HomeMy WebLinkAboutMLA16-00094 Habitat Survey and No Net Loss Assessmentr
s JAN 3' 2018
Habitat Survey
and
No Net Loss Assessment
for the
Nealey Bulkhead replacement
Brinnon, Washington
Prepared for:
Terry Nealey
227 N Cherry Street
Dayton, Washington 99328
(509) 520-8383
Prepared by:
Ecological Land Services, Inc.
1157 3'd Avenue, Suite 220A
Longview, Washington 98632
(360) 578-1371
Project Number 2636.01
January 31, 2018
CABLE OF CONTENTS
INTRODUCTION................................................................................................................................1
JEFFERSON COUNTY SHORELINE MASTER PROGRAM..................................................................1
SITEDESCRIPTION..........................................................................................................................1
SITEDEVELOPMENT PROPOSAL.....................................................................................................2
ENVIRONMENTAL AND HABITAT CONDITIONS...............................................................................2
SHORELINE ENVIRONMENT............................................................................................................
2
WILDLIFEINVENTORY...................................................................................................................
2
BUFFERFUNCTIONS.......................................................................................................................
3
IMPACTANALYSIS...........................................................................................................................3
Shoreline Designation and Zoning Map
ShorelineImpacts.....................................................................................................................
3
Shoreline Buffer Impacts..........................................................................................................
4
HABITAT AREA DESCRIPTION.........................................................................................................4
Site Photos
STATE AND FEDERALLY LISTED SPECIES AND CRITICAL HABITAT .............................................
5
WASHINGTON DEPARTMENT OF FISH AND WILDLIFE, PRIORITY HABITATS AND SPECIES ........
5
WASHINGTON DEPARTMENT OF NATURAL RESOURCES, WATER TYPING ..................................
5
WASHINGTON DEPARTMENT OF NATURAL RESOURCES, NATURAL HERITAGE PROGRAM........
6
WASHINGTON DEPARTMENT OF ECOLOGY, COASTAL ATLAS .....................................................
6
JEFFERSON COUNTY CRITICAL AREA AND HABITAT MAPPING ...................................................
6
RESEARCH AND SITE INVESTIGATION...........................................................................................
6
HABITATNARRATIVE.........................................................................................,............................
7
MITIGATIONSEQUENCING..............................................................................................................9
Special Management Recommendations..................................................................................
9
NONET LOSS ASSESSMENT.........................................................................................................
10
LIMITATIONS.................................................................................................................................10
REFERENCES..................................................................................................................................11
FIGURES & PHOTOPLATES
Figure 1
Vicinity Map
Figure 2
Existing Conditions
Figure 3
Site Plan
Figure 4
Shoreline Designation and Zoning Map
Figure 5
Coastal Shoreline Photo -2006
Figure 6
Coastal Atlas Map
Photoplates
Site Photos
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SIGNATURE PAGE
The information and data in this report were compiled and prepared under the supervision and
direction of the undersigned.
—4 WAM-4— a:&ktr `
Joanne Bartlett, PWS
Senior Biologist
LjaLira Westervelt
Biologist
Terry Nealey — Nealey Bulkhead Replacement Ecological Land Services, Inc.
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INTRODUCTION
Ecological Land Services, Inc. (ELS) has been contracted by Terry Nealey to conduct a no net loss
and floodplain assessment (NNL) to address potential impacts associated with a bulkhead
replacement for the property at 351 Pleasant Harbor Road in Brinnon, Washington. The property
consists of a residential shoreline lot, Jefferson County Tax Parcel Number 988200103, that lies
in a portion of Section 10, Township 25 North, Range 2 West of the Willamette Meridian
(Figure 1). The project is located within the 200 -foot shoreline jurisdiction and requires
completion of the no net loss assessment to satisfy the requirements of Jefferson County Code,
Title 18, Shoreline Master Program (JCCSMP). Mitigation sequencing is required to address
potential impacts associate with the new bulkhead within the shoreline buffer and achieve no net
loss of buffer function and habitat for the shoreline community.
JEFFERSON COUNTY SHORELINE MASTER PROGRAM
This project is being reviewed under the updated JCSMP that was adopted in 2015 because it is
within 200 feet of the shoreline of Pleasant Harbor, part of Hood Canal. The entire property lies
within 200 feet of the shoreline so it is under shoreline jurisdiction and requires mitigation
sequencing to evaluate potential impacts under Jefferson County Shoreline Master Program
(JCSMP). Under the current administrative process, projects proposing construction within the
designated shoreline buffer and FEMA 100 year floodplain must complete a habitat survey, no net
loss analysis, and floodplain assessment to document existing conditions and show that there will
be no net loss of buffer function per Section 18.25 of the JCSMP.
SITE DESCRIPTION
The 0.17 -acre property is located on the east side of Pleasant Harbor Road in Brinnon, Jefferson
County, Washington (Figure 1). The wedge-shaped property widens slightly towards the shoreline
(Figure 2). The shoreline residential lot is comprised of a single-family cabin and deck that is
situated on a moderate slope with stairs that access the beach situated on a steep embankment.
There is a level parking area between the road and the cabin (Photoplates 1 and 2). A narrow path
of paving stones on the north property line serves as shared access to the top of the shoreline bank
with the adjacent property (Photoplates 2 and 3). Along the top of the shoreline bank, there is an
old fence and minimal shrub vegetation (Photoplate 3). Towards the south end of the open top of
bank, there is a corner of maintained lawn and a fire pit (Photoplates 4 and 5). The beach stairs
begin at the top of the bank and scale the steep slope down to the shoreline (Photoplates 5 and 6).
There is a shed and lean-to used for storing boats and kayaks stilted above the beach (Photoplates 6
and 8). The south half of the concrete bulkhead is intact and the north half of the shoreline bank is
comprised of chunks of concrete from the old bulkhead and some debris used to prevent continued
erosion (Photoplate 7). The bulkhead was damaged in a storm event. Most of the property is
densely vegetated with mature fir trees and native shrubs except where shrubs have been cleared to
allow access to the beach stairs. The beach was observed during low tide at the November 2017
field visit. The beach slopes gently to the water and is comprised of sand and small cobble with
oyster shells and some boat wreckage. There was no aquatic vegetation observed in the debris
wrack and the beach is unvegetated. Properties to the north and south have similar stairs and sheds
with low concrete bulkheads (Photoplates 7 and 8).
Terry Nealey — Nealey Bulkhead Replacement Ecological Land Services, Inc
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SITE DEVELOPMENT PROPOSAL
The proposal involves the repair of about 25 feet of shoreline bank for stabilization. The north
half of the shoreline bank has no bulkhead and is subject to significant erosion by tides. Plastic
sheet pilings will be driven into the ground about 3 feet deep and cables will anchor the pilings to
the slope below ground. Filter fabric and gravel will backfill the space behind the piles to
improve drainage conditions and prevent further erosion (Figure 3). The project proposes no new
impacts because the property had a complete bulkhead in the past and repair is necessary to
prevent issues in the future.
In order to accommodate the proposal for work near the beach, the project must address potential
impacts to the 150 foot shoreline buffer. The bulkhead will be located at the ordinary high water
mark (OHWM). There will be no new permanent impacts to important habitat or vegetation. The
addition of the new portion of bulkhead will not result in new or destructive impacts to the
shoreline so therefore achieves no net loss of shoreline buffer function.
ENVIRONMENTAL AND HABITAT CONDITIONS
Shoreline Environment
The shoreline adjacent to this lot is located along the north edge of Pleasant Harbor on the west
side of Hood Canal (Figure 1). This section of shoreline is composed of a cobble beach with sand
and some shell debris (Photoplate 8). Maps obtained for this project indicate the presence of
patchy eelgrass to the south of the property in Pleasant Harbor (DOE 2014) (Figure 5). Estuarine
wetlands are mapped within this area of the bay however, no estuarine conditions were observed
on the shoreline along this section of Pleasant Harbor during the site visit.
This section of shoreline is composed of developed residential properties with nearly 100 percent
armoring along the OHWM consisting of bulkheads that extend down the shoreline for several
hundred feet to the north and south (Photoplate 8). The bulkheads on either side of this lot are
constructed of concrete (Figure 6). This bulkhead appears to have been constructed right along
the OHWM. The properties to the north and south have similar shoreline slopes with boat houses
and stairs upslope of the bulkheads. Both have vegetation growing on the slope that is comprised
of native and non-native shrub vegetation (Figure 6).
Wildlife Inventory
There is no breeding habitat for Pacific sand lance (Ammodytes hexapterus) or any other forage
fish mapped within the shoreline environment (WDFW 2015). There is, however, presence of
oyster beds and Dungeness crab mapped within Hood Canal. Northern Spotted Owl buffer
management area is mapped over the entire township, however, there are no habitat areas mapped
for the shoreline adjacent to this lot. No terrestrial habitat or wildlife occurrences are mapped on
this or the adjacent properties. There are no habitat features available for the federally listed
endangered, threatened, or sensitive species in the vicinity of this project except for listed
salmonids species, which utilize Puget Sound and Hood Canal as part of their lifecycle
(USFWS/NOAA Fisheries 2015). None of the species identified during online research were
observed during the site visit conducted on November 29, 2017. The shoreline environment
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appears to be in a natural condition waterward of the bulkhead with no recent disturbances
observed so provides quality habitat to the species identified within this area of the shoreline.
Buffer Functions
This lot lies within a shoreline residential designation and is zoned Rural -Residential, which
allows 1 dwelling units per 5 acres. There is residential development to the north and south of the
lot that also have boat houses and bulkheads on the beach. Because the shoreline slope is so
steep, the onsite buffer function is fairly low except where native shrubs and trees are growing.
The width of buffers necessary to protect a critical area from degradation is related to the functions
of the critical area and the buffer itself (Castelle, et al. 1992). Buffers function to protect water
quality of critical areas including shorelines by removing sediment and nutrients from runoff and
the function depends on the type of soils, vegetation, and characteristics of the runoff. The
function of buffers is also based on width and slope. In some cases, buffers as low as 50 feet are
effective in filtering pollutants when there is dense groundcover, no slope or a gradual slope, and
the runoff sheet flows across the buffer. The buffer function on this site is a result of steep
topography and historic use as a residential waterfront property. The main function provided by
the onsite buffer includes the ability to filter pollutants and slow the runoff generated on upslope
impervious surfaces that partially reduces the degradation of the shoreline environment. Most of
the runoff generated on this lot originates on level grassy terrain and appears to slowly discharge to
the shoreline by infiltrating through the soil.
Buffers function to limit human intrusion when there are dense vegetation communities which
humans cannot penetrate. These dense vegetation communities also reduce indirect human
impacts such as noise and light, which can affect shoreline areas. The value of the buffer to
provide these functions is based on the condition of the shoreline and wildlife that are currently
utilizing the shoreline (Sheldon, et al. 2005). The shoreline slope is too steep for access aside
from the existing stairs. The buffer functions relatively well in a residential setting.
IMPACT ANALYSIS
Shoreline Impacts
The shoreline of Pleasant Harbor will not be directly impacted by onsite construction activities
because the project represents temporary impacts in an area already disturbed by human
development (Photoplate 6). The bulkhead is proposed in the same location as the previous
bulkhead and therefore avoids new impacts to the shoreline. There will be no impact to vegetation
cover within the buffer because the work will be conducted from the beach and there is no
vegetation growing at the bottom of the shoreline slope. There will be no increase in the amount of
runoff generated onsite because the bulkhead is vertical and will not increase the amount of
impervious surface. There will be no indirect stormwater impacts on the shoreline because the
stormwater generated onsite will remain exactly the same as before.
Noise generated during bulkhead construction, which will include use of equipment and workers to
install the pilings, may influence use of the shoreline environment by wildlife species. This area is
already developed and there is noise currently generated by the existing and adjacent homes. There
will likely be an increase in noise generated during construction but once construction is
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completed, the noise will return to current levels. Noise and light impacts are currently generated
on the adjacent residential lots.
Shoreline Buffer Impacts
The project proposes to construct the bulkhead in the exact location of the previous bulkhead and
in line with the existing concrete bulkhead, which demonstrates avoidance of additional
buffer/shoreline impacts and new impacts. Because the buffer is currently very steep and vegetated
with natives, increased protection will be afforded to the shoreline environment particularly with
regard to habitat. The bulkhead will protect the slope from further erosion which will prevent
excessive sediment and debris from impacting the shoreline. The project will only temporarily
increase the amount of noise and light generated on this lot but will return to normal post -
construction.
The new bulkhead represents a minimal increase in impervious surface so there will be no negative
impact to the shoreline buffer because the bulkhead will serve to protect the shoreline from
continued erosion. Water quality onsite will not change and the new bulkhead will improve onsite
drainage to encourage infiltration. The site will not generate any new pollutants or sediments that
will have a negative impact on the shoreline environment. It will also not change the conditions or
use of the area.
HABITAT AREA DESCRIPTION
The property lies on the west shore of Hood Canal and north of Pleasant Harbor (Figure 1). There
is residential development along the top of the bluff beginning in Brinnon and extending south
around the horn of Pleasant Harbor. The bluff is generally vegetated with native conifer trees and
shrubs partially overhanging the OHWM of the shoreline in places. There are conifer trees rooted
at the top of the bluff onsite, but are sheered off to maintain the view from the cabin. The bluff is
nearly vertical and drops about 30 feet from the terrace on which the lawn area is situated to the
shoreline below. There are mature fir trees between the top of the bluff and Pleasant Harbor Road
which form a dense canopy and prevent the cabin from being seen on aerial photos. The bluff
decreases in height to the north towards Brinnon.
The beach slopes gradually to the water from the toe of the bluff. It is composed of gravel and
sand with some cobble and boat debris. There is some evidence that the bluff has eroded in the
past near the toe due to high tides. The beach is unvegetated and wrack from previous high tides
was composed of woody material and needles from the fir trees. There was no eelgrass or other
marine vegetation observed in the wrack.
The potential presence of listed species, including fish, bird, and mammals, as well as critical
habitat that have a primary association with the habitat of Hood Canal was evaluated by a site visit,
aerial images, the Jefferson County Critical Areas website (Jefferson County 2017), Washington
Department of Fish and Wildlife (WDFW Priority Habitats and Species website (WDFW 2017),
the U.S Fish and Wildlife Service (USFWS 2017) website, the NOAA Fisheries website (NOAA
2016), and the Washington Department of Nature Resources Natural Heritage website (WDNR
2017).
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STATE AND FEDERALLY LISTED SPECIES AND CRITICAL HABITAT
Federally listed fish, bird, and mammals for Hood Canal and Jefferson County (WDFW 2017)
identified using the NOAA Fisheries and USFWS websites are presented in Table 1.
Table 1: State and Federally Listed Endangered and Threatened Species and Critical Habitat
Species, ESU or DPS 2
State Status$
IStatus
Federal
s
Critical Habitats in
Project Wini
Puget Sound ESU
_
Candidate
Threatened
Yes
Chinook Salmon Onchorhynchus tshaw tscha)
Puget Sound DPS
None
Threatened
Yes
Steelhead (Onchorhynchus mykiss)
Bull Trout (Salvelinus confluentus)
Candidate
Threatened
Yes
_ _
Birds
Marbled murrelet
Threatened
Threatened
No
(Brachyram hus marmoratus)
Yellow -billed Cuckoo
Candidate
Threatened
9
No
(Coccvzus americanus)
Streaked Horned lark
Endangered
Threatened
No
Eremo hila al estris stri ata
Mammals
Southern Resident DPS Endangered
Endangered
Yes
Killer Whale Orcinus orca)
_
Hum back WhaleKe atera novaean liae Endan ered
Endangered
Yes
1) ESU - Evolutionarily Significant Unit. A distinct group of Pacific salmon.
2) DPS — Distinct Population Unit.
3) Endangered - In danger of becoming extinct or extirpated; Threatened - Likely to become endangered within the foreseeable future
throughout all or a significant portion of its range and that has been formally listed as such in the Federal Register under the Federal
Endangered Species Act; Sensitive - Vulnerable or declining and could become Endangered or Threatened in the state; Species of
Concern - An unofficial status, the species appears to be in jeopardy, but insufficient information to support listing. State candidate
species include fish and wildlife species that the Department will review for possible listing as State Endangered, Threatened, or
Sensitive. A species will be considered for designation as a State Candidate if sufficient evidence suggests that its status may meet the
listing criteria defined for State Endangered, Threatened, or Sensitive.
4) Washington Department of Fish and Wildlife, PHS website
5) NOAA 2015
WASHINGTON DEPARTMENT OF FISH AND WILDLIFE, PRIORITY HABITATS AND SPECIES
The Washington Department of Fish and Wildlife Priority and Habitat and Species (PHS) website
(WDFW 2017) identifies the presence of oyster beds, Dungeness crab, and Pandalid shrimp within
this portion of Hood Canal. It also lists priority habitat for northern spotted owl and estuarine zone
and wetlands along the intertidal zone, however, no estuarine wetlands were identified in this
section of shoreline or within 200 feet of this property.
WASHINGTON DEPARTMENT OF NATURAL RESOURCES, WATER TYPING
The Washington Department of Natural Resources, Forest Practices Application Review System
(FPARS) mapping website (WDNR 2016a) identifies Hood Canal as a Type S water because it is a
shoreline of the state.
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WASHINGTON DEPARTMENT OF NATURAL RESOURCES, NATURAL HERITAGE PROGRAM
The Washington Department of Natural Resources, Natural Heritage Program (WDNR 2016b)
identifies seven species of rare plants in Jefferson County. The property for which this assessment
has been conducted is developed and maintained, which is primarily dominated by fir trees and
non-native vegetation. No rare plants were identified during the field visit within the floodplain
area, which comprises the very east edge of the property just upslope of the OHWM.
WASHINGTON DEPARTMENT OF ECOLOGY, COASTAL ATLAS
The Washington Department of Ecology (Ecology 2016b), Coastal Atlas Mapping tool does not
identify any marine plant species in this section of Hood Canal. It does indicate patchy eelgrass
and dunegrass fringe along the shoreline around Pleasant Harbor to the south (Figure 6). No other
significant features were noted on the coastal atlas map. No kelp or seaweed accumulations were
noted in the wrack or dispersed on the beach during the November 29, 2017 site visit.
JEFFERSON COUNTY CRITICAL AREA AND HABITAT MAPPING
The Jefferson County Critical Area Maps (JCCA) viewed through the on-line mapping website
was used to identify the presence of critical areas found within and along the shores of Hood Canal
(Jefferson County 2017). The tool maps the property as shoreline residential, indicates wetlands in
the intertidal zone, and FEMA 100 -year floodplain (Figure 5). No estuarine or freshwater wetlands
are mapped on or adjacent to the property or within Hood Canal.
The floodplain area extends from the shoreline of Hood Canal to the beach just below the OWHM
(Figure 4). This portion of the floodplain is composed of a gradual slope absent any vegetation
(Photoplate 8). There are native trees on the slope to the west that overhanging the floodplain and
the upper half of the beach slightly (Photoplates 6 and 8). The mapped floodplain extends south to
Pleasant Harbor. The floodplain mapping also extends north to downtown Brinnon, which lies
north of the property.
RESEARCH AND SITE INVESTIGATION
Fish and Whales
Hood Canal is part of the Puget Sound so it provides habitat for the listed fish and aquatic mammal
species appearing on Table 1. The cobble and sandy beach is un -vegetated and did not contain any
vegetation, seaweed, or eelgrass accumulations (Photoplate 8). The wrack observed on the beach
was composed of small woody debris and seaweed but no eelgrass was documented. Larger
driftwood was observed at the highest point of the beach. The bluff is mostly vegetated with native
fir trees with occasional shrub outcroppings that provide some shading of the shoreline at the toe of
the bluff (Photoplates 6 and 7). However, there is minimal tree canopy to provide additional
shading over the floodplain section of the shoreline. Therefore, the floodplain area of this section
of shoreline provides little to the food web for the listed species. The floodplain area lacks
freshwater habitat and other features that would be important in the life cycle of the listed species,
except that it provides saltwater habitat for the listed fish that utilize Hood Canal.
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Birds
Research conducted for this project shows that the property is not within habitat or management
areas for marbled murrelet, streaked horned lark, and yellow -billed cuckoo (WDFW-PHS 2015;
USFWS 2015). The upland along this section of Hood Canal is developed with residential homes
within 100 feet of the shoreline. There are no habitat features or known habitat for the listed bird
species particularly within the mapped floodplain. The trees at the top of the bluff may be utilized
by local raptor species including bald eagles, but they are located outside the floodplain.
Plants
The Washington Department of Natural Resources, Natural Heritage Program website (WDNR
2016b) lists seven rare plant species that occur within Jefferson County. None of the listed species
or suitable habitat was identified on the property during the November 2017 site visit.
HABITAT NARRATIVE
The habitat narrative includes a discussion of the primary constituent elements (PCEs) for the
species that appear on the endangered, threatened, and sensitive list for this area of Hood Canal as
they appear in the FEMA floodplain habitat assessment guidance (FEMA 2013). The PCEs
include those associated with fish and mammal species utilizing Hood Canal as part of their life
cycle as they would be the most likely species found in floodplain areas of saltwater shorelines.
Primary Constituent Elements
The primary constituent elements for the critical habitat of Puget Sound salmon and steelhead in or
adjacent to Hood Canal include:
• Freshwater spawning sites with water quantity and quality conditions and substrate
supporting spawning incubation and larval development.
• Freshwater rearing sites with:
o Water quantity and floodplain connectivity to form and maintain physical habitat
conditions and support juvenile growth and mobility,
o Water quality and forage supporting juvenile development,
o Natural cover such as shade, submerged and overhanging large wood, log jams, and
beaver dams, aquatic vegetation, large rocks and boulders, side channels, and
undercut banks.
• Estuarine areas free of obstruction and excessive predation with
o Water quality, water quantity, and salinity conditions supporting juvenile and adult
physiological transitions between fresh- and saltwater,
o Natural cover such as submerged and overhanging large wood, aquatic vegetation,
large rocks, and boulders, side channels,
o Juvenile and adult forage, including aquatic invertebrates and fishes, supporting
growth and maturation.
• Nearshore marine areas free of obstruction and excessive predation:
o Water quality and quantity conditions and forage, including aquatic invertebrates
and fishes, supporting growth and maturation,
o Natural cover such as submerged and overhanging large wood, aquatic vegetation,
large rocks and boulders, and side channels.
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• Offshore marine areas with water quality conditions and forage, including aquatic
invertebrates and fishes supporting growth and maturation.
This section of Hood Canal floodplain is composed of cobble and sandy beach at the toe of the
vertical shoreline bluff. The bluff is dominated by sheered fir trees with some non-native shrubs.
No stream channels are present near the property that drains on the beach or within the sloping
floodplain area. The beach itself is composed of cobble and lacks vegetation with only a small
amount of driftwood so provides minimal protection or feeding areas for the listed species. An
assortment of larger rocks and old concrete debris are also present across the beach. Trees
overhang the upper half of the beach on the properties to the immediate north and south of the
property but there is very little vegetation overhanging the onsite portion of floodplain. The only
available primary constituent elements available on or adjacent to this property are the nearshore
and offshore marine areas. The nearshore area on this property does not have overhanging large
wood, aquatic vegetation, large rocks and boulders, or side channels that would prove valuable to
the listed fish species. However, the sand and cobble of the beach is likely valuable as breeding
areas for sand lance, pacific herring, and surf smelt.
Water Quality
Portions of Hood Canal appear on the list of 303(d) waters (DOE 2017a) and there are no
freshwater 303(d) waters that drain into Hood Canal within 1 mile of this property.
Water Quantity
The floodplain is mapped outside the east end of this property is composed of gradually sloping
beach and no vegetation. There are no inputs of water from the upland in this area because of the
steep bank. No freshwater streams or other waterbodies were noted within several hundred feet to
the north and south of the property.
Vegetation Communities and Habitat Structures
The shoreline along this section of Hood Canal is composed of cobble and sand that gradually
slopes down waterward from the toe of the bluff (Photoplates 6 and 8). The bluff itself is mostly
dominated by sheered fir trees with occasional shrub cover (Photoplates 5, 6, and 8). The area at
the top of bluff is maintained by mowing with several Douglas fir trees. Additional fir trees are
scattered across the property and form a forest canopy (Photoplates 3 and 4). The fir trees and
shrubs provide some shading and protection habitat at the OHWM as well as food sources (bugs,
berries, and the like). There are trees and shrubs growing on the shoreline slope to the north and
south of this property (Photoplates 6 and 8).
Floodplain Refugia
There is little floodplain refugia on this property but there is significant refugia provided by the
overhanging trees and native shrub understory farther to the north of the property (Figure 6).
Driftwood along this section of Hood Canal is mostly small to medium in size and accumulates at
the toe of the shoreline slope (Photoplate 7).
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MITIGATION SEOUENCING
This lot lies entirely within 200 feet of Hood Canal, which represents the only critical area on or
adjacent to the property. A new bulkhead is proposed along a portion of the shoreline just outside
the ordinary high water line. This repair portion of the buffer is currently composed of concrete
blocks and debris remaining from patched attempts to stabilize the slope (Photoplate 7). As part of
the mitigation process, projects are required to address mitigation sequencing to assess whether the
project can avoid, minimize, rectify, or reduce impacts before identifying compensation or
mitigation measures.
Avoiding Impacts: The entire lot is within shoreline jurisdiction. The shoreline buffer covers the
entire property as well and extends to Pleasant Harbor Road (Figure 2). The bulkhead is proposed
in the only feasible location because it will be joined with the existing bulkhead at the toe of the
steep shoreline bank. The bulkhead is designed to allow water to drain and infiltrate to avoid new
erosive impacts. Work will be performed at low tide in order to avoid impacts to important marine
wildlife. Impacts are temporary and the beach will return to its current state post -construction.
Minimizing Impacts: The project is minimizing impacts to the shoreline buffer by proposing the
new bulkhead using materials that will not leech chemicals into the water over time. The new
bulkhead will represent a permanent structure in the shoreline environment, but serves to minimize
the amount of debris being used to stabilize the slope by replacing chunks of concrete and plastic
with plastic piles.
Rectifying the Impacts: The project represents a permanent impact to the buffer within shoreline
jurisdiction so cannot rectify the impacts to the affected habitats.
Reducing or Eliminating the Impacts: The project cannot reduce or eliminate the impacts by
preservation and maintenance.
Compensating for the Impacts: The project cannot avoid, rectify, or reduce the impact to the
shoreline buffer but has minimized the impact to the extent possible by proposing to replace the
bulkhead in the area that was once occupied by a bulkhead. Because the project will construct a
bulkhead in an area that has historically been used for the same purpose, there are no new impacts
to the shoreline buffer. The shoreline slope is already heavily vegetated with native trees and
shrubs with minimal cover by invasive plant species (English ivy and Himalayan blackberry). The
bank is so steep that removing any vegetation will create bare soil and promote erosion. Once
construction activities are completed, the shoreline buffer will return to pre -construction condition.
Special Management Recommendations
Management recommendations for critical areas including shorelines involve identifying measures
that will preserve high quality conditions or rectify disturbed conditions that maintain or improve
the function of the critical area. Buffers are one of the main management methods employed to
protect the function of critical areas. In areas where buffer conditions are poor, enhancement is
conducted to improve the buffer function and often enhance or improve the function of the critical
area as well. Other special management recommendations are applied to aid in the preservation of
special critical areas, wildlife species, and/or wildlife habitats that require additional protection
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measures to preserve their function and populations. They are often developed for endangered,
threatened, sensitive, species of concern, rare habitat areas, etc. to preserve the critical area, habitat,
or species. No special management recommendations are necessary for this project because there
are no endangered, threatened, sensitive species or rare habitat areas on or in the vicinity of the lot
that require special protection measures. The shoreline area represents the most important critical
area adjacent to the lot and does not require special protection measures because this project will
have no direct or indirect impacts on the shoreline environment.
During construction activities, best management practices will be utilized to protect the shoreline
environment with regard to siltation caused by exposed soils within the impacted buffer. Onsite
construction activities will be conducted during the summer months to reduce the chance of rain
events that could cause siltation into the downslope shoreline buffer and environment. Best
management practices for siltation will include use of silt fences, hay bales, and other means to
prevent movement of soil material in the critical area during all phases of the construction process.
No Net Loss Assessment
Because the project proposes to replace a bulkhead that was damaged by a storm event, there will
be no -net -loss of buffer function of the shoreline environment. The shoreline slope is currently
dominated by native shrubs and trees so there is little potential for improvement of buffer function.
Construction work is the minimum necessary to continue to protect the cabin and the shoreline
from erosion. Because the project will replace a damaged bulkhead, this project achieves the no
net loss requirement of the JCSMP.
LIMITATIONS
The conclusions listed above are based on standard scientific methodology and best professional
judgment. In our opinion, local, state, and federal regulatory agencies should agree with our
conclusions; however, this should be considered a preliminary proposal that must be reviewed and
approved in writing by the regulatory agency with jurisdiction of the project and the hearing
exammer.
Terry Nealey — Nealey Bulkhead Replacement Ecological Land Services, Inc
No Net Loss Mitigation Plan 10 January 3/, 2018
REFERENCES
Castelle, A.J., C. Conolly, M. Emers, E.D. Metz, S. Meyer, M. Witter, S. Maurermann, T.
Erickson, S.S. Cooke. 1992. Wetland Buffers: Use and Effectiveness. Adolfson
Associates, Inc., Shorelands and Coastal Zone Management Program, Washington
Department of Ecology. Olympia. Pub. No. 92-10.
Jefferson County Code. 2015. Title 18 Shoreline Management Program.
Jefferson County Parcel Search, 2015. https://ieffcowa.reaps.arcgis.com/home/index.html
Accessed December 2017.
Sheldon, D. T. Hruby, P. Johnson, K. Harper, A. McMillan, T. Granger, S. Stanley, and E.
Stockdale. March 2005. Wetlands in Washington State — Volume 1: A Synthesis of the
Science. Washington State Department of Ecology. Publication #05-06-006. Olympia,
WA.
United States Fish and Wildlife Service (USFWS). Endangered Species Website.
http://www.fws.gov/endan erect/. Website accessed December 2017.
Washington Department of Ecology. 2011. Washington State Coastal Atlas
bfts://fortress.wa.,ggy/ecy/coastalatltts/. Website accessed December 2017.
Washington Department of Fish and Wildlife. 2016. Priority Habitats and Species PHS on the
Web. h ://a s.wdfw.wa. oy/ hsontheweb/. Website accessed December 2017.
Terry Nealey — Nealey Bulkhead Replacement Ecological Land Services, Inc
No Net Loss Mitigation Plan 11 January 31, 2018
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Photo 1 was taken from the side
of Pleasant Harbor Road looking
'{ north. There is a driveway
entrance near the north property
line that leads to a parking area in
front of the cabin. Almost all
.tea` vegetation onsite is comprised of
native trees and shrubs.
Photo 2 was taken from the
same location as Photo 1 facing
east. There is an additional
parking space for one vehicle
closer to the south property
line. There is a narrow
footpath leading to the front
door of the cabin.
Photo 3 was taken from the top
of the narrow path leading to
the front of the cabin. Native
shrub and herbaceous
vegetation line both sides of
the path, which also leads to
the open parking area in front
of the cabin.
11573 d Ave. Suite 220A DATE: 12/11/17 Photoplate 1
Project Name: Nealey
Longview, WA 98632 DWN: LHW Bulkhead Replacement
ECv �ICa� (360) 578-1371 PRJ. MGR: LHW Client: Terry Nealey
Land Services Fax: (360) 414-9305 PROJ.#: 2636.01 Jefferson County, Washington
-.7, 5
'f �
k ar a
- - 1
r�
�x �,. � �. �,'�+ , �,.• ter,+ -
�i� '� ,�.'�' i! pr's � �. , i...� �-a�•��'k�C
Photo 4 was taken from the
parking area in front of the cabin
looking northwest towards
Pleasant Harbor Road. There is
no pavement on the property.
Photo 5 was taken from the
same location as Photo 4 facing
northeast. It looks at the front
door of the cabin and the native
species used in landscaping. A
shared walking path occurs
between this cabin and the
adjacent property on the left
side of the photo.
Photo 6 was taken from the top
of the walking path between
properties which leads down to
the shoreline bank. The
properties slope moderately
from Pleasant Harbor Road to
the top of the shoreline bank.
Tn DATE: 12/11/17 ct Name:
2
1157 3 Ave., Suite 220A Project Name: Nealey
Longview, WA 98632 PRJ. LHW Bulkhead Replacement
AIA�i\k- (360) 578-1371 PRJ. MGR: LHWL C G «z Fax: (360) 414-9305 PROJ.#: 2636.01 Client: Terry Nealey
Land Services Jefferson County, Washington
FA
Photo 7 was taken from the east
end of the shared walking path
looking west towards where
Photo 6 (Photoplate 2) was taken.
Vegetation between the cabin and
the top of the shoreline bank is
entirely natural.
Photo 8 was taken from the
same location as Photo 7 facing
southwest. It looks across the
relatively open area between
the cabin and the beach stairs.
There are many fir trees in this
area, but some shrub vegetation
is being maintained to keep an
open walkway to the stairs.
Photo 9 was taken from the
same location as Photos 7 and
8. It looks south along the top
of the shoreline bank. The
beach stairs begin near the
middle of the east property
line. On the southern corner of
the bank, there is a corner of
maintained lawn and a fire pit.
1157 Yd Ave., Suite 220A
DATE: 12/11/17
Photoplate 3
Project Name: Nealey
4 Longview, WA 98632
DWN: LHW
Bulkhead Replacement
Ecological (360) 578-1371
PRJ. MGR: LHW
Client: Terry Nealey
Land Services Fax: (360) 414-9305
PROJ.#: 2636.01
Jefferson County, Washington
4ru
xrTi m
' is
Photo 10 was taken from the
south end of the top of the
shoreline bank. It looks west
along the south property line.
The lawn area is contiguous with
the open area between the cabin
and the beach stairs.
Photo 11 was taken from the
same location as Photo 10
facing northwest. It looks
across the relatively open area
between the cabin and the
beach stairs. There are many
native trees and shrubs in this
sloping area.
Photo 12 was taken from the
same location as Photos 10 and
11. It looks north along the old
split rail fence at top of the
r. shoreline bank. Native trees
and shrubs vegetate the top of
the shoreline slope and are
being maintained to allow the
view to remain open.
1157 3 ra
Ave., Suite 220A
DATE: 12/11/17
Photoplate 4
Project Name: Nealey
wog
Longview, WA 98632
DWN: LHW
Bulkhead Replacement
-a 1
(360) 578-1371
PRJ. MGR: LHW�
Client: Terry Nealey
Land Services
Fax: (360) 414-9305
PROJ.#: 2636.01
Jefferson County, Washington
Photo 13 was taken from the
lawn area looking east at Pleasant
Harbor over the maintained fir
trees. The fire pit is visible in the
foreground.
Photo 14 was taken from the
same location as Photo 13
looking towards the top of the
beach stairs from the lawn.
Photo 15 was taken from
bottom of the second landing
of the beach stairs. The stairs
are steep and duck under the
vegetation rooted on the
shoreline bank.
11573 d Ave., Suite 220A
DATE: 12/11/17
Photoplate 5
Project Name: Nealey
Longview, WA 98632
(360) 578-1371
DWN: LHW
PRJ. MGR: LHW
Bulkhead Replacement
Ecl���
Land Services Fax: (360) 414-9305
PROJ.#: 2636.01
Client: Terry Nealey
Jefferson County, Washington
if !1JE;M1t!�
1
A
Land Se vices
Photo 16 was
taken from the
lowest landing
above the beach
looking back
towards the
shoreline bank.
The bank is
1+
having good
vegetation, is
eroding.
if !1JE;M1t!�
1
A
Land Se vices
Photo 16 was
taken from the
lowest landing
above the beach
looking back
towards the
shoreline bank.
The bank is
extremely steep and despite
having good
vegetation, is
eroding.
Photo 17 was taken from the
beach looking southwest at the
shed at the bottom of the stairs.
It is stilted above the bulkhead
to avoid being flooded during
high tides. There is a lean-to
built against the shed.
Photo 18 was taken from the
same location as Photo 17
looking northwest at the
shoreline bank. The toe of the
bank is being eroded by the
tides.
11573 d Ave., Suite 220A DATE: 12/11/17
Longview, WA 98632 DWN: LHW
(360) 578-1371 PRJ. MGR: LHW
Fax: (360) 414-9305 1 PROJ.#: 2636.01
Photoplate 6
Project Name: Nealey
Bulkhead Replacement
Client: Terry Nealey
Jefferson County, Washington
i
r V.
Photo 19 was taken from the toe
of the shoreline bank. It shows
the material which makes up the
broken bulkhead. There were
tires, old chunks of concrete and
rotten beams on the north side of
the property. This portion of the
slope will be repaired as part of
the project.
Photo 20 was taken from the
same location as Photo 19.
Erosion is apparent due to the
piles of soil and gravel at the
bottom of the bank. There is
plastic and rope buried beneath
the soil which may have been
part of the old bulkhead.
Plastic sheet pilings will
support the slope upon
completion of the project.
Photo 21 was taken from the
same location as Photos 19 and
20 looking at the shoreline
bank as it continues behind the
stairs and shed. The tide
passes under the structures.
The extent of repair will end at
the bottom of the stairs.
11573 d Ave., Suite 220A
DATE: 12/11/17
Photoplate 7
Project Name: Nealey
\ Longview, WA 98632
(360) 578-1371
DWN: LHW
PRJ. MGR: LHW
Bulkhead Replacement
ECQ 1] I
Land Services {Cavices Fax: (360) 414-9305
PROJ.#: 2636.01
Client: Terry Nealey
Jefferson County, Washington
In
1L�a-- �i
M
Photo 22 was taken from the
beach looking south at the south
half of the bulkhead. This area is
being used for boat/kayak
storage. This half of the
bulkhead will remain as is. The
beach is composed of cobble and
sand with some shell debris.
There were also some boat parts
scattered among the cobble.
Photo 23 was taken from the
concrete bulkhead looking into
the lean to. It appears the tide
occasionally reaches into this
area, but the condition of the
concrete below the lean-to is
sufficient to protect the slope.
Photo 24 was taken from near
the southeast property corner
looking west at the shoreline
slope. The fir trees pictured in
Photo 13 (Photoplate 5) are
visible at the top of the photo.
ra DATE: 12/11/17 Photoplate 8
1157 3 Ave., Suite 220A Project Name: Nealey
Longview, WA 98632 DWN: LHW Bulkhead Replacement
(360) 578-1371 PRJ. MGR: LHW
Eco 055,, aI Fax: (360) 414-9305 PROJ.#: 2636.Client: Terry Nealey
01
Land Services Jefferson County, Washington