Colts Neck,NJ 07722 rrathvon@gmail.com Re: Geologic Hazard Assessment for Twana Way Improvements Twana Way Quilcene, WA Dear Richard Rathvon: This letter provides a summary of our road and slope stability assessment completed in February 2025. It is our understanding that you are proposing to improve Twana Way to allow construction vehicle access to your property at 660 Twana Way. Based on our field investigation, it is our opinion that road widening will be required in several places in order to accommodate large trucks and/or other construction equipment. In some locations, road widening can be accomplished by expanding the travelled roadway into the existing shoulder areas(e.g.Figure I). In other areas, road widening will require excavation into existing cut slopes(e.g. Figure 2). Stratum Group assessed all cut slopes where excavation is anticipated.The observed cut slopes are underlain by dense, well drained sand and gravel (Figure 3). It is our opinion that excavation of these existing cut slopes can be accomplished without increasing the potential for landslides and without decreasing the stability of the roadway and adjacent areas as long as the recommendations of this letter are followed. A temporary increase in minor soil raveling should be expected in some areas due to removal of vegetation and soil disturbance. In addition to road widening, regrading of the road may be required to lessen the steepness of the roadway and also to repair holes and ruts. Regrading of the road will not increase the potential for landslides or erosion along Twana Way or adjacent areas as long as the recommendations of this report are followed. Stratum Group 1 Exhibit 9 February 25,2025 Pang 1 of Twana Way Geologic Hazard Assessment -A lit, . -.. - .04‘1,.., - , 4,...,_ .. .-.;3:s: :11-6:::_ot.4**C'; * ,4.1'...- r _ - ... yam, mat: Y J , 1 - Figure 1.Example location of area where road widening can be accomplished by expanding the travelled roadway into the shoulder. 't xa a 1, 4 • 1r a. f $ ''r x` ° 1 M yet: } - f 1 I • A .. .` s?- .. `.:-". • 1.. ART r M ir.� Figure 2. Example location where road widening will require excavation into the existing cut slope on the left side of the photograph. Stratum Group 1 Exhibit 9 February 25,2025 P a r,a d of F Twana Way Geologic Hazard Assessment t ! ' r ' • y_4 Figure 3. Sandy soils that typify the road cuts along Twana Way. Recommendations: 1. Where possible, road widening should be completed by utilizing existing shoulder areas. Excavating existing cut slopes will be required in several areas. Road widening should not involve creating or expanding any fill slopes. 2. New or expanded road cuts up to 6 feet high can exceed 1:1 in steepness as long as the road cut is underlain by compact, well drained sand. Cut slopes exceeding 6 feet in height should be 1:1 or gentler. If steeper cuts are required, Stratum Group should be contacted to assess the stability before excavating. If clay rich soils or groundwater seepage are encountered during excavation, Stratum Group should be contacted to assess to inspect the cut slope. 3. Excavated material should be end hauled. 4. Construction should be completed using best management practices including temporary erosion and sediment control (TESC). Soil and vegetation disturbance should be limited to the proposed excavation and construction areas. Stratum Group 3 Exhibit 9 February 25,2025 P a n P ti of Twana Way Geologic Hazard Assessment Stratum Group appreciates the opportunity to be of service to you. Should you have any questions regarding this assessment please contact our office at(360)714-9409. Sincerely yours, Stratum Group 0\ W a sh;0 9'0 6'4 '• 3S Enginecring Geobgi C. • 20120197 • �y GeoffMalick, L.E.G., M.Sc. 'sed Ge°\° Licensed Engineering Geologist Geoffrey Malick Statement of Limitation and Indemnity This document has been prepared by Stratum Group for the exclusive use and benefit of the client.No other party is entitled to rely on any of the conclusions,data, opinions, or any other information contained in this document.This document represents Stratum Group's best professional judgment based on the information available at the time of its completion and as appropriate for the project scope of work. It is not possible to fully anticipate all future risks or future site evolution. Services performed in developing the content of this document have been conducted in a manner consistent with that level and skill ordinarily exercised by members of the geology profession currently practicing under similar conditions. The client shall understand that the subject property includes geologic hazard areas,and the client has elected to develop and/or reside at this location. The client shall accept that there are inherent risks associated with geologic hazard areas and assume sole responsibility for its future consequences, both as detailed herein and unknown.The client shall accept that is not possible to entirely eliminate all risk associated with geologic hazards. Stratum Group Inc, its staff and owners, shall be indemnified and held harmless from the consequences of development and residence at the subject property. Furthermore,no warranty, expressed or implied, is made. Stratum Group 4 EXHIBIT M Exhibit 11 Panes 1 of d JEFFERSON COUNTY SUBSTANTIAL DEVELOPMENT PERMIT WASHINGTON STATE SHORELINE MANAGEMENT ACT(RCW 90.58) PROPONENT: RICHARD RATHVON 20 LIBERTY KNOLL COLTS NECK, NJ 07722 DATE ISSUED: April 10, 2025 DATE EXPIRES: April 10, 2030 CASE NUMBER: SDP2023-00020 PROJECT DESCRIPTION: Shoreline conditional use(administrative)and stormwater applications to construct a new house in the Natural shoreline environment designation along Dabob Bay. Residential development is proposed outside of the 150-foot shoreline buffer and 10-foot building setback. Construction of the house and installation of the septic system would be located within 200 feet of ordinary high water mark, but most of the concrete parking area is proposed outside of shoreline jurisdiction. The applicants have submitted a geotechnical report, a stream report, and a cumulative impacts report, and all development would be located outside of the stream buffer. The proposal is not subject to review under the State Environmental Policy Act(SEPA). The findings are outlined in a staff report prepared for this proposal, dated April 10, 2025. PROJECT LOCATION: 660 Twana Way, Quilcene, WA 98376 WATERBODY AND/OR ASSOCIATED WETLANDS: DABOB BAY SHORELINE OF STATE-WIDE SIGNIFICANCE: NO SHORELINE DESIGNATION: NATURAL Development pursuant to this permit shall be undertaken subject to the applicable policies and performance standards of the Jefferson County Shoreline Master Program (SMP)and the following conditions: 1. This proposal requires final permitting approval from Washington Department of Ecology (Ecology). Construction shall not begin until Ecology has sent written authorization to proceed. 2. Substantial progress towards completion of the project shall be performed within two years of the issuance of the permit. 3. Work within the jurisdiction of the Shoreline Master Program other than as approved for this shoreline permit shall receive separate review by Department of Community Development(DCD). 4. A silt fence shall be installed 160 feet from the ordinary high water mark(OHWM), as shown on the approved site plan, to prevent sediments from being transported from the construction area to the shoreline. At the drainfield location, the silt fence shall be placed no closer than 150 feet from OHWM. The permittee shall contact DCD planning to review the silt fence installation prior to proceeding with any other work on the property. 5. The permittee shall ensure that all construction-related activities for the house, including ground clearing and stockpiling equipment, are conducted at least 160 feet from OHWM and that all ground disturbance to install the drainfield is conducted at least 150 feet from OHWM. 6. This shoreline permit is for construction of a new single-family residence and development on the subject property is limited to that shown on the approved site plan. 7. This permit does not authorize any modifications to the existing access road. It is the responsibility of the permittee to obtain any required permits. 8. The permittee shall ensure that all development, including ground-disturbing activities, occurs outside of the 50-foot buffer associated with an off-site stream. 9. The permittee shall comply with the 2019 Ecology Stormwater Management Manual for Western Washington and with the stormwater plan prepared by Evergreen Engineering Services(dated June 24, 2024). This includes, but is not limited to, compliance with the following Best Management Practices (BMPs)and stormwater requirements: Exhibit 11 a. BMP T5.10B—Downspout Dispersion Systems (for roof downspout flow); Pang of b. BMP T5.12—Sheet Flow Dispersion(for driveways); c. BMP T5.13—Post-construction Soil Quality and Depth (to restore disturbed areas; d. Exposed soils shall be stabilized; e. Pollutants (such as motor oil and construction debris)shall not be released or discharged; f. Temporary erosion and sedimentation control measures shall be routinely inspected and maintained; and g. Unnecessary ground disturbance is not allowed. 10. The permittee shall adhere to all conclusions and recommendations in the Geologic Hazard Assessment report (dated February 15, 2022)and Geologic Hazard Assessment Update(dated November 14, 2024), both of which were prepared by Stratum Group. This includes, but is not limited to: a. The single-family residence shall be constructed at least 30 feet from the top of the shoreline bluff; b. Stormwater shall not be discharged within 30 feet of the top of the shoreline bluff slope; c. Tree and cover vegetation removal is limited on the bluff and buffer; and d. Yard debris and waste shall not be placed on the bluff face or near any steep slope. 11. No fill or other materials may be placed in the waters or intertidal areas of Jefferson County. Appeals: Pursuant to chapter 18.40.270(2), the decision by the administrator' is final, subject to the following: an applicant or party of record may appeal the decision to the hearing examiner for an open record hearing. Pursuant to chapter 18.25.750(5)JCC, appeals to the Shoreline Hearings Board of a final decision on a shoreline substantial development permit may be filed by any aggrieved party in accordance with RCW 90.58 within twenty-one(21)days of filing the final decision by Jefferson County with the Washington State Department of Ecology and Washington State Attorney General's Office. Information on appeal process and rules of procedure is available on the Shoreline Hearings Board web site at Shorelines Hearings Board l ELUHO Notice: Nothing in this permit shall excuse the permittee from complying with applicable local,state, or federal ordinances, or regulations consistent with RCW 90.58. 'Departmen f Community Development Staff c: Lizzie Carp, DOE, Shorelands Office "Administrator"means the Jefferson County department of community development director or a designated representative.JCC 18.10.010 A definitions. P I'R1 t\'I II u.nf....w "\ 'III I'I\ti N:r21 i ..... C C...a....1.wa. M.m.p.OW..NM \ i \ .s. �..� ...{,�._ PROPERTY LINE A_• - .. - MALI M,TAPAIMPAY i lt QM:SW PA NM 1 \ \ .H taVed APPROVED SPARC _-_ mil BEAR 164MVOM 'N. / \ �� \ PEA ffflO11. i11 4�/,J+. Patmg- YAP. COY. J//% .R3..aa I AO fialCoNal NV 1 \ / EzxsTPNlaauE\ .. ww..OA I n,. w wwow[R, , imetP oor \\ .._ ,,/1 i „._ J-" J to ,aEEMMw � "' ""` fr , f� PROPOSED11 ', / r,.. �,..-.----_. 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