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HomeMy WebLinkAbout18 - DCD Staff Biologist Comments (Donna Frosthom) on No Net Loss ReportAnna Bausher From: Donna Frostholm Sent: Monday, September 25, 2017 8:27 AM To: Anna Bausher Subject: MLA17-00014/SDP17-00005 Anderson NNL Report Anna I have reviewed the No Net Loss and Mitigation Plan (report) prepared by Olympic Wetland Resources, LLC (dated April 2017), the site plan (submitted April 4, 2017), a record drawing for the septic application prepared by Nathan Cleaver Septic Design, Inc (submitted to Environmental Health on August 21, 2017), a septic application drawing prepared by Nathan Cleaver Septic Design, Inc (submitted to Environmental Health on August 22, 2016), and a drawing prepared by Nathan Cleaver Septic Design, Inc (submitted August 31, 2016). Below are my comments on the report. The report has a few incorrect references to code sections and some impact area numbers appear to be underestimated. However, the proposed mitigation is sound and would be expected to compensate for project impacts. For this reason, I am suggesting that you accept the report but add some conditions to the shoreline permit, which I have noted below. Specific comments on the report are as follows: • The introduction of this report references shoreline requirements in the 'old' shoreline master program (SMP). Since the site plan approval advance determination (SPAAD) expired prior to submittal of the residential application, any references to JCC 18.25.410 for residential development would not apply to the current application. • The section on page 1 of the report references variance sections from the 'old' SMP. Since the SPAAD has expired, any reference to JCC 18.25.600 for variance criteria is not applicable to the current application. • The report incorrectly references fish and wildlife habitat conservation areas (FWHCAs) as state of Washington areas; FWHCAs are a part of Article VI of Chapter 18.22 JCC. • The following, most of which were called out in the report, would be regulated as a FWHCA: marine water as a habitat of primary association for listed fish species; forage fish (sand lance, surf smelt); eelgrass; and commercial shellfish area. All of these occur below ordinary high water mark. • The report states that total impact area is 1,735 square feet. However, the house (1,491 square feet) and the garage (484 square feet) total 1,975 square feet of impact area. In addition, a 60 square foot porch is proposed, which brings the total impact area to 2,035 square feet. The removal of the existing structure (240 square feet) could be counted as mitigation, but does not reduce the area needed to construct the residential structures. The report states that 2,500 square feet of upland habitat along the shoreline will be revegetated. With the removal of the existing structure and the replanting of 2,500 square feet of adjacent upland habitat, the buffer mitigation ratio would be greater than 1:1. This exceeds what would be needed to compensate for the loss of the non-native herbaceous vegetation currently present in the impact area. • The Goals and Objectives in the report indicate that monitoring would occur for three years, although DCD typically requires five years. Therefore, either (1) the project biologist should be asked to prepare an addendum that addresses performance standards for monitoring years 4 and 5 or (2) DCD should add a condition to the permit requiring five years of monitoring and specify the performance standards. I have suggested performance standards for monitoring years 4 and 5 below , if you would like to go with the second option. • The Goals and Policies in the report call out a performance bond. DCD has not required this for other variances permitted under the current SMP. • The species in the Landscape Specifications table are all appropriate species to be planted in the adjacent upland habitat and the total quantity of plants listed is sufficient to meet the mitigation proposal to replant 2,500 square feet. • The total number of shrubs to be planted as presented in the Summary (page 7, 100 shrubs) does not agree with the total in the Landscape Specifications (page 5, 90 shrubs) . Since the quantities listed in the Landscape Specifications table sufficiently compensate for project -related impacts to construct the new house, garage, and covered porch, I woyild suggest adding a condition that clarifies that a total of 120 native trees and shrubs are to be planted as mitig#ion. • The report recommends planting native vegetation in the area of the existing structure, once it is removed. Since plallIlts need approximately 9- to 12 inches of topsoil to grow, the property owners may need to import topsoil to thi location. I have suggested a condition below. The following are my comments on the site plan: • The 200 -foot -wide limits of shoreline jurisdiction and the 150 -foot -wide shoreline buffer are not shown on the site plan. • The planting area or the site plan (shaded in green) does not agree with the planting area in the report (green shaded area on site plan should include area where the existing structure will be removed). • The covered porch is not shown on the site plan. Presumably, this would be on the waterward side of the proposed house and should be shown on the site plan. The following are my suggested findings, conditions, and holds: • F — A No Net Loss and Mitigation Plan prepared by Olympic Wetland Resources, LLC (dated April 2017) was prepared for this pr ject. C — The applicant shall implement the mitigation proposal in the report prepared by Olympic Wetland Resources, LLC except that (1) monitoring shall be conducted for a total of five year and the performance standard for monitoring years 4 and 5 shall be 80 percent for plant survival and shall be no more than 10 percent cover of non-native species; (2) a total of 120 native trees and shrubs shall be planted, as per the Landscape Specifications table; and (3) if approximately 9- to 12 inches of topsoil is not present within the footprint of the existing structure, the applicant shall be required to import soil to increase the chances for plant survival in this area. C —The project biologist shall be onsite to review planting locations and check plant health prior to plant installation. C — Plant substitutiorls shall be approved by DCD prior to plant installation. Non-native species and landscaping varieties shall not be approved as a plant substitution. H — Final zoning approval for: No building final until DCD has reviewed and approved the mitigation area for compliance with the approved report and permit conditions. Let me know if you have any questions. Donna FrosthoCm, PINS Associate Planner - Lead/Wetla SyeciaCist Jefferson County Department ofCommunity DeveCopment 621 Sheridan Street, Port 7ownserlc4'Washington 98368 360-379-4466 d ro lhohn 4,co.ie(momwa.us DCD is open from 9:00am — 12:00pm and 1:00pm-4:30pm Monday through Thursday; DCD is closed on Friday. All emails sent to and from this address will automatically be archived by Jefferson County and emails maybe subject to Public Disclosure under Chapter 42.56 RCW.