HomeMy WebLinkAboutFinal MLA18-00105 SDP Staff Report
MLA18-00105/SDP18-00023 Page 1 of 6
Rocky Brook Hydro-electric
DEPARTMENT OF COMMUNITY DEVELOPMENT
STAFF REPORT TO THE JEFFERSON COUNTY
HEARING EXAMINER
Re: Type III Shoreline Substantial ) PROPOSED FINDINGS
Development Permit ) CONCLUSIONS, AND
) RECOMMENDATIONS
File No.: MLA18-00105/SDP18-00023 )
)
Applicant: Rocky Brook Hydroelectric LP )
SUMMARY APPLICATION AND RECOMMENDATION
Date of Application: Jefferson County received the application on November 28, 2018, and deemed it
substantially complete on December 26, 2018.
Proposal: TYPE III SHORELINE SUBSTANTIAL DEVELOPMENT PERMIT - The project is an
upgrade to an existing permitted (SH15-85 - SDP85-00015) hydroelectric facility. The upgrade includes
new turbines in the powerhouse that will decrease the amount of water needed to power the turbines by up
to 50%, and a new outflow structure at the powerhouse to return the water to the creek. All work will be
performed above the ordinary high water mark. A shoreline mitigation plan has been prepared and
submitted with the application to address no net loss of ecological functions and processes. The project
requires SEPA review with public notice and 30-day comment period, with a public hearing and decision
by the Jefferson County Hearing Examiner.
Background Summary: On March 17, 1986, the Rocky Brook Hydroelectric Limited Partnership (LP)
received a Shoreline Substantial Development Permit (SH15-85/SDP85-00015) from Jefferson County
(Exhibit 11) for a Hydroelectric Facility. The facility consists of a 150 square foot intake structure placed
in the stream that is connected to a penstock. The penstock carries water to a 25 x 40 foot powerhouse
located 200 feet north of Dosewallips Road. The water passes through one to four vertical turbine
generators. A surge tank is placed in line with the penstock. Water exits the powerhouse and runs up a
slight incline in an outfall pipe and is discharged near the base of the falls. Electrical lines connect the
system to an intertie (interconnection) owned by Mason County Public Utility District No. 1.
One of the conditions of permit approval is that the public shall be permitted free and unencumbered
access to Rocky Brook Falls at all times except during active maintenance, repair, or removal of the
facility. The site is and has been very popular for locals and tourists alike, but with limited roadside
parking that fills up quickly during the summer months.
The original turbines have simply outlived their usefulness and need to be replaced with current
technology that is twice as efficient, but will also require the re-configuration of the discharge point
downstream 300 feet from its current location, which is the reason for a new Shoreline Permit.
Legal Description & Project Location: Parcel Number 602282004 in Section 28, Township 26N, Range
02W, TAX 7, WM, located at 3020 Dosewallips Road, Brinnon, WA 98325
Recommendation: Approval with conditions
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Rocky Brook Hydro-electric
Project Planner: David Wayne Johnson
BACKGROUND INFORMATION
Applicant/Property Owner: Rocky Brook Hydroelectric LP
Dell Keehn, Partner
7829 Center Blvd SE
Snoqualmie, WA 98065-9096
Representative: Ecological Land Services
Laura Westervelt, Biologist
1157 3rd Ave. Suite 220A
Longview, WA 98632
Site Address: 3020 Dosewallips Road
Brinnon, WA 98325
Site Conditions: The subject parcel is approximately ten acres in size and is accessed via Dosewallips
Road to the south. Rocky Brook Creek runs generally through the center of the parcel. Presently, there is
a parking area along the road, gate, and gravel driveway to the one thousand square foot building that
houses the Hydro-facility turbines. Behind the building are large pipes that carry the water from the top of
the falls and into the building to be forced through the turbines to generate the electricity. Several hundred
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Rocky Brook Hydro-electric
feet to the north along the creek is a concrete outfall structure with steel grating (see photos Exhibit 9).
After the water is run through the turbines, it is discharged out this outfall structure and back into the
creek. The land slopes up from the road at a moderate angle (data unavailable) until it reaches the base of
the falls where is increases to a near vertical rock face. Mapped critical areas on-site include Natural
Shoreline Designation, Type F Stream and Slight to High landslide Hazard area. The parcel is zoned
Rural Residential 1:20 (RR-20). With the exception of the structures noted above, there is no other
development in the project area. The site is heavily vegetated with native plants and trees and remains for
the most part in its pre-development state.
Surrounding Area: All surrounding parcels are zoned Rural Residential 1:20 with the exception of the
property to the North which is Federally owned National Forest Land, as part of the Olympic National
Forest, and is undeveloped. Adjacent properties to the south and east are developed with single-family
residences, while the parcels to the west remain undeveloped.
Shoreline Designation: Pursuant to the Jefferson County Shoreline Master Program (SMP), the parcel
has a shoreline environmental designation of Natural. The purpose of the Natural designation states, “The
natural designation protects from harm or adverse impact shoreline areas that are intact, have minimally
degraded functions and processes, or are relatively free of human influence.” The parcel is designated
Priority Aquatic below Ordinary High Water Mark (OHWM). The purpose of the priority aquatic
designation is to protect to the highest degree possible and, where feasible, restore waters and their
underlying bedlands deemed vital for salmon and shellfish.
Comprehensive Plan Designation: The Jefferson County Comprehensive Plan (adopted August 28,
1998) designates the subject parcels Rural Residential R 1:20.
State Environmental Policy Act (SEPA) Review: A SEPA determination of non-significance was
issued on April 4, 2019 by Jefferson County as lead agency (Exhibit 12). Two comments were received
(Exhibit 12 & 13). The first comment from the Department of Ecology dated February 8, 2019 was a
standard advisory regarding State law on water quality and the requirements for a Construction
Stormwater General Permit. The second comment was from an adjacent neighbor who noted observing
the release of water from the storage tank above the falls, and impacts related to the “free and
unencumbered” public access to the site, both of which were either permitted, or conditions of approval
under the existing permit (SH15-85 #4) and are not part of the subject application. Therefore, there were
no additional mitigation measures identified as a result of SEPA review.
Procedural Information:
Notice of Application
Application submitted to Department of Community Development (DCD): November 28, 2018
Staff determined the application substantially complete: December 20, 2018
Notice of Application mailed to adjacent property owners & agencies: January 9, 2019
Posting of Notices by Staff: January 8, 2019
Publication of Legal Notices: January 9, 2019 (Port Townsend-Jefferson County Leader)
Comment period was open for 30 calendar days (per JCC 18.40.220) through February 8, 2019
Comments: Notices were sent to adjacent property owners within 300 feet of the subject parcel. Staff
requested review and comments on the application from the following agencies:
WA Dept. of Ecology Shorelines
Jamestown S’Klallam Tribe
Port Gamble S’Klallam Tribe
Suquamish Tribe
Port Townsend Leader
WA Dept. Fish and Wildlife
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Rocky Brook Hydro-electric
Dept. of Ecology SEPA Review
Skokomish Tribe
Point No Point Treaty Council
Peninsula Daily News
Jefferson County received two (2) comments on the application (Exhibit 12 & 13). The first comment
from the Department of Ecology dated February 8, 2019 was an advisory regarding State law on water
quality and the requirements for a Construction Stormwater General Permit. The second comment was
from an adjacent neighbor, Mr. Dennis Kuklok, who noted observing the release of water from the
storage tank above the falls, which would be covered under the existing permit and is not part of the
project area subject to this application. The property owner denies they are discharging sediment into the
water and claims they understand the Department of Ecology guidelines and are compliant with the law.
Mr. Kuklok also noted other areas where the site could be improved to mitigate the impacts from public
access as a result of condition of approval #4 under the original permit SH15-85. Staff contacted the
Brinnon Parks and Recreation District
REVIEW CRITERIA
State and Local Approvals and Permits Required:
Jefferson County Department of Community Development: Type III Shoreline Substantial
Development Permit
Department of Ecology: Final Authority on Shoreline Substantial Development permit
Department of Fish & Wildlife: Hydraulic Project Approval (HPA)
Applicable Ordinances and Plans:
Shoreline Master Program for Jefferson County, effective February 21st, 2014,
Jefferson County Comprehensive Plan, adopted August 28, 1998, as amended, and
Jefferson County Code (JCC), JCC Title 18, Unified Development Code (UDC), adopted December
18, 2000 and effective January 16, 2001 as amended
STAFF FINDINGS
The following presents staff findings regarding consistency of the application with the Jefferson County
Comprehensive Plan (Comp Plan) and the Jefferson County Code (JCC). Based on the findings presented
below, recommended staff conditions are included at the end of this staff report.
1. Jefferson County Comprehensive Plan the proposal is subject to all applicable sections of the
Jefferson County Comprehensive Plan. Goals and policies of the Shoreline section of the Comp Plan are
incorporated by reference from the Shoreline Master Program JCC 18.25. The following Comp Plan goals
are applicable to the subject application for a mooring buoy:
JCC 18.25.180 Shoreline use. (2) Goals. (a) Ensure that shoreline use patterns are compatible with the
ecological functions and values of the shoreline and avoid disruption of natural shoreline processes.
(b) Increase protection of shoreline ecological resources by properly siting and regulating water -
dependent and residential uses that have preferred status for use of waterfront lands. (h) Reserve aquatic
lands including tidelands for water-dependent uses.
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Rocky Brook Hydro-electric
2. Jefferson County Code: The proposal is subject to all applicable sections of the Jefferson County
Code.
Jefferson County Code Table 18.22.170 Geologically Hazardous Areas, Protection Standards
The project area is mapped as a potential geohazard. The applicant has submitted a geotechnical report
prepared by Aspect Consulting dated February 1, 2019 (Exhibit 8) in compliance with 18.22.170(9).
Jefferson County Code Table 18.25.270 Fish & Wildlife Conservation Areas, Protection Standards
Rocky Brook Creek is mapped as a Type “F” Fish Bearing Stream with an associated buffer of 150 feet.
The applicant has submitted a Shoreline Mitigation Plan prepared by Ecological Land Services dated
November 28, 2018 (Exhibit 5) in compliance with JCC 18.22.440 Habitat Management Plan.
Jefferson County Code Table 18.25.220 Permitted, Conditional and Prohibited Uses by Shoreline
Environment Designation.
Power/tidal energy generating facilities are prohibited in both the Natural and Priority Aquatic Shoreline
designations. However, the facility is legal non-conforming, permitted as a Shoreline Substantial
Development in 1986 under permit SDP85-15.
Jefferson County Code 18.25.390 In-Stream Structures
The proposed re-location of the outfall meets the definition of an in-stream structure under JCC
18.25.100(I) “In-stream structure” means a human-made structure placed within a stream or river
waterward of the ordinary high water mark that either causes or has the potential to cause water
impoundment, or the diversion, obstruction, or modification of water flow. In -stream structures may
include those for hydroelectric generation, irrigation, water supply, flood control, transportation, utility
service, transmission, fisheries enhancement, or other purposes.
The applicant shall be required to obtain a professionally engineered building permit (18.25.390(g)), and
HPA approval from the Department of Fish & Wildlife (18.25.390(h)) as a condition of permit approval,
and prior to any land disturbing activity.
The applicant has submitted a Shoreline Mitigation Plan prepared by Ecological Land Services dated
November 28, 2018 (Exhibit 5) in compliance with 18.25.390(i)(iii).
Jefferson County Code 18.25.530 Utilities
Utilities are prohibited in the Natural Shoreline designation. However, maintenance of existing utilities is
allowed, provided “the construction, operation and maintenance of utilities shall not cause a net loss of
shoreline ecological functions or processes or adversely impact other shoreline resources and values.”
The applicant has prepared a Shoreline Mitigation Plan (Exhibit 5) and a Stormwater Pollution Prevention
Plan (Exhibit 7) in compliance with 18.25.530(3)(c) & (d)(v)(vi) & (f).
Jefferson County Code 18.25.560 Exemptions Listed
The proposal meets the definition of Shoreline Substantial Development since the relocation of the
outfall/discharge cannot be exempted as maintenance and repair under 18.25.560(2) because it is not the
same size, shape, configuration or location.
Jefferson County Code 18.25.640 Preapplication Conferences
A pre-application conference as required for a Type III project application was held on July 3, 2018
(Exhibit 2).
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Rocky Brook Hydro-electric
S TAFF RECOMMENDATION
Having satisfied the requirements of the Shoreline Master Program, staff recommends approval of the Type
III Shoreline Substantial Development permit for relocation of the water outfall/discharge and replacement of
turbines for a legal non-conforming Hydroelectric facility.
RECOMMENDED CONDITIONS
1. Conditions of approval issued under existing permit SH15-85 are still valid.
2. The applicant shall be required to obtain a professionally engineered building permit from DCD
including review and approval of stormwater pollution prevention, prior to land disturbing activities.
3. An HPA approval from the Department of Fish & Wildlife shall be required prior to land disturbing
activities.
4. The applicant shall implement the Shoreline Mitigation Plan prepared by Ecological Land Services
dated November 28, 2018, specifically the Restoration and Annual Monitoring Plans.
5. Work within jurisdiction of the Shoreline Master Program other than as described above shall receive
separate review from this Department.
6. Any future permits on this site are subject to review for consistency with applicable codes and
ordinances and does not preclude review and conditions, which may be placed on future permits.
Prepared by Associate Planner, David Wayne Johnson, April, 2019