HomeMy WebLinkAboutCopy of 2017-12-01_CommentResponseMatrixUpper Hoh River Road Bank Stabilization Project - Reponses to Jefferson County Comments Received 12-01-17 and Ecology Comments
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Commentor
Donna Frostholm, Staff Biologist
Donna Frostholm, Staff Biologist
Donna Frostholm, Staff Biologist
Emma Bolin, Associate Planner
Donna Frostholm, Staff Biologist
Donna Frostholm, Staff Biologist
Emma Bolin, Associate Planner
Donna Frostholm, Staff Biologist
Donna Frostholm, Staff Biologist
Emma Bolin, Associate Planner
Donna Frostholm, Staff Biologist
Emma Bolin, Associate Planner
Rick Mraz
Rick Mraz
Agency
Jefferson County Dept. of Community Development
Jefferson County Dept. of Community Development
Jefferson County Dept. of Community Development
Jefferson County Dept. of Community Development
Jefferson County Dept. of Community Development
Jefferson County Dept. of Community Development
Jefferson County Dept. of Community Development
Jefferson County Dept. of Community Development
Jefferson County Dept. of Community Development
Jefferson County Dept. of Community Development
Jefferson County Dept. of Community Development
Jefferson County Dept. of Community Development
Washington State Department of Ecology
Washington State Department of Ecology
Comment
Executive Summary: A total wetland impact area of 0.04 acre appears to be rounded up from the following acreages (0.028 acre + 0.008 acre = 0.036 acre), but appears to be rounded down
from Table 1 on page 9 (1,562 square feet + 285 square feet = 1,847 square feet, or 0.042 acre). Table S-1 indicates that the project would affect 0.047 acre (2,047 square feet).
The 0.04 acre of wetland impact is less than the 2,679 square feet (0.062 acre) in the August 29, 2017 Conceptual Wetland Mitigation Plan. The report should clarify the impact area
in square feet and acreage.
2. Executive Summary: The 0.04 acre of wetland mitigation on page i does not agree with the wetland mitigation acreage presented in Table S-1, and should be revised to agree with that
table.
3. Section 3.0: The impact assessment does not appear to address all potential impacts, such as stockpiling excavated soils, stockpiling ELJ/dolosses, parking heavy equipment. The
report does not clearly identify the how the impact calculations were made (e.g., assumed length and width of each access road, length and width of equipment stockpiling). The report
should clearly identify the types of impacts assessed and how the impacts were calculated. If buffer is disturbed for any activity associated with placement of the ELJs in the river,
those disturbances should be included. If all associated activities (such as parking heavy equipment, stockpiling excavated materials) will be located outside of the buffer, this should
be stated in the report so that it is clear why these activities are not included in impact calculations.
(in reference/addition to comment no. 3) It appears that the staging and river access areas are shown in the JARPA figures, but it is unclear if the report includes these areas in the
tabulated impacts. To add to the confusion, these areas are not represented as temporary impacts in the “JARPA figures”. The river access does not indicate width. The temporary impacts,
and all other impacts, need to be clearly presented in the mitigation report or referenced to other documents where appropriate.
4. Table 3: This table appears to underestimate total wetland buffer impacts. Potential wetland buffer impacts need to be calculated and addressed for existing wetland buffers (such
as Wetlands 1 and 5) as well as any other currently existing wetland buffers that would be lost due to implementing this proposal. All buffer impacts need to be mitigated, most of
which can occur at the C-1 wetland mitigation site.
5. Table 7: This table appears to underestimate total stream buffer impacts. For example, stream 9 will be an ELJ/dolosse access point to the Hoh River. Any alteration to any existing
buffers in the project area should be accounted for in the table. If the impact to a fish and wildlife habitat conservation area was included as part of a wetland buffer impact, that
should be noted in the table.
(in reference/addition to comment no. 6) Please see the note above regarding including JARPA figures information in one wetland report. It is unclear if the “unnamed” refers to the numbered
streams and if so, are these impacts inclusive of all of the tributaries on the sheet?
6. Section 5.0: The August 29, 2017 Conceptual Wetland Mitigation Plan was based on 5,358 square feet of wetland creation, while the current mitigation proposal is based on 3,200 square
feet (page 20). The applicant should address where and how wetland impacts were reduced.
7. Section 7.0: Wetland monitoring performance standards (1, 2, and 3) need to include Year 2 benchmarks for monitoring.
(in reference/addition to comment no. 9) For Standards 1-3, Year 2 should be added.
8. Figures 1a through 1e: These figures should be revised to clearly show the areas of impact and should be based on square footage or acreage impact area presented in the report.
These figures should also show the proposed mitigation areas.
(in reference/addition to comment no. 11) A unified report is needed without the complexity of multiple documents.
Please add a statement/commitment to the Compensatory Mitigation Plan describing how the wetland and stream mitigation sites will receive long term protection from development. (Comment
received via email to FHWA)
a description of “the existing conditions of the area proposed for wetland creation and the work that would be done to construct the bench (e.g. number and size of trees removed, other
vegetation removed)” (emphasis added).
Response
Impact numbers have been revised and checked. See revised Compensaty Mitigation Report.
See previous response.
Additional impact maps have been created to clarify anticipated location and extent of impacts. Equipment stockpiling, staging, and marshalling areas will be located in three primary
areas: 1) offiste property owned by DNR where log/dolos units will be assembled and stockpiled; 2) portions of the existing Hoh River Road (side closest to river) will be closed during
construction to provide access and staging; and 3) the existing Jefferson County storage yard located adjacent to Site C3. All of these areas are previously disturbed and will not create
new impacts to wetland or stream buffers. The new maps (Appendix B) identify those upland areas adjacent to the construciton sites where buffer impacts are anticipated. For example,
at Site C2, we assumed that all areas between the road and river will be potentially affected. However, impacts during construction will ultimately be determined by the contractor.
See response above. Impacts have been clarified with new figures (Appendix B).
Analysis did not count any buffer impacts for Wetlands 1 and 5 because those wetlands are assumed to be complete takes. All other wetland buffers potentially affected by construction
are limited to wetlands in the vicinity of Site C3.
See new maps for updated buffer impacts. However, where overlapping stream buffers occur, such as where Stream 9 overlaps the Hoh River buffer, impacts were not double counted. The Hoh
River buffer was assumed to be primary, with buffer impacts to other tributaries only provided where they are outside the Hoh River buffer. It is assumed that all native wetland and
stream buffers in the project area would also qualify as fish and wildlife habitat conservation areas under Jefferson County code. Thus, impacts to the wetland and stream buffers represent
impacts to fish and wildlife habitat conservations areas.
Unnamed stream is S12.
No compensatory mitigation is provided for ditch impacts. Ditches will be replaced in kind.
Preformance standard for Year 2 are included in the revised Compensatory Mitigation Report
Preformance standard for Years 1 through 5 are included in the revised Compensatory Mitigation Report
See new impact figures (Appendix B).
We will provide a revised Compensatory Mitigation Report, but other reports will not be updated since they have already been widely distributed.
Statement added in Section 5.4 of the revised Compensatory Mitigation Report.
Site selection rationale provided in Section 5.2 of the revised Compensatory Mitigation Report