HomeMy WebLinkAbout031 Application SubmittalLOG ITEM
Donna Frostholm A ;R 1
From: Ken Sheppard <KSheppard@sksp.com> pww—j.���T
Sent: Wednesday, May 20, 2020 3:49 PM
To: Don66 Frostholm
Subject: RE: MLA19-00036 BDN Additional Information Request
Attachments: SEPA Checklist Revised 5-19-20.pdf
CAUTION: This email originated from outside your organization. Exercise caution when opening attachments or clicking
links, especially from unknown senders.
Hello Donna —
Sorry for the confusion — it appears that the most recent additions on the upland parcels did not get incorporated into
the latest version of the SEPA Checklist. That has now been corrected, so the attached references the mesh tubes, no
netting, and the additional information on upland parcel use. I think we have made all of the necessary corrections, but
if you see anything inconsistent with this (like any remaining references to PVC tubes or netting, you can either ignore
those references or contact me for further corrections.
Thank you,
Ken Sheppard
Kenneth A. Sheppard
Simburg, Ketter, Sheppard & Purdy, LLP
999 Third Ave., Suite 2525
Seattle, WA, 98104
(206) 382-2600
Fax: (206) 223 3929
www.sksp.com
- CONFIDENTIALITY NOTE -
The information contained in this electronic file is confidential information intended only for the use of the individual or entity named above and
may be legally privileged. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or
copy of this facsimile is strictly prohibited. If you have received this email in error, please immediately notify us by telephone or return
email. Thankyou.
From: Donna Frostholm <DFrostholm@co.jefferson.wa.us>
Sent: Tuesday, April 28, 2020 3:07 PM
To: Ken Sheppard <KSheppard@sksp.com>
Cc: Philip Hunsucker <PHunsucker@co.jefferson.wa.us>; Brad Nelson (braddnelson@comcast.net)
<braddnelson@comcast.net>; smershconstruction@gmail.com
Subject: RE: MLA19-00036 BDN Additional Information Request
Hi Ken,
DCD received a revised SEPA Environmental Checklist on April 17, 2020. In addition to referring the reader to
Addendums M1 through M6, this checklist makes reference to area netting being placed over the tubes. The October
21, 2019 submittal no longer proposed using area netting, with Response to Comment 17 and the SEPA Checklist stating
that mesh tubes would be used to control predators. Please clarify if mesh tubes or area netting will be used. If mesh
tubes are still proposed, please submit an Environmental Checklist that does not reference area netting but does
reference Addendum M1 through M6.
Regards,
Donna Frostholm
Jefferson County DCD
LOG i i E IVI
From: Ken Sheppard <KSheppard@sksp.cam> P� � c
Sent: Friday, April 17, 2020 3:41 PM
To: Donna Frostholm <DFrostholm@co.lefferson.wa.us>
Cc: Philip Hunsucker <PHunsucker@co: jefferson.wa.us>; Brad Nelson (braddnelson@comcast.net)
<hradd n e Iso n@ co m cast. n et>
Subject: RE: MLA19-00036 BDN Additional Information Request
CAUTION: This email originated from outside your organization. Exercise caution when opening attachments or clicking
links, especially from unknown senders.
Hello Donna —
As per your letter, attached please find a Cover Letter, revised SEPA (with new Addendums M-1 through M-6), and
Stormwater Worksheets for both privately owned upland parcels (these also appear as Addendums M-5 and M-6.)
I will assume we do not need to mail you hard copies unless you request that. I have all original signatures here, if you
would like me to mail them to you. Otherwise, I will just hold them in the file in case they are needed later.
If there is anything else you need to satisfactorily complete our response to your 2-12-20 letter, please let me know as
soon as possible. We would of course like to keep this moving along.
Thanks,
Ken
Kenneth A. Sheppard
Simburg, Ketter, Sheppard & Purdy, LLP
999 Third Ave., Suite 2525
Seattle, WA, 98104
(206)382-2600
Fax: (206) 223 3929
www.sksp.com
- CONFIDENTIALITY NOTE -
The information contained in this electronic file is confidential information intended only for the use of the individual or entity named above and
may be legally privileged. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or
copy of this facsimile is strictly prohibited. If you have received this email in error, please immediately notify us by telephone or return
email. Thank you.
From: Donna Frostholm <DFrostholm@co.iefferson.wa.us>
Sent: Wednesday, February 12, 2020 9:29 AM
To: Ken Sheppard <KSheppard@sksp.com>
Cc: Brad Nelson <Brad@seaproducks.com>; smershconstruction@gmail.com; Philip Hunsucker
<PH u n su cker@co. jeffe rson.wa. u s>
Subject: MLA19-00036 BDN Additional Information Request
Ken,
Attached is letter requesting additional information for the BDN application. That letter references county stormwater
forms, which are also attached.
Let me know, if you have any.,questions. L� ITEIA
Regards, # 1
Donna yrosthoCm PUS
Associate Planner ---.� �� .a
Jefferson County Department of Community Development
621 Sheridan Street, Port Townsenct, Waskington 98368
360 379-4466 d ro � , .,AP q.O gMJi,.1Ya.l15
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.
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SEPA ENVIRONMENTAL CHECKLIST "'
Purpose of checklist.
Governmental agencies use this checklist to help determine whether the environmental impacts of your
proposal are significant. This information is also helpful to determine if available avoidance, minimization
or compensatory mitigation measures will address the probable significant impacts or if an environmental
impact statement will be prepared to further analyze the proposal.
Instructions for applicants:
This environmental checklist asks you to describe some basic information about your proposal. Please
answer each question accurately and carefully, to the best of your knowledge. You may need to consult
with an agency specialist or private consultant for some questions. You may use "not applicable" or
"does not apply" only when you can explain why it does not apply and not when the answer is unknown.
You may also attach or incorporate by reference additional studies reports. Complete and accurate
answers to these questions often avoid delays with the SEPA process as well as later in the decision -
making process.
The checklist questions apply to all parts of your proposal, even if you plan to do them over a period of
time or on different parcels of land. Attach any additional information that will help describe your proposal
or its environmental effects. The agency to which you submit this checklist may ask you to explain your
answers or provide additional information reasonably related to determining if there may be significant
adverse impact.
Instructions for Lead Agencies:
Please adjust the format of this template as needed. Additional information may be necessary to
evaluate the existing environment, all interrelated aspects of the proposal and an analysis of adverse
impacts. The checklist is considered the first but not necessarily the only source of information needed to
make an adequate threshold determination. Once a threshold determination is made, the lead agency is
responsible for the completeness and accuracy of the checklist and other supporting documents.
Use of checklist for nonproject proposals:
For nonproject proposals (such as ordinances, regulations, plans and programs), complete the applicable
parts of sections A and B plus the SUPPLEMENTAL SHEET FOR NONPROJECT ACTIONS (part Q. Please
completely answer all questions that apply and note that the words "project," "applicant," and "property or
site" should be read as "proposal," "proponent," and "affected geographic area," respectively. The lead
agency may exclude (for non -projects) questions in Part B - Environmental Elements —that do not
contribute meaningfully to the analysis of the proposal.
A. Background HELP
1. Name of proposed project, if applicable:
BDN, LLC Geoduck Farm
SEPA Environmental checklist (WAC 197-11-960) Responses Revised May 2020
Page 1 of 22
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2. Name of applicant: # �Je�
BDN, LLC P�
3. Address and phone number of applicant and contact person:
BDN, LLC
3011 Chandler Street
Tacoma, WA, 98409
Contact person: Brad Nelson, (253) 377-3353
4. Date checklist prepared: February 2, 2019, Amended through May 19, 2020
5. Agency requesting checklist:
Jefferson County Dept. of Community Development
6. Proposed timing or schedule (including phasing, if applicable):
Construction of Project to begin immediately upon issuance of Jefferson County
Shoreline Conditional Use Permit.
7. Do you have any plans for future additions, expansion, or further activity related to or connected
with this proposal? If yes, explain.
There is no currently planned expansion beyond the areas and activities described in
this document.
8. List any environmental information you know about that has been prepared, or will be prepared,
directly related to this proposal.
A. Biological Evaluation, Marine Surveys and Assessments — 10-28-13 (See
Attachment s Al and A2)
B. BDN Eelgrass Deliniation and Depth of Culture Survey, Confluence Environmental
Company — 10-16-15 (See Attachment 131) and Eelgrass Reverification-7-9-18 (See
Attachment B2.)
C. BDN Smersh Farm Visual Assessment- 2019, Confluence Environmental
Company — October, 2019 (See Attachment C.)
D. BDN Smersh Farm Cumulative Impacts Report, Confluence Environmental
Company — June, 2018 (See Attachment D10) and Addendum — October, 2019 (See
Attachment D2.)
SEPA Environmental checklist (NAC 197-11-960) Responses Revised May 2020 Page 2 of 22
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E. BDN Smersh Farm Habitat Management Plan and No Net Loss Report - Conflr
Environmental Company — October, 2019 (See Attachment E.)
F. U.S. Army Corps of Engineers — Seattle District, Programmatic Endangered Species
Act (ESA) and Magnuson -Stevens Fishery Conservation and Management Act
Essential Fish Habitat Consultation Specific Project Information Form for Shellfish
Activities in Washington State Inland Marine Waters — November 1, 2016. (See
Attachment G.)
H. Letter from Robert Smith to David Greetham, dated March 29, 2017, and attached
Materials. (See Attachment H.)
I. BDN Aquaculture Gear Management Plans, (See Attachment 11, 2016 Plan, and
Attachment 12, Revised 2019 Plan.)
J. BDN Addendum M-1 — Use of Upland Parcel 970200001 Rev. 3/31/20
(See Attachment M-1)
K. BDN Addendum M-2 — Use of Upland Parcel 821344064 Rev. 3/31/20
(See Attachment M-2)
L. BDN Addendum M-3 — Use of Hicks Park. 3/31/20 (See Attachment M-3)
M. BDN Addendum M-4 — Use of Shine Boat Ramp. 3/31/20 (See Attachment M-4)
N. BDN Addendum M-5 — Small Stormwater Packet, Parcel 970200001, 3/31/20
(See Attachment M-5)
O. BDN Addendum M-6 — Small Stormwater Packet, Parcel 821344064, 3/31/20
(See Attachment M-6)
9. Do you know whether applications are pending for governmental approvals of other proposals
directly affecting the property covered by your proposal? If yes, explain.
Other than any applications that may be required in connection with related upland parcels
970200001 and 821344064, We know of no other pending applications directly affecting the
property covered by our Proposal.
10. List any government approvals or permits that will be needed for your proposal, if known.
We have previously received the following government approvals, which are the only
additional approvals we understand are needed for this project:
A. U.S. Army Corps of Engineers approval under Nationwide Permit (NWP) 48,
SEPA Environmental checklist (WAC 197-11-960) Responses Revised May 2020 Page 3 of 22
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Commercial Shellfish Acquaculture Activities, dated December 19, 2016.
(See Attachments J1, J2 and J3.)
B. State of Washington Department of Ecology Letter dated January 6, 2017
confirming that water quality concerns for the Project are adequately addressed and
an Individual 401 certification will not be required. (See Attachment K.)
C. Any approvals required by Jefferson County for the use of upland parcesl
970200001, 821344064, Hicks Park and Shine Boat Ramp.
11. Give brief, complete description of your proposal, including the proposed uses and the size of
the project and site. There are several questions later in this checklist that ask you to describe
certain aspects of your proposal. You do not need to repeat those answers on this page. (Lead
agencies may modify this form to include additional specific information on project description.)
BDN proposes to cultivate Pacific geoduck (Panopea generosa). The planting area will consist
of approximately 5.15 acres, generally between approximately +2 ft. MLLW and a 5-meter
(16.4 ft.) buffer of the native eelgrass (Zostera marina) bed edge, located between
approximately -1 MLLW and -2 MLLW.
To protect geoduck seed from predators, plastic mesh tubes 5" in diameter by 14" long will be
manually placed in the substrate at low tide, while the tidelands are exposed, before any
geoduck seed is planted. The mesh tubes are placed around the barrel of a "clam gun", which
is then used to insert the mesh tube into the substrate such that approximately half of the tube
is below the substrate and half above it. A low pressure water hose may be used to loosen the
substrate sufficiently to properly insert the mesh tubes. Tubes will be spaced at approximately
one tube per square foot in the planting area. Only 5" to 7" of the tubes will be exposed above
the substrate. Tubes will be labeled with contact information for BDN. 12-25 workers will work
to insert these mesh tubes during each approximately 5-hour shift. This will allow for
approximately 6,000-10,000 mesh tubes to be placed per day.
Geoduck seed will then be obtained from a certified hatchery and typically planted in the
installed mesh tubes when 4-5 mm in size. The juvenile geoducks will be placed in the
installed mesh tubes by divers during times when the tubes are submerged. No water jets will
be used during placement of the seed in the mesh tubes. The tubes will be clipped shut at the
top by the divers, using plastic clips, after the seed has been planted. Planting will begin in
spring and continue through fall. Planting activities will occur once per year, typically in June or
July, over a period of 20-25 days.
No netting will be installed over the tubes, and no rebar or other materials will be used in
connection with the planting maintenance or harvest activities. The installed mesh tubes are
very resistant to dislocation during severe weather, or from geoduck movement and activity, so
no securing nets are necessary. No fill materials or other nursery/grow-out structures will be
installed on the site. The project may result in the removal of non-native Japanese dwarf
eelgrass (Z. japonica) located in the proposed planted area.
Site inspections will be made weekly, or more frequently if needed due to adverse weather or
citizen complaints, to ensure that mesh tubes have not become dislodged. BDN has
implemented an aquaculture gear maintenance plan, appended as Attachment 1-2, to address
potential gear escapement and to facilitate quick recovery of any gear displaced by storm
activity. Site inspections will be generally conducted by 2-4 BDN employees walking the
tidelands and surrounding areas at low tide. Site maintenance will also include monitoring and
SEPA Environmental checklist (WAC 197-11-960) Responses Revised May 2020 Page 4 of 22
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67, .-Off-
relocation of built -Up drift microalgae (e.g. Ulva). If low tide periods occur at night, these
workers may use individual LED headlamps for such inspection and maintenance work. If any
maintenance work is required, this will be performed by as many as four people, but should
typically require no more than 1 hour for each such maintenance event. No vessel operations
will take place at night.
Two years after planting, when the geoducks have reached a depth sufficient to avoid
predators, beach workers will remove the tubes by hand at low tide. Consistent with Corps
requirements, if any herring spawn is found on the mesh tubes, they will not be removed until
the eggs have hatched. The mesh tubes will be placed in large bags and removed for reuse or
proper upland disposal.
Usually, harvesting will begin between five and six years after planting; the exact timing of
harvesting will depend on a variety of environmental and economic factors. The total harvest
window is expected to be 1-2 years. The majority of harvesting will be conducted at high tides
by divers using surface -supplied air. A small amount of beach harvesting will be conducted
during the "cleanup" harvest phase at the end of the harvesting period when there are fewer
geoducks remaining on the beach. Both dive harvests and beach harvests use the same
extraction equipment. A diesel or gasoline engine located on the work skiff is used to power a
water jet nozzle that loosens the substrate around each geoduck. The engine will have a
muffler to minimize noise impacts. The water intake hose will include a 2.36 mm wire
mesh.screen covering the intake to prevent fish entrainment in the low-pressure pump. The
water jet nozzle is at the end of an approximately 150' long, 1.5" delivery hose. The nozzle is
approximately 27" long and may supply up to 20-30 gallons of water per minute at 40 psi
After geoducks are removed from the substrate as described above, they will be stored in
crates located on the work skiff prior to transport off -site. During both dive and beach
harvesting, the work skiff will not be anchored in any native eelgrass beds. Dive harvests will
be conducted during daylight hours. Divers work within a 150' radius of the work skiff at depths
of 5' to 20' using surface supplied air. The vessel engine will be turned off while divers are
working for diver safety. When beach harvesting, the skiff is regularly moved so that it always
remains near the water's edge. Water hoses are then run from the skiff to the beach. Dive
harvests will employ 1 diver and 2 support workers in the skiff. Dive harvesting will usually last
for 3-to 6 hours each harvest day. Beach harvests will employ 2 workers on the beach and 2
support workers on the skiff.
Harvesting activities at this location will occur only during daylight hours, over a period of about
5 hours per day, averaging 3-4 harvest days per week during the one to two year harvest
period. BDN will comply with Corps' conditions associated with herring, surf smelt, and sand
lance spawning.
For related use of upland parcels 970200001 and 821344064, Hicks park, and Shine Boat
Ramp, see Addendum M-1 through M-6
12. Location of the proposal. Give sufficient information for a person to understand the precise
location of your proposed project, including a street address, if any, and section, township, and
range, if known. If a proposal would occur over a range of area, provide the range or boundaries of
the site(s). Provide a legal description, site plan, vicinity map, and topographic map, if reasonably
available. While you should submit any plans required by the agency, you are not required to
duplicate maps or detailed plans submitted with any permit applications related to this checklist.
Address: 1160 Shine Road, Port Ludlow, WA, 98365
SEPA Environmental checklist (WAC 197.11-960) Responses Revised May 2020 Page 5 of 22
Waterbody: Squamish Harbor
1 /4 Section: NW Section, 03 Township, 27N Range 01 E
Latitude: 47.865575-47.866644
Longitude: 122.661410 - 122.66364
Tidal elevation: Between -2 and +2 MLL W
B. Environmental Elements HELP
1. Earth hf elpl
a. General description of the site:
(circle one): Flat, rolling, hilly, steep slopes, mountainous, other:
Gently Sloping Tidelands
(Note: See Addendum M-1 through M-6 for description of related upland parcels)
b. What is the steepest slope on the site (approximate percent slope)?
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Approximately 1% slope. The site slopes about 4 feet over its approximately 400 foot
width, from +3 MLLW to -2 MLLW.
c. What general types of soils are found on the site (for example, clay, sand, gravel, peat,
muck)? If you know the classification of agricultural soils, specify them and note any agricultural
land of long-term commercial significance and whether the proposal results in removing any of
these soils.
Substrate at the Smersh site consists mainly of well -sorted, clean, sand with an adjacent
sandy, gravelly beach.
d. Are there surface indications or history of unstable soils in the immediate vicinity? If so,
describe.
No.
e. Describe the purpose, type, total area, and approximate quantities and total affected area of any
filling, excavation, and grading proposed. Indicate source of fill.
There is no proposed filling, excavation or grading.
f. Could erosion occur as a result of clearing, construction, or use? If so, generally describe.
No.
g. About what percent of the site will be covered with impervious surfaces after project
construction (for example, asphalt or buildings)?
No impervious surface will be created as part of this project.
SEPA Environmental checklist (WAC 197-11-960)
Responses Revised May 2020
Page 6 of 22
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h. Proposed measures to reduce or control erosion, or other impacts to the earth, if any:
No erosion is anticipated so no erosion control measures will be implemented.
2. Air hf elpl
a. What types of emissions to the air would result from the proposal during construction operation,
and maintenance when the project is completed? If any, generally describe and give
approximate quantities if known.
The only anticipated emissions will be from engines and pumps on one small harvest
vessel (under 40') or from skiff mounted engine -driven pumps when dive or beach
harvesting is occurring on the project. Usually, harvesting will begin between four and
seven years after planting, but the total harvest window is expected to be 1 year.
Dive harvests will be conducted only during daylight hours. Vessel engines will be turned
off while divers are working for diver safety. When beach harvesting, a skiff with a gasoline
powered pump will be used to provide water for extraction. Dive harvesting will usually last
up to 5 hours each day, and beach harvesting will be done only in a low tide window of 3
hours or less. Thus, the emissions from the use of no more than two small gasoline or
diesel engines associated with harvesting should not have a significant impact on air quality
in the vicinity of the project.
b. Are there any off -site sources of emissions or odor that may affect your proposal? If so,
generally describe.
None that are known to applicant
c. Proposed measures to reduce or control emissions or other impacts to air, if any:
Not applicable.
3. Water hf el
a. Surface Water: hf e
1) Is there any surface water body on or in the immediate vicinity of the site (including
year-round and seasonal streams, saltwater, lakes, ponds, wetlands)? If yes, describe type
and provide names. If appropriate, state what stream or river it flows into.
The Project area consists of Squamish Harbor saltwater tidelands that are exposed
and covered on a daily basis. Shine Creek, a freshwater creek, is approximately 1.5
miles to the west. A small un-named stream enters Squamish Harbor near the
project site.
2) Will the project require any work over, in, or adjacent to (within 200 feet) the described
waters? If yes, please describe and attach available plans.
Yes. See A. 11. above, which describes the nature and extent of all work to be
performed at the site, all of which would be within 200 feet of all described waters except
for Shine Creek.
SEPA Environmental checklist (WAC 197-11.960)
Responses Revised May 2020
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3) Estimate the amount of fill and dredge material that would be placed in or removed
from surface water or wetlands and indicate the area of the site that would be affected.
Indicate the source of fill material.
There is no proposed filling, excavation or grading.
4) Will the proposal require surface water withdrawals or diversions? Give general
description, purpose, and approximate quantities if known.
No.
5) Does the proposal lie within a 100-year floodplain? If so, note location on the site plan.
Yes, being tidelands, the site lies withing the 100 year flood plain.
6) Does the proposal involve any discharges of waste materials to surface waters? If so,
describe the type of waste and anticipated volume of discharge.
No.
b. Ground Water: h
1) Will groundwater be withdrawn from a well for drinking water or other purposes? If so, give a
general description of the well, proposed uses and approximate quantities withdrawn from
the well. Will water be discharged to groundwater? Give general description, purpose, and
approximate quantities if known.
No.
2) Describe waste material that will be discharged into the ground from septic tanks or
other sources, if any (for example: Domestic sewage; industrial, containing the
following chemicals... ; agricultural; etc.). Describe the general size of the system, the
number of such systems, the number of houses to be served (if applicable), or the number
of animals or humans the system(s) are expected to serve.
None.
c. Water runoff (including stormwater):
1) Describe the source of runoff (including storm water) and method of collection
and disposal, if any (include quantities, if known). Where will this water flow?
Will this water flow into other waters? If so, describe.
No runoff (including storm water) will result from Project operations.
2) Could waste materials enter ground or surface waters? If so, generally describe.
No.
SEPA Environmental checklist (WAC 197-11-960) Responses Revised May 2020 Page 8 Of 22
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3) Does the proposal alter or otherwise affect drainage patterns in the vicinity of the site? If so,
describe.
d. Proposed measures to reduce or control surface, ground, and runoff water, and drainage pattern
impacts, if any:
There should be none needed.
4. Plants hf elpl
a. Check the types of vegetation found on the site
X deciduous tree: alder, maple, aspen, other
evergreen tree: fir, cedar, pine, other
X shrubs
X grass
pasture
crop or grain
Orchards, vineyards or other permanent crops.
wet soil plants: cattail, buttercup, bullrush, skunk cabbage, other
X water plants: eelgrass
other types of vegetation
b. What kind and amount of vegetation will be removed or altered?
There will be no removal of native materials during site preparation. Excessive amounts of
macroalgae (e.g. Ulva) may be hand -raked away from the planting area, but left on the site.
Successive tides will redistribute algae across the site. The project may result in the
removal of non-native dwarf Japanese eelgrass (Zosfera japonica) located in the proposed
planted area.
Macroalgae beds are not found in or near the project area. Green algae (Ulva) were present
at a very low density, attached to a small number of hard objects such as derelict clam shells.
Macroalgae density is anticipated to increase in the project area due to geoduck farming as
the mesh tubes provide solid substrate required by macroalgae for attachment and growth.
Because the project will be located outside of a 16-foot protective buffer from native eelgrass,
no negative effects are anticipated to occur to eelgrass due to the proposed project and there
may be an ecological lift from the potential increase in other macroalgal species on the mesh
tubes.
c. List threatened and endangered species known to be on or near the site.
No threatened or endangered plant species are found on the site.
SEPA Environmental checklist (WAC 197-11-960) Responses Revised May 2020 Page 9 of 22
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d. Proposed landscaping, use of native plants, or other measures to preserve or enhance
vegetation on the site, if any:
All project activity will occur at least 16 feet away from native eelgrass (Zostera marina).
Also see b. above.
e. List all noxious weeds and invasive species known to be on or near the site.
The Washington Department of Fish and Wildlife has classified Z. japonica growing on
commercial aquaculture sites as a "Class C" noxious weed (Pleus 2012). This category is
for abundant, widespread nonnative species that are difficult to control. The primary
concern with Z. japonica in relation to shellfish aquaculture is that it occurs on mid -intertidal
areas that were previously bare mud and sand flats. Z. japonica can potentially grow to the
extent that shellfish planting and harvesting cannot be done successfully (Fisher et al.
2011). In addition, extensive Z. japonica can reduce water flow by up to 40% in comparison
to bare mudflats (Tsai et al 2010). Filter -feeding species, including geoduck, could have
their growth or survival affected by this reduction. Given the WDFW classification of Z.
japonica, any loss at the site could be viewed as a positive. However, this classification
does not necessarily mean that Z. japonica presence is detrimental from the perspective of
ecosystem structure and function.
5. Animals JL@jo
a. List any birds and other animals which have been observed on or near the site or are
known to be on or near the site.
Examples include:
birds: hawk, heron, eagle, songbirds, other:
mammals: deer, bear, elk, beaver, other:
fish: bass, salmon, trout, herring, shellfish, other
See Attachment Al, "Biological Evaluation, Marine Surveys and Assessments —
10/28/13, in particular Section II, Pages 9-12, and Attachments 1 through 4 to that
Evaluation.
b. List any threatened and endangered species known to be on or near the site.
The following fish, marine mammal, and bird species listed under the Endangered Species
Act may occur, or have critical habitat within the proposed action area:
Puget Sound Chinook
Hood Canal Summer -run Chum
Puget Sound Steelhead
Bull Trout
Yelloweye Rockfish
Boccacio Rockfish
Marbled Murrelet
Southern Resident Killer Whale
For more details, see Attachment A 1, "Biological Evaluation, Marine Surveys and
Assessments—10/28/13", in particular Section II, Pages 9-12, and Attachments 1 through 4
SEPA Environmental checklist (WAC 197-11-960) Responses Revised May 2020 Page 10 of 22
LUCU ITEM
to that Evaluation, and Attachment A 2, "Confluence Environmental Company Addendum to
Biological Evaluation — 9/23/16."
c. Is the site part of a migration route? If so, explain.
Yes. Hood Canal Summer -run Chum salmon may migrate along the shoreline of the site.
d. Proposed measures to preserve or enhance wildlife, if any:
The protection of juvenile geoduck as provided in 11 above will preserve those shellfish
from predators. Further, see "BDN Smersh Farm Habitat Management Plan and No Net
Loss Report - Confluence Environmental Company — October 2019 (Attachment E), and
BDN Aquaculture Gear Management Plan, 10/17/19'. (Attachment 1-2) for more detailed
description of Project measures to be taken to preserve or enhance wildlife.
e. List any invasive animal species known to be on or near the site.
None.
6. Energy and Natural Resources hf eM
a. What kinds of energy (electric, natural gas, oil, wood stove, solar) will be used to meet
the completed project's energy needs? Describe whether it will be used for heating,
manufacturing, etc.
Diesel or gasoline powered small engines will be used to power vessels and harvesting
equipment during the planting, growing and harvesting phases.
b. Would your project affect the potential use of solar energy by adjacent properties?
If so, generally describe.
No.
c. What kinds of energy conservation features are included in the plans of this proposal?
List other proposed measures to reduce or control energy impacts, if any:
Because the energy use connected with the Project in minimal, there are no specific
conservation measure planned for the Project
7. Environmental Health hf eM
a. Are there any environmental health hazards, including exposure to toxic chemicals, risk
of fire and explosion, spill, or hazardous waste, that could occur as a result of this proposal?
If so, describe.
1) Describe any known or possible contamination at the site from present or past uses.
There is no known contamination or possible contamination at the site from present or
past uses.
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2) Describe existing hazardous chemicals/conditions that might affect project development
and design. This includes underground hazardous liquid and gas transmission pipelines
located within the project area and in the vicinity.
There are no known existing hazardous chemicals/conditions that might affect project
development and design.
3) Describe any toxic or hazardous chemicals that might be stored, used, or produced
during the project's development or construction, or at any time during the operating life
of the project.
The only toxic chemicals anticipated to be stored or used in connection with the Project
are gasoline and diesel fuels for operating land based vehicles, harvest vessels, air
pumps, and water pumps. No toxic chemical will be produced by development or
operation of the Project.
4) Describe special emergency services that might be required.
The only special emergency services that might be required in connection with the
Project would be oil spill response and cleanup. Such services are provided through the
Washington Department of Ecology, and for the Project would most likely be provided by
the WSDOE response team based in Olympia, which provides year- round, statewide,
24-hour a day response services.
5) Proposed measures to reduce or control environmental health hazards, if any:
Land vehicles (e .g. all -terrain vehicles or trucks) shall be washed in an upland area such
that wash water is not allowed to enter any stream, waterbody, or wetland. Wash water
shall be disposed of upland in a location where all water is infiltrated into the ground (i.e.,
no flow into a waterbody or wetland). Land vehicles shall be stored, fueled, and
maintained in a vehicle staging area located 150 feet or more from any stream,
waterbody, or wetland.
For boats and other gas -powered vehicles or power equipment that cannot be fueled in a
staging area 150 ft. away from a waterbody or at a fuel dock, fuels shall be transferred in
Environmental Protection Agency (EPA) -compliant portable fuel containers 5 gallons or
smaller at a time during refilling. A polypropylene pad or other appropriate spill protection
and a funnel or spill -proof spout shall be used in the event of a spill. A spill kit shall be
available and used in the event of a spill. All spills shall be reported to the Washington
Emergency Management Office at (800) 258-5990. All waste oil or other clean-up
materials contaminated with petroleum products shall be properly disposed of off -site.
All vehicles operated within 150 feet of any stream, waterbody, or wetland shall be
inspected daily for fluid leaks before leaving the vehicle staging area. Any leaks detected
shall be repaired in the vehicle staging area before the vehicle resumes operation and
documented in a record that is available for review on request by any regulatory or
enforcement personnel.
Except as to water -borne boats and vessels, the direct or indirect contact of toxic
compounds including creosote, wood preservatives, paint, etc. with the marine
environment shall be prevented. For water -borne boats and vessels, all paints and other
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LOG OTEI4
compounds coming into contact with the water will be approved for such use under all
applicable rules and regulations.
b. Noise
1) What types of noise exist in the area which may affect your project (for example:
traffic, equipment, operation, other)?
The uplands neighboring the proposed Smersh geoduck farm are rural residential, and they
are zoned as shoreline residential under the current Shoreline Master Plan for Jefferson
County. There are numerous single-family residential houses in the Shine neighborhood
which is bordered on the north side by the heavily trafficked State Route (SR) 104. Between
6,000 and 22,000 vehicles pass the Shine neighborhood each day on SR 104 (15,000
average annual daily trips) traveling at 60 miles per hour (WSDOT 2017). Existing noise in
the area includes that which is typically found associated with water -dependent activities
(e.g., boat use), residential uses (e.g., vehicle use, lawn mowers, beach walking), and
vehicular traffic. Using the standard that 10 percent of the average annual daily traffic
represents hourly average traffic (WSDOT 2018) leads to 1,500 vehicles per hour passing
near the Shine neighborhood on SR 104. At 60 mph the sound from vehicle traffic is
approximately 75 dBA at 50 feet (WSDOT 2018). This sound level attenuates to
approximately 45 dBA at 800 feet which is approximately the halfway point between the
Smersh parcel and SR 104. The estimated noise level based on population density is
approximately 40 to 45 dBA (FTA 2006).
Measurements of ambient underwater noise were recorded at the Hood Canal Bridge in
2004. Median background peak sound pressure was between 118.2 and 137.5 dBPEAK re 1
pPa and median root mean squared (RMS) levels were 115 and 135 dBRMS re 1 pPa
(Battelle 2005).
2) What types and levels of noise would be created by or associated with the project on a
short-term or a long-term basis (for example: traffic, construction, operation, other)? Indi-
cate what hours noise would come from the site.
Noise -generating elements of the proposed project are consistent with existing use of the
surroundings (small boat use and walking on the beach). Both airborne and underwater
noise would be generated from the proposed project when boats are used to access the
project site and during the operation of pumps for harvest on a 5- to 7-year cycle.
The proposed project does not include the use of heavy equipment. Access to the site
would occur about once a month, and more frequently during limited periods for activities
such as planting or harvesting. Access would be via the upland parcels or via boat. The
outboard motors typically used on boats used for aquaculture typically create a noise level
of about 60 dBA at 50 feet (Berger et al. 2010). However, once at the site, boat engines
would be turned off until employees are ready to leave. Small diesel or gas -powered
water pumps with hoses would be used to harvest the geoducks for several days every 5
to 7 years. While noise levels of the water pumps have not been directly measured, they
are considerably quieter than the outboards, referenced above, that produce a sound level
of 60 dBA at 50 feet. Based on an ambient noise level of approximately 40 dBA to 45 dBA,
terrestrial noise associated with the proposed project is expected to attenuate to ambient
conditions 199 to 285 feet from the pumps. The landward margin of the geoduck planting
area is approximately 160 feet from the ordinary high water line, leading to the conclusion
that nearby residents will be exposed to only slight increases in noise if they approach within
close proximity to the shoreline near the project site.
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The loudest noise source proposed for the project) is expected to increase noise levels by
15 dBA to 20 dBA above ambient noise levels (assuming 60 dBA produced by the water
pump and 40 to 45 dBA ambient noise).
Underwater noise would also be generated from the motors on boats used to transport gear
and personnel to the project area and the small engines used for the water pumps during a
geoduck harvest.
For more information on anticipated noise generation, see BDN Smersh Farm Habitat
Management Plan and No Net Loss Report — Confluence Environmental Company — June,
2018 (See Attachment E, pages 9-12.)
3) Proposed measures to reduce or control noise impacts, if any:
There is no evidence that increases in either airborne or underwater noise from the use of
boat motors or water pumps associated with the rearing and harvest of geoducks would
result in negative effects to fish and wildlife species. Noise resulting from aquaculture
operations throughout Washington State was reviewed with respect to potential effects to
fish, marine mammals, and birds listed as threatened or endangered under the Endangered
Species Act (NMFS 2009, USFWS 2009, NMFS 2011). These reviews found that noise
levels did not exceed disturbance thresholds that would affect foraging, migration,
reproduction, or fitness for any of the ESA -listed species in Puget Sound. The proposed
shellfish aquaculture operation in Squamish Harbor would not significantly alter noise above
existing background conditions. Therefore, harvest operations are not anticipated to
increase underwater noise to a level that will result in a loss of ecological functions, and no
specific measures are planned or needed to reduce or control the already minimal noise
impacts. Nonethless, applicant plans to locate the water pumps used during harvesting in
an insulated box, thereby decreasing pump noise.
8. Land and Shoreline Use Lhel
a. What is the current use of the site and adjacent properties? Will the proposal affect current land
uses on nearby or adjacent properties? If so, describe.
The site is currently vacant tidelands, located on a heavily altered shoreline in a medium -
density, residential neighborhood. The shoreline has been altered by rip rap hardening.
There is a concrete boat ramp and gravel parking lot on the adjacent public property.
Riparian trees have been removed from a number of the adjacent properties to increase
private views, and a paved roadway is adjacent to the shoreline for approximately 1 mile
next to the Smersh parcel.
The uplands neighboring the proposed Project are rural residential, and they are zoned as
shoreline residential under the current Shoreline Master Plan for Jefferson County. There
are numerous single-family residential houses in the Shine neighborhood which is bordered
on the north side by the heavily trafficked State Route (SR) 104.
The proposed project will not affect current land uses on nearby or adjacent properties.
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3.j
For related use of upland parcels 970200001 and 821344064, Hicks park, and Shine Boat
Ramp, see Addendum M-1 through M-6
b. Has the project site been used as working farmlands or working forest lands? If so, describe.
How much agricultural or forest land of long-term commercial significance will be converted to
other uses as a result of the proposal, if any? If resource lands have not been designated, how
many acres in farmland or forest land tax status will be converted to nonfarm or nonforest use?
No.
1) Will the proposal affect or be affected by surrounding working farm or forest land normal
business operations, such as oversize equipment access, the application of pesticides, tilling,
and harvesting? If so, how:
20
c. Describe any structures on the site.
There are no structures currently on the site
d. Will any structures be demolished? If so, what?
No.
e. What is the current zoning classification of the site?
RR-5 — Rural Residential
f. What is the current comprehensive plan designation of the site?
RR-5 Rural Residential
g. If applicable, what is the current shoreline master program designation of the site?
Aquatic — Shoreline Residential
h. Has any part of the site been classified as a critical area by the city or county? If so, specify.
Yes. Portions of the Project Area are classified as Wetlands Critical Area, FEMA Flood Zone
Critical Area, Seismic Hazard Critical Area, Seawater Intrusion Protection Zone, and Critical
Aquifer Recharge Area.
i. Approximately how many people would reside or work in the completed project?
12-25 workers will work in 5-hour shifts to plant mesh tubes during the geoduck planting
phase, which will take place once every 5-7 years. The work will be sporadic, depending on
tides and weather, beginning in the spring and lasting through the fall. After planting, weekly
site inspections will be conducted by 2-4 BDN employees walking the tidelands and
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surrounding areas at low tide. 6-12 months after planting, the mesh tubes will be removed by
hand, again by 12-25 workers working in 5-hour shifts. This work will also be sporadic,
depending on tides and weather, and will be done from winter to early summer.
Usually, harvesting will begin between four to seven years alter planting; the exact timing of
harvesting will depend on a variety of environmental and economic factors. The total harvest
window is expected to be 1 year. Dive harvests will employ 1 diver and 2
support workers in the skiff. Dive harvesting will usually last up to S hours each day for two
divers. Beach harvests will employ 2 workers on the beach and 2 support workers on the
skiff.
j. Approximately how many people would the completed project displace?
None.
k. Proposed measures to avoid or reduce displacement impacts, if any:
None planned, as there will be no displacement.
L. Proposed measures to ensure the proposal is compatible with existing and projected land
uses and plans, if any:
See Attachments C through E for descriptions of the compatability of the project with existing
and projected land uses and plans.
m. Proposed measures to reduce or control impacts to agricultural and forest lands of long-term
commercial significance, if any:
None are required, as there are no anticipated impacts to agricultural and forest lands of
long-term commercial significance.
9. Housing hf elpl
a. Approximately how many units would be provided, if any? Indicate whether high, mid-
dle, or low-income housing.
No housing units will be provided.
b. Approximately how many units, if any, would be eliminated? Indicate whether high,
middle, or low-income housing.
None
c. Proposed measures to reduce or control housing impacts, if any:
None
10. Aesthetics hf elpl
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a. What is the tallest height of any proposed structure(s), not including antennas; what is "
the principal exterior building material(s) proposed?—-�
No structures are proposed. The only artificial objects that will be placed on the subject
tidelands are HDPE plastic 12 mm. mesh, 5" diameter by 14" long geoduck planting tubes,
which will be placed into the sandy substrate at an approximate density of 1 tube per square
foot with 3" to 5" of the tube exposed above the substrate.
These tubes will be stored in open piles or stacks in areas in the northern half of related
upland parcel 8213444032 currently covered by grass or small shrubs. Total coverage of
these piles at any one time will be not more than 4,000 square feet, and the piles will not
exceed 7 feet in height.
b. What views in the immediate vicinity would be altered or obstructed?
15 to 20 homes have unobstructed view of the proposed geoduck planting area when nearby
trees are in the leaf -off condition. The estimate of 15-20 homes with unobstructed
views will be reduced during the summer when trees have a cover of leaves that are likely to
more fully block views. For more detail on potential and actual visual obstruction, see
Attachment C, BDN Smersh Farm Visual Assessment-, Confluence Environmental Company
— October, 2019.
Tubes stored on related Parcel 8213444032, or vehicles temporarily parked there may be
visible to a minor degree from three nearby homes.
c. Proposed measures to reduce or control aesthetic impacts, if any:
The proposed project will be visible for only short duration during very low tides. Geoduck
mesh tubes will initially be black and of low visibility, and will quickly take on a natural color due
to colonization by aquatic flora and fauna. Maintenance will occur monthly, and after any storm
events, to ensure farm is tidy and tubes have not become dislodged. While not in use,
equipment will be stored off -site.
Piles of stored tubes on upland parcel 8213444032 will be restricted to 7 feet in height and no
more than 4000 square feet of total coverage. (See Addendum M-2)
11. Light and Glare h[ pjo
a. What type of light or glare will the proposal produce? What time of day would it mainly
occur?
No work will be performed at night other than checking of mesh tubes and other gear by
beach maintenance workers on an as -needed basis (see Item A. 11. above for a more
detailed description of this work.) Beach maintenance workers will use individual LED
headlamps (with an output of 6000 lumens or less) to provide a narrow beam of individual
lighting for that worker. Overall, the project will not produce any significant light or glare that
will be visible to upland owners.
No vessel operations will be performed at night.
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b. Could light or glare from the finished project be a safety hazard or interfere with views?
No.
c. What existing off -site sources of light or glare may affect your proposal?
None.
d. Proposed measures to reduce or control light and glare impacts, if any:
Not applicable.
12. Recreation hf @M
a. What designated and informal recreational opportunities are in the immediate vicinity?
The only nearby designated recreational opportunity is the neighboring park, which is primarily
a boat launching ramp, usable at high tide only, with an associated gravel parking lot. The
main informal recreational activites are beach walking by resident and visitors at low tide, and
use of the water over the project at high tide by recreational boaters.
b. Would the proposed project displace any existing recreational uses? If so, describe.
The boat ramp is only useable during high tide, when the geoduck tubes would be submerged,
so there is no displacement of that use. There will be no impacts to beach access as the
project is located on private tidelands that are not currently accessible by the public. The
project will not impact recreational boating use in any significant way. Dive harvest vessels will
be small, and moored over the project tidelands in such a way as to not significantly interfere
with other vessels in the area.
c. Proposed measures to reduce or control impacts on recreation, including recreation
opportunities to be provided by the project or applicant, if any:
None are proposed, as none are necessary
13. Historic and cultural preservation hf pM
a. Are there any buildings, structures, or sites, located on or near the site that are over 45 years
old listed in or eligible for listing in national, state, or local preservation registers ? If so,
specifically describe.
No such structures or sites exist in the project area.
b. Are there any landmarks, features, or other evidence of Indian or historic use or occupation?
This may include human burials or old cemeteries. Are there any material evidence, artifacts, or
areas of cultural importance on or near the site? Please list any professional studies conducted
at the site to identify such resources.
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�'�""�• Via►
No landmarks, features, or other evidence of Indian or historic use or occupation are known to
exist at the site.
c. Describe the methods used to assess the potential impacts to cultural and historic resources on
or near the project site. Examples include consultation with tribes and the department of
archeology and historic preservation, archaeological surreys, historic maps, GIS data, etc.
No consultations or studies have been undertaken, since the project consists of bare tidelands
with no evidence of any prior habitation or human use.
The Corps of Engineers has determined that cultural resource surveys are not required for this
project.
d. Proposed measures to avoid, minimize, or compensate for loss, changes to, and disturbance to
resources. Please include plans for the above and any permits that may be required.
No specific measures are proposed.
14. Transportation hf e
a. Identify public streets and highways serving the site or affected geographic area and describe
proposed access to the existing street system. Show on site plans, if any.
Land access to the project site is via Shine Road, a public street running parallel to the
shoreline and serving the adjacent tidelands and upland properties. Public Highway SR 104
runs roughly parallel to the shoreline and at the location of the project is about'/4 mile north of
Shine road.
b. Is the site or affected geographic area currently served by public transit? If so, generally
describe. If not, what is the approximate distance to the nearest transit stop?
The site is not directly served by public transit, but the Jefferson Transit Route V, Poulsbo, has
a bus stop approximatsly 1.2 miles to the East at the western end of the Hood Canal bridge.
c. How many additional parking spaces would the completed project or non -project proposal
have? How many would the project or proposal eliminate?
The project will not require any additional parking spaces, and will not eliminate any existing
parking spaces.
d. Will the proposal require any new or improvements to existing roads, streets, pedestrian, bicycle
or state transportation facilities, not including driveways? If so, generally describe (indicate
whether public or private).
20
e. Will the project or proposal use (or occur in the immediate vicinity of) water, rail, or air
transportation? If so, generally describe.
No.
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f. How many vehicular trips per day would be generated by the completed project or proposal? If
known, indicate when peak volumes would occur and what percentage of the volume would be
trucks (such as commercial and nonpassenger vehicles). What data or transportation models
were used to make these estimates?
During active planting and beach harvest activites, about ten to twenty passenger vehicle trips,
and one or two truck trips (to deliver or load geoducks or other project materials) will be
generated each day. During beach inspection periods, one to two passenger vehicle trips will
be generated each day. During waterborne harvesting, one or two truck trips (to deliver or load
geoducks or other project materials) will be generated each day. No data or transportation
models were used to make these estimates.
See also Addendums M-1 through M-6 for vehicle use of related upland parcels.
g. Will the proposal interfere with, affect or be affected by the movement of agricultural and forest
products on roads or streets in the area? If so, generally describe.
No.
h. Proposed measures to reduce or control transportation impacts, if any:
None needed or planned.
15. Public Services hf eM
a. Would the project result in an increased need for public services (for example: fire protection,
police protection, public transit, health care, schools, other)? If so, generally describe.
No-
b. Proposed measures to reduce or control direct impacts on public services, if any.
None needed or planned.
16. Utilities hf @
a. Circle utilities currently available at the site:
electricity, natural gas, water, refuse service, telephone, sanitary sewer, septic system,
other
No utilites currently directly serve the site.
b. Describe the utilities that are proposed for the project, the utility providing the service,
and the general construction activities on the site or in the immediate vicinity which might
be needed.
None planned or needed
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# LOCH ITEM
C. Signature HELP
The above answers are true and complete to the best of my knowledge. I understand that the lead
agency is relying on Jhemlo makeitsAecision. ;
Signature:
Name of signer
Position and Agency/Organization Authorized Agent of Applicant
Date Submitted: May 20, 2020
D. Supplemental sheet for nonproject actions rHELPJ
(IT IS NOT NECESSARY to use this sheet for project actions)
Because these questions are very general, it may be helpful to read them in conjunction
with the list of the elements of the environment.
When answering these questions, be aware of the extent the proposal, or the types of
activities likely to result from the proposal, would affect the item at a greater intensity or
at a faster rate than if the proposal were not implemented. Respond briefly and in general
terms.
1. How would the proposal be likely to increase discharge to water; emissions to air; pro-
duction, storage, or release of toxic or hazardous substances; or production of noise?
Proposed measures to avoid or reduce such increases are:
2. How would the proposal be likely to affect plants, animals, fish, or marine life?
Proposed measures to protect or conserve plants, animals, fish, or marine life are:
3. How would the proposal be likely to deplete energy or natural resources?
Proposed measures to protect or conserve energy and natural resources are:
4. How would the proposal be likely to use or affect environmentally sensitive areas or
areas designated (or eligible or under study) for governmental protection; such as parks,
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wilderness, wild and scenic rivers, threatened or endangered species habitat, historic or
cultural sites, wetlands, floodplains, or prime farmlands?
Proposed measures to protect such resources or to avoid or reduce impacts are:
5. How would the proposal be likely to affect land and shoreline use, including whether it
would allow or encourage land or shoreline uses incompatible with existing plans?
Proposed measures to avoid or reduce shoreline and land use impacts are.
6. How would the proposal be likely to increase demands on transportation or public
services and utilities?
Proposed measures to reduce or respond to such demand(s) are:
7. Identify, if possible, whether the proposal may conflict with local, state, or federal laws or
requirements for the protection of the environment.
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