HomeMy WebLinkAbout018 Communication with representativeDonna Frostholm
From:
Jesse DeNike <jesse@plauchecarr.com>
Sent:
Monday, December 23, 2024 2:57 PM
To:
Donna Frostholm
Subject:
RE: SDP2024-00006 Rock Island Shellfish
Attachments:
Updated Site Plan. 1 22324.pdf; 31 jpg; Contour comparison with OHWM.png
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Hi Donna,
I've attached an updated site plan that identifies the location of the rock gabion walls, the parking lot, and the trail that
has gravel. The trail is approximately 4 feet wide, and a photograph of it is attached. Mr. Carson did not remove any
native vegetation in the areas where the gravel and rock walls are located. These areas did not have vegetation when
Mr. Carson took over the property or had only Himalayan blackberries.
The firewood is used as part of Rock Island's farming operations. Farm workers may burn the wood for heat while
conducting work at the farm. The gravel parking area is used for parking vehicles used as part of the farming operations,
and the rock walls serve as a barrier for the gravel and for retaining. The parking area is also used to lay down, stage, or
temporarily store farm materials and equipment. Note that much of the material that is shown in the picture you sent is
gear left over from the previous operator. Per direction from the Corps, Rock Island has removed this material and is in
the process of having it properly disposed of. They hope to have such material removed from the property within the
coming weeks if not sooner. None of the other equipment or other materials will remain on a permanent basis (e.g., the
fencing and boats).
The wall by Container B has lights on the back and the front for safety, so that individuals can identify/locate the front
and back of the wall. The wall by Container A has lights on the bottom that serve the same purpose. The lights are LED
and approximately 15 watts. In short, all of the items you mentioned are in support of or part of the farm, and no
residential use is proposed.
With respect to the location of the right of way, I believe Mr. Carson has had a survey performed of the properties to
confirm the boundary between his properties and the right of way. While the right of way is 60 feet wide, the centerline
of the right of way is not located at the center of the paved roadway but is rather to the north of it. If Public Works has
different information, we can follow up separately with them.
Regarding the OHWM, Confluence used information provided by NOAA. NOAA has a beach slope reference line layer
here: Untitled map which has elevations for all of the common tidal metrics. Confluence added this line to a map and
compare it to the vegetation line to see if they aligned, which in this case they did. Confluence prepared the attached
figure, which compares OHWM as identified by the County's sources and NOAA's. The two lines are very close and even
intersect in multiple places. Confluence could not put its own labels on the contours, but you can see a tiny little "5"
marking the line in front of Confluence's OHWM, which means the line behind it (that intersects with Confluence's) is
the 10-foot contour. If the County believes that its OHWM lines is more reliable, then we may be willing to just use that
line. Again, the two lines seem very close, and we would like to avoid a costly site visit if possible.
I hope this answers all your questions. If you need additional clarification, please let me know as soon as possible.
Jesse
From: Donna Frostholm <DFrostholm@co.jefferson.wa.us>
Sent: Tuesday, December 17, 2024 2:17 PM
To: Jesse DeNike <jesse@plauchecarr.com>
Subject: RE: SDP2024-00006 Rock Island Shellfish
Hi Jesse,
See below in red.
From: Jesse DeNike <iesse@plauchecarr.com>
Sent: Monday, December 16, 2024 2:44 PM
To: Donna Frostholm <DFrostholm@co jefferson.wa.us>
Subject: RE: SDP2024-00006 Rock Island Shellfish
ALERT: BE CAUTIOUS This email originated outside the organization. Do not open attachments or click on links if you are
not expecting them.
Hi Donna,
I will send these questions to Rock Island Shellfish and the consultant, and then will follow up.
In the meantime, can you please send me a map or link to the County's GIS mapping that you are reviewing for purposes
of identifying the OHWM? I'm guessing the map is available at the following link but would like confirmation as to what
DCD is relying on: https://jeffcowa.rnaps.arcgis.com/home/index.htm]. Given aquaculture-related structures are allowed
within the shoreline buffer, is the purpose of resolving any discrepancy regarding the exact location of the OHWM to
determine whether any structures unrelated to aquaculture are appropriately located? Or is there another question that
this gets to? You have the correct link. Click on 'Public Lands Records Mapping' —'OK' — and then zoom in to the
parcels. In the upper right, there is a green bar, click on the layers list icon. The contours layer can be turned on and
OHWM is generally near the 10 foot contour. In the upper right is a icon to measure distances. Also from the layers list,
you can turn on shoreline designations by clicking on 'Shoreline Permitting' and then on 'SMP — Shoreline Environment
Designations'. From the 'Basemap Gallery' (in the green bar) photos and elevation hillshades can be used. These maps
provide guidance for approximating the location of OHWM from the office. It may be that a site visit is needed to
confirm the OHWM.
The reason I need to get the extent of shoreline jurisdiction clarified is because shoreline permits can only be issued for
development and uses within 200 feet of OHWM. If the entire property is in shoreline jurisdiction, then the entire
shellfish farm can be reviewed under shoreline regulations. However, if any portion of the proposal is outside of
shoreline jurisdiction, a stormwater permit would be needed.
You are also correct that if development and uses other than aquaculture are proposed within shoreline jurisdiction,
DCD would have to ensure that the proper permitting process is followed.
Can you also please provide additional information regarding the meeting you reference with Public Works regarding
Killapie Beach Road? Is that with respect to this project, and if so, shouldn't a Rock Island representative attend? I recall
you mentioned in a Sep. 13 email that you may refer Rock Island to Public Works to discuss, but I haven't seen any such
referral to date. It has been determined that a DCD/Public Works meeting is not needed at this time. However, DCD will
be deferring to Public Works about using the county road to access Carson's three parcels. Contact Eric Kuzma, Assistant
Public Works Director, about options for using the road for the shellfish farm. His phone number is 360-385-9167 and his
email address is EKuzma@co.iefferson.wa.us .
Jesse
Port Ludlow
A & B: 20-foot
containers used for
storing aquaculture gear ' '_
and harvested oysters
(container used for
storing oysters tol
contain A/C unit
C: 20-foot trailer 014 ?cK WALLS
outfitted with solar {� L
panels supplying power
to A/C unit.
No development within
Killapie Beach Right of Way
l djacent to project parcels
- Historic and current areas
p without vegetation shown.
" No expansion of such areas
proposed.
,r- -Parcels historically used
nd proposed for shellfish
quaculture.
Containers used to store
cultivation gear and to cool
harvested product in
compliance with Dept of
v health requirements.
- Rebar to support oyster
baskets may be welded on
ite in unvegetated areas,
using stick welding with
t lectrical power generated
om solar panels.
r Project Site Location Zostera japonica N
Project Parcels C Zostera marina
— OHWM )♦ 20 ft Containers & Cargo Trailer
CONFLUENCE Proposed planting area OHWM 150 ft Standard Buffer
rA�co.MPANY Mixed seagrassspecies SMA Jurisdiction (200 it Standard Buffer) 0 100
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From: Donna Frostholm <DFrostholm co.lefferson.wa.us>
Sent: Monday, December 16, 2024 2:15 PM
To: Jesse DeNike <iesse@pIauchecarr.com>
Subject: RE: SDP2024-00006 Rock Island Shellfish
Hi Jesse,
As part of reviewing the responses sent to Department of Community Development (DCD) on October 17 and November
12, 2024, a site visit was made to Killapie Beach Road on December 4, 2024. DCD observed more gear and other items
stockpiled in the gravelly area immediately adjacent to the road than was present during the previous site visit on
August 7, 2024. County mapping indicates that Killapie Beach Road has a 60-foot-wide right-of-way so it appears gear
may still be in the road right-of-way. I have attached a photograph from the most recent site visit showing the extent of
development immediately adjacent to the road.
The most recent site plan submitted only shows three containers being proposed for the aquaculture application. As
you can see in the attached photograph, it appears much more area on the three parcels has been developed for the
proposed shellfish operation. Gravel placement and much of the gear on the property would meet the definition of
development in the Jefferson County Code (JCC) 18.25.100(4)(g), which includes the definition of structure in JCC
18.25.100(19)(rr). Please revise the site plan to show all existing development on the three parcels.
It is not clear how some of the development on the property supports the aquaculture proposal. For example, the rock
cages have an electrical hook up that appears to be lights (rock cages are shown in an attached photo). These lights are
not addressed in the Environmental Checklist. State whether the rock cages are to be retained or removed. If the intent
is to keep them, please clarify how the rock cages and lights are to be used for aquaculture operations and show them
on the site plan.
As an attached photograph shows, firewood has been stacked. Clarify if the proposal includes using the parcel for
residential purposes. If no residential use is proposed, indicate how the wood will be used in support of aquaculture
operations.
The ordinary high water mark (OHWM), as shown on the site plan submitted on November 12, 2024, is inconsistent with
county GIS mapping. Since the site plan shows OHWM farther waterward than county mapping would suggest it should
be, DCD is requesting that the a description as to how the consultant determined OHWM be submitted.
DCD is trying to schedule a meeting with Public Works to discuss Killapie Beach Road. Once that meeting has occurred, I
will follow up with you.
Once I receive the requested information, the proposal can move forward. If you have any questions, let me know.
Regards,
Donna Frostholm
Jefferson County DCD
From: Jesse DeNike <jesse@plauchecarr.com>
Sent: Friday, December 6, 2024 10:24 A
To: Donna Frostholm <DFrostholm@co.lefferson.wa.us>
Subject: RE: SDP2024-00006 Rock Island Shellfish
ALERT: BE CAUTIOUS This email originated outside the organization. Do not open attachments or click on links if you are
not expecting them.
Hi Donna,
I'm checking back in to see if you have additional questions about the information below and when we might get the
hearing set. As you may know, oyster farming (in particular, the planting period) is seasonal dependent, and we would
like to have the hearing scheduled for early this winter in order to ensure the farm can be installed for the upcoming
planting season.
Thank you.
Jesse
Frgm: Jesse DeNike
Sent: Tuesday, November 26, 2024 11:27 AM
To: Donna Frostholm <DFrostholm@co.iefferson.wa.us>
Subject: RE: SDP2024-00006 Rock Island Shellfish
V1
Hi Donna, (1 -
The site plan was pTpared by consultants at Confluence Environmental Company. I asked them to reconfirm with me
that the site plan is td, cale, and they said that it is. They also said that th OHWM is accurate based on available
information, and the sh\oreline buffer and shoreline limits are accurately placed with respect to the indicated OHWM
line. \\
With respect to the current use f the property, as previously discussed it was purchased by Mr. Carson's family recently
to continue shellfish cultivation ac 'vities. When it was acquired, there were areas of the uplands that had been
previously cleared of vegetation, so of which were infested with Himalayan blackberries. There were also prior
structures that had been used by the pr ious operators/owners.
Mr. Carson has been (and is currently) managing the property in support of aquaculture. The only structures currently
on the property (identified on the site plan and '\priously
�low) are in support of aquaculture. All areas currently
without vegetation are in historically cleared areonly vegetation removal that Mr. Carson has conducted is to
remove Himalayan blackberries that have infestecleared areas. Further, Mr. Carson has allowed native
vegetation to reestablish in previously cleared arson has a great appreciation for the natural environment
and intends to keep the footprint of operations t�m needed for the farm's success.
With respect to the road right-of-way, ther as some rock place\righ
rea previously, and it was likely there during
the August site visit. Mr. Carson has exper enced other individualg vehicles in that right of way in a dangerous
or intimidating manner, and the rock hell dissuade those activn concerns were raised regarding materials
placed in the right of way, this rock has now been removed from f way.
If you have any questions or concerns regarding the above items, it may be most efficient to discuss over a call. Please
let me know if that is the case, and when you expect the hearing to be schedule
Thank you.
Jesse
From: Donna Frostholm <DFrostholm@co.iefferson.wa.us>
Sent: Monday, November 25, 202410.05 AM
To: Jesse DeNike <'esse P plauchecarr.com>
Subject: RE: SDP2024-00006 Rock Island Shellfish
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