HomeMy WebLinkAbout008 Information Request Letter�C JEFFERSON COUNTY
DEPARTMENT OF COMMUNITY DEVELOPMENT
621 Sheridan Street I Port Townsend, WA 98368
01 360-379-4450 1 email: dcd@co.jefferson.wa.us
http://www.co.jefferson.wa.us/260/Community-Development
July 10, 2019
JAMES M SMERSH
PO BOX 1246
MERCER ISLAND WA 98040-1246
RE- SITE ADDRESS: 1160 SHINE RD
CASE #: MLA19-00036
Dear JAMES M SMERSH
The Department of Community Development is in the process of reviewing your application. The following
information is needed to continue review of your project.
DCD reviewed the application submitted on April 3, 2019 and the revised Cumulative Impacts Report submitted
on May 17, 2019. Based on this review, the following information and clarifications should be submitted prior to
noticing the application.
General Comments (relevant to all submitted documents):
1. Provide a chart or response list showing responses to all of the comments below by comment number.
2. Clarify which areas may be used as work areas, parking for employees, and stockpiling of materials. The
following areas were referenced in the application materials but not consistently between documents:
Smersh waterfront parcel (721031007), Smersh parcel north of Shine Road (970200001), unidentified
parcel(s) along Madrona Vista Place, unidentified area(s) along Whatney Lane, county park parcel
immediately adjacent to Smersh waterfront parcel (721031008), and Shine Tidelands state park. Submit
revised documents, as appropriate, to clearly state when, how, and to what extent each of the above areas
will be used during the planting and grow -out, maintenance, and harvesting phases of the project.
3. The current site plan only shows the proposed geoduck planting area. It does not show upland areas that
may be used as work areas, employee parking, or stockpiling of materials. Submit a scaled site plan that
shows all areas within the county that would be used during all phases of the project.
4. The description of shorelines and critical areas focuses on the planting area, but does not address the entire
project area. Submit documents that address shorelines, critical areas, and associated buffers in other
portions of the project area, such as parking, stockpiling, and work areas. Descriptions should include a list of
all Type S waterbodies and all Type F streams within 150 feet of the project area, all Type N streams within
75 feet of the project area, and any wetlands or geologically hazardous areas within the upland project areas.
Type F, Type N, and Type S waters are defined in WAC 222-16-030.
Environmental Checklist Comments:
5. Provide the following attachments that were listed in the SEPA Environmental Checklist (section A.8), but
were not included with the submittal received April 3, 2019:
• Attachment B: Eelgrass Delineation, dated October 16, 2015;
• Attachment G: U.S. Army Corps of Engineers Programmatic ESA, dated November 1, 2016;
• Attachment H: Letter from Robert Smith to Dave Greetham, dated March 29, 2017; and
• Attachment I: BDN Aquaculture Gear Management Plan, dated October 26, 2016.
6. The project description (section A.11) states that 24 -inch -long rebar will be placed horizontally and vertically
within the 40 -foot by 40 -foot areas covered by nets. Provide additional information about rebar installation
(e.g., how high above the substrate will the rebar extend) and the amount of rebar needed to secure the nets.
Submit a schematic diagram in plan view and side view that shows the tubes, vertical and horizontal rebar
placement, and nets within each 40 -foot by 40 -foot area.
7. Land vehicles are proposed (section B.7.a.5) but the frequency and duration of use is not addressed. The
Environmental Checklist states that some land vehicle activities will occur more than 150 feet from
waterbodies. However, the Smersh waterfront parcel is less than 150 feet deep. Provide additional
information about where the vehicles will be stored and maintained. Depending on the extent of the proposed
use of the land vehicles, the noise section may need to be revised (B.7.b.2).
8. The aesthetics section (B.10) does not address rebar being placed on the beach to secure the nets. Provide
information about aesthetics related to rebar being placed on the beach to secure the nets.
9. Additional information is needed for the transportation section (B.14). Presumably, some workers will drive to
the project area, and the number of parking spaces should be identified. If workers will not be parking on the
Smersh waterfront property, identify where their vehicles will be parked. If the intent is to use the adjacent
county park or road easements, that should be clearly stated and the impacts to the county park or road
easements should be evaluated.
Comments on Biological Evaluation (MSA, dated October 28, 2019):
10. This report indicates that Shine Tidelands will be used as a staging area for loading materials onto the skiff. If
the proposal intends to use this state park as a staging area, provide additional information about how, when,
and the extent to which the park will be used. Clarify how often trucks will be transporting materials to the
park. If this state park will be used as a skiff staging area, the Environmental Checklist and the Habitat
Management Plan should be revised accordingly.
11. This document states that individual LED headlamps and navigational lighting will be used. Provide additional
information about when workers and the skiff will be working after dark. The Environmental Checklist (section
B.11) does not indicate that lights would be used, and may need to be revised.
12. The BE Addendum states that BDN employees will use public parking areas on Madrona Vista Place, just off
of Shine Road and across the street from the Smersh waterfront property. A review of the parcels along
Madrona Vista Place indicate they are all in private ownership. Please clarify if public parking areas means
BDN employees will be using the Madrona Vista Place road easement and, if so, assess the impacts.
13. This Addendum states that the Smersh parcel located across the street will be used as a staging area. Clarify
what equipment and materials will stored or stockpiled on this parcel and how often trucks will be transporting
equipment to the parcel.
Comments on Habitat Management Plan and No Net Loss Report:
14. The placement of one PVC tube every square foot adds up to a substantive amount of plastic being installed
within 5.15 acres of intertidal habitat. The biological reports submitted for this application do not address
potential water quality or habitat impacts associated with the potential for plastic pollution. Provide
information about the potential impacts associated with the potential for plastic pollution.
15. A fish habitat stream is mapped along the east side of the Smersh parcel, which is within the project area.
Potential impacts to this waterbody and associated buffer need to be addressed to comply with the fish and
wildlife conservation areas of Chapter 18.22 JCC.
16. The reports indicate the skiff may ground out at low tides. The potential impacts to fish and wildlife habitat
conservation areas and intertidal conditions are not addressed. Provide information about potential impacts
of the skiff resting on intertidal habitats and substrates.
17. Netting will be used on 5.15 acres and may remain onsite for 5 to 7 years, until the geoducks are harvested.
During this time, high energy storm events have the potential to occur, which may result in damage to some
of the netting. Provide information on the potential impacts that netting may have on aquatic life and natural
shoreline processes if it comes loose.
18. The report does not address the potential impacts to existing functions, such as habitat for dabbling and
diving ducks. If the netting, tubes, or rebar will affect habitat values or displace wildlife, this should be stated.
Provide information about the potential impacts to existing functions.
2
Comments on Cumulative Impacts Report:
19. This report presents information on natural shoreline processes and project -related impacts, but information
pertaining to cumulative impacts is limited. Submit a revised report that includes an assessment of
foreseeable future actions (JCC 18.25.1009(3)(aa)). This could include, but is not limited to, submittal of
aquaculture proposals in the intertidal areas of Squamish Harbor by others, use of county park for
recreational purposes, and potential future construction of residential in -water or over water appurtenant
structures (such as docks).
20. Provide a figure showing the location of aquaculture farms that were approved by the U.S. Army Corps of
Engineers and implemented prior to February 21, 2014, which is when the current Jefferson County SMP
went into effect. This figure should show previously-approved/implemented aquaculture projects relative to
the proposed farm. Provide information in the cumulative impacts report about past aquaculture permitting in
Squamish Harbor.
Comment on Visual Assessment:
21. It is not clear whether the placement of rebar was considered for this assessment. Submit an addendum
letter that clarifies how visible the rebar will be at low tide and if the report findings were based on rebar being
placed in the intertidal zone and any plans for mitigation.
If you have any questions, I can be contacted at dfrosthofm[opco.jefferson.wa. rfs or 360-379-4466.
Please submit the above information to the Department of Community Development within 90 days of the date of
this letter which would be 10/8/2019. Please call 360-379-4450 to speak with the assigned planner if you have
any questions.
Sincerely,
Department of Community Development Staff
C. File
BDN LLC
Ken Sheppard
Philip Hunsucker