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HomeMy WebLinkAbout025Final Environmental Impact Statement for the proposed Brinnon Master Planned Resort November 27, 2007 JEFFERSON COUNTY DEPARTMENT OF COMMUNITY DEVELOPMENT 621 Sheridan Street Port Townsend, WA 98368 www.co.jefferson.wa.us Pleasant Harbor Marina and Golf Resort -i- November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) INTRODUCTION—FEIS The Final Environmental Impact Statement issued in conjunction with the consideration by the County of a Master Planned Resort proposal for the Brinnon Subarea known as the Pleasant Harbor Marina and Golf Resort consists of the following documents: • The Final EIS issued November 27, 2007; • FEIS Introduction • DEIS sections with new responses to comments • Summary of conditions and supplemental reports • The DEIS appendices issued September 5, 2007; and • FEIS public comments (124-413) Public Process The Draft EIS was issued September 5, 2007 with a 45-day comment period through October 24, 2007. Public meetings were held by a Planning Commission committee on September 11, 18, and 25, 2007 in Brinnon at which members of the public were introduced to the project and the DEIS (September 11); representatives of the Jefferson County EDC and WSU extension office discussed economic, job, and community benefits and impacts (September 18); and September 25, 2007 when consultants responsible for the DEIS provided more detailed overviews of the proposal. Public comment was accepted at all stages and recorded by the DCD Long-Range Planner, Karen Barrows. In addition, written comments were received between September 5 and October 24 from citizens, agencies, and Tribes. Comments are recorded in the FEIS appendices and responses to comments are provided in the FEIS under each of the scoped topics addressed. Project Context and Regulatory Controls The Pleasant Harbor Marina and Golf Resort ("the Resort") is located in the southerly area of Jefferson County in an area designated in the Comprehensive Plan/Brinnon Subarea Plan as appropriate for a Master Planned Resort as provided in RCW 36.70A.360 and Jefferson County Code Chapter 18.15. The first step in that process is a decision on the 2007 Comprehensive Plan amendment for the Master Planned Resort designation and land use map. That decision, together with the Planning Commission recommendation, will be before the Jefferson County Board of County Commissioners December 3, 2007 for a public hearing and is proposed to be acted upon by December 10, 2007. If approved, the ordinance amending the Comprehensive Plan Map would identify the conditions of approval at this planning stage and direct the formulation of specific zoning sections and a development agreement, which would provide the basis for project-specific review and the enforcement of the conditions of approval set forth by the Board of County Commissioners and this FEIS. How to Read this FEIS The DEIS was used as a basis for the FEIS, with additions as follows: The new FEIS introduction describes the overview. Responses to comments were added within Chapter 3 at the end of each topic. Pleasant Harbor Marina and Golf Resort -ii- November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) A new Chapter 5 includes a summary of FEIS mitigation requirements, technical comments, and the log of comments. The original text from the DEIS is incorporated except as modified by the materials described above. Summary of Concerns and Responses The EIS was the product of a scoping process identifying nine topic areas of concern: shellfish; water quality, quantity and use; transportation; public services; shorelines; fish and wildlife; rural character; archeology and cultural resources; and critical areas. The County has been examining all public responses to the program (FEIS Appendix 1), with the DEIS comments as noted. All of the comments received have been sorted by topic or topics of concern and responses have been consolidated in Chapter 3 under each of the topics addressed in Sections 3.2- 3.11 by the addition of a final section addressing comments and response to comments. Comments are published in the County public comment log, which is part of this FEIS. As there was a great deal of overlap in the comments, the responses are by topic and concern, and each letter or comment considered is identified in the section. All comments made were noted, even those which did not warrant or merit specific responses under SEPA. This was usually because the concern addressed project-specific design topics that are premature for specific response at this stage and are covered by project-related review conditions or cumulative concerns addressed in the collective responses to each topic. A final chapter (Chapter 5) is added in this FEIS, which is a summary of the environmental mitigation imposed on the project, to be implemented at the project-review level through, first, the development of specific zoning and development agreement guidelines incorporating the specific requirements, and then project-specific review for each phase of the development to be identified in the development agreement. Chapter 5 also includes the comment log in which comments are identified and the location of answers are addressed. General Concerns 1. How much detail is appropriate at the Comprehensive Plan level, and when should detailed conditions be imposed? The FEIS is to address the non-project probable adverse impacts of a proposal and provide means for avoiding, minimizing, and/or mitigating identified consequences. The EIS process has resulted in modification of the proposal from the original 1880 units (MLA 06-87 3-1-06 application) to the present 890 residential units. The FEIS identifies a substantial number of permit checks to assure that the project envisioned by the Board of County Commissioners through the Brinnon Subarea Plan in an approved Master Planned Resort are achieved in practice. The FEIS process does not require or expect the community to speculate. It is appropriate for the County to set goals and objectives at this legislative stage, and define the processes to achieve those goals and objectives in regulatory tools, including development regulations and development agreements addressing how the project is to be reviewed at the project stage. The County can then process project-specific applications with the detailed engineering proposals and review that will allow the County and other review agencies to determine whether the goals and objectives for the project have in fact been met. The project was processed with a "phased review" of this proposal. "'Phased review' means the coverage of general matters in broader environmental documents, with subsequent narrower documents concentrating solely on the issues specific to the later analysis (WAC 197-11-060(5)." WAC Pleasant Harbor Marina and Golf Resort -iii- November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) 197-11-776. The phased review at this step is the consideration of a Comprehensive Plan enabling the development of a Master Planned Resort at this site and the mitigating conditions necessary to avoid, minimize, or mitigate the potential impacts of such project. A subsequent and narrower phase of SEPA review occurs at the project-level phase when specific construction projects and specific mitigations are detailed to achieve the objectives of the project and the conditions imposed through SEPA and project review. The first step of phased review, the Comprehensive Plan amendment, undertaken at this stage, has satisfied the question of what mitigations are necessary to avoid, minimize, or mitigate the potential environmental impacts of the proposed Master Planned Resort. Mitigating conditions and specific topics to be addressed at the permitting phase have been identified to make sure the community goals and objectives are achieved. Detailed engineering responses as to how to achieve certain goals and requirements are reserved for the project phase when the specifics of each phase can be addressed and analyzed in context. For this reason, specific response to many of the questions or comments addressing a need for additional detail as to how certain objectives are to be achieved are deferred to the project level, when detailed engineering reports and further project-specific studies are complete and available for evaluation of a specific proposal. This approach is particularly appropriate for a project that has a number of phases and may be constructed over a projected 5-10 year period. All mitigation requirements, including the more detailed "how is an objective to be achieved" comments are noted in this FEIS and will be carried over to the project-level review through the FEIS and subsequent environmental review to make sure the concerns are addressed at the project level. SEPA review is required at each development permit stage. At permit review, the County is able to assure compliance with development regulations, County standards, and the requirements of this FEIS. In this way, achieving the public interest identified in the Comprehensive Plan, Brinnon Subarea Plan, Shoreline Master Program and other government regulations are achieved. 2. What are the key regulatory permits and how are conditions to be enforced? A wide variety of permits are required for any resort of the magnitude proposed to be constructed, but four County permits and two State permits will provide the basic regulatory mechanism for controlling the project. a. Water Rights. Under Washington law no project may be constructed unless the community has adequate water capability to service the project. The applicant has applied to the Washington State Department of Ecology for water rights approval, and no new project development can occur until WDOE certifies the amount of water available and the County determines that each project phase proposed can be constructed within allowable limits. Concerns about potential impact to the aquifer, potential impacts to other water users and their wells, and concerns about salt water intrusion are all addressed specifically at this stage. b. Wastewater Treatment and Reuse. The Comprehensive Plan requirement for any Master Planned Resort is for onsite reuse of wastewater generated by the development. The applicant has proposed a reuse and recycling treatment system for use in toilet flushing and irrigation that requires approval of the Washington State Department of Ecology. Detailed engineering plans are submitted to WDOE, and issues about the ability of the system to achieve the Class A recycled water quality standard and maintain that standard during operation are addressed. In this case the engineering report would address in detail concerns raised about irrigation application and considerations for aquifer protection, including nitrogen and pathogen reduction and disinfection to prevent impacts on the aquifer through soil infiltration or transport to Hood Canal by reason of surface or subsurface water flows. Pleasant Harbor Marina and Golf Resort -iv- November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) c. Stormwater Management. Jefferson County has a stormwater management program encompassed in a stormwater permit. At the project level, before any site grading is done, the County must review and approve detailed engineering plans which address (1) preservation of critical area habitat, particularly wetland water quality, quantity, and habitat protection; (2) relocation and restoration of disturbed wetlands (WDOE also has regulatory control over wetland mitigation projects); (3) construction period controls to assure that stormwater from the site is captured and treated and not discharged to Hood Canal or Pleasant Harbor; (4) that protected areas are adequately staked and protected to assure protection of natural areas to be retained on the site; (5) that temporary cover is adequate to control erosion and prevent runoff until final control structures are in place; and (6) pursuant to the FEIS requirements, that the stormwater system be able to handle maximum events, not just 100-year events, to achieve the no discharge objectives identified in the EIS. d. Plat and Site Plan Review. All development on the site will require a subdivision application where new lots are to be created and site plan review for the development of existing or approved lots. During this process, issues of traffic, utilities, public safety, public access, and the many other requirements of the FEIS as well as the County development regulation requirements are implemented. Specific mitigating conditions are imposed at this stage and are enforceable through a preliminary approval that identifies the standards to be achieved, and a final approval that is not given until all conditions are met. This FEIS requires that memorandums of understanding with each of the public service providers be in place and provided during the approval process to assure that needs of the agencies serving the project are addressed and met concurrently with development. It is expected that mitigation will entail some combination of tax receipts, onsite facilities, and mitigation payments to agencies to meet identified needs as a result of the development. The list is not exclusive, but intended to identify that public service and public facility issues shall be addressed and resolved contemporaneously with any project phase approval. e. Shoreline Substantial Development Permit. The Shoreline Substantial Development Permit is issued at the local level for all development within 200 feet of the water's edge at Pleasant Harbor based on Shoreline Master Program requirements. Since the Maritime Village is considered a single project, the entirety of the Maritime Village is subject to the approval of the Substantial Development Permit for all development within shoreline jurisdiction. Compliance with all requirements of the Shoreline Master Program and County development standards must be met, as well as Shoreline Management Act requirements (which are reviewed by WDOE). In addition, the Substantial Development Permit will specifically define and address the monitoring and adaptive management program required by this FEIS for Pleasant Harbor as the resort is phased in and as operations continue. f. County staff will monitor all conditions and mitigations. Any citizen complaints will be processed through the DCD compliance division. Specific Concerns 1. Shellfish The FEIS documents that the Hood Canal area is a sensitive area with endangered salmon and important fish, crab, and shellfish beds, particularly at the Duckabush and Dosewallips River estuaries. Protection of water quality, eel grass, and the near shore and riparian habitats are important to maintaining these aquatic resources. Statesman proposes to use a low impact approach to development. Low impact development methods include steps to capture and treat all onsite stormwater from developed surfaces (including impervious surfaces as well as the golf course and other open areas). Stormwater is to be captured and retained onsite, even in extreme (over 100-year) events. The water use and water treatment permits will specifically address the issue of the aquifer and Pleasant Harbor Marina and Golf Resort -v- November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) seeps as a potential direct or indirect pathway for potential contaminants to assure that the treatment system proposed is adequate to provide the protection necessary to assure no impact to the fish or shellfish beds adjacent to or near the proposed facility. The location of a resort in an area that has significant fishing and public shellfish beaches will increase pressure on the resource. But the resources are managed for public use and access, and the resort does afford the public a safe manner to come and stay in the area. Regulatory control of public access to public beaches, public shellfish, and fish are all controlled. The resort is required to provide public education programs to increase public awareness of the licensing requirements, limits, hunting and harvest seasons, and other information to facilitate the proper use and access to public resources. 2. Water Quality, Quantity, and Use As described above, the acquisition of water rights and the approval of an onsite wastewater treatment and reuse system will be two of the key project-related permits. Permit review will address at the engineering level of detail how to protect the aquifer, how much water is in fact available, and how public health and safety are protected in the approval and monitoring of construction and operation of such facilities. No plats or site plans can be approved without sufficient water to assure the phase meets all public health and safety requirements. Water usage and recapture rates are aggressive, but within proven limits of technology. The plan for the project is to phase in the development, assuming standard rates of use for the early phases, reducing the per unit utilization only as early phases demonstrate the ability of the project to achieve the intended savings and efficiencies. This phasing will assure that at all times the project operates within allowable limits, including years with both heavy storm events and years when rainfall may be negligible. No building permits can be issued until adequate water access, treatment, and use facilities are identified to serve the phase. In addition, the stormwater protection plan is required to address water quality protection and habitat protection, particularly for wetlands. This condition assures that even at the earliest site grading, habitat, wetlands, and the waters surrounding the site are protected as required by this FEIS. Water calculations must include water necessary to maintain no net loss of wetland habitat function and value. Water for the resort must be in addition to water used to maintain habitat. 3. Transportation Transportation studies show that even though the project is anticipated to substantially increase the auto traffic in the area, future traffic levels with the project would operate within the adopted levels of service required by the State and County. During preliminary plat review, the County and WSDOT will identify and approve designs for safe ingress and egress from the site. Both County and WSDOT approval is required for ingress and egress to US HWY 101, and any specific plan must meet both County and State standards for safe public passage. Onsite, Black Point Road would need to be improved where it serves resort traffic to County standards, and the internal roads, whether public or private, must meet all requirements in size, composition, and connectivity for safe access and for fire and public safety purposes. The project would have trails open to public access for walking, bicycles, and other non motorized transport. In addition, the project contemplates shuttle services, which would reduce local traffic and provide common transport to local areas of interest. The project has no plans for helicopter or seaplane service, and any proposal to include facilities for either would require supplemental environmental review to determine both the appropriateness of such service and if approved adequate conditions to assure safe operation and minimum community impacts. Pleasant Harbor Marina and Golf Resort -vi- November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) Traffic mitigation at each phase may include both onsite and offsite mitigation, or contributions to state or local projects mitigating impacts from the project site. US HWY 101 is recognized as a highway that does contain limitations as to speed, auto, and nonmotorized safety. Control of the flow of traffic on US HWY 101 is through the WSDOT, and all project development is required to conform with the requirements and standards of that agency. Any offsite road improvements required as a result of increased traffic (such as Brinnon intersections) are controlled outside of the WSDOT right of way by the County, and such facilities must be improved and constructed to County standards and approvals identified at the time of preliminary plan or project development. Public Services South Jefferson County is an area with limited public services. Police, fire, transit, and public health services are all available, but without capability to meet significant increase in case loads that a major resort may bring. In addition, local schools are in financial downturns, with the grade school in need of significant upgrade and local students bussed to Quilcene High School. To address public service and facilities needs, the County is requiring specific analysis of the impact and meetings with each, in connection with plat and site plan review, and to negotiate a memorandum of understanding that will become a condition of any permit or approval. The memorandum of understanding is a binding agreement as to the needs of the particular service provider for the services and facilities necessary to meet the needs created by the resort and how those needs are to be met. In the event an agreement cannot be reached, the County may deny the application for development. The applicable standard will be that all requirements for public service and safety be met, and that in combination with the provision of tax revenues, agreed facilities and mitigation fees, the agency is able to meet its appropriate level of service reliably and over time. Shorelines The site is on Black Point with Conservancy and Suburban shorelines onsite and Natural shorelines nearby. No development is proposed along the southern shore where a 200-foot riparian buffer is proposed and the beach is to be closed for both public safety and environmental protection. Public access to publicly controlled beaches and water-oriented, water-dependent and water-enjoyment uses are proposed within the footprint of the present physical development of the marina, service roads, and parking area of Pleasant Harbor Marina. Setbacks, open space, bulk, and density requirements of the Shoreline Master Program and Shoreline Management Act must be met during review for the Shoreline Substantial Development Permit process. The proposal includes no change to the size and operations of the marina, but includes replacement of existing docks and walkways which are, in many places, dilapidated or obsolete and many are contaminated with an invasive species (tunicate) which the applicant and WDFW are working to eradicate in the Harbor. Pleasant Harbor does have eelgrass, which is important to protect. The Coast Guard controls anchorage in harbors such as Pleasant Harbor. The marina is required to have a marina management plan that requires compliance with safe boating regulations, including sewage pump-out rules, limits repair and refueling activities that may pose a risk to water quality, and a monitoring and adaptive management program designed to protect Pleasant Harbor from unanticipated changes. Fish and Wildlife The upland site is not used by threatened or endangered species, though it abuts Hood Canal and Pleasant Harbor, which have several listed fish species, and is between both the Dosewallips and Duckabush River systems, which are important to existing fish production and species restoration Pleasant Harbor Marina and Golf Resort -vii- November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) programs. Protection of water quality, as noted above, is the most significant feature to protect fish, shellfish, and other aquatic species. The riparian habitat along the southern shoreline and the forested buffer along HWY US 101 are to be retained, except for point of ingress and egress on US HWY101. Some habitat use by larger mammals (deer, elk, and bear) may be interrupted, but the area was not identified as important or common habitat for larger mammals. Elk herds in the area are found in the Dosewallips and Duckabush River systems, but have not been observed within the project area. In response to comments raised, WDFW was contacted, and specific data from the resource manager was obtained to substantiate this point. Habitat for birds, small mammals, reptiles, amphibians, and particularly those which are wetland dependent are protected by limiting the program to 20% impervious surface at the golf course resort, and 22% at the marina, as well as pervious and natural areas that have the potential to provide habitat within areas to be used for public enjoyment. Some physical habitat loss is unavoidable. A habitat management plan is required to address habitat protection in the context of the resort. Commentators have noted that the resort will increase pressure on fishing and access to public trails, land, and other facilities in the area. Master Planned Resorts are required to be located in areas of significant natural amenities, and the County has identified the public lands in the Olympic Mountain range and Hood Canal as such an amenity. The resort does promote public access and does increase pressure to use the public facilities, including trails and waterways. The resort is required to provide public education programs on the wise and appropriate use of public lands so the public may enjoy the area. Education will also include programs concerning regulations about public use designed to minimize public impact on managed fish and wildlife habitat and resources. Rural Character and Population The Master Planned Resort has been a divisive issue in the Brinnon community for a number of years. Many commentators want Brinnon to remain the same and not be subject to the impact of a Master Planned Resort. Others view the Master Planned Resort as essential to the economic revitalization of South Jefferson County. The community decision favoring a Master Planned Resort was expressed in the Brinnon Subarea Plan in 2002, which envisioned the concept of a Master Planned Resort at Black Point. This resort is tailored to the traveling public and short-term tourist, being different than the resort community found at Port Ludlow. The Brinnon Subarea Plan specifically called out a resort hotel or inn, 18-hole golf course, potentially 25 homes along the water, and a mixed use commercial facility astride US HWY 101. The plan was conceptual, but was to have onsite treatment facilities and avoid significant adverse environmental impacts. The proposed resort and 18-hole golf course project is focused toward tourist use rather than permanent residency. With the exception of staff housing and 10% of the remainder which may be permanent housing, all other units are in the hotel rental pool and will be offered to seasonal and short- term tourists interested the area. The resort will bring a substantial number of people to stay in the area (890 units with 85% average occupancy in the summer, 50% in mid season and 30% in the winter months). The resort population provides a demand for commercial and public services likely to be met through combination of onsite and offsite services and faculties, and particularly in the rural village at Brinnon. The resort can have an impact on land valuations in the vicinity, but land values have been rising in the area for several years (independently of the resort). Estimates of property value increase in the Hood Canal properties range upwards of 25-30% per year for the past several years. This pressure has Pleasant Harbor Marina and Golf Resort -viii- November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) reduced in 2007. Brinnon, within a 2-3 hour drive of most of the Puget Sound population, is within areas of increasing pressure for resort and vacation properties. A Master Planned Resort was envisioned in the Black Point area when the County adopted its Comprehensive Plan and Brinnon Subarea Plan. Control on incidental growth is achieved by the mandate that the urban services in the Master Planned Resort not be used to serve properties outside the resort area. The County has land use plans in place under its GMA comprehensive plans, and no other changes in those plans or designations are proposed as a part of or as a result of the proposed Master Planned Resort. While it is possible that the attractiveness of the Brinnon Area will be highlighted by the resort and some rural properties will be developed in South Jefferson County as a result of the resort (and part of its "cumulative effect"), some potential purchasers of resort or retirement property may be satisfied with the access provided by the resort, providing a fully-serviced area from which to enjoy the area, rather than having to build and maintain seasonal housing. The resort will change the nature of Brinnon, simply by increasing the level of activity in the area. Continued implementation of the County's rural rules and regulations about development are the principal control on the consequences of that change. Archeology and Cultural Resources Preliminary site investigations revealed no active or obvious areas of significance. A site-specific review process during construction to assure that important finds are properly identified and protected during the construction process shall be required. The preliminary plats and shoreline permit conditions will provide detailed procedures by which such objectives shall be achieved. Critical Areas Critical areas onsite include wetlands, fish and wildlife habitat, critical aquifer recharge areas, and geologically hazardous areas. Offsite they include flood hazard areas of both the Duckabush and Dosewallips Rivers. Critical area protection is built into the program in a number of ways. Wetlands have been formally delineated. The U.S. Army Corps of Engineers (USCOE) has determined the onsite wetlands are isolated and outside of their jurisdiction. However, both Jefferson County and the State have no net loss policies protecting the functions and values of the wetlands. Protection of water quality and water quantity, and preparation of a mitigation plan for any critical areas disturbed by project development are requirements before any site work can begin. A mitigation plan to define wetland compensation will be prepared that addresses this need during the project portion of any phased review. Aquifer protection is an issue with the golf course. The FEIS requires a management plan to address nutrient and pesticide management, and golf course management to protect the aquifer (and surrounding waters) from adverse impacts by reason of the golf course construction, maintenance, and operation. Habitat management is addressed through a habitat management plan that addresses areas and species to be saved and protected. Revegetation of disturbed areas, and use of native materials and low water use landscaping to retain the northwest character are designed to provide habitat protection and control during construction and operation. Existing vegetated buffers along US HWY 101 and shoreline at the marina are to be preserved and stabilized where possible. The steep slopes on the southerly border are protected by a riparian buffer and closure of the beach trail to prevent public use and access. Structures are located several hundred feet back from the bluff Pleasant Harbor Marina and Golf Resort -ix- November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) and stormwater plans are required to address how the stormwater management system will be designed to avoid adverse impacts to the southerly bluffs. At the marina, existing vertical cuts creating parking areas are failing and require shoring and support to protect the forested buffer and ultimately US HWY 101. The proposal includes a support wall along the maritime village westerly side to stabilize the bank, and footings and foundation for the village within the existing footprint of the parking and building area of the present marina. All development in the resort will comply with shoreline and critical area regulations through project review at each permit stage. This Final EIS identifies the environmental risks of this proposal at a non-project level with proposed supplemental requirements in addition to County standards that are designed to avoid, minimize, or mitigate probable environmental impacts of the proposed Master Planned Resort contemplated in the alternatives of this FEIS. The environmental analysis with mitigation spelled out in this FEIS achieves that result and is hereby approved to be issued. Published by Jefferson County This 27th day of November, 2007 Stacie Hoskins, Planning Manager SEPA Responsible Official Pleasant Harbor Marina and Golf Resort -x- November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) Pleasant Harbor Marina and Golf Resort -xi- November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) INTRODUCTION—DEIS This Environmental Impact Statement addresses a proposed Comprehensive Plan amendment and master plan approval proposed as a future project to be located in Jefferson County and to be known as the Pleasant Harbor Marina and Golf Resort. The EIS is prepared to allow Jefferson County and its citizens to review the plan amendment and master plan, its purpose and need, the affected environment, the range of alternatives, and an analysis of environmental impacts and potential mitigation. A Master Planned Resort (MPR) is a change from rural to urban uses which may be approved in a rural area under the guidelines of the Washington State Growth Management Act, RCW 36.70A.365; the Jefferson County Comprehensive Plan, Chapter 3, Long-range Goal 24, and Policies 24-1-13; and the Brinnon Subarea Plan, which had previously identified the Pleasant Harbor-Black Point area as a potential location for a Master Planned Resort (2002). The Brinnon Subarea Plan (BSAP) specifically considered potential uses for the 310.6 acres at the Black Point Pleasant Harbor area south of Brinnon, encompassed within a designated “potential” master planned resort area, including a resort with an 18-hole golf course, clubhouse facilities, and hotel/inn with conference center, health, athletic facilities “with on-site advanced stormwater and wastewater treatment systems” and the “infill" of associated visitor supported commercial, recreational and residential uses associated with the marina and a Master Planned Resort. The Statesman Pleasant Harbor proposed resort area encompasses approximately 256 acres within the MPR potential area identified in the Brinnon Subarea. The proposal specifically includes an updated and expanded commercial center for the marina, golf course, and resort housing, including residential, restaurant, spa, hotel managed facilities, targeted to both long-term and short-term tourist facilities. The proposed resort is served by onsite advanced stormwater and wastewater treatment systems specifically contemplated in the Subarea Plan to protect community environmental values and particularly water quality in Hood Canal. The Master Planned Resort approval process and criteria are detailed in the Jefferson County Code, JCC 18.15.115 – 18.15.135, with the requirements for approval by the Planning Commission set forth at Jefferson County Code, Section 18.15.132. These regulations will be the basis for the application, review, and possible approval of this Plan amendment and master plan approval. Project-specific permits are necessary to build a specific project, but any subsequent permits would have to be consistent with the approvals given in the Plan under consideration. The proposal is also reviewed under the State Environmental Policy Act (SEPA), and the County has required an EIS to assure that environmental issues are addressed at a logical time and in an appropriate context. As such, the environmental review is a staged or “phased review” which is permitted under SEPA. The master plan programmatic review presently before the County for review and approval considers the overall propriety and implications of the resort in the proposed setting and addresses how impacts may be avoided and necessary mitigation may be assured. Project-level review, which comes later in the process, occurs in connection with the application for a specific permit, so the specific engineering requirements to assure both compliance with the master plan and protection of the environment are achieved. As such, the programmatic view of the project is conceptual; the project review of the proposal will be site and time specific. The master plan program in Jefferson County also requires a development agreement, authorized by RCW 36.70B.170, to identify development standards, phasing, responsibility for implementation, and period of vesting to County standards for the planned development to assure that the conceptual master plan will be carried out as proposed. Pleasant Harbor Marina and Golf Resort -xii- November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) The EIS under review is a programmatic EIS issued to address non-project actions.1 The Environ- mental Impact Statement is part of the project review and public process, which for this project will include a review by a Planning Commission, committee with public involvement particularly from the Brinnon Subarea, public hearing(s) before the Planning Commission, and ultimately a public hearing before the Board of County Commissioners before any final action is taken. Due to the size of the project, and the areas involved, the County has determined that the public comment period for the EIS will last through the public hearings on the project by the Planning Commission. The Final EIS will incorporate all comments received and recommendations by the Planning Commission. The Final EIS is required to be issued at least seven days prior to action by the Board of County Commissioners, anticipated in December 2007. During the environmental review process, written materials may be directed to the Department of Community Development at any time, and they will be made part of the record. In addition, public review before the Planning Commission committee and the Planning Commission will also address environmental issues. Once the Planning Commission makes its final recommendations, the County will complete its environmental review and issue the Final EIS before the Board of County Commissioners takes any action on the approval. The EIS is processed by the County through the Environmental Review Official, Stacie Hoskins, and information about the EIS may be obtained at the Department of Community Development between the weekday hours of 9 am and 4:30 pm, located at 621 Sheridan Street, Port Townsend, WA 98368; telephone: 360/379-4450. Many materials are also posted on line at: http://www.co.jefferson.wa.us/commdevelopment/Black_Point_MPR.htm Published by Jefferson County This 5th day of September, 2007 Stacie Hoskins, Planning Manager SEPA Responsible Official 1 A non-project action is an agency decision on policies, plans, and programs (WAC 197-11-704) pursuant to the State Environmental Policy Act, Chapter 43.21C RCW, and the implementing regulations at Chapter 197-11 WAC. Pleasant Harbor Marina and Golf Resort -xiii- November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) FACT SHEET Project Title Pleasant Harbor Marina and Golf Resort Environmental Impact Statement (EIS) Description of Proposal The proposed action is a non project action to amend the Jefferson County Comprehensive Plan to add approval for a Master Planned Resort in the Black Point area of the Brinnon Subarea Plan, Application MLA06- 87. The proposed Master Planned Resort will be developed on 256± acres and will include a golf course, central resort facility, additional commercial uses, and residential additions to the Pleasant Harbor Marina area with a total of 890 residential units. Location of Proposal Pleasant Harbor, south of Brinnon at US HWY 101 & Black Point Rd. in Jefferson County, Washington. Parcel Numbers 502153002, 003, 023, 022, 021 & 020; APN 502154002; APN 502152005, 012, 013, 014, 015 & 016, in Sections 15 & 22, Township 25, Range 02 West, WM, located in Brinnon, WA 98320. Historic Reference Proposal area has been subject to logging and was formerly a 500-unit NACO/Thousand Trails seasonal campground for trailers and campers. Presently a 285- boat slip marina with associated retail commercial outlet and approval for 60-unit RV park are in place. Proposed Action Adoption of a Comprehensive Plan amendment approving the Master Planned Resort and associated approval of a development agreement confirming mitigation phasing and development regulation vesting rules required by the County. Proponent Statesman Group of Companies U.S. Head Office 9300 E. Raintree Drive, Suite 100 Scottsdale, AZ, 85260 USA Corporate Head Office: 7370 Sierra Morena Blvd SW Calgary, Alberta, CANADA T3H 4H9 Date of Implementation Master Plan approval requested December 2007 as part of the County’s overall Comprehensive Plan review process. Lead Agency Jefferson County Department of Community Development Pleasant Harbor Marina and Golf Resort -xiv- November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) Responsible Official Stacie L. Hoskins Planning Manager Dept. of Community Development 621 Sheridan Street Port Townsend, WA 98368 Contact Person Karen Barrows Assistant Planner Dept. of Community Development 621 Sheridan Street Port Townsend, WA 98368 Jefferson County File MLA06-87 Date of Draft EIS Issuance: September 5, 2007 Planning Commission Public Hearing: October 3, 2007 Comments: Through October 24, 2007 FEIS Published November 27, 2007 Proposed Date of Final Action Public Hearing: December 3, 2007 Final Action: December 10, 2007 Location of Final EIS for Review Copies of the Final EIS will be available at: Jefferson County Department of Community Development 621 Sheridan Street Port Townsend, WA 98368 Fire District #4 Headquarters 272 Schoolhouse Road Brinnon, WA 98320 Cost of Final EIS Initial 200 copies available at no charge; disks of the DEIS and Appendices available from Dept. of Community Development at $1.10 each; each additional printed copy at cost (estimate $90 each). Additional Information For more information, visit the County website at http://www.co.jefferson.wa.us and follow link to 2007 Comprehensive Plan Amendment Cycle Pleasant Harbor Marina and Golf Resort -xv- November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) REQUIRED APPROVALS Jefferson County – non project approval ™ Comprehensive Plan Amendment to enable the Pleasant Harbor MPR site ™ Land Use Map amendment to identify the Pleasant Harbor Master Planned Resort site ™ Development agreement approval ™ Master Plan approval ™ Unified Development Code amendment to add a section on the Pleasant Harbor MPR Jefferson County— project approval (phased review applications filed after Master Plan approval): Golf Course Resort • Golf Course • Hotel and related facilities • Resort Housing • Employee Housing • Wastewater Facility • Water Supply Facility Local or County Permits: ™ Preliminary/final plat for roads utilities and other infrastructure ™ Stormwater permit for: ™ preliminary site grading, cut and fill ™ new roads and impervious surfaces ™ construction and operation of the resort properties ™ critical area protection and modification. ™ Class IV conversion Forest practice permit for predevelopment logging ™ Shoreline permit for any development within 200 feet of the shoreline (close beach access to south and possible wetland mitigation and buffer work) ™ Shoreline exemption for dock replacement for Tunicate eradication ™ Building permits for construction Jefferson County— project approval (phased review applications filed after Master Plan approval): Maritime Village • Residential • Commercial Local or County Permits: ™ Preliminary and final plat or binding site plan for new roads, utilities infrastructure and any lot modification ™ Stormwater permit for: ™ preliminary site grading, cut and fill ™ new roads and impervious surfaces ™ construction and operation of the resort properties ™ Critical area protection and modification Pleasant Harbor Marina and Golf Resort -xvi- November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) Local or County Permits (cont.): ™ Class IV conversion Forest practice permit for predevelopment logging ™ Shoreline Permit for all development within 200 feet of the shoreline of Pleasant Harbor. (Simple dock replacement as part of the Tunicate eradication program with WDFW is considered repair or replacement and would not require a shoreline permit.) ™ Building permits for construction ™ Fuel containment and fire plan (Fire Dist. #4) Jefferson County— project approval (phased review applications filed after Master Plan approval): Golf Course Resort • Golf Course • Hotel and related facilities • Resort Housing • Employee Housing • Wastewater Facility • Water Supply Facility Maritime Village • Residential • Commercial State Permits: ™ Wastewater treatment and upland disposal (Class A recycled water) facility permits from WDOE ™ Class A Water System approval by WDOH ™ US HWY 101 right of way access permits for access to US HWY 101 from WDOT ™ Well closure approval by WDOE ™ Hydraulic project approval by WDFW for all work below OHWM in Pleasant Harbor ™ Water rights certificate approval by WDOE ™ Underground storage tank certification by WDOE ™ Construction period air quality permits from air quality authority ™ NPDES general permits for clearing from WDOE ™ Water quality certification, wetlands, by WDOE Jefferson County— project approval (phased review applications filed after Master Plan approval): Maritime Village • Residential • Commercial Federal Permits: ™ Section 404 and 10 permits for all work in waters of the U.S. and stream modification or crossing (road crossing streams a & b). Pleasant Harbor Marina and Golf Resort -xvii- November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) EIS AUTHORS AND PRINCIPAL CONTRIBUTORS Statesman CEO Statesman Group of Companies Ltd 7370 Sierra Morena Blvd. SW Calgary, Alberta, CANADA T3H 4H9 Contact: M. Garth Mann Phone: 403-256-4151; Fax: 403-256-6100 Application Coordination and Processing A. W. “Sandy” Mackie Perkins Coie LLP 111 Market Street NE, Suite 200 Olympia, WA 98501 Phone: 360-956-3300 Wetlands and Streams, Wildlife, Shorelines and Marina Assessment GeoEngineers, Inc. 1550 Woodridge Drive SE Shorelines and Marina Assessment Port Orchard, WA 98020 Contact: Wayne Wright Phone: 360-769-8400; Fax: 360-956-1208 Geology and Soils, Aquifer and Hydrology Studies Subsurface Group LLC 630 6th Street South Kirkland, WA 98033 Contact: Scott Bender Phone: 425-828-7545; Fax: 425-828-7548 Perrone Consulting, Inc. P.S. 11220 Fieldstone Lane NE Bainbridge Island. WA 98110 Contact: Vincent J. Perrone Phone: 206-778-8074 Civil Engineering and Water Reclamation/ Systems 2020 ENGINEERING, Inc. 700 Dupont Street Bellingham, WA 98225 Contact: Mark S. Buehrer Phone: 360-671-2020; Fax: 360-671-0322 Pleasant Harbor Marina and Golf Resort -xviii- November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) Water Engineering Systems NovaTec Consultants Inc. NovaTec Envirocorp Inc. Suite 101 - 2415 Columbia Street Vancouver, British Columbia Canada V5Y 1N5 Contact: Troy D. Vassos Phone: 604-873-9262; Fax: 604-873-2353 Historical and Cultural Resources Assessment Western Shore Heritage Services, Inc. 8001 Day Road West, Ste. B Bainbridge Island, WA 98110 Contact: Glen Hartmann Phone: 206-855-9020; Fax: 206-855-9081 Traffic Impact Assessment Transportation Engineering Northwest PO Box 65254 Seattle, WA 98155 Contact: Michael Read Phone: 206-361-7333 ext. 101; Fax: 206-361-7333 DISTRIBUTION LIST Copies mailed or delivered to: Jefferson County • Planning Commission members • Board of County Commissioners • Prosecuting Attorney’s Office • Department of Public Works • Department of Health & Human Services, Natural Resources Division • Jefferson County Fire Protection District #4 • Jefferson County Library at Port Hadlock State Agencies • Department of Community, Trade and Economic Development, Growth Management Services • Department of Ecology, SEPA Unit Notification of availability emailed or mailed to: Jefferson County • All other County departments not listed above Pleasant Harbor Marina and Golf Resort -xix- November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) Local Agencies & Organizations • City of Port Townsend • Jefferson County Public Utility District #1 • Port of Port Townsend • Jefferson County Conservation District • Brinnon School District • Quilcene School District • Jefferson Transit • Mason County Department of Community Development • Kitsap County Department of Community Development • Clallam County Department of Community Development • Washington Environmental Council • Olympic Environmental Council • Wild Olympic Salmon • North Olympic Salmon Coalition • Point-No-Point Treaty Council • Port Gamble S’Klallam Tribe • Jamestown S’Klallam Tribe • Skokomish Tribe • Hoh Tribe • Port Townsend & Jefferson County Leader • Peninsula Daily News • Forks Forum Pleasant Harbor Marina and Golf Resort -xx- November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) State Agencies • Department of Community, Trade & Economic Development (CTED) • Department of Natural Resources (Anne Sharrar & SEPA Review) • Department of Transportation (Bill Wiebe & SEPA Review) • Department of Health (John Aden) • Department of Social & Health Services (Elizabeth McNagny) • Department of Corrections (Rebecca Barney) • Department of Fish & Wildlife (Steve Penland, Tim Rymer, Jeff Davis & SEPA Review) • Department of Ecology (GMA Review) • Puget Sound Partnership (John Cambalik) • Parks & Recreation Commission (Bill Koss) • Interagency Committee for Outdoor Recreation (Lorinda Anderson) Other Interested Parties • Washington Association of Realtors • Bangor US Naval Submarine Base Pleasant Harbor Marina and Golf Resort -xxi- November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) TABLE OF CONTENTS Page INTRODUCTION—FEIS i INTRODUCTION—DEIS xi FACT SHEET xiii SUMMARY xxiii CHAPTER 1—THE PROPOSAL 1-1 1.1 Location of the Proposal 1-1 1.2 The Proposed Master Plan 1-4 1.3 Summary of the Proposal and Permitting Limitations 1-17 CHAPTER 2—THE PHYSICAL SETTING 2-1 2.1 Location of the Proposal and Alternatives 2-1 2.2 Brinnon Subarea 2-1 2.3 Existing Site Conditions (Black Point/Pleasant Harbor) 2-4 2.4 Hood Canal 2-6 2.5 The Olympic Mountains 2-8 CHAPTER 3—PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL (including responses to comments) 3-1 3.1 Existing Conditions 3-1 3.2 Shellfish 3-2 3.3 Water Resources: Use, Reuse, Management, Treatment, and Disposal 3-14 3.4 Transportation 3-39 3.5 Public Services (including tax burden, rescue services, and health services) 3-55 3.6 Shorelines 3-69 3.7 Fish and Wildlife 3-72 3.8 Rural Character and Population (including housing density, mix retail and rental affordability) 3-74 Pleasant Harbor Marina and Golf Resort -xxii- November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) 3.9 Archeological and Cultural Resources 3-78 3.10 Critical Areas 3-78 3.11 Other Issues 3-84 CHAPTER 4—DESCRIPTION OF ALTERNATIVES REVIEWED AND IMPACTS 4-1 4.1 No Action Alternative 4-1 4.2 Brinnon Subarea Plan Alternative 4-12 4.3 Hybrid Plan 4-20 CHAPTER 5—FEIS MITIGATING CONDITIONS FOR SUBSEQUENT PROJECT REVIEW, TECHNICAL COMMENTS, AND COMMENT LOG 5-1 5.1 Conditions for Permit Approval in Any Phase of the Approved Proposed MPR 5-1 5.2 Technical Comments 5-13 5.3 County Comments Received After the Issuance of the DEIS 5-22 PUBLIC COMMENTS (in separate volume) DEIS APPENDICES (in separate volume) Appendix 1 Historic Reference site plan and topography maps of American Campground Appendix 2 Marina Impact Analysis, 8/15/06, prepared by GeoEngineers Appendix 3 Shoreline Characterization Report, 8/3/06, prepared by GeoEngineers Appendix 4 Soils and Geology Evaluation, 8/10/07 prepared by Subsurface Group Appendix 5 Water Supply and Groundwater Impact Analysis, 6/26/06, revised 8/14/07, prepared by Subsurface Group Appendix 6 Transportation Impact Study, 8/28/07, prepared by Transportation Engineering Northwest Appendix 7 Fish and Wildlife Habitat Assessment, 7/20/06, prepared by GeoEngineers Appendix 8 Cultural Resource Assessment for the Proposed Pleasant Harbor Marina and Golf Resort, Jefferson County, WA, 6/30/06, prepared by Western Shore Heritage Services Appendix 9 Wetland Delineation, 7/20/06, prepared by GeoEngineers Appendix 10 Example of a Notice of Mariners with map showing restricted or closed areas of Dabab Bay (DBRC) Pleasant Harbor Marina and Golf Resort -xxiii- November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) SUMMARY The EIS describes a proposal for an amendment to the Jefferson County Comprehensive Plan and development regulations to add a new Master Planned Resort in the Brinnon Subarea of Jefferson County. The Master Plan proposal sets forth a conceptual plan for a resort hotel and rental units, combined with a significant expansion of the Marina Village facilities at Pleasant Harbor. The proposal under review would establish a Master Plan allowing up to 890 units and corresponding resort commercial development within the Master Plan area, subject to conditions imposed by the County through the approval of the amendment, if granted. The approval at this stage is only "programmatic" and additional environmental review is required at the project level when the specifics of any phase are identified in more detail and reviewed for permit approval. The County issued a scoping notice asking the applicant to respond to nine different specific issues including: (1) shellfish; (2) water quality, quantity, and use; (3) transportation; (4) public services, including tax burden, rescue services, and health services; (5) shorelines; (6) fish and wildlife; (7) rural character; (8) archeological and cultural resources; and (9) critical areas, including wetlands, aquifer recharge, frequently flooded areas, fish and wildlife conservation areas, and geologically hazardous areas. The project description is set forth in more detail in Chapter 1, and the setting and amenities in the surrounding area are identified in Chapter 2. The potentially significant adverse environmental impacts are identified in Chapter 3 and the comparative impact of the alternatives is identified in Chapter 4. The alternatives include a no action alternative, a resort encompassing the entire area identified in the Brinnon Subarea Plan as a potential Master Planned Resort, and a hybrid alternative that identifies a combination of Master Plan approval for the proposed project and rural resort type development on adjacent properties. The potential impacts are identified under the topic headings noted, and each section has detailed mitigation requirements to be imposed at the project level. Specific project caps and limits were set forth in the project review to make sure County concerns at the programmatic level were addressed. (1) Shellfish—The area is an important shellfish area and the waters around Pleasant Harbor and in Hood Canal are important for all varieties of fish as well as shellfish, so water quality is a major element. Key mitigation points: • Class A reuse and recycling program required to avoid process water discharge to Hood Canal. • Treatment of all waters at the marina area to assure 2005 Puget Sound water quality standards are met for all discharges. • Tunicate eradication program in concert with WDFW to help eradicate an invasive species. • Stormwater management plan for all clearing and grading to assure that the goal of no discharge of contaminates to the waters of Hood Canal or Pleasant Harbor is achieved. The detailed mitigation requirements are found at Section 3.2.7, and detailed discussions of water quality and harbor and marina-related issues are found in Appendix 2 and Appendix 3. (2) Water Resource Use, Reuse, Management, Treatment, and Disposal—The proposal is required to use an onsite wastewater treatment reuse and recycling program with no discharge to Hood Canal for Pleasant Harbor Marina and Golf Resort -xxiv- November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) storm and treated waters. The proposal also looks to a rainwater harvesting program to supplement existing water rights and looks to both low impact development and low flow fixtures to provide a reduced water service demand for the project. The key conditions include: • A requirement to obtain necessary water rights in advance of proceeding to preliminary plat approval or public hearing for the project, including investigation of alternate water resources that may be available. • A requirement to have approved and installed a wastewater treatment system that is capable of processing all site water demands to Class A recycled capability. • A requirement to have sufficient onsite water storage to provide year around irrigation and sustainable firefighting capability on site. The detailed mitigation requirements are found at Section 3.3.8, and a detailed discussion of water- related issues are discussed in the Water Supply and Groundwater Impact Analysis, Appendix 5. (3) Transportation—The project fronts US HWY 101 and is projecting a significant increase in traffic in the local area once the resort is operational. Levels of Service (LOS) away from the resort are not significantly impacted, but traffic control at the intersection is a major concern and will need to be addressed in detail at the permitting stage (project level). Key transportation issues and concerns: • The entry and exit points for the marina and resort need to be sufficiently far from US HWY 101 to permit the intersection to operate safely. For this reason the entry to the golf resort is proposed to be 0.7 miles east on Black Point Road, and the proposed access near US HWY 101 limited to emergency and limited purposes only. • The resort is providing bicycle and pedestrian pathways to encourage nonmotorized circulation through the resort and to provide a "safe haven" for bicyclists who are on US HWY 101 and seek to get off the highway for the length of the resort. • The resort is required to do a detailed traffic report at the commencement of each phase submitted for permits to get approval of intersections from the State Highway Department for US HWY 101 and from the County for all other public and private roads to assure (1) all roads are constructed to appropriate standards, (2) emergency access and escape is provided for all units, and (3) all necessary infrastructure to serve traffic and circulation is completed with each phase. The detailed traffic mitigation requirements are included at Section 3.4.4, and the Transportation Impact Study is at Appendix 6. (4) Public Services—Additional community concerns include: the ability of the community to provide public facilities and public services to the community, and how to design the community to provide the economic benefits intended by the Comprehensive Plan and still minimize impact on the overall character of the community. The issues are addressed in detail in Section 3.5. Public capability and services are identified and the additional new services are to be identified through a memorandum of understanding with the public service providers, including County, health, schools, Pleasant Harbor Marina and Golf Resort -xxv- November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) and emergency services. (See 3.5.1.5, Fire Protection and Emergency Service Mitigation and 3.5.2.2., 3.5.3.1, 3.5.4.) An additional concern was the combination of economic and rural character implications of locating a major resort in the Brinnon area. The County Comprehensive Plan currently identifies the site as an appropriate location for a Master Planned Resort. At the Master Plan approval level, the EIS examines the economic and environmental issues and recommended mitigation. (See Section 3.5.5, Economy, Housing and Employment.) Brinnon is short of rental housing for a large construction crew that is expected to be onsite for about five years as the project develops. The applicant identified using the existing 60-unit RV park on the Black Point property for construction workers during the development to mitigate the impact of a large influx of new workers. The project is expected to provide new employment and spending in the community, create demand for new facilities and services in the Brinnon Rural Village Center, and impact the local property values to some degree, which is already occurring as a result of the County's indication in the Comprehensive Plan that the Brinnon Subarea is a target for some form of a Master Planned Resort. Land values are also increasing independently of the resort proposal (which has been discussed for many years), simply due to the increasing demand for recreation and retirement property which Hood Canal fits so well due to its proximity to major metropolitan areas. Mitigation designed to protect the overall rural character and yet assure the development of a successful resort are to hold the overall density to less than four units per acre (roughly the density of the waterfront development surrounding the project and along Hood Canal in the vicinity); provide specific limits on the number of units and impervious surface; provide for the protection of the shoreline bluffs and preservation of significant wetland and natural buffer areas; and build the taller buildings into the hillside with below level parking to have most structures be at a residential height level (35 feet) when viewed from off the property. The overall area’s rural character is also preserved by the County rural density and limited uses in the rural zones, which are in place surrounding the resort, together with the limitation that the resort public facilities (sewer and water) cannot be used to serve uses outside of the resort. More detailed requirements are set forth at Section 3.5.9. (5) Shorelines—The Pleasant Harbor Resort is located on Suburban (Pleasant Harbor) and Rural (Hood Canal) Shorelines and as such are subject to the requirements of the Shoreline Master Program for Jefferson County. A detailed discussion of the shoreline requirements and Master Plan response is set forth in Section 3.6 and addresses land use (particularly the prohibition for stormwater or other discharge to Hood Canal to protect water quality), the preservation of a shoreline buffer on the south shore to provide a natural riparian zone for water quality and habitat protection, limiting public access to the Pleasant Harbor side where safe access and water quality issues can be addressed, and closing off public access to the south shore where safe access cannot reasonably be provided due to the steep cliffs and where water quality protection could be in jeopardy. Shoreline conditions are detailed at Section 3.6.7. (6) Fish and Wildlife—Fish and wildlife are addressed in Section 3.7, with specific details discussed in the Fish and Wildlife Habitat Assessment, Appendix 7. The site evaluation identified some habitat benefits for the project site, but no primary association by threatened or endangered species. The site is retaining over 39% natural open space in addition to the golf course and other open areas, and providing both wetland and wetland buffers and the riparian buffer along the south canal shoreline for Pleasant Harbor Marina and Golf Resort -xxvi- November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) habitat value. There is also a buffer strip of mature trees between US HWY 101 and the Maritime Village, which provides existing habitat benefits and is to be retained. The development of more than 100 acres of the site into a golf course, Maritime Village, resort housing, and related facilities will necessarily have an impact on the wildlife that does use the site presently. But these tend to be local birds and small mammals in no danger of extirpation in the area. The native habitat that does remain is to be retained in patches rather than small strips, which does improve habitat quality and usefulness over a wider range of species. Habitat mitigation is found in Section 3.7.4 and Appendix 7, and the requirement at the permit level to provide specific habitat mitigation plans in concert with each development phase to control stormwater and assure that wetlands, buffers, and protected open space habitat are identified and protected through all phases of operation and construction. (7) Rural Character and Population—This section (Section 3.8) also addresses the issues of housing and the potential changes in the Brinnon Subarea as a result of the resort. Mitigation is identified in Sections 3.5.7 and 3.5.9 discussed above. (8) Archeological and Cultural Resources—Any large-scale project needs an archeological assessment to make sure that cultural and archeological resources are not disturbed or compromised. An assessment was done finding no sites of significance in the areas to be developed. (See Cultural Resources Assessment, Appendix 8.) Mitigation includes a requirement to notify proper authorities if such resources are identified during any level of project development. (9) Critical areas—The EIS discusses the key critical areas affected by the project, including the wetlands (Section 3.10.1), aquifer recharge areas (Section 3.10.2), fish and wildlife conservation areas (Section 3.10.3), and geologically hazardous areas (Section 3.10.5). The site has no flood hazard areas. The objective of the proposal was to avoid impacts where possible, so the steep bluffs of the south shore are protected by a significant setback, and the steep slope rules provide for setbacks in the Marina Village area where slopes occur. Wetlands and buffers are also avoided, with the exception of Wetland B in the golf course area, which is in the kettle necessary for the irrigation and water reuse reservoir. Where this wetland is being disturbed, however, mitigation plans require a significant replacement wetland and buffer to be identified and installed prior to any actions to remove the existing wetland. Requirements are also in place to protect the water quality of the wetlands during both construction and operations, and to make sure the golf course is operated consistent with County regulations for golf courses in aquifer sensitive areas. (The County has adopted King County standards for such uses.) Critical area mitigation measures are identified at Section 3.10.6. Alternatives were evaluated, including the no action alternative, a proposal to designate the entire BSAP MPR area as a resort, and a hybrid looking at the Pleasant Harbor proposal east of US HWY 101 and a rural development directed to recreational use consistent with rural regulations, but recognizing the proximity with the resort would generate demand for more intense rural uses with the resort than without. All of the alternative uses and potential impacts are addressed in Chapter 4. With the exception of the No Action Alternative, the alternatives all have similar impacts since the bulk of the property is put to resort uses, which mean they share similar impacts in terms of clearing, grading, and development and share common mitigation requirements with the proposal to avoid, minimize, or protect and mitigate the environmental values discussed. The principal differences are discussed. The No Action Alternative presumes the existing proposals for west of US HWY 101 would be in place and the marina would continue in its current status, but that the property east of US HWY 101 would be developed into a small local golf course and 24 home sites, plus six on the existing marina lots, for a total of 30 new residences. The major differences are that the No Action Alternative would be solely Pleasant Harbor Marina and Golf Resort -xxvii- November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) Rural (through a Planned Rural Residential Development) and would have to rely on existing water rights and individual wells on the separate properties. Mitigation to avoid water quality impacts would be required, but the site would be less developed and significantly less traffic would be attracted to the site for use. The major differences are lack of public water and sewer facilities, less of the overall site developed and more retained in natural settings, and significantly less traffic. The No Action Alternative also does not provide the economic and community benefits contemplated in the Comprehensive Plan of a Master Planned Resort. The Brinnon Subarea Plan Alternative assumes a different format for the development, with 24 units in houses on 15 lots along the southern shore and marina properties, and a 200-unit hotel resort conference center on the property south of Black Point. The major difference with the Pleasant Harbor Resort proposal is that the entire 310 acres would be brought into the resort and the resort would develop a resort village with commercial services on the properties west of US HWY 101. The intense development of the MPR property would require similar facilities and conditions as the Master Plan proposal under review. Water, sewer, and other public facilities can accommodate the proposal and the same mitigation requirements would be in place for the BSAP Alternative as the Master Planned Resort under review. The major difference is in traffic. The US HWY 101 alignment, speed, grade, and site distances are such that crossing movements would be a safety factor and likely unable to retain the "C" level of service required on US HWY 101. A signalized intersection would not be permitted under current standards for highway design, and as such grade separation for both traffic and pedestrians would be required. The Hybrid Alternative assumes the Master Plan for the east side of US HWY 101, so the programs and mitigation identified in Chapter 3 would be required. On the west side the additional development is permitted under County rural rules, but would be limited by the need to serve the project with septic tanks and individual wells. Here again, water quality and quantity conditions are required to protect water quality. The issue of traffic separation and ingress and egress onto US HWY 101 is an issue to be addressed at the permit level and will pose challenges due to the volumes of traffic and the need to avoid any unsafe turning movements. Coordinated traffic planning will be important and will be the principal issue. The other impacts and mitigations are similar to the Master Plan and the BSAP Alternative and similar conditions would be expected. Additional information on permit-related conditions may be found in the Appendices. 57577-0001/LEGAL13724133.2 Pleasant Harbor Marina and Golf Resort -xxviii- November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) THE PROPOSAL CHAPTER 1 Pleasant Harbor Marina and Golf Resort Page 1-1 November 27, 2007 CHAPTER 1—THE PROPOSAL The proposal is a Comprehensive Plan amendment and Master Plan approval for a Master Planned Resort (MPR) proposed for the Black Point area of the Brinnon Subarea in Jefferson County consisting of a golf course resort, marina, and Maritime Village. 1.1 Location of the Proposal The geographic location is shown as a red star on the Figure 1-1 Location Map below. Figure 1-1 Location Map The project is located in the Brinnon Subarea (Area 11) of Jefferson County, shown in Figure 1-2, as copied from Figure BR 1 of the Brinnon Subarea Plan (BSAP). Figure 1-2 Brinnon Planning Area FINAL EIS - (Site Specific Amendment MLA 06-87) THE PROPOSAL CHAPTER 1 Pleasant Harbor Marina and Golf Resort Page 1-2 November 27, 2007 The BSAP identified the Black Point area as the location of a potential Master Planned Resort (See Figure 1-3). Figure 1-3 Brinnon Subarea – Conceptual Master Plan Area The Pleasant Harbor proposal includes a substantial portion of the Black Point property proposed for Master Planned Development in the BSAP. FINAL EIS - (Site Specific Amendment MLA 06-87) THE PROPOSAL CHAPTER 1 Pleasant Harbor Marina and Golf Resort Page 1-3 November 27, 2007 The property within the BSAP potential MPR area is 310.6 acres under multiple ownerships, as shown in Figure 1-4. Figure 1-4 Brinnon Subarea – Conceptual Master Plan Area Ownership The proposed Master Planned Resort is located on the “Statesman” property (approximately 256 acres) upland and 15.2 acres of DNR marina lease area. FINAL EIS - (Site Specific Amendment MLA 06-87) THE PROPOSAL CHAPTER 1 Pleasant Harbor Marina and Golf Resort Page 1-4 November 27, 2007 1.2 The Proposed Master Plan The Pleasant Harbor Marina and Golf Resort Master Plan proposal involves two components: • The Golf Course and resort located on the Black Point portion of the property south of Black Point Road. • The marina and Maritime Village adjacent to the current Pleasant Harbor Marina and north of Black Point Road. • The overall layout is shown in Figure 1-5. Area: 256± acres Impervious: 17% Pervious: 48% Natural: 35% Note: Pervious includes lawns and other pervious developed areas. The natural area consists of pervious areas that are planned to be undeveloped. Figure 1-5 Site Plan - Overall FINAL EIS - (Site Specific Amendment MLA 06-87) THE PROPOSAL CHAPTER 1 Pleasant Harbor Marina and Golf Resort Page 1-5 November 27, 2007 1.2.1 The Golf Course and Resort—220± Acres The golf course portion of the resort is located on the Black Point portion of the property east of US HWY 101 and south of Black Point Road. Area: 220± acres Impervious: 17% Pervious: 55% Natural: 28% Note: Pervious includes lawns and other pervious developed areas. The natural area consists of pervious areas that are planned to be undeveloped. Figure 1-6 Site Plan – Black Point Lands FINAL EIS - (Site Specific Amendment MLA 06-87) THE PROPOSAL CHAPTER 1 Pleasant Harbor Marina and Golf Resort Page 1-6 November 27, 2007 Legend for Figures 1-5 and 1-6 – Golf Course Resort The MPR for the Black Point Lands (see Figures 1-7, 1-8, 1-9) includes: • A championship 18-hole golf course of 6,200± yards “Links Design” • 60,000 square foot resort center: • Restaurant and lounge with outdoor lanai • Conference center and reception • The spa • The pro shop and offices • 128-unit terrace lofts for resort occupancy • 462 – two-story garden townhomes • 97 – one-level villas • 52-unit staff housing • Class A reuse recycle sewage / effluent / water treatment plant and ponds • A 200-seat community center • A 3,000 square foot restaurant for golfing refreshments and community dining • 739 total residential units FINAL EIS - (Site Specific Amendment MLA 06-87) THE PROPOSAL CHAPTER 1 Pleasant Harbor Marina and Golf Resort Page 1-7 November 27, 2007 Figure 1-7 Terrace Condo-Tel Center FINAL EIS - (Site Specific Amendment MLA 06-87) THE PROPOSAL CHAPTER 1 Pleasant Harbor Marina and Golf Resort Page 1-8 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) Figure 1-8 Golf Course Alpine Townhome Housing - Typical THE PROPOSAL CHAPTER 1 Pleasant Harbor Marina and Golf Resort Page 1-9 November 27, 2007 Figure 1-9 Staff Housing, Community Center, Mechanical Area, and Emergency Entry Typical Golf resort sections are shown in Figures 1-10 and 1-11. FINAL EIS - (Site Specific Amendment MLA 06-87) Alpine Townhome Figure 1-10 Section – Residential Type 1 Development –Black Point Lands THE PROPOSAL CHAPTER 1 Pleasant Harbor Marina and Golf Resort Page 1-10 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) Alpine Villa Figure 1-11 Section – Residential Type 2 Development –Black Point Lands Fire safety note—As a general matter, all buildings are required to provide a 1.5 x height collapse zone, and an area suitable for ladder access to any side of the building not served by paved surfaces of 10- 15 feet wide. The specifics of such a program are detailed in conjunction with building plans, and are not necessarily shown on these sketches (applies to the marina area as well as the Golf area). THE PROPOSAL CHAPTER 1 Pleasant Harbor Marina and Golf Resort Page 1-11 November 27, 2007 1.2.2 The Marina and Maritime Village The Maritime Village is the northerly component of the Master Planned Resort, located between US HWY 101 and the Pleasant Harbor Bay, and consists of the marina, the maritime resort, and water side resort. See Figure 1-12. Commercial 16,000± square feet Water-side units 63 units Townhouses 40 units Villas 48 units Total 151 residential units Figure 1-12 Site Plan – Marina Area: 37± acres Impervious: 22% Pervious: 5% Natural: 73% Note: Pervious includes lawns and other pervious developed areas. The natural area consists of pervious areas that are planned to be undeveloped. FINAL EIS - (Site Specific Amendment MLA 06-87) THE PROPOSAL CHAPTER 1 Pleasant Harbor Marina and Golf Resort Page 1-12 November 27, 2007 Legend for Figure 1-12 Site Plan – Maritime Village and Waterside Lots FINAL EIS - (Site Specific Amendment MLA 06-87) THE PROPOSAL CHAPTER 1 Pleasant Harbor Marina and Golf Resort Page 1-13 November 27, 2007 1.2.2.1 Maritime Village Subarea The Maritime Village subarea is located at the northerly end of the marina and is a redevelopment of the existing marina and commercial facilities serving the marina. Figure 1-13 Site Plan – Marine Village Subarea Redevelopment of the existing marina complex into a mixed use "Maritime Village." Four mixed use buildings would include 16,000± square feet of commercial space, with recreational residences located above, accessed via an adjoining service road. A waterfront pedestrian promenade will be developed along the shoreline between the new structures and the existing marina. • The 16,000± square feet of commercial space is proposed to contain a mix of uses. • Retention of the existing 285-slip Pleasant Harbor Marina. No expansion is planned for the existing docks other than cleanup of wood docks, creosote piers, and replacing the fuel tanks and delivery system. • Development of a new access road from Black Point Road north on the upland side of the properties as a one-way access to the Maritime Village area. • Closure of five existing access/egress points from US HWY 101. The new Maritime Village will replace the existing convenience store and boater’s room (circa 1950s), as well as other smaller existing structures. The septic tank(s) and pump house will be replaced with a Sewage Treatment Plant and Water Treatment System. The Fuel Containment Tanks and Pump will be replaced with the new fuel system. The Maritime Village Promenade may include a variety of small service and commercial facilities in a 16,000± sq. ft. facility. A typical mix could include: • A convenience store • An entertainment center • A marine store • A small restaurant and pizza delivery FINAL EIS - (Site Specific Amendment MLA 06-87) THE PROPOSAL CHAPTER 1 Pleasant Harbor Marina and Golf Resort Page 1-14 November 27, 2007 • A gift and arts and crafts store • A registration/reception area for guests that is combined with Pleasant Harbor Yacht Club (includes showers, steam rooms, change rooms, and laundry facility) A Maritime Village could also include both active and passive water features. No vehicles (other than emergency vehicles) are allowed access to the pedestrian promenade adjacent to Pleasant Harbor. The promenade is pedestrian only and connects with an extensive pedestrian pathway network linked throughout the resort. The Maritime Village resort front or rear balconies or solariums are always orientated towards the view lines of the one- and two-story resort villas and townhomes. • The secondary one-way road exits US HWY 101 (see Figure 1-15). • The buffers to the five natural streams on the property are to be restored and natural buffers retained within 50 feet of the stream’s edge. • Commercial parking and guest parking will be available at below grade parking areas as well as surface parking off Black Point Road. All subsurface parking will have to provide fire safety systems, including air handling, water, emergency access, and egress. • A shuttle provides public transportation to offsite locations, and pedestrian pathways provide public walking areas within the resort. • The Maritime Village development is designed to be set back 30 feet from the top of natural slopes, except those improvements directly serving the marina. Typical sketches are illustrated in Figures 1-14, 1-16, 1-17, and 1-18. The figures are illustrative of the general location, bulk, and density of the residential units proposed. Site-specific considerations include compliance with County shoreline setbacks and setbacks from the top and toe of protected slopes, and orientation to fit the specific site requirements. Figure 1-14 Section – Residential Type A Development –Maritime Village FINAL EIS - (Site Specific Amendment MLA 06-87) THE PROPOSAL CHAPTER 1 Pleasant Harbor Marina and Golf Resort Page 1-15 November 27, 2007 The rehabilitated area includes pathways and fire access consistent with local code requirements. Figure 1-15 Maritime Village Circulation Plan Figure 1-16 Section – Commercial/Residential Development –Marina Lands FINAL EIS - (Site Specific Amendment MLA 06-87) THE PROPOSAL CHAPTER 1 Pleasant Harbor Marina and Golf Resort Page 1-16 November 27, 2007 1.2.2.2 The Waterside Residential Area The eastern portion of the Maritime Village portion of the resort consists of townhomes and terraced condominiums that have private access from the reconstruction of the existing 12-foot roads to one-way accesses for the residential condominiums and another 12-foot one-way road providing public access to the Maritime Village. • The Water Side Lots; the Bed and Breakfast; and the Kaufman Blue House. This land area is planned for stacked Alpine Style Garden Town Homes, Terrace Condominiums and residents’ surface parking. A new Habitat Townhome design follows the grades and creates view lines as shown in Figure 1-17. Figure 1-17 Section – Residential Type B Development –Marina Lands FINAL EIS - (Site Specific Amendment MLA 06-87) Figure 1-18 Section – Residential Type C Development –Marina Lands THE PROPOSAL CHAPTER 1 Pleasant Harbor Marina and Golf Resort Page 1-17 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) The figures are illustrative of the general location, bulk, and density of the units and commercial development proposed. Site-specific considerations include compliance with County shoreline setbacks and setbacks from the top and toe of protected slopes. Such considerations may require minor changes in location and orientation to fit the specific site requirements. The illustrations are typical and not site specific. 1.3 Summary of the Proposal and Permitting Limitations The golf course resort development will involve the development of the preliminary and final plat, creating the lots on which the project is constructed (including all road, sewer, water, stormwater, and other infrastructure). All infrastructure serving the phasing plan of the plat must be installed before site development may begin. The key elements of the residential portion of the project are the terraced lofts, the Alpine townhomes and Villas. The drawings shown are conceptual, but any development must substantially reflect the orientation, layout, and composition of the proposal. Mandatory elements of any application shall include: • Total acres • Golf side—220± acres • Marina side—37± acres upland and 15.2± acres tidelands • Total units 890 project limits • Golf side—739 units • 52 staff apartments • Not more than 68 units (10% of resort properties) as permanent residences, plus any units transferred from the marina side • Not more than 40% of resort units for long-term tourist use (seasonal stays not to exceed six months) • At least 50% of resort units in short-term tourist pool • Marine side—no more than 151 units • Not more than 16 (10%) permanent residences (may be shifted to golf course side, but total permanent residences shall not exceed 84 units) • Not more than 30% seasonal tourist, not to exceed six months • At least 60% in short-term tourist pool • Impervious surface • Golf side—20% • Marina side—40% 57577-0001/LEGAL13724174.1 THE PROPOSAL CHAPTER 1 Pleasant Harbor Marina and Golf Resort Page 1-18 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) THE PHYSICAL SETTING CHAPTER 2 Pleasant Harbor Marina and Golf Resort Page 2-1 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) CHAPTER 2 – THE PHYSICAL SETTING This section describes the physical setting in which the proposed action and alternatives will occur. 2.1 Location of the Proposal and Alternatives The site is located in southerly Jefferson County on the shores of Hood Canal and Pleasant Harbor, a naturally occurring bay. The area is encompassed in the Brinnon Subarea Planning Area of the County. 2.2 Brinnon Subarea Brinnon is an unincorporated community situated at the mouth of the Dosewallips River on both sides of US HWY 101, between the Olympic Mountains and Hood Canal. The Brinnon planning area is defined by the Forest Service’s Rainbow Campground at Mount Walker on the north and the Jefferson County line to the south, and includes all the land in between Hood Canal west to the Olympic National Park. Within the Brinnon planning area the majority of the lands are forest lands owned by the federal and state government and private timber companies. There are also small concentrations of retail and commercial services in Brinnon and at Black Point/Pleasant Harbor. With the exception of small lot subdivisions, the BSAP is characterized by low density residential development with a remote, rural character. Higher density residential lands tend to occur along or near the Hood Canal shoreline and portions of the Duckabush and Dosewallips Rivers. Current residential zoning is in the form of five-, ten-, and twenty-acre lots. At the time of adoption of the BSAP there was an anticipated 20-year demand for 280 residential lots to accommodate the projected population increase. There are approximately 900 vacant lots on record. Recent interest in canal and vacation housing, however, may accelerate the projected rate of absorption. Current population for the BSAP is estimated at 1,320 people, based on the year 2000 population of approximately 1200 and 2.03% annual growth rate for five years. Local population may grow to 5,000 when summer and seasonal residents are counted in the peak summer season. Recent population trends in the area suggest the majority of this increase is from people retiring to the area who are 50 years of age and older. Ownership and occupancy trends also suggest that nearly half of developed lots are in seasonal or recreational use, and the percentage of seasonal ownership will likely increase, due to the overall growth of the Puget Sound region and the attractive natural amenities of west Hood Canal. This demand for recreational properties contributed to the doubling of average housing prices between 1990 and 2000. The demand for both permanent retirement and recreational homes continues to drive up local housing prices. THE PHYSICAL SETTING CHAPTER 2 Pleasant Harbor Marina and Golf Resort Page 2-2 November 27, 2007 Figure 2-1 Brinnon Comprehensive Plan Land Use Designations FINAL EIS - (Site Specific Amendment MLA 06-87) THE PHYSICAL SETTING CHAPTER 2 Pleasant Harbor Marina and Golf Resort Page 2-3 November 27, 2007 The Brinnon core is designated a Rural Village Center (a LAMIRD under GMA) in the Jefferson County Comprehensive Plan. This is an area of approximately 66 acres, with about 19 acres currently vacant. Developed land is a mix of residential and commercial uses such as a restaurant, motel, insurance office, grocery/gas station, nursery, and post office. The intent of the Rural Village Center (RVC) designation is to allow for commercial infill development to take advantage of what is expected to be an increase in local tourism from the overall growth of the Puget Sound region, and to allow for the possibility of higher density, lower income housing. Also in the RVC are the Brinnon School and the headquarters for the Brinnon Fire District #4. Figure 2-2 Aerial Photo, Black Point to Brinnon (Brinnon town site located just north of the river, not south as shown on the map) Brinnon has a large number of platted lots, but development in some areas is limited by a high ground water table, a lack of sewer facilities, and a flood plain/flood way (see Figure 2-3). FINAL EIS - (Site Specific Amendment MLA 06-87) THE PHYSICAL SETTING CHAPTER 2 Pleasant Harbor Marina and Golf Resort Page 2-4 November 27, 2007 Figure 2-3 Dosewallips Floodway 2.3 Existing Site Conditions (Black Point/Pleasant Harbor) The area known as Black Point is an approximately 710-acre peninsula that is surrounded on the north, south, and east by the waters of Hood Canal. Pleasant Harbor is formed by the west shore of Black Point and the mainland and is connected to Hood Canal by a narrow channel at the harbor's north end. US HWY 101 defines the remaining western edge of Black Point. 2.3.1 Black Point (Figure 2-4) Land use on Black Point itself is comprised of full-time and seasonal residences; vacant residential parcels; a previous, nonconforming 500-unit RV campground that is currently used in the summer season and is permitted for 60 RV sites; a real estate office; and approximately 30 acres of forest owned by the Washington State Department of Fish and Wildlife (WDFW), which has a boat ramp and picnic facilities at the south end of Pleasant Harbor. There are 246 platted parcels on Black Point. Of the remaining parcels, 158 are developed with some kind of residence, 72 are vacant, 4 are set aside for community use, and 4 are owned by the WDFW. FINAL EIS - (Site Specific Amendment MLA 06-87) THE PHYSICAL SETTING CHAPTER 2 Pleasant Harbor Marina and Golf Resort Page 2-5 November 27, 2007 According to the 2000 Census there are 107 permanent residents on Black Point, which represent approximately 57 full-time dwelling units. This suggests the other 101 developed residential lots are for seasonal or recreational use. The majority of the existing lots (225) are zoned for one dwelling per five acres, so the existing lot configuration is not expected to increase. The Black Point subdivisions are served by a public water system and onsite sewage Figure 2-4 Black Point Properties disposal systems (septic tanks and drainfields) on individual lots. There are two subdivisions of significantly smaller lots in this zoning district: a larger concentration along Rhododendron Lane at the northeast tip of Black Point and a smaller concentration off of Roberts Road at the southeast corner adjacent to US HWY 101. The majority of these smaller lots are developed with residences and serviced by Pleasant Tides water system and individual septic systems. Figure 2-5 Pleasant Harbor Undeveloped areas of Black Point are dominated by stands of mature second and third growth forest composed of indigenous coniferous and deciduous trees, along with a healthy community of understory plants and shrubs. 2.3.2 Pleasant Harbor Marina Pleasant Harbor (see Figure 2-5) is an all-weather, deep-water harbor that contains two marinas and is accessed through a narrow channel from Hood Canal. A State Park overnight moorage dock and ten private docks share the shoreline of Pleasant Harbor with the two marinas. A public boat launch is also located at the southernmost extent of Pleasant Harbor on Washington Department of Fish & Wildlife lands. A new boat ramp has been constructed in the southwest corner of the harbor by the WDFW to promote access to the Hood Canal fishery (see Figures 2-6 and 2-7). The Pleasant Harbor Marina is a commercial marina located on the harbor's north side. The marina contains 285 boat slips. The marina is equipped with a fuel dock for marine fueling for both boats and float planes. Pump-out facilities are located on the gas dock, providing sewage disposal for boats in the harbor. Figure 2-6 New WDFW Boat Launch FINAL EIS - (Site Specific Amendment MLA 06-87) THE PHYSICAL SETTING CHAPTER 2 Pleasant Harbor Marina and Golf Resort Page 2-6 November 27, 2007 A second, smaller marina, the Home Port Marina, is located northeast of the Pleasant Harbor Marina near the entrance to the harbor. Another marina is located more than four miles away on the east shore of Hood Canal in Seabeck. Marinas are limited on Hood Canal, so Pleasant Harbor acts as an important fueling, mooring, and sewage disposal site for boaters on the Canal. Figure 2-7 WDFW Boat Launch 2.4 Hood Canal Hood Canal is a dominant environmental feature of the proposal area. Unlike a true canal, it is a sixty- mile long narrow, deep, body of water much like a fjord. The freshwater sources of the Canal include snow and glacier melt from the Olympic Mountains, and numerous spring fed lakes and wetlands of the Kitsap Peninsula, all of which are carried to the Canal by a number of rivers and many small streams. There are also points along the Canal that directly receive groundwater. Figure 2-8 shows the extent of the Hood Canal drainage basin. Hood Canal supports multiple natural environments, along with recreational and commercial interests. The Canal has long been known for its diversity and abundance of wildlife. It contains several types of fisheries, including salmon and shellfish, which are an important part of the local economy and of particular commercial interest to local Tribes. Tourism is a significant part of the Hood Canal Region's economy, attracting people for recreation such as sailing, fishing, orca and bird watching, and for camping and hiking in the nearby state and national parks and forests. It is a strategic waterway and home to the Bangor Naval Submarine Base. Its shores and near uplands have also become home for an increasing number of people as the Puget Sound region has continued to grow. Figure 2-8 Hood Canal – River Basin The geology and underwater topography of the Canal play a key role in overall water quality and the dynamics of how its waters circulate. Compared to the rest of the Canal, the entrance is relatively shallow at approximately 150 feet in depth. Immediately south of the entrance the FINAL EIS - (Site Specific Amendment MLA 06-87) THE PHYSICAL SETTING CHAPTER 2 Pleasant Harbor Marina and Golf Resort Page 2-7 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) Canal becomes very deep, averaging between 500 and 600 feet. The geology creates a bottle-neck in the Canal that restricts water flow and the ability to exchange or 'flush' with the changing tides and seasons. Estimates of the length of time for complete water exchange range as high as thirty years. In addition, the waters of Hood Canal are often highly stratified. Fresh water from the surrounding drainage basin tends to remain near the surface and creates an upper layer of water that has a different temperature and salinity than the deeper layer. This stratified water mixes poorly, making oxygen and nutrient exchange difficult. The end result is that Hood Canal is highly susceptible to impacts of surrounding development and “high impact” human activities that introduce sediments, chemicals, and organic material into the Canal's waters. For this reason, any resultant development must focus on low impact, zero discharge designs where possible. 2.4.1 Recreation on Hood Canal The state recreational areas near the proposed master plan are both significant and popular, with more than one half million visitors to the area annually, principally in the summer season. Washington State Parks has developed a Management Plan for the state-managed parks in the Dosewallips Area, near Brinnon: (1) Dosewallips State Park, 424.5-acres/5,500 feet of shoreline – has picnicking, hiking, boating, fishing, public recreational shellfishing for oysters, clams, crabs, shrimp (387,221 visitors in 2004); (2) Triton Cove State Park, 28.5 acres/593 feet of shoreline – has picnicking, shore fishing, public recreational shellfishing, and boating (42,212 visitors in 2004); (3) Pleasant Harbor State Park, 1 acre/100 feet of shoreline – has sheltered moorage (2,439 visitors in 2004); (4) Toandos Peninsula, with 10,000 feet of shoreline, has public recreational shellfishing with boat access; (5) Point Whitney Shellfish Laboratory on the tip of Pt. Whitney has a boat launch available for public use. (6) Right Smart Cove, 1 acre/200 feet of shoreline – has kayaking and limited access. An on-line version of the approved June 2006 Dosewallips State Park Area Management Plan may be obtained at: http://www.parks.wa.gov/plans/dose/Dosewallips%20Final%20Plan.pdf. See also the Dosewallips State Park web site at http://www.parks.wa.gov/parkpage.asp?selectedpark=Dosewallips. Additionally, the state-owned Duckabush Tidelands, located off US HWY 101 about 3.9 miles south of Brinnon, are open year-round for public recreational shellfish harvesting. THE PHYSICAL SETTING CHAPTER 2 Pleasant Harbor Marina and Golf Resort Page 2-8 November 27, 2007 2.5 The Olympic Mountains The other outstanding natural and recreational features of the area are the Olympic Mountains, and its combination of National Forest, National Park, and recreation areas. Figure 2-10 Olympic National Forest Figure 2-9 Olympic National Park The Brinnon Subarea includes access to the Olympics through three trailhead systems: the Duckabush and the Dosewallips to the north, and the Hamma Hamma to the south. The Seal Rock Park campground, located just north of Brinnon, provides public access to the shoreline. The Olympic National Forest is managed by the U.S. Forest Service, and the Olympic National Park by the National Park Service. Significant information about both systems is available on line: Olympic National Forest website: http://www.fs.fed.us/r6/olympic/ Olympic National Park website: http://www.nps.gov/olym Published reports identify more than four million tourists per year visit the National Forest and National Park annually, and here again, the use is heavily skewed to the tourist season from May to October. See: http://www.olympicpeninsula.org/research.html. Access to the Olympic National Forest and Olympic National Park will be one of the attractions of the resort. FINAL EIS - (Site Specific Amendment MLA 06-87) THE PHYSICAL SETTING CHAPTER 2 Pleasant Harbor Marina and Golf Resort Page 2-9 November 27, 2007 Figure 2-11 National Forest/National Park Trail Systems Near Brinnon 57577-0001/LEGAL13724199.1 FINAL EIS - (Site Specific Amendment MLA 06-87) THE PHYSICAL SETTING CHAPTER 2 Pleasant Harbor Marina and Golf Resort Page 2-10 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-1 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) CHAPTER 3 – PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL The purpose of SEPA is to examine the potential environmental consequences of a project that “have a reasonable probability of more than a moderate impact on the environment” resulting from the proposal. SEPA is also used to identify means of avoiding the impact or mitigating the impact where avoidance is not feasible, and to identify alternatives that may provide a beneficial result. The County issued a determination June 13, 2006 concerning the probable significant adverse impact for the proposed Master Planned Resort, based on three alternatives: • No action • The proposal • The conceptual plan described in the Brinnon Subarea Plan. During subsequent discussions, the County requested analysis of a “hybrid model” which looked at the proposal in context with the surrounding Master Planned Resort (MPR) lands outside the MPR to view the overall impact of the project in context with other anticipated development. This alternative is referred to as the "hybrid" model. All four alternatives are addressed in the EIS. As a result of the scoping process, the County concluded that the potential for adverse impact affected nine areas of the environment and related sub issues: (1) shellfish, (2) water, (3) transportation, (4) public services, (5) shorelines, (6) fish and wildlife, (7) rural character, (8) archeological and cultural resources, and (9) critical areas. (See Scoping Notice dated June 13, 2006.) This section will address the base conditions for each, the proposal and the preliminary recommendations for avoidance or mitigation. The alternatives share many of the impacts and the difference may be in timing or scale. The analysis of the alternatives and the resulting impacts will be discussed in Chapter 4. At the programmatic level, the approval of the Comprehensive Plan amendment and Master Plan and associated development agreement do not vest the right to construct any specific project. If approved, the Master Plan is the guideline for future permitting to assure the permits issued for the development of projects within the approved Master Plan area are consistent with the guidelines and mandatory elements set forth in the EIS. The format here will be to address the specific inquiry by scoping notice topic and address how the issue is affected by and to be addressed by any specific Master Plan approval. Supplemental environmental review and the opportunity for the public to address project-specific environmental issues will be provided at each permit review process. 3.1 Existing Conditions The golf course resort is located south of Black Point Road and occupies approximately 220 acres. The site was previously devoted to a 500-unit campground formerly owned by Thousand Trails and NACO, and was well developed with a clubhouse, roads water system, and camp sites. (See map at Appendix 1.) The site is characterized by several relatively flat terraces, interspersed with steep slopes and a series of kettles or depressions; the bottoms of three kettles are characterized by wetland vegetation. Most natural runoff on the site is presently contained in the kettles or filtered through natural vegetation. The southern portion of the site is a steep bluff (100+ feet high) and a narrow beach PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-2 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) fronting the shellfish beaches on the Duckabush River delta. A small path presently leads from the top of the bluff to the beach, but no development is located in proximity to the bluffs or the beaches. Pleasant Harbor is an all-weather deepwater harbor along the western edge of the Hood Canal, 18 nautical miles south of the Hood Canal floating bridge, near Brinnon, Washington. The existing marina contains 285 boat slips, including 21 that can accommodate vessels up to 150 feet in length and dates from the late 1940s and was most recently permitted for expansion in 1997.1 The current Pleasant Harbor Marina is equipped with a fuel dock for marine fueling with a sewage pump-out located on the dock. The marina was expanded to its current configuration under permits granted in 1997 and the occupancy and planned operations of the marina as a functional part of the resort are within the range of uses and densities contemplated when the marina expansion was approved. Further expansion of the marina or its operations, beyond that approved under previous permits, is not anticipated as part of the proposed project by Statesman Corporation. Most recently, permits were approved for the expansion of the WDFW boat launch (constructed and put into operation in 2007) located at the southerly end of the marina. While the presence of the resort may increase the overall use of both the marina and boat launch as a destination or launch site for boating activities, both the marina and the boat launch are planned for public activity and both facilities are anticipated to operate within previously approved limits even with the development of the resort. Any expansion of either marina or boat launch facilities would require new permits and review. None is planned in conjunction with the resort. The Pleasant Harbor/Black Point area is ringed with residential development on small lots with septic disposal. Many of the waterfront lots in the harbor have docks or float facilities that are used for boating, making the harbor an active maritime area, particularly in the summer. Pleasant Harbor has some live aboards, and, to a greater extent so does the marina to the north. The WDOH has a water quality monitoring station, #293, in the Hood Canal near the mouth of Pleasant Harbor to measure bacteria levels used to determine shellfish closure zones (WDOH 2005). Water quality in Pleasant Harbor “meets standards but there are some concerns;” however, the WDOH has prohibited shellfish harvesting in Pleasant Harbor based on standard concerns with any shellfish grown in an area adjacent to a marina (WDOH 2006a). This decision is not likely to change due to the risk of shellfish containing harmful biotoxins and pollutants to humans. Commercial and recreational shellfish harvesting is not allowed in prohibited areas. 3.2 Shellfish Jefferson County received scoping comments concerning potential adverse impacts: • Whether the resort would result in increased vessel operation in Pleasant Harbor that may create a risk of increased closure to shellfish harvesting in the immediate surrounding area. • How to address an invasive species, Club Tunicates (Styela clava),2 that has been found in the marina and reduce the potential that Pleasant Harbor will be the catalyst for a rapid bloom of Tunicates onsite having specific, localized impacts on the shellfish in Black Point and Pleasant Harbor. 1 The shoreline permit for the marina expansion is SDP96-0009, issued July 14, 1997. The Final Binding Site Plan for Marina Expansion at Pleasant Harbor Marina was approved August 18, 1998, Sheets 1-5. The permits and associated terms and conditions are available at the Jefferson County Department of Community Development office and Headquarters Fire District # 4. 2 Club Tunicates are not shellfish, but are addressed here for convenience purposes. PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-3 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) • How to assure the potential for the project to affect water quality in Hood Canal, as it may affect fish or shellfish is addressed, and means are identified to eliminate or mitigate potential significant adverse impacts. If water quality degradation occurs as a result of the resort activity, other marine-dependent organisms, including fish, invertebrates, whales, and porpoise may be affected. Where such impacts are identified, measures to eliminate the source of contamination must be identified and addressed in any permit review. The purpose of the mitigation measures suggested and/or required by this EIS is to assure that the project is designed to avoid water quality impacts. 3.2.1 Shellfish—Pleasant Harbor No additional shellfish closures are anticipated as a result of the approval of the Pleasant Harbor Marina and Golf Resort. Water quality data for Pleasant Harbor and the existing marina, including data relating to the existing marina operation, was collected as available and summarized in the report found in Marina Impact Report. (See August 15, 2006, Report at Appendix 2.) Shellfish closure zones established by the Washington State Department of Health (WDOH), marine water quality data records from Jefferson County Department of Health, Washington State Department of Ecology (WDOE), Washington Department of Fish and Wildlife (WDFW), and local Tribes were sought and collected as available. The water circulation patterns of Pleasant Harbor were collected from current and tidal records. The boating movement around the piers and docks was also recorded and examined to determine the route of travel in the harbor. A field assessment of Pleasant Harbor and the marina environment was conducted to assess the existing conditions to obtain information on the areas of concern and to obtain site photographs. The marine survey was conducted from a boat and included water quality measurements as well as wildlife observations. The field survey also documented general characteristics in the harbor. Additional information is also provided based on meetings and discussions regarding the Styela clava and proposed dock replacement program with the WDFW since September 2006. A site visit to the marina with the WDFW occurred on September 15, 2006. Shellfish resources, including mussels, clams, and oysters were observed within Pleasant Harbor and in the vicinity of the Pleasant Harbor Marina. The number of slips at the Pleasant Harbor Marina will not increase as a result of the proposed resort, nor will the operation capacity of the marina increase from previously approved expansion as a result of the resort. Boating traffic and movement in the harbor may be expected to increase from the general public over time as a result of increased interest in the resort. However, increased level of activity is occurring in marinas regionally due to the limited number of marinas available, and no material increase is predicted over that contemplated in permits for the existing marina. A new boat launch has been constructed by the WDFW on the western side of the harbor. See Figures 3-1 and 3-2. This boat launch will require a fee to launch a boat. This new boat launch will attract more boaters to Pleasant Harbor to enjoy the recreational activities in the area. All of Pleasant Harbor is designated as a no-wake zone. Pleasant Harbor Marina typically receives about 1,000 guest moorages per year (Pleasant Harbor Marina 2006). There has been no dredging of Pleasant Harbor in the past 20 years and there are no plans for any marina expansion located in Pleasant Harbor. PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-4 November 27, 2007 Figure 3-2 New WDFW boat launch Figure 3-1 New WDFW boat launch The shoreline permit conditions for the marina expansion approved in 1997 (at a time when a Master Planned Resort was already under discussion for the area) do remain in effect, and as discussed below, certain additional mitigation requirements will be imposed to assure water quality is maintained, but no significant change or deterioration is expected. 3.2.1.1 Shellfish Mitigation Measures—Pleasant Harbor Mitigation for impacts resulting from the current operations, including stormwater runoff and the dependence of the area on wells and septic tanks, is found in requirements to upgrade the public facilities at the Maritime Village, upgrading the fueling and pump out docks, and the onshore facilities to minimize the risk of spill. The marina is required to have spill prevention plans and spill containment facilities in place, and all such plans shall be reviewed at the time of the shoreline permit review to assure that the plans are up to date and consistent with best management practices. The permit and mitigating conditions required for the marina will remain in place, and additional mitigation will be required to provide additional assurance that the marina operations will not adversely affect the use or health of shellfish operations. All of the marina and golf course shoreline areas are subject to regulation under the County’s existing and planned shellfish protection district. The resort shall be required to comply with shellfish protection district conditions. There is always a potential for water quality or conditions to shift over time, and the shift may or may not be due to marina or resort operations. Taking advantage of the existing state water quality monitoring program at the mouth of Pleasant Harbor, however, the resort will be required to annually collect all water quality monitoring data from the state monitoring stations in the area and to summarize any changes to the County. The owner is also required to conduct water quality monitoring under the terms of the marina permits, which shall be continued. Should any changes in water quality be identified, the County and agencies with jurisdiction may require changes in operation to end, minimize, and/or mitigate any recent activities causing adverse change. The resort will be required to participate in an adaptive management program to rectify the problem, including eliminating the source, mitigating and treating to avoid the problem, or taking other steps necessary and appropriate to preserve water quality for any source tied to the resort or resort marina operations. The marina also provides the opportunity for an expansive boater education program similar to those under review by the County in conjunction with its shellfish protection district and shoreline permits will assure that a boater education program appropriate to the size and setting of Pleasant Harbor is incorporated into any shoreline permit operational requirement for the marina and/or Maritime Village. FINAL EIS - (Site Specific Amendment MLA 06-87) PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-5 November 27, 2007 The most significant mitigation resulting from the Master Plan proposal is found in the replacement of the existing septic system for the marina (a common source of contamination, particularly in harbors and bays) with a sewer system to eliminate the risk of effluent or treated wastewater entering the bay (all wastewater is treated to Class A standards in the new wastewater treatment system and used for irrigation in the golf course area away from the harbor). The elimination of septic tanks, particularly those serving commercial uses, is a priority goal of groups seeing to clean up Puget Sound and should provide significant long-term benefit where usage of the overall facilities increases. 3.2.2 Shellfish—Outside Pleasant Harbor The overall health of the shellfish resources in the adjacent portions of the Hood Canal is good, with only a few harvest advisories and one shellfish closure in the area. The shellfish closure nearest to the closed waters of Pleasant Harbor is located more than 1 mile north in the Hood Canal along the shoreline of Brinnon, Washington (WDOH 2006). Significant shellfish beaches are found to the south fronting the Duckabush river system and north of Brinnon (see generally Chapter 2, section 2.4.1). A review of available literature identifies no presence of Priority Shellfish, Sea Urchin (Strongylocentrotus spp.), Dungeness Crab (Cancer magister), or Pandalid Shrimp (Pandalus spp.) located in Pleasant Harbor (WDFW 2006). However, presence of these species is documented in the water of the Hood Canal surrounding Black Point. Priority marine species may be present in Pleasant Harbor during certain times of the year. A detailed discussion of marine species in the vicinity of the site is found in the Shoreline Characterization Report, August 3, 2006, at Appendix 3. Pacific oysters were observed in the inter-tidal zone along the shoreline in Pleasant Harbor. It is possible that there will be an increased demand for public shellfish harvesting by visitors to the proposed development. Notification and information (before harvesting shellfish) will be available at the proposed development at specific locations, such as the marina, Maritime Village, and Conference Center. Identification of public shellfish harvest areas and limitations and mapping of private beds for which public shellfish harvesting is not permitted will be part of the public service kiosk information at the Maritime Village. Shellfish harvesting is a popular activity in the area, with open beaches for public use managed by the State. The resort is located in an area central to the local shellfish interest and provides an alternative for visitors to the area, taking some pressure off the Dosewallips State Park, which presently sees almost 400,000 visitors per year. The park allows visitors to take advantage of local fish, shellfish and other recreational opportunities. 3.2.3 Aquatic Invasive Species Tunicates Since 2004, at least a dozen invasive Tunicate colonies (Figure 3-3) have spread throughout the sound, turning up in Hood Canal, Birch Bay, Totten Inlet, Des Moines, and Neah Bay. Their proliferation concerns state biologists, who worry the non-native invader will continue to expand along the coast causing ecological damage and threatening native species. (Fact Sheet, Washington Department of Fish and Wildlife, March 2006). See Figures 3-3 and 3-5. Certain non-native Tunicates are considered an "aquatic invasive species"—non-native plants and animals ranging from spartina to zebra mussels, which threaten the biological diversity of Washington State's coastal waters. Tunicates, also known as Sea Squirts, are siphon-feeding marine animals that have a heart, stomach, and intestines. They have no known predators Figure 3-3 Invasive Species FINAL EIS - (Site Specific Amendment MLA 06-87) PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-6 November 27, 2007 and can quickly blanket the hull of boats, pilings, and other hard surfaces, out competing or suffocating other sea life, including clams, mussels, and oysters. WDFW representatives believe that as Tunicates continue to multiply in Washington waters, they pose a serious threat to the State's multi-million dollar shellfish aquaculture industry, just as the creatures have done in other parts of North America. The Washington Legislature took action in 2004 to halt the advance of Tunicates and other invasive species. Lawmakers directed the WDFW to develop a response plan to address discoveries of aquatic invasive species. The response plan is currently being developed. The State also has developed standards for discharging ballast water, which is considered the likely source for the introduction of most invasive plants and animals. Ballast water is drawn into ships for stability and often contains many foreign species. Each year, approximately 3,500 large vessels enter Washington, and approximately 40 percent of those ships discharge ballast in state waters. Vessels themselves also pose a threat. Tunicates and other aquatic invasive species can attach to hulls and anchors. Recreational boats can also spread invasive species if the vessel is moved from one body of water to another. Beginning in 2006, as part of the mitigation efforts, WDFW will provide boaters at boat ramps and harbors throughout the coastal region information on invasive species and how to properly clean boats and trailers. WDFW enforcement also will be involved in the effort, educating other law enforcement agencies on the invasive species problem, monitoring aquatic plant and animal dealers, and checking vessels at boat launches and harbors. As part of the response plan initiative the Department of Fish and Wildlife contacted the current owners of Pleasant Harbor Marina and the applicant to discuss the opportunity for partnership in addressing the issue. Figure 3-4 Pleasant Harbor Meeting Through experiments the WDFW has determined that power-washing vessels and concrete docks are a more effective removal process than hand-picking Styela clava (Sea Squirts). In Pleasant Harbor approximately 40% of the docks are wooden or have Styrofoam billets, which are not conducive to the preferred method of power washing. In order to facilitate the management and/or ultimate eradication of Styela clava in Pleasant Harbor, the WDFW is seeking to have all the wooden docks and those with Styrofoam billets to be replaced over time with concrete docks and concrete floats. Figure 3-5 Club Tunicate (Styela clava) 3.2.4 Tunicate Mitigation The proposed wooden dock replacement program for Pleasant Harbor Marina, which includes all of D, E and F docks, is the mitigation measure requested by the WDFW. In addition, I-dock will be replaced as it utilizes the Styrofoam billets and not the concrete floats as the rest of the marina docks. The concrete docks and floats will enable and facilitate the WDFW’s initiative to minimize the impact and/or eradicate Styela clava from Pleasant Harbor. The ideal time for the dock replacement is during the off season, since this will have the least impact on peak season demand and occupancy. Logistically there is less activity during off season, and off- season timing will minimize the impact on existing operations and customers. Peak season is from FINAL EIS - (Site Specific Amendment MLA 06-87) PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-7 November 27, 2007 May through September and off season is from October through April. It is also important to note that Styela clava are less active when the water temperatures are below 15 degrees Celsius, making this the ideal time for the dock replacement. There are two options for dock replacement, Figure 3-6, depending upon the source of funding and timing, which is yet to be determined. The preferred option is to replace the docks in stages in order to minimize the financial burden and impact on overall operations of the marina. For example, D-dock year 1, E-dock year 2, F-dock year 3, and I-dock year 4. See phasing plan at Section 3.3.3. The alternative is to replace all the docks in one season; however this would be more disruptive to existing operations and customers. This alternative is dependent upon the source of funding to make this option viable over a short time frame. Figure 3-6 Pleasant Harbor Aerial The WDFW is working to make Styela clava a prohibitive species in the State of Washington. When Styela clava is named a prohibitive species, it will provide the WDFW additional powers and authority needed to eradicate this evasive species. Within Pleasant Harbor, it is anticipated that this new legislation will enable the WDFW to expedite the wooden dock replacement program, which would ultimately impact our proposed timeline and phasing plan. This would result in the upgrades to the marina and Maritime Village to occur in an earlier phase. As part of the dock replacement program, consideration should be given to the opportunity for dock reconfiguration. The number of slips that can accommodate boats longer than 50 feet is limited and most marinas in Hood Canal have long waiting lists for these longer slips. 3.2.5 Shellfish—Water Quality—Protection Protection of the water quality in Pleasant Harbor and Hood Canal is a principle concern of the region during the construction and operation of the resort. The program will focus on means to avoid, minimize, or mitigate any anticipated impact. Impacts occur from existing operations (septic fields and untreated or partially treated stormwater), and could occur from construction (sediment and debris) and operations, particularly wastewater, stormwater and nutrient loading from operations. Pleasant Harbor is vulnerable to water quality issues, as is the adjoining Hood Canal. A shallow sill, approximately 150 feet deep, exists at the entrance of the Hood Canal that restricts the exchange of water between Hood Canal and the Puget Sound. It is estimated that water exchange within Hood Canal takes a magnitude of two years to completely flush (UW-HCDOP 2006). Studies conducted by the University of Washington have identified that the restricted circulation of the water within Hood FINAL EIS - (Site Specific Amendment MLA 06-87) PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-8 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) Canal, coupled with a high input of nutrients from numerous natural and non-natural sources, have led to serious water quality issues in the marine waters of the canal (UW-HCDOP 2006). A detailed discussion of water quality outside of Pleasant Harbor in the vicinity of the site is found in the report titled Shoreline Characterization Report Pleasant Harbor Marina and Golf Resort August 3, 2006 (Appendix 3). Water circulation in Pleasant Harbor is limited by a narrow (100 feet) and shallow (10 feet at low tide) inlet located at the east end of the harbor. The harbor area itself ranges from 30 to 40 feet in depth (Pleasant Harbor Marina 2006). The harbor water levels fluctuate with the tides and currents of the Hood Canal. The water quality samples are detailed in the Marina Impact Analysis, Appendix 2. The level of pH varied by less than 0.28 inside and outside of the harbor. Dissolved oxygen levels were within 2.36 mg/L in the upper sampling layer and within 2.24 mg/L in the lower sampling layer throughout all monitoring locations. Water temperatures inside of the marina were 3 to 4°C higher than the water quality samples taken outside of the harbor; however, this is expected to occur in shallow harbors such as Pleasant Harbor (Curley 2002 and University of Washington 2005). The salinity levels in Pleasant Harbor were also lower than those observed outside of the harbor. This lower salinity value can be attributed to circulation in combination with precipitation, groundwater, and seasonal and perennial freshwater input on the shoreline of the harbor (Curley 2002 and University of Washington 2005). Even though Pleasant Harbor has a narrow inlet and there are two marinas located in the harbor, water quality data suggests that the harbor is flushed by the tides on a regular basis to obtain the same water quality levels of the Hood Canal. With the elimination of the septic system serving the existing marina and the capture and treatment of stormwater from the marina development prior to entering the harbor, the overall effect of the Master Plan proposal is a reduction in pollutant pathways to the harbor and should result in greater protection of the overall harbor water quality than exists presently. On the Black Point land of the development, all rainwater percolates through the soils on site. Rainwater contributes to the wetland systems on the center and east side of the property, and there is no or limited runoff to the Canal from the majority of the site. See Figure 3-19. The construction of the golf course, residences, and commercial facilities are all designed to capture rainwater and stormwater onsite. This water will be utilized onsite, treated, and then be infiltrated back into the aquifer to eliminate site runoff and to maintain the aquifer system. This innovative approach eliminates offsite impacts and the potential for degradation of water quality and shellfish populations outside of Pleasant Harbor. The avoidance of offsite stormwater discharge either during construction or operation of the golf course facility achieves the objective of no net impact to the water quality of Hood Canal by reason of the construction and operation of the golf course resort. 3.2.6 Shellfish Mitigation—Construction Period On the marina side, construction grading is limited to the new road alignment, development pads, and parking areas, taking advantage of the natural conditions. On the golf course side, significant grading will occur, so special care must be taken to assure stormwater management measures will be implemented concurrently with clearing and grading for all phases, to protect water quality, both off site and in existing wetlands, during construction. The area to be cleared was previously cleared for the RV park. The cleared area is located in the internal portions of the site and a 200-foot buffer is planned along the southern shore that provides protection from wind. Narrow strips of trees are likewise avoided to reduce the risk of wind damage. Potential impacts during the clearing phase include the risk of runoff to the harbor or Hood Canal, a change in the hydrology of the site due to the removal of trees, and changing of the topography and potential impact to wetlands from silts, sediments, or hydrologic flow, both surface and subsurface. Habitat management plans and stormwater protection are required at the permit phase to address site- specific issues and mitigation. PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-9 November 27, 2007 The proposal does include a program to dedicate Wetland B to onsite retention and stormwater management, and the depth of the kettle is such that it can easily accommodate preconstruction stormwater from much of the site and prevent any accidental release. (See soils report at Appendix 4 and site plan conditions.) Figure 3-7 Cut/Fill Map To achieve adequate controls during grading and infrastructure construction, the County requires a detailed cut and fill plan with a stormwater management plan approved by the Public Works Department. Details shall be sufficient to demonstrate protection of Pleasant Harbor, Hood Canal, and onsite wetlands and streams prior to approval of each permit, or plan requiring review. See discussions at Section 3.3.7, Stormwater Management. See also detailed discussions at Section 3.10.1 discussing the need to preserve wetland hydrology during all phases of construction, development, and operation of the resort. 3.2.7 Shellfish, Tunicate, Water Quality Mitigation The Master Plan sets the guidelines for future development and any permit approval for the Master Plan, or any phase thereof must contain conditions which provide assurance that the objectives of the Master Plan will be achieved. To assure that result, the following conditions will be required of all plats, shoreline substantial development permits, and site plan approvals for portions of the Master Planned Resort project. FINAL EIS - (Site Specific Amendment MLA 06-87) PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-10 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) • During construction (all permits). • Construction period NPDES general permits will need to be obtained and conditions followed to control stormwater during construction to assure no offsite discharge. • All construction shall be covered by a stormwater management plan to show how stormwater shall be collected and infiltrated to prevent any turbidity, sediment, or other contaminants from reaching the harbor or waters of Hood Canal. • All stormwater crossing newly constructed surfaces shall be captured and treated onsite before discharge, including the golf course side, where irrigation and stormwater shall be captured treated, retained, and infiltrated onsite with no offsite discharge. • A stormwater site plan that includes a construction stormwater pollution prevention plan shall be developed by the proponent and reviewed and approved by Jefferson County prior to conducting land disturbing activity on the site. • During operation (Maritime Village permits) • All stormwater from impervious surfaces shall be captured and treated to Puget Sound Water Quality standards (2005 edition) before discharge. • There shall be no discharge of sewage or contaminated bilge waters at the marina. Pump out facilities shall be provided and operational at all times. • Cleaning of fish or sea life shall be prohibited within the controlled access areas of the marina. • The Project permits shall incorporate shellfish protection district guidelines. • The marina shall have the right to inspect any vessel at any time. • The marina shall develop and manage an active boater education program appropriate to the marina setting to supplement the County program developed as part of the shellfish protection district. • All fueling operations shall be brought up to current codes and protection against leaks, and unauthorized discharges shall be provided as part of any permit issued for work on the marina side of the resort. This is a first priority for the project. Fueling permits for facilities shall also require a refueling plan approved by the local Fire Code official as part of the first permit and in place prior to the issuance of any certificate of occupancy for work at the marina or Maritime Village. • Fuel storage or transfer shall be prohibited on marina floats, docks, piers, and storage lockers. • No storage shall be permitted on docks, including storage of oily rags, open paints, or other flammable or environmentally hazardous materials except emergency equipment as approved in the Emergency Service MOU. • Painting, scraping, and refinishing of boats shall be limited to minor repairs when in the water, which do not result in any discharge to the waters of the harbor. • Any minor repairs must employ a containment barrier that prevents debris from entering the marine waters. • Notification and information (before harvesting shellfish) will be available at the proposed development at specific locations, such as the marina, Maritime Village, and Conference Center. • The marina operations shall incorporate mitigation requirements appropriate under the County Shellfish Protection Plan, and shall integrate a boater education program into a PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-11 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) marina public education plan, which shall be implemented and maintained for so long as the resort is in operation, as part of a resort habitat management plan. • The marina operations shall collect water quality data (from State sources so long as available or from approved testing plan should the state sources move or not accurately reflect Pleasant Harbor conditions), and shall be required to participate with the County in an adaptive management program to eliminate, minimize, and fully mitigate any changes arising from the resort and related Pleasant Harbor or Maritime Village. • During operation (Black Point Golf Course Lands) • Construction and grading permits shall require stormwater management plans to demonstrate no discharge to waters of Pleasant Harbor or Hood Canal of any contaminants, turbid waters, or sediments as a result of operations. • The stormwater management system for all phases shall capture, treat, and infiltrate or store for reuse all stormwater from impervious surfaces of the improved golf course areas. • The golf course shall be operated in accordance with the best practice standards of the King County golf course management guidelines, or substantial equivalent, including, but not limited to, American Golf Association standards. • The golf course/resort facilities will be required to participate in any adaptive management programs required by the County as a result of the water quality monitoring program described above and any changes caused by the resort operations. By improving the current water treatment system at the marina area and the elimination of septic systems, and by the assurance that the golf operations will be managed to generally accepted best management practices for Pacific Northwest golf courses and the Master Planned Resort can avoid, minimize, and fully mitigate potential impacts to the shellfish and water quality of Pleasant Harbor and Hood Canal. 3.2.8 Shellfish Summary Shellfish are not harvested in the harbor and additional boat traffic is not expected to materially increase over that planned when the marina expansion was approved. Nevertheless, additional marina operation mitigation is required to control marina operations (see Section 3.2.1 infra). Puget Sound Water Quality Manual standards and County standards for stormwater management, for demolition, construction and operation phases shall be identified and approved as a part of any permit issuance for the marina side of the project. The golf course portion of the resort shall capture and control all stormwater onsite (except rain falling on the natural buffer areas and not crossing any portion of the built environment) to avoid risk of contamination to waters of Hood Canal south of the project site. Requirements for onsite waste treatment and Class A reuse and recycle systems also facilitate this requirement, and protect shellfish outside of Pleasant Harbor. In concert, the combined mitigation is protective of shellfish both inside and outside of Pleasant Harbor. The developer is working with the State to facilitate a Tunicate eradication program tied to dock replacement and using materials less likely to attract and harbor Tunicates. Water quality as an element of shellfish protection is protected by controlling runoff in the Maritime Village area to assure it is properly treated prior to discharge, and on the golf course side by requiring onsite treatment and use or infiltration rather than offsite discharge. 3.2.9 Shellfish: Responses to DEIS Comments Responding to concerns raised in comments from Taylor Shellfish Farms (357), John Adams (126), Dunagan (103), Hood Canal Environmental Council (275 and 385), Department of Fish and Wildlife PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-12 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) (306), Hal Beattie (125), Rebekah Ross (132), Ventura (312); Tyler (319), Lopez (272), Russell (282), Bowers (328), Beattie (310), Siefert (338). Concerns were raised about the impacts of the Master Planned Resort on Hood Canal as a result of construction near the 2,000-foot southern border adjacent to the Duckabush system and what steps are available to assure that water quality in Hood Canal is protected. Specific concerns include water quality and impact to shellfish and fish populations from water discharge and seeps resulting from land management and particularly fertilizers and pesticides used on the golf course, pet wastes, and aquifer recharge systems. The EIS adopts a two-step or phased approach to the concerns about water quality and the related issues of fish and shellfish in Hood Canal. The first step, at the programmatic level, is to address the areas of concern and identify mitigation measures that are responsive to the concern. The proposed development has been conceptualized and preliminarily designed to prevent degradation of water quality in Puget Sound/Hood Canal, and mitigation measures and BMPs will be implemented to minimize the potential for impacts to fish, shellfish, or water quality. The base condition to achieve this goal is through appropriate design and permit requirements which provide no runoff from developed areas is discharged to Hood Canal. Stormwater is captured onsite and stored in large kettles. Any excess stormwater not required for irrigation will be allowed to infiltrate to recharge the aquifer under WDOE standards and guidelines. This permit condition requirement is designed to protect water quality, as well as fish and shellfish habitats to the extent possible. Reuse water will be treated to a Class A standard, stored separately from collected stormwater, and used to supplement irrigation requirements (i.e. applied at a rate less than the agronomic demand). Nitrogen will be removed from the reuse water during treatment, and any remaining nitrogen and phosphorus is expected to be used by the irrigated plants, reducing the need for fertilizer application. Permits used to review and assure compliance with the program are the state's NPDES and water discharge requirements under Chapter 90.48 RCW and the County's review and approval of stormwater management plans. Master Plan conditions addressing the water quality, fish, and shellfish concerns include the following: • The upland wastewater treatment system will produce a Class A recycled water quality for reuse applications onsite, rather than a point source discharge/outfall to Hood Canal. • The 2,000-foot southern boundary and beach, which was promoted as an accessible amenity for prior users, is closed in the Master Planned Resort proposal and a 200-foot natural area buffer is to be retained (restored where camping and roads have intruded) to provide a natural edge and riparian protection. A permanent conservation easement or dedication to a land trust are being considered as a means of maintaining the 200-foot natural area in a natural state in perpetuity. A walking trail may be incorporated into this buffer area consistent with a habitat management plan. • The golf course is required to be designed to best management practices for stormwater, pesticide, and fertilizer control. Techniques include subsoil amendment and grass management programs (water, vegetation control, fertilizer, and pesticides) tied to local conditions and agronomic rates that limit the use of chemicals and other products to the minimum necessary and in manners and amounts which significantly limit the risk of either surface or groundwater pollution. Permit requirements to have the site engineered, constructed, and operated to meet best management practices available for water quality (not only for Hood Canal and the aquifer, but also the wetlands, habitats and streams onsite) and to provide a regulatory mechanism for engineering review in the context of a project-specific proposal to verify if compliance conditions are met. In addition, the golf course will also have a chemical and pest management plan prepared and implemented to control use, application, and storage of potential environmental pollutants. PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-13 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) • The County Code references the King County standards for golf course designs on aquifer sensitive areas, but that is an older document. The FEIS requires additional guidance on best management practices to assure best available technology is used at the project level prior to development approval. Reference sources include the Audubon certification guidelines and the Golf Course Superintendents Association of America recommendations as part of a site-specific best management practices manual tailored to best available science and local conditions, which must be approved during the permitting process to guide installation, operation, and maintenance of the golf facilities. The U.S. Golf Association (USGA) recommended environmental management system provides additional guidance. • The stormwater management system is to be designed to capture not only 100-year storm events, but upset events and extreme storms, so that under all conditions the stormwater from impervious, golf, and other managed surfaces is used either for supplemental irrigation purposes, or allowed to infiltrate to recharge the aquifer. A specific condition of approval is that the stormwater system on the golf course portion of the resort be designed to control runoff from major events and potential upsets within the developed area without discharge to Hood Canal. This means the detention and capture basins must be capable of containing more than the 100- year storm. Project design will address how such overall retention is to be achieved onsite and shall be approved as part of the County stormwater control permit process prior to any construction onsite. • NPDES permits and state water discharge permits under Chapter 90.48 RCW provide construction, operation, and management parameters and monitoring programs to verify that water infiltrating into the aquifer meets state no impact guidelines. To protect the aquifer, the water recycling and reuse system will produce a Class A reuse and recycling water quality standard. Managing and retaining all stormwater onsite for use in supplemental irrigation and aquifer recharge, combined with water recycling and reuse practices, will ensure there will be no degradation in water quality within Hood Canal due to this development. The water reuse treatment system design and reviews must demonstrate compliance with this requirement. • On the marina side all stormwater from upland impervious surfaces will be captured and retained onsite for supplemental irrigation use and aquifer recharge. Stormwater from areas outside of the Maritime Village capture system will be treated prior to discharge to Puget Sound water quality standards. Here again, the stormwater management program is to identify a program of maintenance and monitoring to assure that required standards are met. • The FEIS conditions the MPR on a monitoring and adaptive management program that provides for ongoing testing of water quality, and should changes be detected, a management program provides for project changes to be implemented until the operable guidelines are achieved. • Pet wastes can be a source of contamination and must be addressed through site controls approved as a part of the permitting process. An additional condition of the FEIS is to require an approved pet management guidance plan for the project as part of the conditions of approval. • The Project is within the area of the Jefferson County Shellfish Protection District and the recommendations/requirements of the district will be incorporated into permit-level reviews. Comment noted that the WDFW tidelands are regularly used for waterfowl hunting from October through January, and that the Point Whitney Shellfish Lab is owned and managed by WDFW, not the State Parks Department, and is not part of the State Parks managed system. Point Whitney provides access to clam and oyster recreational harvest, as do the WDFW lands in Triton Cove, and the lands abutting section 1 (1900 feet). Comments noted. PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-14 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) The increased demand for shellfish harvest on public land is acknowledged. The point about decreasing pressure at Dosewallips State Park was directed to camping at the Park. The Park remains full during a substantial portion of the summer season and cannot meet the public demand for places to stay in the area. The harvest of clams and oysters on public lands is controlled by agency regulations, and the resort is required to provide a prominent location for educational material to alert visitors to the rules, the need to protect private and tribal lands, and to follow all license requirements. The shellfish closure in Pleasant Harbor mentioned in the DEIS is limited to oysters, clams, mussels, and scallops. The agency clarification on this point is noted. Crab harvest and occasional opal squid harvest have been documented in the harbor, though not on a large scale. Both Duckabush and Dosewallips waters are grounds for crab harvest and provide additional support for the water quality efforts of the project to assure that offsite waters are not affected by project development. The project is bound to a water quality monitoring and adaptive management program for the harbor to address any changes in the basin that may occur. The proposal specifically prohibits an access trail to the southern shoreline. Statesman is considering conservation easement for the southern shoreline and other devices to prohibit access from the resort. Trail and pathway access will be designed to limit and discourage indirect efforts of access, which are both unsafe and give rise to potentially harmful consequences in the Duckabush tide flats area. The marina is subject to regulation and control, including rules about use and limits on potentially polluting activities, and a water quality monitoring and adaptive management program to address conditions as they may change in the future. The specifics of an adaptive management and testing program are to be designed and approved during the permitting process to assure that the program is effective. Comments about algae blooms and depleted oxygen are acknowledged. The FEIS requirement for zero stormwater discharge from the golf course resort and marina impervious surfaces provides a means of addressing the solution to contaminated runoff that contributes to the algae and depleted oxygen problems. The monitoring program is to be designed to identify and permit ongoing changes to mitigate and resort-oriented impacts that may be identified in the future. 3.3 Water Resources: Use, Reuse, Management, Treatment, and Disposal The management of water has been a primary focus of the development planning; the goal has been to utilize onsite water resources with an eventual no impact or positive impact to the groundwater, surface water, and wetland systems. The proposal will utilize an innovative concept of use, treatment, and reinfiltration. The specific issues required to be addressed in the scoping notice included: • Sewer service (on site system) • Rainwater harvesting • Water quality • Groundwater and saltwater intrusion • Surface water and particularly irrigation water and potential migration to the harbor or the Canal. 3.3.1 Sewer Service Onsite System The Brinnon Subarea Plan specifically referenced the use of an onsite waste treatment and disposal system in identifying the potential BSAP MPR site, to avoid wastewater discharge to Hood Canal or the harbor. The Statesman MPR proposes to use such a system. No specific system has yet been selected or approved (this would be a condition of final plat approval), but several alternatives are all capable of creating water that may be recycled and reused on the project area and meet the objectives and criteria set forth in this Master Plan. PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-15 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) 3.3.1.1 Treatment Technologies There are wide ranges of proven biological treatment technologies capable of producing the necessary effluent quality to meet the resort goal of a wastewater reuse/recycling system. The three principle technologies being considered for this project are the Sequencing Batch Reactor (SBR), Membrane Bioreactor (MBR), and the Recirculating Biofilter (RBF). All three processes are capable of being designed and operated to achieve either advanced secondary or tertiary (phosphorus and/or nitrogen {nutrient} removal) treatment. A detailed discussion of the programs are found in case studies in reclaimed water use, WDOE Publication 05-10-013, June 2005. Sequencing Batch Reactor (SBR) The SBR process is essentially an activated sludge process in which biological treatment and clarification are accomplished in a single basin by changing the operating conditions in that basin on a timed sequential basis. The first stage involves filling the bioreactor under anaerobic conditions (without oxygen). Aeration is then applied providing mixing conditions to keep bacteria in suspension and providing bacteria with a supply of oxygen for aerobic digestion. After a specified period of time the aeration is stopped and the bacteria are allowed to settle. Clarified liquid is decanted off of the surface and the cycle is repeated. The elimination of the need for a separate secondary clarifier tank or activated sludge pumping is the primary advantage of SBR systems. The primary disadvantage is the potential for upset conditions that can adversely affect the effectiveness of clarification. WDOE has approved operation of such systems under NPDES permit terms designed to minimize or eliminate upset conditions. Because the Statesman program is a closed system, any upset condition is contained onsite in the retention/irrigation pond, which prevents potential contamination to Hood Canal or the harbor, even in the event of an upset. This condition is applicable to all systems under review for the project. Membrane Bioreactor (MBR) The MBR process is essentially a conventional extended aeration activated sludge process in which the secondary clarifier has been replaced by an ultra-filtration membrane with a nominal pore size small enough to filter out bacteria, resulting in a high quality effluent. The membrane pores are typically 0.1 to 0.5 microns in size, so bacteria, micro-orgasms, and other insoluble solids cannot pass through. This eliminates the need for downstream clarification and filtration. However, the pore size is not a complete barrier to viruses, so disinfection is still required. One of the key advantages of the MBR process over the SBR process, is that bacteria populations can be maintained at a much higher concentration in MBR systems or other clarifier-based treatment technologies. Because the bioreactor contains a much greater number of bacteria, the volume of the MBR bioreactor is much smaller than that required for SBR processes, and the land area and tank sizes are smaller than for SBR processes. The primary disadvantages of MBR processes include the high cost of membranes and the potential for membrane fouling. Membrane manufacturers use several techniques to prevent fouling including coarse air scrubbing and chemical treatment (chlorine and/or acid treatment either internally or externally). The expected life of a membrane is in the order of 7 to 8 years, but may be considerably shorter depending on the propensity of the wastewater to produce fouling conditions. Two commercially available MBR processes are under consideration, both of which involve placing the membranes within the bioreactor: Zenon Zeeweed, and Sanitherm Sanibrane process. PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-16 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) Recirculating Biofilter (RBF) The RBF process is also based on a conventional treatment process, but in this case one in which bacteria are attached to media with a high surface area, and bathed in wastewater rather than being kept in suspension. The wastewater effluent must pass through the media, providing an inherent level of filtration, and no clarification is required. The treated effluent is then collected and recirculated back over the filter media. The key advantages of this technology over the SBR and MBR processes include simpler operation, lower energy requirements, and inherent modularization enabling treatment to be carried out efficiently on a decentralized cluster basis, rather than a central treatment facility. The key disadvantage is the need for a larger land area than either the SBR or MBR technologies. Despite the inherent filtration, like the SBR process, the effluent from the RBF process must be tertiary filtered (e.g. chemical coagulation and sand filtration) to meet a Class A reuse standard. The RBF process being considered for this project is the AdvanTex textile-based system manufactured by Orenco Systems Inc. of Sutherlin, Oregon. 3.3.1.2 Wastewater Treatment Approval Wastewater treatment in a reuse/recycling program to create useable Class A water is a process permitted through WDOE. The specific plan approval requires an engineering feasibility report identifying the flows and range and volume of treatment required, a demonstration that the proposed system can achieve the required treatment to meet Class A recycled water standards, and ultimately licensing and approval by the WDOE for operation. Facility permits are continuing in nature, requiring inspection and reporting of periodic limits to assure proper operation and maintenance, including daily, weekly, monthly, and periodic reports, as well as specific inspections and reports. Under the program proposed, the applicant would be required to seek the approval of the wastewater treatment system after preliminary plat approval, but before permits for construction and development are issued. In this way, the agencies will know precisely the treatment loads to be addressed and the proper facilities to accommodate such loads. A detailed environmental review of the project-specific wastewater treatment elements is included in the WDOE approval process and will be required as part of the project-specific review of the first development phase of the resort. 3.3.1.3 Class A Standard All residential and commercial wastewater collected within the development will be treated to a Class A reuse standard. The use of reclaimed water is permitted in Washington State and is jointly regulated by WDOH and WDOE. The guidelines for water reuse contained in the "State of Washington Reclamation and Reuse Standards," September 1997, Publication #97-23, define four levels of treatment of which Class A is the highest quality. Washington’s 1992 Reclaimed Water Act provided a new program for treatment and management of wastewater as a new water supply to replace drinking water for non-drinking (nonpotable) purposes. Reclaimed water use is a fundamental element of our state’s strategy to provide sustainable water supplies that will meet our future needs. Class A water requires advanced secondary treatment plus chemical coagulation and filtration, and disinfection to reduce total coliform bacteria to less than detection levels (i.e. less than 2.2 MPN per 100ml). In addition, a reclamation system must include emergency storage for upset conditions and must have automatic alarms, treatment unit redundancy, and qualified operations staff. PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-17 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) 3.3.1.4 Permitted Uses Once water has been treated to a Class A standard, it will be reused on the resort for nonpotable purposes, including: • Irrigation of landscaping, including golf courses. • Discharge to wetlands. • Groundwater recharge by percolation. • Use for toilet flushing. The primary reuse applications under consideration for this project include toilet flushing and storage for use in seasonal irrigation application to the development's golf course and ultimately infiltration back into the aquifer for reuse and recharge. Wastewater treated to Class A standards will be discharged to the central large kettle. This kettle will be lined and will serve as a reservoir for the resort’s irrigation needs. The reservoir will hold enough water to maintain irrigation even in drought years, and will have sufficient storage to retain water in the event of a failure of the wastewater system. As the reservoir area is a lined pond that will prevent infiltration, remediation of any upset may then occur under onsite controlled conditions without disrupting Hood Canal fish or shellfish or area-wide water quality. 3.3.1.5 Biosolids Wastewater treatment involves the collection of organic and inorganic solids and the removal of biodegradable materials from solution by bacteria. Bacteria digest the biodegradable organic material in the wastewater and increase in population. They periodically need to be removed along with undigested solids (a byproduct referred to as biosolids). These biosolids require a further stage of treatment before they can be beneficially used. This treatment must comply with Federal Regulations 40CFR, Part 503 and similar State standards which specify three criteria for the sludge to be beneficially applied to land. • The biosolids must meet pollution standards, particularly toxics such as heavy metals and pesticides. Since there are no significant sources of these types of pollutants from the uses planned for the resort, meeting these criteria should not be a problem. • The biosolids must not generate significant odors that would attract vectors such as rats and other animals and nuisance insects. This may be accomplished by enabling the bacteria to continue to consume the residual organic materials contained within the biosolids through mechanical digestion processes or by composting, or stabilization through the application of lime and/or high temperatures to the waste biosolids. • The biosolids must be treated to reduce the level of pathogens (disease causing micro- organisms) to one of two specific biosolids application Classes: Class A and Class B. Both Class A and B involve stabilizing the biosolids to reduce the volatile organic content, and level of pathogens through digestion or chemical means. Class A biosolids are further treated, usually by subjecting the biosolids to elevated temperatures for prolonged periods, to achieve further pathogen destruction. Composting is considered to be an effective means of achieving a Class A biosolids product due to the heat produced during the process. Class B biosolids can be land applied on sites that have limited public access, whereas Class A biosolids may be freely distributed or sold to the public for various soil amendment uses and to take advantage of its nutrient content. The proposal will dispose of the biosolids produced from wastewater in one or all of the following methods: • Stabilize through aerobic digestion, and haul the biosolids away in a dilute slurry for spreading on agricultural lands. • Dewater to about 16% solids and stabilize with lime treatment; producing a biosolids product that is a semi-solid and can be hauled in a dump truck to a commercial land-spread site. PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-18 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) • Dewater to about 16% and compost to stabilize the biosolids, converting it to a useful byproduct that can be sold or used onsite as a soil amendment material. 3.3.1.6 Wastewater Mitigation Summary • The wastewater system, which is to be reviewed and approved for use by WDOE, shall be approved and installed and in operation prior to final plat approval and prior to the construction of the first residential or commercial structures with kitchen or bathroom facilities. • The facility shall be installed with capacity to serve the phase being constructed (including any required reserve capacity by WDOE), but phasing of the system may be allowed if approved for system operation by WDOE. • Construction period waste may be handled in septic tank systems approved for RV pump out. 3.3.2 Water Supply, Groundwater, Rainwater Harvesting, and Recycling/Reuse The water supply approach for the development is an integrated use of groundwater (wells), rainwater harvesting, and treatment and reuse of wastewater (reclaimed water). The water management approach is designed to have no impact or a net positive impact on the groundwater resources of the peninsula. 3.3.2.1 Daily Water Supply The overall water demand for the resort results from two factors: first, the potable water demand from the resort itself, and, second, the irrigation and nonpotable uses of water used in the operation and maintenance of the golf course and marina. The estimated potable water use is based on a daily residential demand used to establish the Equivalent Residential Unit (ERU) for the development. Current resource estimates are provided in Water Supply and Groundwater Impact Analysis, Appendix 5. The maximum annual water utilization anticipated is 137 acre feet and if the Master Plan is approved, Statesman will proceed with approval for a water right in that amount. The intent of the resort is to utilize rainwater harvesting in concert with groundwater as the source of potable water. Even though groundwater will be used as a supply source, the water management system designed by the resort will result in the aquifer receiving about the same recharge from resort operations than prior to construction of the resort. The first objective when evaluating the impact of a water use is the evaluation of water supply sources, and how those sources may be efficiently be addressed. Jefferson County encourages projects to pursue water-efficient strategies, and such strategies shall be incorporated into the Master Planned Resort to reduce water consumption. Not all strategies can be used in all circumstances, but efforts in the following provide realistic opportunities to achieve maximum benefit in controlling or limiting overall water use. Existing Water Rights Statesman has available 28 acre feet plus the potential for an additional 12.5 acre feet, per the discussions with Pleasant Tides Water Co-op (an acre foot is approximately 325,830 gallons) from existing water rights. WDOE is currently evaluating the rights, but use of existing water rights will be a first objective of the project. Shared Water Rights Pleasant Tides Water Co-op, which serves the Black Point area, presently has significant water rights. These rights are consumed in serving the existing customers. Statesman has determined, however, that the project could, with the consent of the Pleasant Tides Water Co-op, install new equipment and facilities to modernize the Pleasant Tides water system, and in doing so achieve a net savings from the PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-19 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) current system, which could then be used in the resort. WDOE would have to approve the system upgrades and increase in place of use, and the owners of the Pleasant Tides system would need to consent to any change. The Master Plan program will require the applicant to investigate the feasibility of improvements to existing systems as a potential source of water, to achieve some degree of new water through water saving efficiencies built into the Pleasant Tides system. Rainwater Harvesting Rainwater harvesting is a technique where water that falls onto the site is captured and contained in a manner where it is available for reuse. Roof top drains, road way swales, and stormwater management systems all provide means for capturing, treating, and reusing rainwater, reducing the ultimate draw on the aquifer. Rainwater harvesting does not reduce recharge to the aquifer system. The water will be treated and partially used for potable supply purposes and then treated for irrigation uses. The only net loss of water in this approach is from evaporation of water as it is stored in the ponds, and evapotranspiration of the portion of the water used for irrigation. The advantage of this system is that only a bit over 20 percent of the captured water is used for irrigation; the remaining water will be infiltrated back into the aquifer. The infiltration is a more direct means of aquifer recharge, where a larger portion of that water is now lost to evapotranspiration or discharge through seeps at the bluffs. The net effect will be an increase in aquifer recharge compared to predevelopment conditions. Reuse Recycling State policy promotes reuse and recycling of wastewater, and the Master Planned Resort is designed with an onsite treatment and Class A recycled water program for use and reuse on the site. (See discussion supra.) The water supply approach for the development is an integrated use of groundwater (wells), rainwater harvesting, and treatment and reuse of wastewater (reclaimed water). Groundwater wells will be the potable water supply source for the resort. Water for other uses, such as for toilet flush and irrigation, will come from stored reclaimed water, and from stormwater runoff and rainwater collected from the site. Because the source of the irrigation water is partly provided by the collected rainwater (in addition to the reclaimed water), the irrigation supply is dependant upon the local climatic conditions. Irrigation requirements are highest during the drier periods of the year; thus water will be collected during rain events and stored in ponds for water demands during the remainder of the year. The storage ponds will be located in the existing topographic depressions found on the site (glacially formed kettles). The ponds will be constructed for the storage of water by grading and lining the bottoms of the kettles. The ponds will be designed to hold up to 110 million gallons of water. Some of the water that is stored in the ponds will be directly infiltrated to recharge the underlying aquifer to maintain and enhance the aquifer system beneath Black Point and the seeps dependent on the existing aquifer regime. The direct infiltration of excess water also meets the requirement of zero direct discharge of onsite waters to Hood Canal, and serves to recharge the aquifers to maintain seeps and other food and nutrient sources, particularly along the south beach. The project management plan must be designed to retain a natural hydrologic flow to the protected wetlands and the replacement wetlands for the irrigation kettle to provide assurance that wetland functions and values will be maintained at all times. Rainwater from building roof tops and roadway surfaces of the resort will be collected and routed to the storage ponds. The rainwater that is collected from roof runoff is considered “clean” water and therefore does not need additional treatment before entering the storage ponds. The stormwater runoff from roadway and parking surfaces is considered “polluted” and must be treated before entering the ponds. Natural treatment facilities (i.e., rain gardens) are proposed to meet runoff water quality requirements per the DOE stormwater management treatment criteria. (See Section 3.3.7 on stormwater management for details about proposed LID design methods.) PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-20 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) Wastewater from residential and commercial uses will be conveyed to one or more treatment facilities that will treat the wastewater to a Class A reuse standard (reclaimed water). The reclaimed water will either be stored in a reclaimed water reservoir for toilet flush uses or it will be conveyed to the storage ponds for irrigation and sustainable fire flow. (Sustainable fire flow is 1,000 gallons per minute for 60 minutes.) The aquifer will be recharged through both natural infiltration and direct infiltration. Natural infiltration will occur in the golf course and other landscape and natural areas. Direct infiltration will be accomplished through the use of designed infiltration facilities in which some of the stored water in the ponds will be directed into a designed infiltration area to provide additional aquifer recharge. Some minor amounts of water losses from the system are expected throughout the year due to evaporative and evapotranspiration processes. These losses have been estimated to be less than 3 percent of the annual pre-development water budget. This provides for an aquifer recharge program that can be maintained over the year by designing controlled water releases using the direct infiltration system. Together with the water stored in the ponds, this will allow the flexibility to provide a desired seasonal recharge rate that can be adjusted to meet monthly water balance quantities. In concert, the existing rights, improved efficiency of the Pleasant Tides system, if available, and the reuse recycling program could account for the entire water budget for the program without any new draw on the aquifer. Even if rainfall were deficient, or the Pleasant Tides water was not available, or available only in limited quantities, the maximum water draw on the aquifer is estimated to be 137 acre feet per year. The efficient use of water by reason of reuse and recycling, wetland recharge, and ultimately stormwater infiltration will minimize overall water consumption and assure no net material impact, which is the Master Plan goal. Detailed environmental studies will be required at the project- specific level for approval of wells, upgrades, and the construct of the use/reuse system to assure this goal is met. Once water rights are acquired and the full rainwater/reuse system is in place, it is possible that in many years the resort could operate without a net groundwater draw. A material condition of the Master Plan is that the applicant demonstrate the availability of water resources at the time of preliminary plat or binding site plan approval, and that no approval shall be given without a written finding, based on agency and expert approvals in the record, that water resources are adequate to serve planned demand is in fact available and ready for use. Washington law requires such a demonstration at the building permit level, but for purposes of the Master Plan and assuring adequate resource protection, such showing must be made before any preliminary plat may be approved. 3.3.2.2 Daily Water Demand The second way to manage and conserve water resources is to reduce demand and more efficiently use water that is available. The Master Planned Resort is proposing a number of factors to reduce overall water demand, which in concert will significantly reduce overall demand on the aquifer. These techniques include low flow and other low-impact development techniques within the resort to reduce water demand, the use and reuse of recycled wastewater to allow water to be used multiple times on site and eventually recharge the aquifer, and identification and use of existing and alternate sources of water that may serve a significant portion of the water demand from existing water rights rather than new water rights. The estimated daily water demand provides the quantity of water that will be used for the design of the potable water system and the wastewater (reclaimed water) treatment system. These daily demands are based on full occupancy of the resort. The estimated maximum residential potable water demand is approximately 62,300 average daily demand (ADD) at 70 gpd/ERU. See Table 3-2. Statesman Corporation estimates 25,000 gallons per day for commercial uses at the resort, including the Club House, restaurants, and Maritime Village. See Table 3-2 Daily Water Demand (Commercial and Residential) for a summary of the total estimated daily water demands. Measured in acre feet, the overall annual water demand is approximately 121 acre feet, potentially less if full efficiency can in fact PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-21 November 27, 2007 be achieved. See Water Supply and Groundwater Impact Analysis, Appendix 5, Section 3.3.7.2 and Table 2. The use of low impact development techniques indicates that an overall onsite water use per unit may be reduced from 175 gpd to as low as 70 gpd. The goal of achieving reduction from the 175 gpd to a lower amount over time shall be one objective of project design. For safety and planning purposes, the standard 175 gpd has been used. Table 3-1 Residential Potable Water Demand TOTAL ESTIMATED POTABLE WATER USE WITH HIGH-EFFICIENCY CONSERVATION FIXTURES Shower and Tub 1.50 gpm 8.2 min/day 12.30 gal/day 38% Kitchen Sink 0.50 gpm 8.1 min/day 4.05 gal/day 13% Bathroom Sink 0.50 gpm 8.1 min/day 4.05 gal/day 13% Clothing Washer 25.00 gal/load 0.37 loads/day 9.25 gal/day 29% Dishwasher 6.00 gal/load 0.1 loads/day 0.60 gal/day 2% Leaks 1.70 gal/day 5% 32 gal/day 100% 70 gal/day Note: Total Consumption Per Person: ERU - Total Consumption Per Residence (2.2 people per unit): % Usage figures obtained from: American Water Works Association (AWWA) Research Foundation, Residential End Uses of Water study , Mayer and DeOreo, et al., 1999 Usage Usage Units Total Use Per PersonUsageFlow Rate Flow Units DAILY INDOOR POTABLE WATER DEMAND ESTIMATE Leaks 5%Dishwasher 2% Clothing Washer 29% Bathroom Sink 13% Kitchen Sink 13% Shower and Tub 38% Shower and Tub Kitchen Sink Bathroom Sink Clothing Washer Dishwasher Leaks FINAL EIS - (Site Specific Amendment MLA 06-87) PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-22 November 27, 2007 Table 3-2 Daily Water Demand (Commercial and Residential) POTABLE WATER ADD 70 890 62,300 Avg. Daily Demand, based on Est. Daily Residential Potable Water Demand spreadsheet MDD 140 890 124,600 Max. Daily Demand = 2*ADD ADD 70 357 25,000 Avg. Daily Demand, based on 25,000 gpd given by Statesman. Equivalent ERUs = 25,000/70 MDD 140 357 50,000 Max. Daily Demand = 2*ADD ADD 70 1247 87,300 Avg. Daily Demand, based on residential + commercial ERUs MDD 140 1247 174,600 Max. Daily Demand = 2*ADD PHD 234 gpm, Peak Hourly Demand based on Eq. 5-3, WSDOH WSDM RECLAIMED WATER ADD 11 890 9,790 Avg. Daily Demand, based on Est. Daily Residential Potable Water Demand spreadsheet, with toilet flush MDD 22 890 19,580 Max. Daily Demand = 2*ADD WASTE WATER ADW 97,090 Avg. Daily Waste, based on potable water demand + reclaimed water demand MDW 194,180 Max. Daily Waste = 2*ADW Note: Demand formulas from: WSDOH Water System Design Manual , August 2001. Demands based on full occupancy. Notes Residential gpd/ERU Residential + Commercial gpd/ERU ERU gpd Notes Notes Notes Residential gpd/ERU ERU ERU gpd DAILY WATER DEMAND SUMMARY (Not Including Reclaimed Water for Irrigation) Commercial gpd/ERU ERU gpd gpd NotesResidential + Commercial gpd/ERU ERU gpd FINAL EIS - (Site Specific Amendment MLA 06-87) PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-23 November 27, 2007 3.3.2.3 Potable Water Storage The storage requirements are as follows for an Average Daily Demand (ADD) of 70 gpd/ERU. The total storage is comprised of operating & dead storage (OS/DS), equalizing storage (ES), and the larger of standby storage (SB) or fire supply storage (FSS). The OS/DS is dependent upon the actual tank and appurtenances selected, and will be in the ball park of 15,000 gallons. The ES provides a buffer in the event the wells are not able to produce the peak hourly demand (PHD), which is 234 gpm for an ADD of 70 gpd/ERU. Since the two wells are expected to be able to produce 280 gpm which is more than the PHD, ES will not need to be provided. The SB provides enough water for the ADD per ERU for 2 days, which is approximately 174,600 gallons. The FSS is 120,000 gallons, based on a fire flow of 1000 gallons for 120 minutes, and is counted as nested in the SB storage since it is the larger of the two. This nested FSS will provide potable water to the fire sprinklers and fire hydrants. Thus the total conventional storage required is approximately 189,530 gallons for an ADD of 70 gpd/ERU. Should final design parameters require a higher ADD per unit, storage would be increased commensurately. 3.3.2.4 Occupancy and Seasonal Occupancy The Master Plan projects 10% of the total resort units as full-time residential, up to 30% of the units for seasonal or long-term (one month or more) guests, and at least 50% of the units for short-term tenancies (less than one month). The total estimated annual water demand is related to both the type of water use (i.e., potable, reclaimed, and irrigation requirements) and the seasonal uses of the resort. The resort will have seasonal occupancy that would vary by season for both owner and non-owner guests. Occupancy estimates in Table 3-3 reflect the combination of seasonal residents and high vacation/convention use during peak seasons. The annual average residential unit occupancy is estimated at 2.2 people per unit for the Condo-tel and vacation residences. Table 3-3 Seasonal Occupancy Occupancy Category Months Included Number of Months Units Occupied Percent Occupied Low Season (Full Time Residences) 85% Average Annual January to December 12 474 53.3% Peak Season Mid Season 50% 4757 3445 30%5267 June, July, August, September April, May, October November, December, January, February, March FINAL EIS - (Site Specific Amendment MLA 06-87) PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-24 November 27, 2007 Table 3-4 Seasonal Occupancy Summary < Average 53.3% 30% 30% 30%30% 30% 50% 50%50% 85%85%85%85% 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%JanuaryFebruaryMarchAprilMayJuneJulyAugustSeptemberOctoberNovemberDecemberMonthPercent Occupied The averages reflect fuller occupancy on weekends and holidays and lower occupancy earlier in the week, a common pattern for resorts. While the units may in fact be sold out for several weeks during the summer, such loading is not the norm, and the 85% reflects a truer picture of resort demand for facilities of this size over a full season. Winter season 30% occupancy is based on full-time residents and much more limited use during the winter, with limited winter tourist attraction and some conference use (typically two and three day conferences). The percentages were taken from resorts throughout the Jefferson County/Hood Canal area. The estimated daily water demand provides the quantity of water that will be used for the design of the potable water system and the wastewater (reclaimed water) treatment system. (See Table 3-2 Daily Water Demand (Commercial and Residential).) For determination of annual water budgets, such as water quantities that are the basis for water rights, the annual water demands are based on the seasonal occupancy rates as described in section 3.3.5 Seasonal Occupancy. 3.3.3 Phased Water Demand A project of this size will be developed in phases over a series of years. Water demand changes as the phases are completed. A summary of the estimated daily potable water demand is summarized in Table 3-5 Phased Potable Water Demand based on a likely completion scenario. These estimated daily demands assume a full occupancy rate, which could occur at times during the peak season of the year. During the seasonally lower occupancy times of the year the daily flows would be proportionally lower. (See Table 3-3 Seasonal Occupancy.) Golf Course Resort Area (measured from Preliminary Plat approval) Year 1. Clearing and grading—-rough in the golf course, install main roads and utilities, water for dust control and cover planting the graded areas for stormwater management and runoff control. Year 2. Construct the golf course, pave main roads, complete sewer system, complete stormwater management system for main roads and first phase, clubhouse, hotel and restaurant, staff housing, final plat approval. Year 3. 1/3 Residential units FINAL EIS - (Site Specific Amendment MLA 06-87) PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-25 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) Year 4. 1/3 Residential units Year 5. 1/3 Residential units Marina Resort Area (measured from Shoreline Substantial Development permit approval) Year 1 Install road, parking and utilities (water and sewer) (begin marina dock replacement) Year 2. Maritime Village upgrade (commercial development and 88 units) Year 3. Water side development, 63 units. Table 3-5 Phased Potable Water Demand Phase Total Residential ERUs Percent Total Daily Water Demand Average Daily Water Demand (gpd) Cumulative Water Use Acre Feet Utilized Phase 1 198 22 25,000 5,500 30,500 24 Phase 2 428 48 54,500 12,000 66,500 52 Phase 3 615 69 78,300 17,200 95,500 74 Phase 4 703 79 89,600 19,800 109,400 85 Phase 5 890 100 113,500 25,000 138500 108 The water phase in plan shows that the 28 acre feet existing water rights could supply the first two years of project development, with rainwater harvesting and recycling/reuse alone providing the balance. The water supply and groundwater impact analysis is detailed in Pleasant Harbor Marina and Golf Resort—Water Supply and Groundwater Impact Analysis. See Appendix 5. Statesman has available two ground water rights issued for community domestic supply totaling 115 gallons per minute (gpm) and 28 acre feet per year (afy), Water Rights No G2-20465 and No. G2- 24359. Statesman also has a claim to a right for an additional 12 afy under water rights held by the Pleasant Tides Water Co-op for community domestic use. Water Rights No. G2-21134, No. G2-23623, and No. G2-27946P. See Shared Water Rights below. As discussed in other sections of this DEIS, the Master Planned Resort is designed in five phases. The phasing is important in satisfying the water requirements of the Master Planned resort and in determining the necessary water rights. The WDOH has recommended that the water system be developed for a maximum daily demand (MDD) of 350 gallons per day (gpd) per equivalent residential unit (ERU), or on average 175 gpd/ERU (ADD). In a letter dated April 19, 2007, WDOH recognized that if the Master Planned Resort was developed in phases, WDOH would consider approving the Statesman Sustainable Water Resources Management Plan for 70 gpd/ERU (ADD) and 140 gpd/ERU (MDD) if the water usage records from the early phases confirms these estimates. WDOH’s policy is to review monitoring records from two non-drought years of water use. The storage requirements are as follows for an ADD of 175 gpd/ERU. The total storage is comprised of operating & dead storage (OS/DS), equalizing storage (ES), and the larger of standby storage (SB) or sustainable fire supply storage (FSS). The OS/DS is dependent upon the actual tank and appurtenances selected, and is approximately 15,000 gallons. The ES provides a buffer in the event the wells are not able to produce the peak hourly demand (PHD), which will be approximately 41,700 gallons. The SB provides enough water for the ADD per ERU for 2 days, which is approximately 436,450 gallons. The FSS is 120,000 gallons, based on a fire flow of 1000 gallons for 120 minutes, and is counted as nested in the SB storage since it is the larger of the two. Thus the total conventional storage required is approximately 493,150 gallons for an ADD of 175 gpd/ERU. Similarly, for an ADD of 70 gpd/ERU the total storage is calculated as 189,580 gallons. PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-26 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) Based on the higher 175 gpd/ERU ADD, the current water rights will provide a potable water supply for 204 ERUs, sufficient to cover the units for Phase 1 and a portion of Phase 2. When WDOH approves the ADD of 70 gpd/ERU, the number of ERUs authorized under the existing rights will then allow for 510 ERUs which will satisfy potable water requirements for Phases 1 and 2 and a portion of Phase 3. Statesman will not, however, rely on the 40 afy of existing water rights or need to wait for 2 years of monitoring data prior to proceeding with full development. As discussed herein, the final intent is to fully supply the Master Planned Resort with rainwater and reuse, which permits the phases to be constructed as set out above. Statesman is filing applications for both a groundwater right and a surface water right. The surface water right will request authorization to use rainwater and runoff, which will be treated and available for potable water supply. The groundwater right will be providing a supplemental or back up supply to the surface water use, the existing water rights, and a reclaimed water permit for irrigation of the golf course and the fire smart program. The groundwater right will request 280 gpm and 239 afy, which is the maximum total quantity that will be necessary for all water use at the Master Planned Resort assuming the maximum of 175 gpd/ERU ADD. The full balanced operation at 70 gpd/ERU (ADD) shows a total balance of 259 acre feet available and 259 acre feet in use, for a net balanced draw of zero. See Figure 3-8, Water Balance Summaries. PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-27 November 27, 2007 A schematic of the planned systems and alternative, likely used in concert in the final plan, reflects the variety of techniques available for water supply and utilization on the site. Figure 3-8 Water Cycle Concept Flow Diagram; Well Water Potable Supply FINAL EIS - (Site Specific Amendment MLA 06-87) PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-28 November 27, 2007 Figure 3-9 Water Cycle Concept Flow Diagram; Surface Water Potable Supply FINAL EIS - (Site Specific Amendment MLA 06-87) PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-29 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) 3.3.4 Water Use and Potential Impact—Geologic Conditions The Master Plan site is typically composed of Vashon Age glacial soils that are dense to very dense sand and gravel, with varying amounts of silt and some cobbles. Older Pre-Vashon non-glacial deposits consisting of dense to very dense sands and hard silts and clays were observed in one test boring and exposed in the bluffs along Hood Canal. The ground surface throughout the area is hummocky and typical of a site modified by glacial processes; the site includes a number of kettles, which are large glacial depressions. Ground surface elevations range from about 60 feet in the bottom of the deepest kettle, to elevation 320 feet on a hill in the southeast portion of the site. Though ground surface elevation varies considerably across the site, the average site elevation is about 180 to 200 feet. The slopes along Hood Canal consist of near vertical 100 ft high bluffs. Human activity has altered the landscape for construction of roads and other improvements. The peninsula is surrounded on three sides by sea water. Due to density differences, fresh water essentially floats on sea water. The fresh water head (above sea level) beneath the peninsula ranges between 11 and 34 feet. As such, there is a significant fresh water lens beneath the peninsula. Though there is a very significant fresh water aquifer beneath the peninsula, it is important to maintain a positive fresh water head above sea level in the aquifer. The water supply and reuse strategy of the resort has been designed to prevent adverse impacts on the groundwater resources of Black Point and to avoid risk of saltwater intrusion. The development area averages about 55 inches of precipitation annually. Most of the precipitation events in the site area are generated from southerly storms that move north up the canal. The climate is marine; winter months are typically moderate and wet, while summer months are typically mild and dry. Complete discussion of site geology and local climatic conditions are provided in the Appendix documents. See Soils and Geology Evaluation at Appendix 4 and Water Supply and Groundwater Impact Analysis at Appendix 5. 3.3.5 Water Quality—Water System Management by Public Agencies Maintenance of drinking water quality for all potable water and reuse/recycling standards fall under the auspices of the permit treatment and effluent standards for both the water system and the wastewater treatment system. The potable water system will be a conventional water system design, including a well combination with collected surface water treatment/disinfection system, storage reservoir, and conveyance piping to points of use. The size of the project will require a Class A water system approval. While the system could be operated privately, the proposal is construction of the system by the developer and operation by the Jefferson County Public Utility District, which has indicated a willingness to operate such a system. The wastewater treatment system is also proposed to be managed by the Jefferson County PUD, but could be managed by a local utility or privately. The advantage of a PUD operation is that the overall water quality system is under long-term public control to assure proper maintenance, reporting to the key regulatory agencies (WDOE and WDOH), and providing long-term assurance and safe operation. Public operation of the facilities will require the development of both a comprehensive plan and an engineering plan for water service and sewer service, which will explore in much greater detail the specifics of a given design and operation. At the Master Plan level the requirement is to assure that both systems are designed, approved, and operational in advance of the completion of the first phase of the golf course portion of the resort intended for additional public use. Should public operation not prove feasible, the alternative is private operation with water system control and wastewater treatment operations under the supervision of properly licensed technicians, reporting as required under water system operational permits and the Chapter 90.48 RCW wastewater discharge permit. PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-30 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) 3.3.6 Surface Water Management–Irrigation Water The water stored in the irrigation water pond, which includes a combination of reclaimed water, treated stormwater, and rainwater, will be pumped in a pressurized piping system for the irrigation of the golf course and for water supply to the sustainable fire flow and other needs. Other landscape areas will be maintained or designed as native planting areas to minimize or eliminate the need for irrigation. At this preliminary phase, the overall water budget for irrigation is projected at 108 acre feet for the golf course, fire suppression, and other uses during the irrigation season, which is April to October. The pond has been designed to retain sufficient water to provide full irrigation supply to the golf course, and supply is dependent upon securing necessary water rights permits. See Water Supply and Groundwater Impact Analysis, Appendix 5. The precise calculations will depend on the specific design of the golf course and will be part of the golf course permit review. At the Master Plan level the feasibility and operability of such a system is demonstrated as both achievable and appropriate for the setting. A key element of any irrigation plan for the golf course will be the adoption of best management practices to minimize the use of potentially harmful chemicals and a best management program to address golf course operation to assure that any opportunity for direct runoff to Hood Canal or the harbor is eliminated, and the potential for ground water impact is minimized. To achieve this result, the plat review for the golf course shall prohibit discharge of irrigation water to Hood Canal or the harbor, and include the adoption of a series of best management practices. Jefferson County uses the King County aquifer protection guide for golf course management BMPs, and the same conditions or substantially similar programs are required for this project at the permit level. 3.3.7 Stormwater Management The site will be designed to meet the recommendations of the current edition of WDOE’s Stormwater Management Manual for Western Washington, February 2005 together with WDOE’s adopted Low Impact Development Technical Guidance Manual for Puget Sound, January 2005. The stormwater management plan will be designed to meet the project’s requirement for zero- discharge of water to the Hood Canal from the golf course resort area, and the full treatment of all site water from the marina area before discharge to the harbor (a significant upgrade from current direct discharge conditions). Stormwater management plans are approved by the Jefferson County Public Works Department. As a condition of any permit approval, including shoreline or preliminary plat approval, the approved stormwater management plan be included as part of the submittal presented for final approval. The project has a significant cut and fill program planned for the golf course area which could cause significant adverse impact if not properly controlled. A separate stormwater management plan is required for the clearing and grading and subsequently for the development and operation of the facility. Prevention of pollution and maintenance of hydrology for protected wetland areas are the twin goals of the stormwater pollution prevention plans for the project Construction Stormwater Pollution Prevention Plan (SWPPP) Construction site stormwater runoff for this project is regulated at the state level by WDOE through the 2005 Stormwater Management Manual for Western Washington (SWMM) and at the local level by Jefferson County through the Jefferson County Stormwater Management Plan (Plan). WDOE requires a Construction General Stormwater Permit for all development activities where more than one acre will be disturbed and stormwater will be discharged to surface water or to storm drains that discharge to surface water. If all stormwater is retained on site, a General Stormwater Permit is not required. Although this development is well over an acre, the project will be designed, both during construction and post-development, to retain and/or infiltrate all stormwater on site as part of the overall sustainable water management plan. Therefore there will be no stormwater from the developed areas of the site that will be discharged off the site and into the Hood Canal. PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-31 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) The project will require a construction Stormwater Pollution Prevention Plan (SWPPPP) addressing how the stormwater will be treated and retained on site. There are 12 elements of the SWPPP that must be addressed: • Mark clearing limits • Establish construction access • Control flow rates • Install sediment controls • Stabilize soils • Protect slopes • Protect drain inlets • Stabilize channels and outlets • Control pollutants • Control de-watering • Maintain Best Management Practices (BMPs) • Manage the Project If one element is considered unnecessary, the SWPPP must provide a justification. Each of these elements is discussed in detail in the SWMM. Each element lists several BMPs that can be utilized in reducing or eliminating the pollution of surface waters from construction activities. Stormwater runoff during construction will be handled through the use of Best Management Practices (BMPs) as defined in WDOE’s Volume II of the SWMM. BMPs are methods that reduce or prevent the release of pollutants to surface waters. For this project, several BMPs will be used to treat and retain stormwater on the project site. Some of the common methods that will most likely be used include: • BMP C101: Preserving natural vegetation • BMP C102: Buffer zones • BMP C105: Stabilized construction entrance(s) • BMP C107: Construction road/parking area stabilization • BMP C120: Temporary and/or permanent seeding • BMP C121: Mulching • BMP C122: Nets and blankets • BMP C123: Plastic covering • BMP C130: Surface roughening • BMP C162: Scheduling • BMP C200: Interceptor dike and swale • BMP C201: Grass-lined channels • BMP C202: Channel lining • BMP C207: Check dams • BMP C230: Straw bale barrier • BMP C233: Silt fence • BMP C234: Vegetated strip • BMP C235: Straw waddles • BMP C240: Sediment trap • BMP C241: Temporary sediment pond The golf course construction will require land clearing and grading activity. The construction of the course will be carried out so that soil exposure is kept to a minimum by completing earthwork activity in phases, including stability and seeding of all disturbed areas. Stormwater runoff will be directed via lined channels with sediment barriers to several “kettles,” or natural closed depressions, sediment traps, and/or sediment ponds located around the project site. The stormwater will either infiltrate in the kettles, traps, and ponds or be pumped to dispersion trenches. A 200-ft undisturbed natural vegetation PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-32 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) buffer will be kept between the shoreline and golf course resort development. Silt fencing and other BMPs as needed will be used along the site perimeter to prevent sediment from entering the natural undisturbed and shoreline areas. In order to ensure that the Construction Stormwater Pollution Prevention Plan is implemented appropriately and that approved stormwater management facilities are constructed as per the approved plans, the proponent shall designate a civil engineer licensed in the State of Washington as the Project Engineer. The Project Engineer shall be responsible for ensuring that State and County stormwater management standards are met. Clearing, grading, implementation of the Construction Stormwater Pollution Prevention Plan, and construction of roads and stormwater management facilities shall be conducted under the supervision of the Project Engineer. The Project Engineer shall submit regular reports to Jefferson County while construction is in progress. Low Impact Development (LID) Site Design As part of the development’s requirement to protect Hood Canal, all water on the site will be collected and either used appropriately onsite, will be routed to the storage ponds, or infiltrated to the groundwater aquifer. The development’s sustainable water resource management plan also includes site design requirements to meet a zero-discharge of water from any of the built areas of the property. In summary, this zero-discharge criterion will be met by collecting and conveying water to storage ponds that will be built within the existing onsite kettles. The ponds will store water during high precipitation periods and, as needed, the stored water will be used to meet water demands. Any surplus water will be directed into the ground to provide aquifer recharge and to ensure that all water sources on the site are not discharged into Hood Canal. The project will incorporate LID design methods in the construction of the civil infrastructure systems. The site will be designed to meet the recommendations of the SWMM, together with WDOE’s adopted Low Impact Development Technical Guidance Manual (LID Manual) for Puget Sound, January 2005. Some of these recommended LID techniques are proposed for the project’s roadways and stormwater management systems including narrow streets, raingardens (to provide water quality), and rainwater harvesting (to provide flow control). Narrow streets serve several purposes in a LID design. First, they reduce the amount of pollution- generating impervious surface. Second, narrow streets also reduce traffic speeds which create a safer community. Raingardens are typically shallow man-made depressions with compost-amended soils and plantings that are used to treat and infiltrate stormwater runoff. The amended soils in the raingardens will capture pollutants as water percolates through them. The water would be collected by perforated underdrain pipes below the amended soil layer and be conveyed to a stormwater pond for reuse. Raingardens also provide a nice landscaping feature, and they can also act as a natural buffer between the street and residential units. Native plants and shrubs tolerant of water inundation, soil saturation, and dry periods would be utilized. Raingardens used for treating street runoff are typically located parallel to streets adjacent to the street shoulder or in medians. Rainwater harvesting utilizes above or below-ground cisterns, usually located by downspouts, to collect rainwater for later use such as irrigation. Overflow from the cisterns would be directed into the Raingardens for infiltration and conveyance to an on-site pond for later reuse. The stormwater management plan will be designed to meet the project’s requirement for zero- discharge of water to the Hood Canal. This will be accomplished by stormwater treatment and storage, appropriate water uses, and infiltration of water for aquifer recharge. PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-33 November 27, 2007 Figure 3-10 Typical LID Roadway Section (including narrow travel lanes and raingardens) Figure 3-11 Typical Raingarden Section FINAL EIS - (Site Specific Amendment MLA 06-87) PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-34 November 27, 2007 Figure 3-12 Conceptual Stormwater Layout Final layout approval for the golf course approval will require specific approval of the system to assure that no offsite discharge goal is in fact achieved. On the Maritime Village portion of the project, a zero discharge system cannot be achieved due to topography. However, the existing retention, treatment, and discharge system can be significantly upgraded to assure that all stormwater from upland impervious surfaces are captured and treated prior to release to the aquifer. Permit approvals will consider the feasibility of capturing and pumping some portion of the Maritime Village stormwater for collection into the reuse system. All stormwater not so captured will be treated as provided above. Here again, consistency with the Master Plan will require approval of a stormwater management system for the Maritime Village area that demonstrates compliance with the stormwater treatment manual, including provision for addressing potential upsets or spills upland and mechanisms to assure such events can be handled onsite and do not pose a risk to the harbor. FINAL EIS - (Site Specific Amendment MLA 06-87) PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-35 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) 3.3.8 Water Summary and Conditions • Sewer service (onsite system) • Any project approval for the golf course area will require construction and operation permits for a wastewater treatment system for the project by WDOE and an operational plan in place as a condition of final plat approval and construction of any structures for occupancy or residency. • Any project approval for the Maritime Village remodel and upgrade shall include a demonstration that existing facilities can adequately serve the remodel areas. No additional residential units would be approved until the sewer system is installed and operating. • Water supply, groundwater, and rainwater harvesting • Any project approval for the resort shall contain a condition that the applicant demonstrate entitlement to sufficient water rights to serve the approved phase from WDOE (water rights transfer and/or rainwater harvesting rights and use conditions) prior to preliminary plat approval and construction of any facilities on the property. • Water quality • Stormwater management plans for clearing and grading and for construction and operation phases must be approved and systems in place to assure control of the stormwater as provided above. • The golf course project approval shall require the adoption of best management practices for the management of stormwater onsite and the reuse of water as irrigation water, with a condition that the system demonstrate no direct discharge to Hood Canal of any stormwater from impervious or golf course surfaces, and that the grass management program include specific BMPs to assure proper management of all elements of the golf course management system consistent with the King County manual for golf course management in aquifer sensitive areas or its substantial equivalent. • Approval of any permits for the marina redevelopment area shall be conditioned upon the approval of a stormwater management plan that intercepts and treats all stormwater from existing or new impervious surfaces to Puget Sound water quality management standards prior to discharge, and that the Maritime Village has a plan and facilities in place to deal with any upland upset that may threaten pollutant discharge to Pleasant Harbor. • The Project Engineer shall be responsible for ensuring that State and County stormwater management standards are met. Clearing, grading, implementation of the Construction Stormwater Pollution Prevention Plan, and construction of roads and stormwater management facilities shall be conducted under the supervision of the Project Engineer. The Project Engineer shall submit weekly reports to Jefferson County while construction is in progress. • Groundwater protection and saltwater intrusion • Preliminary plat approval for the golf course resort that requires water use in excess of current approved water rights. Preliminary plat approval shall require a hydrogeological report demonstrating that the additional water use does not pose a threat of saltwater intrusion to existing wells or sources of water supply. A hydrogeological report is required for each construction or development phase to demonstrate compliance with this condition. • Surface water and particularly irrigation water and potential migration to the harbor or Hood Canal were addressed in the section on water quality above. • Fire fighting flow • Adequate and sustainable fire flow will be provided by the Class A water system. The Class A water system will provide this level of service at all times. PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-36 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) 3.3.9 Resources: Use, Reuse, Management, Treatment, and Disposal (Water Quantity, Water Quality, and Use): Responses to DEIS Comments Responding to comments by the Hood Canal Environmental Council (275 and 385); WRIA (16 and 359); Ellie Sather (287), Jefferson County Public Health (284), WDOE (281, 375, 376, and 381), Department of the Navy (285, 366, and 377); Pleasant Tides (Don Herrin letter) (220), Hal Beattie (125 and 133); Sugino (130), Germaine (129); Rebekah Ross (132), Murdoch (139), Dimino (193), Mitchell (212), Moore-Lewis (305), Ventura (312), McMillan (314); Streid (313 and 317), Lopez (272), Russell (282), Beattie (310), Sather (289), Mitchell (297). Applicant has proposed that the Pleasant Tides water system be substantially upgraded and made more efficient, to provide an alternate source of water for the project. The Pleasant Tides program is strictly voluntary, however, and should they elect not to have Statesman participate in a joint use agreement, the Black Point aquifer under the resort site has a unique configuration that provides ample water to serve the needs of the resort, without salt water intrusion, and without jeopardizing draws on local wells. Concern is raised that the technology is new and therefore unproven. The project incorporates numerous low impact, and water saving and treatment reuse approaches that are commonly in use in a number of resort venues, both in the United States and in Europe. Many are incorporated in existing Statesman resort properties under development in British Columbia. Historically, resorts have not been asked to be on the leading edge of low impact and water conservation approaches to development. The Statesman proposal incorporates technology proven to establish Class A treated water and accepted by state regulatory and resource agencies, including reuse, recycling, and low impact development techniques to achieve low-flow, non discharge approaches to water management. A specific project requirement is to assure hydraulic protection for streams and wetlands in a stormwater habitat management plan approved and put into place prior to any site disturbance. A question was raised about the water quantity available from rainfall for the resort and whether the Quilcene gauge used in the initial reports was inaccurate when compared with the Brinnon gauge. Subsequent investigation shows the Brinnon gauge and the Quilcene gauge reflecting nearly identical levels of rainfall and well within the parameters of the project. The wastewater materials explain the sources and uses of water, reuse, and treatment and how the system was designed to have no net impact on the aquifer and in some years an above normal recharge of the aquifer system with treated recycled water in excess of the current "natural" condition. He also noted that the storage pond has the capability of holding a minimum two-year supply of water in reserve for fire fighting purposes and for years in which rainfall falls below expected variations. The water report must address the ability of the site and aquifer to handle both the draw and infiltration and to assure that all systems are sufficiently removed from the south bank to protect bank stability. The project is on a peninsula easterly of the mouths of the Duckabush and Dosewallips Rivers. As such, no direct impacts to those watersheds are anticipated by the construction and operation of the resort. Increased use and pressure on publicly-owned recreational facilities is anticipated. The resort is required to provide education programs to make residents aware of facilities and the rules and best practices associated with facility use, including fishing, beach, and forest use. Local state and federal management agencies are responsible for the development and enforcement of public land use regulations. The MOU process, built into the project approval phase, is designed to address impacts and mitigation addressed to a wide variety of public services and facilities. The EIS at the Comprehensive Plan level anticipates and considers the issues. The project-level approvals, when a specific phase is under review, will address the project-specific issues on a proper (nexus and proportionality) basis. The phased review provides analysis of the site and current conditions to demonstrate the feasibility of the project proceeding on the planned basis. At the project level, issues about the specifics of sewer plant design, water rights serving each phase, and the technical issues of the capture, treatment, and PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-37 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) reuse of water and protection of water resources is achieved in the context of fully engineered plans and approvals by state agencies. The allocation of general feasibility and issue identification at the comprehensive plan level and the resolution of those issues during project approval is an appropriate approach to large projects. The adoption of the Comprehensive Plan approval for a Master Planned Resort at Brinnon is followed by the approval of specific zoning requirements to implement the requirements imposed by the FEIS, and a development agreement that identifies phasing and approvals required to assure that the entire resort and its impacts are addressed properly at each stage of development. It provides an adequate basis for addressing the final systems and approvals necessary to assure the reliability and long-term operational success required for successful resort operation. The proposal does project significant cut and fill on the site, but an overlay of the RV development on the site and the overall grading plan shows that the grading is substantially confined to areas previously disturbed by the RV park, roads, and campsites, and the fill is primarily a very large kettle in the middle of the site. The grading plan is subject to detailed requirements for wetland and critical area habitat protection and stormwater protection plans prior to development, including post grading stabilization controls prior to vertical development. The overall timing of the grading is controlled by the referenced permits and the development agreement, which is to detail the phasing plan and all components. The FEIS contemplates a water quality monitoring program for Pleasant Harbor in conjunction with the Shoreline Substantial Permit for the marina phase of the development. The monitoring program would be coordinated with state monitoring programs and provide the basis for an adaptive management program. The specifics of the program are to be addressed as part of the shoreline permit review and be in place prior to any new development in the shoreline area. Concerns about nitrogen loading and the potential impact on the aquifer are site and project dependent. The FEIS identifies the risk to the aquifer and Hood Canal from nitrogen and golf course management issues. The project-specific proposal is to address a specific nutrient management program, directed specifically to site conditions, the design of the golf course, design of the wastewater treatment system to remove nitrogen, and the design and application of the water reuse and stormwater management programs proposed for the site. All will be subject to review by regulatory agencies, including WDOE and the County, to minimize the potential for excess nutrient reaching the aquifer. Issues identified in the comments, including residual nitrogen and the ability of the proposed system to protect the aquifer will be reviewed at the project level and must be determined to be adequate prior to permit approval for the golf course phase of development. (Please see comment and response under shellfish above for more information.) The reuse system does lend itself to a geothermal source for heating and cooling the facility, further reducing energy consumption and the carbon footprint. Reducing the impervious footprint and using low impact design methods also reduces the overall impact. No specific LEED rating has been selected and will be addressed at the project level, and operational details about recycling and energy efficiency will be addressed at the project level in light of the overall commitment to provide an energy efficient and resource efficient facility. The wastewater ponds shown on the project plans can accommodate two years worth of water, and are designed to accommodate both very dry and heavy rainfall years and potential upset conditions. Engineering specifics are project-level details that must demonstrate adequate levels of safety beyond the standard 100-year event. This is done to assure expected maximum levels are contained. The stormwater control ponds are separate from wetland mitigation areas. The reuse water will be used to meet the agronomic demands for irrigation, supplemented by stored stormwater as needed. Consequently, mounding as a result of reuse water infiltration is not expected to be an issue. Mounding as a result of infiltration and recharge using stored stormwater is a design constraint that will be addressed at the project level when the stormwater system is designed and approved. Roof top composition is a design-related issue, but the issue of direct discharge versus PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-38 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) treatment and reuse is a design-related issue under the WDOE "no degradation" standards for groundwater and aquifer protection. The specific location of wells and the alternatives available are a design-related issue to be addressed at the engineering level to minimize the potential for impacts on existing water resources and potential alternatives in the event of upset or unintended consequences. Salt water intrusion is not considered a reasonable probability under the system described. Preliminary engineering figures identify the overall net impact as a "positive recharge” rather than “consumptive” use of the aquifer. These issues will be addressed in detail at the design and permit approval stages. The FEIS identifies water quality and discharge as a major issue to be addressed onsite and the NPDES permits for both construction and operation are acknowledged, as are discharge permits under Chapter 90.48 if water discharge is not part of the final plans. WDOE review of engineering plans and treatment and disposal for the wastewater treatment program are all part of the required project approval process. Water rights applications have been submitted and are pending WDOE review. The additional water rights will be subject to processing through WDOE approval requirements. Water availability and water rights are two limiting factors identified as potential constraints on the project and as such demonstration of adequate water to serve each phase is required as part of the planned permitting program. Should the necessary water not be reliably available for a proposed phase, the phase cannot be approved. The DEIS did fail to address the State's Section 401 and wetland regulatory authority, which is acknowledged. WDOE approval of required permits and certifications will be part of any project approval altering or potentially affecting wetlands. State water quality standards are acknowledged. The marina use and any potential increase will be addressed at each phase of development. As noted above, some increase could occur but the amount, timing, and nature of such traffic cannot be known at this time. No change in the configuration or capacity of the marina is anticipated, merely the rehabilitation or repair of existing degraded conditions. As phases are constructed, marina traffic will be monitored, as will water quality in the Harbor to measure and address any unanticipated impacts. Additional traffic information will be available through project review for each phase of the development and the Navy will be advised of all such applications. The waters of Hood Canal are controlled by navigation controls and notices to mariners, which can address specific concerns and regulations designed to aid Naval operations. The marina is committed to maintain information kiosks in aid of public education about naval operations and activities. The Canal is an open water, however, in which boating traffic is invited and encouraged to use (such as the upgrade of the WDFW boat launch at Pleasant Harbor). The Master Planned Resort will work with local agencies to assure education is achieved and is committed to a monitoring and adaptive management program to assure water quality. Water closures or acoustic limits would have to be imposed by the Navy or Coast Guard to regulate the general boating public. The consultants have reviewed the well head protection programs for the Pleasant Tides and Pleasant Harbor Beach tract wells, which are located near the intersection of Black Point Road and US HWY 101. The Washington State Department of Health has guidelines for construction in the vicinity of public water supplies, which the project is required to meet. From a preliminary design point of view, no adverse consequences to the wells are anticipated. During final design and before project approval the wells, protected areas, and location of roads will be specifically addressed to assure that quantity and quality of water is not disturbed and the wells are adequately protected. Any joint program with Pleasant Tides Water Co-op would require mutual consent and if they elect not to explore joint opportunities, the MPR will be required to meet its water needs elsewhere. The fact that no present agreement is in place is accurate, and the comment and expression of concern is noted. Impervious surfaces and developed areas are capped as defined in the FEIS. The final report as to actual use regarding preservation of the aquifer will be in the engineering reports at the project level, PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-39 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) including a project-specific aquifer recharge report. The specific manner of infiltration and recharge will be determined by WDOE in its review and approval of the Class A reuse/recycling program, addressing water quality, water quantity, and capability; protection from pathogens; and other issues to assure no impact on either other water users in the area or the aquifer runoff and seeps. The possibility of incorporating water use/reuse from other systems, if they are developed in time, could provide an opportunity to reduce dependence on aquifers and provide a mutual benefit should such alternative systems be available and would certainly be examined during the project phases. The water treatment system looks at the totality of the treated loads to assure that the water discharged meets Class A water standards. The project is required to have a stormwater and habitat management plan in place prior to the start of any construction to protect habitat and critical area and to avoid stormwater or construction runoff from entering the Canal. The aquifer has been identified as underlying the resort property, and use as proposed is not expected to affect other water users. Specific parameters of use and limits to avoid impact are to be addressed during the water rights permitting program under WDOE guidelines. The overall availability of water and limitations or constraints as a result of the location will be identified at the water rights permitting phase, which must be concluded before specific project elements are permitted for construction. 3.4 Transportation The County identified five specific issues to be addressed as part of the transportation review. (1) US HWY 101, (2) internal circulation, (3) marina circulation, (4) pedestrian circulation, and (5) bicycle circulation. This section summarizes traffic and transportation existing conditions, project impacts, and mitigation measures of the Alternatives. A more detailed discussion and relevant technical supporting information and attachments are contained in Appendix 6: Transportation Impact Study. 3.4.1 Site Vicinity and Access Assumptions The Pleasant Harbor development is located on US HWY 101 in the vicinity of Black Point Road in Jefferson County, Washington. A project site vicinity map is shown in Figure 3-13. The subject properties would include two main development districts under the Statesman proposal: Black Point Property and Maritime Village (see Figure 1-5). There are existing facilities in the subject area, including a boat launch, beach, parking area, approximately 30 acres of forest, cottage business, a bed & breakfast, real estate office, vehicle/boat maintenance and repair shop, welding service, and vehicle and boat storage facility. Pleasant Harbor Marina currently provides moorage and fuel services with limited shopping and food service. For transportation evaluation purposes, full build-out and occupancy of the project is within six to seven years from commencement. Vehicular site access would be consolidated for the Maritime Village and Black Point Property at US HWY 101 and Black Point Road. A egress-only driveway from the Maritime Village onto US HWY 101 would also be provided. All other five existing access connections onto US HWY 101 would be closed and removed. There are three new site access roadways proposed onto Black Point Road for the Black Point Property and Maritime Village, including: ¾ A private frontage road that parallels US HWY 101 between Black Point Road and the Maritime Village. Existing traffic associated with the WDFW Boat Launch at Pleasant Harbor could intersect this new frontage road in a consolidated access onto Black Point Road. ¾ An emergency-only access into Black Point properties, located opposite the proposed golf course resort on Black Point Road. This access roadway would serve as an emergency secondary access/egress. PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-40 November 27, 2007 ¾ A main entry roadway onto Black Point Road, approximately 0.35 miles from US HWY 101, that would serve all traffic to/from the Black Point Property. FINAL EIS - (Site Specific Amendment MLA 06-87) Figure 3-13 Project Site Vicinity PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-41 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) 3.4.2 Existing Transportation Conditions This section describes existing transportation system conditions in the study area. It includes an inventory of existing roadway conditions, traffic volumes, intersection levels of service, collision history, public transportation services, nonmotorized transportation facilities, and planned roadway improvements. 3.4.2.1 Roadway Conditions The following paragraphs describe existing arterial roadways that would be used as major routes for site access. Roadway characteristics are described in terms of number of lanes, posted speed limits and shoulder types and widths. US HWY 101 is classified by the Washington State Department of Transportation (WDOT) as a rural principal arterial. The roadway generally consists of 2 travel lanes 11-feet wide with 3- to 10-foot paved shoulders. The posted speed limit is 50 mph in the vicinity of the subject properties. SR 104 is classified by WDOT as a rural principal arterial. The roadway consists of 2 travel lanes 11 feet wide with 8-foot paved shoulders. The speed limit is posted at 60 mph. Center Road north of US HWY 101 is a two-lane major collector roadway with 11-foot travel lanes and 7- to 9-foot paved shoulders. Curbs, gutters, and sidewalks are located on the west side of the street, and a raised curb is located on the east side of the street. The curb-to-curb pavement width is 38 feet. The posted speed limit is 30 mph in the vicinity of Quilcene and 35 mph further north of Quilcene. Dosewallips Road is a two-lane minor collector roadway with 11-foot travel lanes and 1-foot paved shoulders. The speed limit is posted at 35 mph. Dosewallips Park Entrance Road is a two-lane, 20-foot local access roadway. The posted speed limit is 10 mph west and 5 mph east of US HWY 101. Black Point Road is a two-lane local access street, with existing demand of less than 300 daily vehicles. The Jefferson County Public Works Road Log identifies 24 feet of pavement and 3-foot shoulders. However, based upon measured conditions in the field by Transportation Engineering Northwest (TENW) at several points along Black Point Road (in the vicinity of all proposed access points), the total pavement width ranges between 26 and 27 feet in width with 1- to 3-foot grass/gravel shoulders. The speed limit is posted at 35 mph. Black Point Road was constructed between 1974 and 1975, with a structural section of 12 inches of Class B gravel base overlaid with 2 shots of bituminous surface treatment. Old Black Point Road is an undefined County Road that potentially serves as the first 0.04 miles of the existing entrance into the K.O.A. campground on the subject properties. According to the County Road Log, it intersections Black Point Road at approximately 0.05 miles from US HWY 101 and was established as a 12-foot of right-of-way. No record of this right-of-way is noted on recent property Alta surveys or title reports. Duckabush Road is a two-lane minor collector roadway with 11-foot travel lanes and no shoulders. The posted speed limit is 25 mph. 3.4.2.2 Existing Traffic Volumes Daily traffic volumes represent the number of vehicles traveling a roadway segment over a 24-hour period on an average weekday. Peak hour traffic volumes represent the highest hourly volume of vehicles passing through an intersection during a typical 4-6 p.m. peak period. For the purposes of this traffic study, the p.m. peak period was used as the peak hour since the proposed project would generate the highest traffic during this period. Existing channelization and traffic control at all study PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-42 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) intersections is provided in Appendix 6. Figures 3-14 and 3-15 show existing daily and p.m. peak hour traffic volumes. Daily traffic volumes were obtained from WDOT. Traffic Count Consultants Inc. also conducted daily traffic counts on US HWY 101 (south of Quilcene and south of Brinnon) and Center Road, including p.m. peak hour turning movement counts at all study intersections in August/September 2006 (traffic counts are provided in Attachment A). Historical traffic volumes on US HWY 101 and study intersection roadways in the project site vicinity indicate a weighted average growth rate of 2 percent per year between 1998 and 2004. Furthermore, Jefferson County traffic and population forecasts in Quilcene and Brinnon estimate a 2 percent annual growth rate out to 2024. Therefore, a 2 percent per year growth rate was used to factor historical daily traffic volumes to estimate 2006 conditions. At milepost 324.80 on US HWY 101 (approximately 15 miles south of Black Point Road), WDOT maintains a permanent traffic recorder station. During the peak summer month of August, traffic volumes recorded on US HWY 101 are approximately one-third higher than the annual average daily volumes. Traffic counts collected by TENW were collected prior to and during the Labor Day Weekend in 2006, representing a conservative period and allowing for evaluation of potential traffic impacts during a worst-case scenario of peak use of the proposed resort facilities during peak summer traffic flows in the study area. 3.4.2.3 Intersection Levels of Service Levels of Service (LOS) serves as an indicator of the quality of traffic flow at an intersection or road segment. The LOS grading ranges from A to F, such that LOS A is assigned when minimal delays are present and low volumes are experienced. LOS F indicates long delays and/or forced flow. of Appendix 6 summarizes the delay range for each LOS at unsignalized intersections. The methods used to calculate the levels of service are described in the updated 2000 Highway Capacity Manual (Special Report 209, Transportation Research Board). The measure of effectiveness for unsignalized intersections, an LOS and estimate of average control delay is determined for each minor or controlled movement based upon a sequential analysis of gaps in the major traffic streams and conflicting traffic movements. In addition, given that unsignalized intersections create different driver expectations and congestion levels than signalized intersections, their delay criteria are lower. Control delay at unsignalized intersections include deceleration delay, queue move-up time, stopped delay in waiting for an adequate gap in flows through the intersection, and final acceleration delay. LOS standards in Jefferson County are LOS C for rural roads and LOS D for all other roads. LOS on State Highways is LOS C for US HWY 101 and SR 104. PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-43 November 27, 2007 Figure 3-14 2006 Existing Daily Traffic Volumes (from WDOT tables) FINAL EIS - (Site Specific Amendment MLA 06-87) PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-44 November 27, 2007 Figure 3-15 2006 Existing P.M. Peak Hour Traffic Volumes FINAL EIS - (Site Specific Amendment MLA 06-87) PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-45 November 27, 2007 Existing p.m. peak hour LOS at study intersections are summarized in Table 3-6. All intersections currently operate at LOS B or better. Detailed LOS summary worksheets are provided in Appendix 6. Table 3-6: 2006 P.M. Peak Intersection Levels of Service Unsignalized Intersections Control Type LOS Average Delay #1 – SR 104 at Center Road Ramp EB Left A 8 SB B 14 #2 – SR 104 Ramp at Center Road EB B 10 NB Left A 8 #3 – US HWY 101 at Center Road EB B 10 WB B 12 NB Left A 8 SB Left A 8 #4 – US HWY 101 at Dosewallips Road EB A 10 NB Left A 8 #5 – US HWY 101 at Brinnon Lane EB A 10 WB B 10 NB Left A 8 SB Left A 8 #6 – US HWY 101 at EB B 11 Dosewallips Park Entrance Road WB A 10 NB Left A 8 SB Left A 8 #7 – US HWY 101 at Black Point Road WB A 10 SB Left A 8 #8 – US HWY 101 at Duckabush Road EB B 10 NB Left A 8 Note: Analysis based on HCS 2000 results using HCM 2000 control delays and LOS A project-specific LOS evaluation update will be required at the time of the preliminary plat application to identify specific mitigation requirements, but the studies done at this stage show traffic at all levels and affected intersections operating well within acceptable limits and no significant capacity improvements are anticipated as a result of the project. Significant right of way and intersection improvements will be required at the immediate vicinity of the project to accommodate left turns and the revised access to the master plan area reducing the overall number of entry points onto US HWY 101. Design of these sections and WDOT approval for all work on State Right of Way is required at the time of preliminary Plat approval. 3.4.2.4 Collision History The frequency and severity of collisions are commonly weighted against speed, volume, and functional classification of a roadway segment or intersection. These variables are considered in determining if a certain location has an unusually high collision rate. The average annual collision rate is calculated by summing the total number of collisions that occurred at a specified intersection or roadway segment during the past three years and dividing the total by three. Collision data for an intersection is also measured by collision rates per million entering vehicles (MEV). Collisions per MEV reflect the number of vehicles traveling through an intersection, providing a different indication of design-related versus volume-related incidences. FINAL EIS - (Site Specific Amendment MLA 06-87) PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-46 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) Table 3-7 summarizes historical collision data as provided by the WDOT for the most recent 3-year period between January 1, 2003 to December 31, 2005 at all study intersections. There have been no fatal collisions within the project site vicinity in the most recent 3-year period. There were no reported collisions at US HWY 101 and Center Road, US HWY 101 at Black Point Road, SR 104 Ramp at Center Road, and SR 104 at Center Road Ramp. All study intersections have an average annual collision rate equal to or less than 1.0 and a collision rate per MEV equal to or less than 0.88. None of the study intersections are considered to be high collision locations. Table 3-7: Intersection 3-Year Historical Collision Rates Intersections Fatal Collisions Injury Collisions PDO Collisions Total Collisions Average Annual Collision Rate Collision Rate per MEV #1 – SR 104 at Center Road Ramp 0 0 0 0 0.0 0.00 #2 – SR 104 Ramp at Center Road 0 0 0 0 0.0 0.00 #3 – US HWY 101 at Center Road 0 0 0 0 0.0 0.00 #4 – US HWY 101 at Dosewallips Road 0 0 1 1 0.3 0.31 #5 – US HWY 101 at Brinnon Lane 0 0 1 1 0.3 0.30 #6 – US HWY 101 at Dosewallips Park Entrance Road 0 1 2 3 1.0 0.88 #7 – US HWY 101 at Black Point Road 0 0 0 0 0.0 0.00 #8 – US HWY 101 at Duckabush Road 0 1 1 2 0.7 0.71 Source: WDOT Standard Accident History Detail Report, Provided August 2006 for period between January 1, 2003, to December 31, 2005. MEV - Million entering vehicles. As with the traffic volume data, traffic collision data will be reviewed in conjunction with the preliminary plat to assure the plat is approved based on the most current data. But the table shows no significant issues that need to be addressed during platting other than the standard road design and ingress and egress requirements common to plat review and approval. US HWY 101 does have a history of accidents due to road alignment and grade and due to excessive speed. Caution must be exercised in connection with any development west of US HWY 101, particularly development which would increase crossing movements as the intersection at Black Point road does have severe limits to accommodate crossing traffic. Alignment of entrances to any development west of US HWY 101 will have to be viewed by the County in the context of the planned increased traffic from the resort. 3.4.2.5 Public Transportation Services Jefferson Transit Route 1 provides public transportation services in the area, with a stop on US HWY 101 at Black Point Road, adjacent to the project site. Route 1 provides Monday to Saturday service to Brinnon, Quilcene, and the Hadlock/Irondale/Chimacum Tri-Area. Service at US HWY 101 and Black Point Road is provided between 7:10 a.m. until 7:55 p.m. with stops every 2 to 3 hours. Saturday service is provided at the US HWY 101 and Black Point Road intersection from 8:55 a.m. until 7:10 p.m. with stops every 4 to 5 hours. PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-47 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) 3.4.2.6 Non-motorized Transportation Facilities US HWY 101 consists of 3- to 10-foot paved shoulders. Black Point Road provides 1- to 3-foot grass/gravel shoulders which are generally inadequate to accommodate pedestrian or non motorized traffic. US HWY 101 does accommodate significant summer bike travel, even though the highway does not have identified bike lanes. The increased vehicular travel to the resort operates well within LOS limits for US HWY 101. Riders on US HWY 101 are aware of its limitations in terms of narrow shoulders and site distances the length of Hood Canal. The internal circulation system of the resort allows riders to get off US HWY 101 in the resort area and travel through the resort. The resort traffic does not materially change that situation. The Master Plan description identifies the internal trail network planned for the resort, which is open to the public and does encourage both walking and bicycling off the State highway. The compact development of resort facilities is designed to facilitate internal circulation through nonmotorized means. If significant development were to occur west of US HWY 101, consideration should be given to safe pedestrian access, including potentially overpass crossing due to safety issues crossing US HWY 101 at Black Point Road. 3.4.2.7 Planned Roadway Improvements by others Jefferson County’s 2007-2012 Transportation Improvement Program (TIP) identified no transportation- capacity improvement project that would be impacted by vehicular trips from the proposed project 3.4.3 Transportation Impacts The following section describes transportation impacts the proposed Pleasant Harbor development would have on the surrounding arterial network and critical intersections in the site vicinity. The discussion includes non-project related traffic forecasts, new trips generated by the proposed development, distribution and assignment of new project trips, traffic volume impacts, impacts on LOS at nearby significant intersections, public transportation services, non-motorized facilities, and site access, circulation, and safety issues. 3.4.3.1 Non-Project Traffic Forecasts For the purpose of this traffic analysis, year 2017 was selected as the build-out year based upon full completion and occupancy of the proposed Pleasant Harbor development. As summarized previously, historical and forecasted traffic volumes indicate an average growth rate of 2 percent per year during the relevant period. Therefore, existing traffic volumes were factored by 2 percent per year to estimate year 2017 baseline conditions without the proposed development alternatives. 3.4.3.2 Project Trip Generation This section summarizes trip generation for the proposal. From a trip generation standpoint, all the proposed uses under the four EIS Alternatives would involve typical or traditional residential, commercial, resort, or recreational uses. Trip generation rates compiled by the Institute of Transportation Engineers (ITE) Trip Generation, 7th Edition, 2003, were used to estimate daily traffic and p.m. peak hour traffic that would be generated by the EIS alternatives. Given the resort nature of the Statesman Alternative, a.m. peak hour trip generation and the associated background traffic on adjacent streets would not be significant. Therefore, to evaluate a worst-case scenario, p.m. peak hour vehicle trip generation was considered assuming peak summer traffic conditions in combination with no reductions for seasonal occupancy factors. 3.4.3.3 Statesman Plan MPR Alternative Trip Generation The subject properties under the Statesman Plan MPR Alternative encompass approximately 250 acres and would include two main development districts: the Black Point Property and the Maritime Village. The development involves creation of a Master Planned Resort (MPR) that would include an 18-hole golf course with a 3,000 square foot refreshment center, 890 residential units, a 60,000 square foot PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-48 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) resort/retail/spa conference center, a 200-seat (10,000 square foot) community center, a 16,000 square foot commercial retail Maritime Village, and incorporation of an existing 285-slip marina. Appendix 6 further outlines the supporting documentation and trip generation assumptions related to this Alternative. Based upon recommended practices and procedures in the ITE Trip Generation Handbook, a combination of average trip rates and fitted curve equations for all suites hotel (ITE Land Use Code 311), condominiums/townhouses (ITE Land Use Code 230), recreational homes (ITE Land Use Code 260), golf course (ITE Land Use Code 430), specialty retail (ITE Land Use Code 824), low-rise apartments (ITE Land Use Code 221), a 250-person conference facility (Salish Lodge Expansion activities-based approach 1 ), and marina (ITE Land Use Code 420) were used to estimate net new trips generated by the proposed development. Table 3-8 summarizes estimated net trip generation by the proposed Statesman Plan MPR Alternative. An estimated total of approximately 4,100 daily and 363 p.m. peak hour vehicular trips (186 entering and 177 exiting) would be generated at full build-out and occupancy of the Statesman Plan MPR Alternative. Table 3-8: Statesman Plan MPR Alternative - Net Project Trip Generation LU P.M. Peak Daily New Code Units Enter Exit Trips Trips All Suites Hotel 311 154 28 34 62 800 Condominiums/Townhouses 230 216 76 37 113 1,200 Recreational Homes/Adult Community 260 420 45 64 109 1,300 Golf Course (acres) 430 123 4 8 12 200 Specialty Retail 824 16.5 18 26 45 700 Low-Rise Apartments 221 100 42 55 68 700 Conference Facility (Salish Lodge –max attendees) n/a 250 25 35 60 400 Marina (existing vested use) 420 311 35 24 59 900 Gross Total Trip Generation 274 250 523 6,200 Less Internal Trips - Assume 20% Total -55 -50 -105 -1,200 Marina (Existing Uses) -35 -24 -59 -900 Net Project Trip Generation 186 177 363 4,100 Source: ITE Trip Generation Manual, 7th Edition, 2003, and TENW. Given the anticipated limited buildout of supporting retail uses for resort occupants (owners, guests, or renters), trip generation rates were selected for resort residential uses that reflect trip making during the p.m. peak hour for shopping, services, and other such activities to commercial areas outside of the development. In addition, as a conservative assumption, it was assumed that 20 percent of all trips would be internal in nature; therefore, the remaining 80 percent of vehicular trips were considered to be new vehicle trips generated by the development, impacting the immediate vicinity street system. This internalization assumption also reflects the potential for additional trip making off-site due to limited supporting retail services within the resort. Trip making by resort employment (property management, on-site spa, concierge, laundry/dry cleaning, golf course, and other resort hotel functions) are inherent within trip generation rates of those noted commercial or proposed uses. 1 Source: Salish Lodge Expansion, Transportation Impact Study, TENW, November 2001. PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-49 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) 3.4.3.4 Trip Distribution and Assignment Using standard engineering practices and guidelines, new vehicle trips generated by the proposed Pleasant Harbor development were distributed and assigned to the surrounding street system based on local traffic patterns and recent traffic studies conducted in the study area and approved by Jefferson County. As shown in Figure 3-16, project trip distribution was assumed to follow these patterns from the proposed site: • 35 percent to the east via SR 104 to Seattle and Tacoma. • 3 percent to the west via Dosewallips Road and Duckabush Road. • 25 percent to the north via US HWY 101 and SR 104 to the Olympic Peninsula, Port Townsend, and Whidbey Island. • 30 percent to the south via US HWY 101 to Olympia, Tacoma, and Seattle. • 7 percent local to Dosewallips State Park and Quilcene. PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-50 November 27, 2007 Figure 3-16 Project Trip Distribution 3.4.3.5 Traffic Volume Impacts Traffic volumes were estimated for daily and p.m. peak hour conditions to the year 2017 without the proposed project and with the four land use Alternatives. Peak hour traffic impacts remain within FINAL EIS - (Site Specific Amendment MLA 06-87) PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-51 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) approvable LOS limits at study intersections in 2017 without the project and under all development alternatives. Detailed traffic volume forecast estimates are provided Attachment A of Appendix 6: Transportation Impact Study. 3.4.3.6 Public Transportation Impacts Jefferson Transit Route 1 stops approximately one-third of a mile from the project site at the intersection of US HWY 101 at Black Point Road, providing transit service four times per day to the main entrance of the Pleasant Harbor properties. The applicant proposes to purchase and maintain a van or small shuttle bus available for guests and tenants to utilize on an as-needed basis for use in group trip making, coordinated events, airport shuttle, and other miscellaneous traffic. The applicant also proposes to work with Jefferson Transit in scheduling and expanding service as necessary to the resort as well as considering joint opportunities to provide layover or transit service and facilities within the site. 3.4.3.7 Non-motorized Transportation Impacts US HWY 101 currently consists of 3- to 10-foot paved shoulders. Black Point Road provides 1- to 3- foot grass/gravel shoulders. The applicant will be required to fully fund and construct associated frontage improvements onto US HWY 101 and Black Point Road to accommodate nonmotorized facility improvements such as sidewalks, improved shoulder widths, or paved pathways internal to the project and accommodations for bicycle traffic through the intersection with US HWY 101 and project frontages. The applicant proposes to work with Jefferson County in developing a nonmotorized circulation system within the site available to the public that would not impact County or State highways and would provide for pedestrian and bicycle circulation between the two main development districts (i.e., Black Point Properties and Maritime Village). 3.4.3.8 Intersection Level of Service Impacts As summarized in Table 3-9, intersection LOS impacts during the p.m. peak hour were evaluated at study intersections in 2017 without the proposed project and under all development Alternatives. As shown, all stop-controlled movements at study intersections would operate at LOS C or better with and without the development Alternatives in 2017. All intersections would meet adopted local and state LOS standards. PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-52 November 27, 2007 Table 3-9 2017 PM Peak Hour Level of Service Impacts 3.4.3.9 Site Access, Safety, and Circulation Issues Full build-out and occupancy of the project is anticipated by 2017. Vehicular site access would be consolidated for the Maritime Village and Black Point Property at US HWY 101 and Black Point Road under the Statesman Plan MPR Alternative. A right-only driveway from the Maritime Village onto US HWY 101 would also be provided. All other existing access connections onto US HWY 101 would be closed and removed. There are three new site access roadways proposed onto Black Point Road for the Black Point Property and Maritime Village under the Statesman Plan MPR Alternative, including: 1. A private frontage road that parallels US HWY 101 between Black Point Road and the Maritime Village. Existing traffic associated with the State of Washington Boat Launch Pleasant Harbor would intersect this new frontage road in a consolidated access onto Black Point Road. 2. An emergency-only access into Black Point properties, located opposite the proposed private frontage road on Black Point Road, would also serve a maintenance facility and the proposed community center. 3. A main entry roadway into the resort on Black Point Road, approximately 0.7 miles from US HWY 101, that would serve all traffic to/from the Black Point resort property. FINAL EIS - (Site Specific Amendment MLA 06-87) PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-53 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) The internal roadway within the development would provide adequate on-site, two-way circulation. The applicant would be required to fully fund and construct the necessary site driveways and associated improvements onto US HWY 101 and Black Point Road. As noted in the Section 3.4.2.1, Black Point Road was originally constructed approximately 20 years ago with a 12-inch Class B gravel base and two shots of bituminous surface treatment. Based upon increased traffic loads during construction and at full buildout and occupancy, the structural section and roadway do not meet current road standards for a collector and would be brought up to current standards during final plat development for the golf course. 3.4.3.10 Access Management Standards Access management standards identified in the Washington Administrative Code (WAC) Chapter 468- 52-040-2 – Highway Access Management – Access Control Classification System and Standard were evaluated in relation to the proposed action. US HWY 101 in the site vicinity is classified as a Class 2 facility under WDOT’s access management standards. Based on proposed closure of all existing access connections into the Maritime Village area, the proposed private access connections would be located more than 660 feet away from other existing private access connections. Therefore it complies with minimum access management standards. 3.4.3.11 Marine Resort Internal Access The internal circulation road between the Maritime Village and the golf course permits circulation without traversing US HWY 101. All traffic exiting on the one-way street north of the Maritime Village shall be directed north bound only on US HWY 101 under the current proposal. At the project level detailed designs for circulation must be approved by both Jefferson County and WDOT. 3.4.4 Mitigation Measures Transportation Summary A review was conducted of vehicular trip generation, public transportation and nonmotorized transportation impacts, and site access and safety issues of the EIS Alternatives considered under the Pleasant Harbor DEIS. Based upon this traffic impact analysis, the following mitigation measures will be required as part of a preliminary plat approval for each project phase. • Fully fund and construct associated improvements for Black Point Road to meet County standards from US HWY 101 to the project entrance. • Provide adequate site distance to the east of the proposed main site driveways onto Black Point Road and the egress from Maritime Village in US HWY 101 to improve and maximize entering and exit sight distance. • At the US HWY 101 and Black Point Road intersection, provide a southbound left-turn lane as part of project development in all scenarios except the no action alternative. With the Statesman proposal, the expansion of the existing T-intersection would also provide for a median refuge area for left turns from Black Point Road onto US HWY 101. • Provide a northbound right-turn pocket or taper at US HWY 101 at the Black Point Road intersection under the Statesman proposal. • Residents of the Maritime Village shall be given access to the golf course resort without traveling US HWY 101. A detailed traffic design to accommodate traffic on US HWY 101 returning to the resort must be developed, with further traffic analysis and design approval by WDOT and Jefferson County. • Reconstruct the Black Point Road approach to US HWY 101 with adjacent left turning lanes, a widened approach onto US HWY 101, and an “entry treatment” on Black Point Road at US HWY 101. The proposed site access concept would also include a consolidated intersection onto Black Point Road with a realignment of the WDFW boat launch at Pleasant Harbor. PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-54 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) • Provide all access roads and internal roads available for public use to County road standards. Private drives may be to a lesser standard approved by the Pubic Works Department and emergency service providers during the preliminary plat phase if desired by the applicant. • Provide an internal pathway and circulation system within the site that would not impact County or State highways, would provide for pedestrian and bicycle circulation between the two main development districts, and would allow US HWY 101 bicycle traffic bypass through the resort (i.e. Black Point properties and Maritime Village). In addition, the preliminary plat approval for the golf course portion of the resort should evaluate trip management plans as an alternative to simple roadway expansion. Such plans may include: • Provide a van or small shuttle bus for guests and tenants to utilize on an as-needed basis for use in group trip making, coordinated events, airport shuttle, and other miscellaneous traffic. All such services shall be coordinated with Jefferson Transit to schedule expanded service as necessary to the resort as well as consider joint opportunities to provide layover or transit service and facilities within the site. 3.4.5 Transportation: Responses to DEIS Comments Responding to comments by Jefferson Transit (228), Jefferson County Public Health (284), Germaine (129); Beattie (133), Mitchell (212), Peterson (260), Moore-Lewis (305), Lopez (272), Hendricks (270). Transportation: Additional public transportation links would be required as noted by Jefferson Transit. Transit-related issues are part of the project-level review for each phase and would be addressed based on project-specific proposals. The emergency access is for the resort and does not affect other homes in the area served by public roads outside the resort. Increased boat traffic: The commentator is correct that the resort provides a magnet for marina use. Early on there was discussion of increasing the size of the slips. At the present time, however, there is no plan to make any changes to the size or configuration of the slips in the marina. Existing facilities would be upgraded to repair obsolete or contaminated floats and walkways (Tunicate eradication program). A marina operations plan is required to identify responsibility for mitigation programs, including enforcement of no discharge rules, boater education, and the harbor monitoring and adaptive management program all provide a basis for ongoing monitoring and adjustment to address issues that may arise. Van or shuttle service could certainly serve local residents as well as the resort. This is a program to be explored at the project level as such services are identified. The specifics of the shuttle service have not been addressed at the planning stage, but would be part of the permit-approval process. The issues identified (JCHD #6) would certainly be part of the consideration. There are no present plans for flight, charter, or helicopter service. At the project level, if facilities are proposed to facilitate such services, detailed environmental review of the specific proposal would be required. Road runoff is a concern to potential pollution. The new impervious surfaces at the resort are governed by County and state water quality manuals that require capture and treatment. At Pleasant Harbor, one benefit of the proposal is the capture and treatment of road runoff presently traveling untreated to the bay. Details as to truck traffic and construction traffic would be addressed in the phasing plans and the specific operational plans as the details of a specific proposal are reviewed at the project level. Specific mitigation can then be addressed to fit conditions at the time the traffic is anticipated. Concerns about PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-55 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) increased traffic due to the bridge closure, and the remote nature of the resort relative to supply sources have been identified and would be issues in any phase of traffic impact assessment. The limitations of US HWY 101 for bicyclists are noted. The road does not provide adequate shoulders. The resort provides a refuge and safe transit within and through its facility. It is reasonable to assume that some traffic from the facility may transit to Clallam County, as well as Mason and Kitsap Counties. The project-level traffic impact analysis for each phase will address specific traffic patterns anticipated in the context of the demands from the phase proposed as well as the overall impacts. The FEIS acknowledges that there have been fatalities on US HWY 101 and that WSDOT is making repairs and using speed limits, safety warnings, and other traffic control devices to manage traffic on US HWY 101. The road is the sole access in and out of Brinnon, and the resort does operate within the LOS levels established by the State for utilization of the state highway system, including US HWY 101. Specific turn lane analysis is a function of project-level traffic design and will be taken into account at that time. 3.5 Public Services (including tax burden, rescue services, and health services) The County Scoping Notice addressed three issues for examination under the Public Service section (1) fire, (2) police, and (3) schools. 3.5.1 Fire Protection and Emergency Medical Services (EMS) Black Point and Pleasant Harbor are located within Jefferson County Fire Protection District (JCFPD) #4, which provides both fire protection and EMS. District #4 serves approximately 131 square miles and operates out of three strategically located fire stations. It is staffed by 1 full time paid Fire Chief and 21 volunteer firefighters, including firefighters with emergency medical training (EMT). 3.5.1.1 Equipment and Resources Station 41 serves as Fire District #4 headquarters and administrative offices and is located on School House Road in Brinnon proper. All district administration is conducted from this location. This station is staffed by the Chief Monday through Friday - 9 to 5pm. In the event of an emergency, the primary response unit will come from station 41. Volunteer crew members respond from their residences to their assigned stations. Emergency equipment at this station includes the following: • 5,000 gallon Tanker Trailer • 2000 GPM Rescue Pumper • ILS Ambulance (intermediate life support) • Type 1 Brush Unit • Chief's Car • Marine Unit (18 foot boat) Station 42 is located at the south end of the District adjacent to the Duckabush River at 51 Shorewood Drive. This station is located just south of the project site. Equipment at this station includes: • 1500 gpm Class A Pumper • ILS Ambulance (intermediate life support) Station 43 is located at the north end of the district at the base of Mt. Walker on Bee Mill Road. Equipment housed at this station includes: • 1,000 gallon Pumper • BLS Ambulance (basic first aid) PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-56 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) District #4 also has mutual aid agreements with surrounding jurisdictions, fire districts, and emergency health service providers. Mutual aid agreements are in place with the following Fire Districts and emergency providers: Fire: East Jefferson Fire & Rescue (JCFPD #1) Port Ludlow Fire & Rescue (JCFPD #3) Quilcene Fire Dept. (JCFPD #2) Discovery Bay Fire Dept. (JCFPD #5) Mason County Fire #17 EMS: Port Ludlow Fire & Rescue (JCFPD #3) Mason County Medic One Olympic Ambulance Airlift North West Quilcene Fire Dept. (JCFPD #2) Discovery Bay Fire Dept. (JCFPD #5) East Jefferson Fire & Rescue (JCFPD #1) In addition, District #4 can draw on resources from fire districts in Clallam County, Kitsap County, and Mason County through an inter-local agreement and the Olympic Peninsula Mobilization agreement. 3.5.1.2 Demand for Emergency Services Table 3-10 below summarizes the emergency call volumes received in District #4 by type from 2003 though July 2007. Note that this does not include service calls for such things as patient assists, investigations, and complaints. Average response time from the Brinnon Fire Station 41 is between two and three minutes. Table 3-10 EMS Demand Fire EMS Transports 2003 81 144 95 2004 43 149 73 2005 63 151 95 2006 84 188 102* 2007 51 114 60 * Total as of June 2007 Emergency call volumes increase significantly with the summer season. This increase begins in April and May with the return of people from out of state who have summer homes in the Brinnon/Black Point area. It continues with the end of the school year as families in-state take extended vacations on their local properties, and as more people come to the area to take advantage of the State parks and other recreation opportunities. It should be noted that the State park system eliminated parking fees in 2006, and as a result there has been an immediate increase in the use of local State parks. This will likely result in a permanent incremental increase in the number of summer season emergency calls. On average EMS calls account for approximately two-thirds of the yearly volume. A majority of these calls involve people who are 55 years of age and older. The Brinnon/Black Point area has an aging population, both in the permanent residents and those that own seasonal residences. This trend is expected to continue as more vacation homes are developed and as people retire to live in the area. Emergency calls from this age group typically result from such things as someone falling, a reaction to changes in medication, and heart attacks. It is expected that these types of calls will increase as more people in the 55 years and older age bracket are added to the local population. PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-57 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) District #4 crews must bring their own water when responding to a fire anywhere in the district. The water is transported in the tanker and/or pumper noted above in the list of equipment. Both of these vehicles are standard size fire vehicles, including the two pumper vehicles used to extinguish fires. This places two limitations on District #4 crews. First, narrow steep roads can make it extremely difficult for these vehicles to get to a fire and maneuver once there. Second, since the water must be transported, there is a limited amount of water on hand to fight a fire. In the event of a very large fire, the water supply could quickly run out. In these situations, District #4 crews would have to be assisted by adjacent fire districts. An additional limitation is that existing equipment will only allow crews to mount rescue and fire fighting operations on buildings two stories in height. NFPA standards call for 1.5 times building height for a collapse zone and 10-15 foot ladder approach to all buildings. Final designs shall incorporate fire code requirements with approval of the local fire authority. The proposed development utilizes a number of large water containment areas onsite. This water is Class A treated water used for irrigation (recharging the aquifer), the Firewise program for spray irrigation of natural areas, and non-potable water for toilet flushing. The ponds are excellent resources in emergency situations for drafting sites and/or dry hydrants for fire operations. 3.5.1.3 Pleasant Harbor Marina The existing Pleasant Harbor Marina complex poses a particular challenge for District #4 firefighters. The marina’s piers and slips were constructed in two parts. The newer, northern portion has concrete piers and a dry stand-pipe, to which fire crews can connect and pump to the existing dock fire main system. The stand-pipe system needs to be projected throughout all modification and upgrades to the site and extended to the whole marina as docks are replaced. In addition, the existing access road into the marina complex is very narrow, steep, with tight switchbacks and no turnaround capabilities. There is only one way in and out. As a result, there is no effective access for the water tankers and pumpers to reach the marina. Fire crews would have to station these vehicles above the complex and run hoses down slope and between buildings to reach fires in the marina and lower parts of the property. The proposed development has greatly improved the access/egress capabilities for emergency vehicles, including fire hydrant connections with hose access on north and south sides. 3.5.1.4 Impacts Increased Emergency Services and Facilities Development of the Master Plan will add an additional 80 permanent residential units to the community and 52 staff apartments. Transient population is estimated to be an additional 1500 people at any given time to the service demands on District #4. The average age of the permanent and seasonal occupants is likely to be in the 40s or older, and it is expected there would be a corresponding increase in the number of EMS calls coming from the proposed resort population. The building envelope constructed at the resort will be larger than the predominantly single-story homes and the few smaller two-story structures found in the rest of the District. Simply put, larger buildings create the potential for larger fires. Without adequate onsite fire flow, a large fire in one of these buildings could quickly exceed the District's current capabilities. In addition, the proposed Condo-tel/conference center building would be three stories from the north exposure, but five stores on the golf course side. All buildings will meet International Building Fire Code requirements, as well as state standards where applicable. Fire service will be appropriate to building type and shall address fire suppression, access, and fire safety for the project. PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-58 November 27, 2007 The water system designed for the proposal will be required to establish adequate and sustainable fire flow as part of its approval. Site planning, emergency vehicle access, roadway design, and hydrant locations will follow applicable fire access standards and District #4 local fire authority needs assessment. An emergency service memorandum of understanding shall be entered into with the service provides and address specifically how EMS services shall be provided to the resort facilities. To address the emergency access issues at the existing marina complex, the redevelopment of the Maritime Village will include a new road to this part of the proposal (see site plan at Figure 3-17). The entry would be at Black Point Road and run one way northeast parallel to US HWY 101 and on the upland side of the proposed buildings, exiting onto US HWY 101 immediately north of the Maritime Village (see Figure 3-17). This would eliminate the existing narrow road and allow emergency vehicles direct access to each of the proposed buildings. The site will also be designed to allow fire crews access between buildings. Since the water system will extend to this part of the proposal, fire hydrants will be installed at the marina consistent with local fire authority approval. For the golf course portion of the site a secondary emergency access point is proposed for emergency vehicles only, and the closed ends of all cul de sacs will be connected or linked with proposed pathways of 10 foot width and controlled knock out ballards to permit fire access to all buildings from two directions. Figure 3-17 Private Internal Road Network Increased Equipment and Facilities The winter or permanent population is projected to increase 200 to 300 people as a part of the resort development, which would translate into a few additional calls, but is well within the capacity of the FINAL EIS - (Site Specific Amendment MLA 06-87) PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-59 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) existing facilities and services and anticipated area growth. During the summer, the resort population of between 1500 and 2000 people will strain existing personnel and services and equipment for which specific mitigation will have to be provided. A condition of any final plat approval for the resort facilities will be a memorandum of agreement with Fire District #4 to assure adequate funding facilities and personnel to address the increased need created by the resort. The memorandum shall take into consideration the increased tax revenue to the system provided by the resort and the means of providing an agreed upon incremental personnel facilities or equipment not covered by the increased revenue. 3.5.1.5 Fire Protection and Emergency Service Mitigations Any preliminary plat for the development of a portion of the resort shall require the following: • Ensure the onsite water system will provide for adequate sustainable fire flow. • All resort buildings to include internal sprinkler systems with FDC connections. • Incorporate Firewise site design standards in the layout of the proposed resort, as appropriate and approved by the local fire authority. • All subsurface parking will have to provide fire systems, including air handling, water, and emergency access and egress. • Install hydrants, two portable fire pumps with hoses and related fire suppression equipment at the marina and maintenance area as approved by the local fire authority. • Develop an “emergency action plan” with the Fire District in conjunction with predevelopment, development, and operation to assure clear lines of responsibility and response in the event of any incident requiring emergency response. • Any development of the existing marina complex as part of an MPR shall include improving emergency vehicle access to this portion of the resort. • Through a memorandum of agreement with District #4, provide the equipment necessary to mount rescue and fire fighting operations on any structure over 18 feet from ground level, including but not limited to the Condo-tel/Conference Center Building. • Enter into an “action plan” with the local fire authority at District #4 to assure coordinated control of additional services necessary to achieve an adequate level of service to the resort. • Provide a back-up electrical power supply to the resort to ensure continued operation of emergency systems and water supply during any outage. • Comply with the provisions of a memorandum of agreement with local service providers to address service equipment and personnel needs created by the resort, taking into consideration increased tax revenues from the resort activity. • Enter into a memorandum of understanding with the local fire authority to address the following issues: • “Firewise” design standards • “Emergency action plan” for predevelopment and operational service for each phase of development • Provide necessary facilities to mount rescue and fire fighting operations in all phases of the resort • “Action plan” for coordinated control and additional services 3.5.2 Police Protection Police protection is provided by the Jefferson County Sheriff's Office, which serves all of the unincorporated areas of the county. The Sheriff's Office is located at the Justice Center in Port Hadlock PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-60 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) and also maintains an office at the Courthouse in Port Townsend, a substation in Clearwater, and an annex in Quilcene. Personnel include 47 full-time positions, 12 reserve deputies, and 20 volunteers. LOS standards for police facilities in the County Brinnon Subarea Plan MPR Alternative, indicates that staffing and facilities are adequate to serve the increase in population under all three Alternatives. Deputies are dispatched to the Brinnon/Black Point area from the Justice Center in Port Hadlock or from the annex in Quilcene on days that it is staffed. The Brinnon/Black Point area is in the Sheriff's patrol district S5. In 2005 the Sheriff's Office reports responding to 403 calls in the district, accounting for 6% of all calls in unincorporated Jefferson County. It appears that the majority of calls involved traffic violations, DUI arrests, and burglaries. The Sheriff's Office also maintains a Marine Division that is currently staffed by one full-time sergeant and one patrol deputy, and can also call on three reserve deputies. Through a contract with Washington State Parks and the United States Coast Guard, the program receives annual funding, which covers the costs of manpower, training, equipment, and other expenses. The Marine Unit utilizes one 24' patrol boat, which is fitted with equipment and electronics required for inter-agency coordination with multiple types of emergencies, and provides a platform for the Sheriff’s dive rescue/recovery team. The proposed resort development will maintain onsite security staff. 3.5.2.1 Emergency Services Impacts The population projections for emergency services apply equally well to the need for additional police services. The resort is located at the southern end of the County and coordination to address the need for additional services will be important. Provision of police response to the community is a function of the County Commissioners and the County Sheriff and is most commonly a budget issue. In recognition of the increased property tax, sales tax, and other revenues from the resort, and the resulting economic benefit to the community planned by the County in attracting and providing for a resort in this area, the County needs to address the application of those revenues to provide additional services to the area. The resort has made available an office at the Maritime Village for a Sheriff staff member as determined necessary. The applicant has proposed a development agreement with the County and the State of Washington to assure some of the funds created by the resort will be retained in the Brinnon area to provide police and other services. 3.5.2.2 Mitigation Project Level: Permit approval for both the marina and the golf resort shall address security-related issues, and shall include specific mitigation which may include: • Controlled access at the entry and exit points of the resort and docks. • Onsite security and surveillance systems for the protection of resort guests, residents, and property coordinated with local service providers to assure appropriate communication and control systems are in place. Community level: Explore the use of a development agreement or other assurance to provide a mechanism for the County to provide some public safety funding to the Brinnon area from the revenues received from the resort to assure that the funds will not be diverted to the more populous north county. 3.5.3 Health Services The Brinnon/Black Point area does not currently have a medical facility in the local community. The area is served by Jefferson General Hospital in Port Townsend and Mason General Hospital in Shelton. A medical clinic has been established north in Quilcene, supported by Jefferson General Hospital. This clinic may be expanded to include counseling for mental health, substance abuse, and other related services. PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-61 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) The proposal includes 500± square feet of clinic space in the development of the Maritime Village for a certified nurse and/or a general practitioner. Selected staff will also be provided with basic emergency medical training. 3.5.3.1 Mitigation Project-specific mitigation shall be addressed in the public services memorandum of understanding (MOU), which shall address reasonable site needs and the means of providing and paying for services. The MOU shall be in place prior to issuance of building permits for development of resort facilities. 3.5.4 Schools The Brinnon/Black Point area is located within the Brinnon School District #46 and serves grades K through 8. Students of high school age have choices of schools in adjacent districts. The Brinnon School has four regular classrooms, two portable classrooms, and a computer room, along with a library, gym, and administrative offices. In 2000 the school district had a total enrollment of 74 students. This declined to a low of between 30 and 40 students in 2005, but rose to 56 during the 2005-2006 school-year. School enrollment for 2006- 2007 was 49, and the expected enrollment for the 2007-2008 school year is 45. Seasonal recreational homes are not expected to add students to the school district, so no impacts are expected from that component of the resort population. Since the proposed apartments are intended for both resort staff and Brinnon residents, it is expected that some of these units would be occupied by families with school age children. The Capital Facilities Element of the County BSAP MPR Alternative has established an LOS standard for the Brinnon School of 23 students per classroom. With four regular classrooms and two portable classrooms, the school can accommodate up to 138 students based on the established LOS. For the last six years the school has had excess capacity and the coming school year will only reach 48% of its capacity. The resort development phase is not anticipated to provide any additional school age children since the construction crew camp is temporary quarters and most families will attend school in their home districts. As the permanent population increases (both staff and permanent residents), some increase in school age population is anticipated, though minor. Staff increases significantly for the summer and this staff tends to be single or families without children. The longer term resort families tend to be over 55 and thus have limited children of school age, particularly K-8. There is also significant turn-over in Staff positions. As a result, for planning purposes this EIS estimates a potential school age increase of 5-10 students in any given year for the Brinnon schools, and the high school age increase may only be one or two students in any year. Specific mitigation agreements with the School will be addressed as part of the preliminary plat process for the golf course. 3.5.5 Economy, Housing and Employment 3.5.5.1 Economy In the last several decades the traditional resource-based industries have declined to the point that the south county area has seen some of the highest unemployment rates and lowest average incomes in Jefferson County. The area is in a rich natural setting close to State and National Parks and has numerous recreation opportunities such as hiking, sailing, and bird watching. It is estimated that over 500,000 people visit the Olympic Peninsula each year, but there are few tourist accommodations in the south county to attract this market. County policies and development code support the growth of a viable tourist industry by allowing limited development of small-scale tourist facilities, designating areas as Rural Village Centers, such as Brinnon, and for the development of an urban-scale resort through the MPR on Black Point. PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-62 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) The intent of the MPR designation at Black Point is for the creation of a destination resort that would act as a catalyst for the local economy by providing visitors a package of amenities developed in a contained setting to ensure compatibility with the surrounding rural setting. 2 3.5.5.1.1 Construction Period The resort is expected to provide more than $300,000,000 in local construction and development costs to build the necessary facilities. Neither the Brinnon subarea nor Jefferson County as a whole has the resources or expertise to provide the construction materials and services to build on this scale. Thus, much of the material purchased on a wholesale basis will be obtained elsewhere and delivered to the site. But the County will benefit from the payroll of the project from the construction crews housed in the area and local subcontractors and laborers will certainly play a major role in the overall development program. Payroll for 100 employees during construction is estimated to run approximately $6 million per year onsite during construction and $2 million per year (2007 dollars) thereafter during operations. Much of that money can be expected to be spent in the Jefferson, Kitsap, and Mason County area. Some of the local markets may seek to expand to meet the increased demands, and additional services and supplies may be purchased in Port Townsend, Shelton, or the Kitsap cities, which are the nearest metropolitan areas. 3.5.5.1.2 Operational Period Property Taxes Property taxes provide a consistent and significant revenue stream to the local governments. The resort is expected to carry an assessed value in excess of approximately $300,000,000, which would generate annual property taxes of approximately $3 million per year to the community, which is divided among the districts on the following basis: County (including roads) 25.7% Local schools 22.7% State levy 25.3% Special Districts (including Fire District #4) 26.3% Sales Taxes The construction costs of the project are expected to generate nearly $20,000,000 in sales tax revenue, of which approximately 25% goes to Jefferson County. While it is difficult at the conceptual stage to quantify the additional revenue impacts, the staff salaries, and the local expenditure of funds by tourists (projected to be between $80 and $100 per day per family) also provide ongoing additional support for services and utility services once the resort is operational. The ongoing revenue stream from the project from property, sales, and specialty taxes (including a hotel/motel tax on tourist facilities (presently 2%) provide a revenue stream by which general and special public services are provided. These funds must be taken into account during the permitting approval process when addressing the need for additional mitigation impact fees or revenues. 2 Socioeconomic impacts are not required to be addressed in environmental documents, but may be pursuant to WAC 197-11-448(2)(4). The materials are included because the County Comprehensive Plan and BSAP address the master planned resort as an employment/economic development program for south Jefferson County. PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-63 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) Input to the Economy Economic forecasts at the conceptual stage are necessarily estimates. But materials from both Washington state and the U.S. National Park Service provide estimates or guidelines of economic activity from the proposed development.3 Occupancy Assumptions: 85% occupancy for PRIME Season [757 units] 50% occupancy for MID Season [445 units] 30% occupancy for LOW Season [267 units] PRIME Season = 92 days (Mid June to Mid September) MID Season = 92 days (May to Mid June & Mid September to end October) LOW Season = 181 days (November - end April) Total spending estimated at $560 per day per unit spent in the area; including the $295/day accommodation fee. Thus: $265 for expenses other than accommodation. Accommodations $295 per unit per day at 890 residential units (2.2 people per unit) PRIME Season 757 units x $295 = $223,315 per/day x 92 prime season days = $20,544,980 per/annum MID Season 445 units x $295 = $131,275 per/day x 92 mid season days = $12,077,300 per/annum LOW Season 267 units x $295 = $78,765 p/d x 181 low days = $14,256,465 per/annum Total Accommodation Per Annum: $46,878,745 Food/Meals $150 per unit per day at 890 residential units (2.2 people per unit) LOW Season = 181 days (November - end April) PRIME Season - Food 757 units x $150 = $113,550 per day x 92 days = $10,446,600 per annum MID Season – Food 445 units x $150 = $66,750 per day x 92 days = $6,141,000 per annum LOW Season - Food 267 units x $150 = $40,050 per day x 181 days = $7,249,050 per annum Total Food/Meals Per Annum: $23,836,650 Alcohol PRIME Season – Alcohol 757 units x $15 = $11,355 per day x 92 days = $1,044,660 per annum MID Season – Alcohol 445 units x $15 = $6,675 per day x 92 days = $614,100 per annum 3 Economic Impacts suggested below are based on the National Park Service Money Generation Model. PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-64 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) LOW Season - Food 267 units x $15 = $4,005 per day x 181 days = $724,905 per annum Total Alcohol Per Annum: $2,383,665 Transportation PRIME Season – Transportation 757 units x $35 = $26,495 per day x 92 days = $2,437,540 per annum MID Season – Transportation 445 units x $35 = $15,575 per day x 92 days = $1,432,900 per annum LOW Season - Transportation 267 units x $35 = $9,345 per day x 181 days = $1,691,445 per annum Total Transportation Per Annum: $5,561,885 Retail Trade PRIME Season – Retail 757 units x $65 = $49,205 per day x 92 days = $ 4,526,860 per annum MID Season – Retail 445 units x $65 = $28,925 per day x 92 days = $2,661,100 per annum LOW Season - Retail 267 units x $65 = $17,355 per day x 181 days = $3,141,255 per annum Total Retail Trade Per Annum: $10,329,215 Wholesale Trade PRIME Season – Wholesale 757 units x $32 = $24,224 per day x 92 days = $2,228,608 per annum MID Season – Wholesale 445 units x $32 = $14,240 per day x 92 days = $1,310,080 per annum LOW Season - Wholesale 267 units x $32 = $8,544 per day x 181 days = $1,546,464 per annum Total Wholesale Trade Per Annum: $5,085,152 While any specific operation may vary from the estimates, an operating resort in the area is a significant source of economic activity that will necessarily involve the local community and county. Employment During construction it is estimated that approximately 80 to 125 people will be employed onsite periodically at any one time through the five-year construction period. It is expected that much of this basic work force can be found within the County, though certain specialized skills may require workers from outside the immediate region. The Company proposes to upgrade the existing RV facilities on a temporary basis (presently approved for 60 units) to provide temporary housing for construction workers. The number of additional workers needed in the more skilled trades is difficult to estimate and would likely come from the surrounding area and region. Statesman estimates that upon completion, the resort would create 40 permanent new jobs. The number of seasonal employees is estimated to be 50. Therefore, during peak season there will be an estimated 90 employees. The staff housing (52, 2-bedroom apartments) will provide onsite residences for the project. Currently 310 people are in the local workforce. The jobs created by the proposal would represent a 30% direct increase in local employment. It is anticipated that seasonal employees PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-65 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) would typically be students with the advantage to local students who can work the shoulder seasons but students from all over the country who may wish to spend a summer working in the Pacific Northwest. Full-time employees are expected to be younger people attracted to the prospect of growing with a new business. Statesman has indicated there would be opportunity for advancement and career growth for motivated individuals. Given the potential amount of direct expenditures in the local area, it is anticipated other employment opportunities would be created. With a predictable seasonal population and new attractive amenities on Black Point, new businesses are expected to form or locate in the immediate area. These could include such things as B&Bs, convenience gas and grocery, tour and guide services, small galleries and other art and craft facilities, restaurants and cafes, and a variety of other tourist-oriented commercial uses. Brinnon Brinnon proper has been designated a Rural Village Center (RVC) by the Jefferson County Comprehensive Plan. The purpose of the designation is to acknowledge the concentration of commercial and public uses, and logical boundaries were identified to allow for the infill of commercial and higher density residential uses to meet future economic and affordable housing goals. The UDC allows a variety of retail, commercial, and residential uses within the RVC designation. Bulk and scale are controlled by limiting the footprint of individual buildings to 20,000 square feet or less, a maximum height of thirty-five feet (i.e. three stories), and no more than 60% onsite impervious surfaces. There are approximately 19 acres vacant within the 66-acre RVC designation. Development is limited by flood plain and other limitations, but Brinnon does have land within the RVC which would expect additional development. Water supply and septic limitations are the significant limiting features in the area and County health department and State requirements for adequate water supply will limit overall total development. That said, Brinnon does have room for increased retail, business and mixed use development which could reasonably flow from the proximity to a major resort. The Rural Village Center provides the locale for additional commercial and service businesses to locate, consistent with the size and scale of a rural village, to accommodate increased demand for supplies and services by the traveling public. In addition, some recreation and service-related businesses are expected to benefit from the location of the Master Planned Resort as a result of its location in the Brinnon Subarea. None of the expected facilities would necessitate any expansion of the existing Brinnon Subarea, but rather simply reuse or add onto existing facilities. 3.5.6 Affordable Housing The BSAP area of Jefferson County has a mixture of affordable, moderate income, and estate-type housing and properties. Of the developed residential properties, nearly half are seasonal or vacation residences and are typically not part of the rental market. Approximately 80% of the remaining are owner occupied, leaving little in the way of rental housing stock. In addition, land use regulations establish minimum lot sizes of 5, 10, and 20 acres. Large lots reduce affordability and current regulations in most cases do not allow for higher density developments in rural areas. Higher densities make individual units more affordable. While the RVC designation would allow for limited higher residential densities, this area of Brinnon is located within a mapped floodplain, limiting the size and use of septic systems and drain fields to support denser housing. The rental housing market is particularly limited, outside the occasional vacation rental of homes on Hood Canal. Since most of the construction crews are expected to live out of the area, Statesman proposes to use the existing 60-unit RV facility onsite for construction housing. This facility would be temporary and must be in place prior to commencement of construction of the infrastructure for the project. The creation of new permanent and seasonal jobs will impose an added demand for affordable housing locally. To offset this demand, Statesman proposes building 52 units of new multiple-family apartments PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-66 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) on site. Much of the staff support for the resort is seasonal or part time. Providing affordable units as part of the proposal addresses both the increased demand represented by the proposal and provides the infrastructure to support the higher densities necessary to address affordability. 3.5.7 Rural Character and Aesthetics 3.5.7.1 Rural Character In accordance with the provisions of the GMA, the Jefferson County Comprehensive Plan Goal LNG 18.0 states that "Rural character is defined by local rural lifestyle, opportunity to live and work in rural areas, local rural visual landscapes, resource productivity, environmental quality, and significant areas of open space." Subsequent policies make it clear that significant amounts of open space and continued environmental quality are key components of preserving local rural character. Rural character is also to be preserved by not allowing the conversion of rural lands into suburban or urban densities or into uses inappropriate for a rural setting. The rural setting also includes development for tourist and recreational facilities and the allowance of planned resorts, urban uses in otherwise rural settings. The Brinnon Subarea Plan confirmed that the Black Point Pleasant Harbor is an area of significant amenity and could accommodate a planned resort as part of the overall rural area development. A key element of any allowed urban use in rural areas such as master planned resorts is that the resort and its facilities not allow the extension of urban or non rural uses outside the resort area. As such local guidelines require: "All necessary supportive and accessory on-site urban-level commercial and other services should be contained within the boundaries of the MPR, and such services shall be oriented to serve the MPR " (JCC 18.15.126(5)). The section must be read in the context of the Brinnon Subarea Plan and Comprehensive Plan, which suggest facilities available in the RVC of Brinnon. School facilities are in Brinnon, as are fire and emergency services. These facilities would serve the resort. The emergency services facilities may add “urban level” equipment to enable them to address the more complex challenges presented by a large resort facility The urban sewer and water facilities in the resort may not, however, be used outside of the resort area, except to serve identified emergency health needs. They may not be used to serve any development in excess of allowed rural uses or densities. Zoning around the proposal is residential in the form of 5-, 10-, and 20-acre minimum lot sizes for future subdivision. With few exceptions, allowed uses in these residential zones are housing and those activities that can be conducted within a residential lot, such as home occupations or those rural scale activities serving the local or tourist population. Here, rural character is retained by scaling the size of the residential structures consistent with local construction (less than 35 feet in height); clustering the more intense development internal to the project site and at the marina where dense activity already occurs and a suburban shoreline designation suggests higher levels of anticipated activity on the shoreline; locating the hotel and Maritime Village topographically so the buildings are set into the hill and do not project above the average tree height; retaining the buffer on the shoreline; locating the bulk of the housing away from local roads and out of site from US HWY 101 except the node at Black Point Road; retaining a tree buffer along US HWY 101 adjacent to the marina; and devoting more than half of the site to open space (including the golf course), wetlands, buffers and natural areas all reduce the visual impact of the resort on the surrounding community and help retain the overall rural character of southern Jefferson County. 3.5.7.2 Densities While the existing rural residential zoning is low density with large lots, there are pockets of residential development on and near Black Point that are more suburban in nature due to platting prior to current regulations. As a result, there is a mix of residential densities in the immediate area of the proposal. Hood Canal residential development, both north and south of the project site, has residential densities PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-67 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) that average 3.5 units per acre. At the northeast of Black Point around Rhododendron Lane, density is approximately 4 units per acre. Adjacent to the southwest portion of the golf course there is a small subdivision with a 7-unit per acre density. Overall gross density for the proposal of 890 units on 256 acres is approximately 3.5 units per acre. The densities contemplated for the majority of the proposal are less but not dissimilar to some of the existing densities found in the immediate area. The primary difference is that the vacation residences proposed for the resort are clustered into a number of townhouses or attached structures, rather than single homes on individual lots. The scale of construction is similar to the residential scale locally, however, as the residential structures are one and two story and adhere to the overall 35 foot height limits when viewed from outside of the project. Measured from the North Elevation, most units have parking under the building to reduce impervious surfaces and will have a total height not greater than 35 feet to the eave line (as will the terraced lofts that includes the major conference center, but by blending these facilities into the topography, the overall look to the north exposure is of a series of low buildings surrounded by large areas of open space). The combination of bluffs and protected native vegetation area along the southern shoreline means the site will have little, if any, visibility from US HWY 101 or the water along Hood Canal. The typical single-family home in the area has between 35% and 50% impervious surface to total area. By contrast, the clustered development of this project, with the protection of the wetlands and riparian buffers, and the dedication of a significant portion of the site to open space means the overall impervious surface coverage for the site is anticipated to be 20% or less. 3.5.8 Aesthetics Aesthetics refers to the visual components of rural character: rural landscape and open space. The local rural landscape has a predominance of natural open spaces over the built environment. To be compatible with its surroundings, design and layout of an MPR needs to be done in a manner that minimizes the visibility of structures when viewed from outside of the site. The RV campground is marginally visible from the south as one travels north on US HWY 101 and from portions of the subdivisions at the mouth of the Duckabush River, and is the largest part of either of the MPR alternatives. This portion of a proposed MPR has the greatest potential for visual impact to the rural landscape. MPR buildings on those properties adjacent to US HWY 101 would not be readily visible from the highway. Resort buildings should be constructed of natural materials and have architectural features such as pitched roofs and modulated facades for greater compatibility with the rural setting. There is also the potential for light and glare to interfere with the character and enjoyment of the night sky, and impact adjacent properties. Lighting in any MPR alternative will be required for both safety and security. Required lighting should be the minimum necessary and shielded to eliminate glare onto adjacent properties both on and off site. Lights should be kept lower to the ground where possible and use low wattage lamps to reduce impacts to the night sky. 3.5.9 Potential Impacts and Mitigation Summary The unavoidable impact of the proposal is that it would add complexity and intensity to the Black Point area, including visual elements, densities, and land uses. The area has historically had resort-type use on a different scale, which failed. The policy intent of the Jefferson County and Brinnon Subarea plans is to site a resort in this location to stimulate the local economy, while being sensitive to local environmental conditions and sensibilities. The construction camp facility to accommodate construction crews in an RV camp using the Bed and Breakfast and Kaufman Home, will minimize the construction period impact on the local population and housing. PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-68 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) Once completed, the proposal will directly add many new permanent jobs and should indirectly stimulate additional employment. The proposal also includes 52 new units of affordable housing, which should make it possible for others to live and work in the immediate area. The onsite visual landscape will change, but a significant amount of the proposal will be in some form of open space. The golf course itself is open space and the areas between the fairways will be preserved, planted, and maintained with native trees and understory. Forested open spaces are dedicated along the bluff of Black Point. Wetland areas are also preserved and enhanced as necessary. The dedicated open space along the bluff, along with the stands of native trees and understory between fairways, will reduce the visibility of structures in Black Point when viewed from the south. Buildings in Pleasant Harbor will not be readily visible from US HWY 101. While multi-level stories in height, the buildings are located on sites that slope down towards Pleasant Harbor. Their bulk and scale will be reduced when viewed from the highway since they are set back not less than 100 feet from the highway with natural trees shielding view lines. Buildings are visible from a south exposure of Pleasant Harbor. The key to the provision quoted is that the Master Planned Resort not lead to suburban or urban level development in the surrounding area and that result is achieved through several techniques: • The retention of rural area zoning on the lands outside of the Master Planned Resort. • The additional public services shall serve the urban levels of intensity within the Master Plan area, the RVC level services in the RVC area, and the rural development in the surrounding area, and allow extension of urban level sewer utilities only in the event of a health hazard. The purpose of the regulatory restriction is to prevent a fundamental change in the overall development patterns planned for the area. Increasing the quality or quantity of services in such area as a result of the development is one of the economic benefits. • A water facility may serve both urban and rural uses as a water system is preferable to individual exempt wells. The water system shall not be used to serve uses in the rural area in excess of that allowed by County codes for rural area development. • The number of proposed residential units shall be no greater than 890 units, including both the resort residences and staff/affordable housing. • The proposal shall maintain natural open spaces along the shoreline bluffs along site perimeters as is practical with golf course layout, between fairways, and the upper portion of the development. • The proposal shall ensure retention of selected stands of significant trees along the bluff of the golf course to reduce the visibility of the site from the south. • The proposal shall provide landscaping between US HWY 101 and the new access road proposed on the upland side of the Maritime Village. • With the exception of the Condo-tel/conference center, with terrace lofts and the Maritime Village, all structures shall be kept to a maximum of two stories in height from higher grade elevations. • The overall project approval shall address light and glare to reduce the projection of evening lights off the golf course and marina properties. (Reduction does not mean lights cannot be seen, but that through shielding and proper placement and orientation, the offsite impacts are minimized.) • The proposal shall provide construction period housing and housing specifically dedicated to staff and local service personnel to reduce the impact on local housing. PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-69 November 27, 2007 3.5.10 Public Services: Responses to DEIS Comments Responding to concerns raised by Jefferson County Public Health (284), WDOE (281, 381, 375 and 376), Stephens (127), Thompson (136), Dimino (193), Mitchell (212); Beattie (310). The resort is located in a rural area and medical services are limited as indicated. The proposal contemplates some form of onsite facilities, but the precise nature and how such facilities would be incorporated into the local service network is an issue addressed at the project level and phasing plans. The public service Memorandums of Understanding would address the issues raised at the project- approval level. Comment from WDOE noted—Recycling is to be a big part of "green development” for the project site and given the location and potential waste issues, ways to manage and reduce waste loads will be an appropriate part of project-level review. The project is required to work with the schools on identified issues. The FEIS requires an MOU with affected agencies to be addressed at the time of project approval to assure adequate facilities are provided concurrently with demands, and to address specific needs created by the resort phase. The projected growth of other recreation facilities in the area is a testament and response to the significant increased demand for public access to public facilities. Increased traffic on trails, beaches, and other public lands is projected by all resource and recreational agencies. Responsible public agencies have and are updating management plans in place to address the additional use. The resort is required to provide educational materials regarding proper use of public facilities. The resort power needs will be addressed at the project level, by phase. Preliminary estimates identify adequate capacity for service to the area to meet the needs of the project. 3.6 Shorelines The County's scoping notice identified four concerns directly affecting shorelines: (1) stormwater, (2) shellfish, (3) surface water, and (4) public access. 3.6.1. Shoreline Designation All of the salt water shorelines of the Master Plan area are shorelines of the state and shorelines of statewide significance under the Washington State Shoreline Management Act, and the Shoreline Master Program for Jefferson County. The Brinnon area shorelines are “suburban” for Pleasant Harbor and “conservancy” for the southern bluff shoreline along Hood Canal. Figure 3-18 Shoreline designations FINAL EIS - (Site Specific Amendment MLA 06-87) PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-70 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) 3.6.2 Shoreline Guidelines The Maritime Village area is located within the basin and shoreline jurisdiction of Pleasant Harbor. The Harbor is designated “suburban” which is a shoreline zone that contemplates a relatively intense level of shoreline development to promote use and enjoyment of the shoreline. Historic development and expansion of the marina and the boat launch, as well as the intensity of residential development on the Black Point area are reflective of the development contemplated by this zone. The Maritime Village improvements described in the project proposal are reflective of that intensity. A shoreline substantial development permit will be required for all development within the Maritime Village, including both marina-related commercial and limited resort housing in the waterside area. The golf course is set back more than 200 feet from the south shore conservancy shoreline of Hood Canal, which is a significant shellfishery area. In the master plan this shoreline is dedicated to open space and no structures or golf facilities are to be constructed in the shoreline area. Site-specific wetland mitigation plans may provide for water features and wetland mitigation areas at or in the outer 100 feet of the shoreline area to enable the creation of a wetland forested edge mitigation wetland should such designs prove warranted and feasible during permit review. Any site-specific issues of such a feature would be reviewed under the project-specific environmental review for the shoreline permit required and a specific construction/operation mitigation plan shall be approved prior to construction. The dock replacement program is also subject to project-specific review. The present degraded road/trail access to the conservancy shoreline is cut off in the MPR for safety and environmental reasons and a shoreline permit would be required for all such construction to assure safety in the area. Public access to the shorelines in the resort is limited to the marina area’s “suburban” shore where the more intense use is anticipated and public facilities to safely accommodate that access are provided. 3.6.3 Stormwater Stormwater as an environmental issue has been addressed in detail elsewhere in the report. See Shellfish/water quality section supra at Section 3.2. The golf course area is designed to retain the shoreline jurisdictional area (ordinary high water plus 200 feet) in a natural condition. No project stormwater is to be discharged into Hood Canal. The existing stormwater facilities along the highway are inadequate by today’s standards and require upgrading to protect water quality in Pleasant Harbor and Hood Canal. All development within the shoreline area of the harbor is required to be captured and treated prior to discharge into the harbor. As a result, with modern stormwater management and treatment mechanisms, the net discharge to the harbor is cleaner, with less turbidity, solids and potential pollutants (road runoff) than currently exists. 3.6.4 Shellfish As noted in the water quality section on shellfish, shellfish harvesting in the harbor is prohibited. The significant shellfish beds are in the Hood Canal locale, both north and south of the project. To protect fish and shellfish resources, the Master Plan application has pulled all development back from the southern shoreline (including closing the current dangerous trail access) to retain the natural condition and minimal use of the southern shoreline. This closure to direct public access reduces the potential for harm to the significant shellfish beds located to the south. In addition, all stormwater on the golf course is collected, treated, and discharged on site with no direct offsite discharge of any water from impervious or golf course surfaces. In addition, a 200 foot riparian buffer of trees and native vegetation is retained along the shoreline edge to retain the natural condition to the extent possible and provide native plant treatment for stormwater falling outside the developed area. The purpose is to retain the natural filtration component of the riparian edge to retain the natural condition for stormwater runoff from the undeveloped areas. PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-71 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) As noted in the section on Shellfish generally (Section 3.2), the Pleasant Harbor area has been closed to shellfish harvesting due to the concentration of single-family homes and onsite disposal systems, as well as the two marinas. No shellfish harvesting in the harbor is affected by the development of the golf course area or Maritime Village. All stormwater from developed areas is collected and treated prior to discharge in accordance with adopted stormwater guidelines for the region. The Master Planned Resort will significantly upgrade current systems and project a better water quality situation than presently exists. 3.6.5 Surface Water The surface water on the site includes three small wetlands on the golf course area and five small (non fish-bearing streams) on the marina side. As discussed in detail in the section on critical areas (Section 3.10), the central wetland is to be filled to become part of the water and irrigation management system, with onsite mitigation provided as required by County critical area requirements. The other wetlands are protected from potential impact by retaining the hydrology supporting the wetland, but capturing and treating all stormwater and irrigation water in approved systems in advance of discharge to the wetlands. Class A recycled water is available to assure adequate hydraulic flows are maintained to protect wetland functions and values. The streams carry both stormwater from the state highway and intermittent freshets in the wet season. As with the wetlands retained on the golf course area, the streams will be left in their native condition, buffered, and all stormwater will be captured and treated for both solids (turbidity) and water quality prior to discharge. As result, the flows will be maintained and water quality improved as a result of the project. 3.6.6 Public Access Public access to publicly-owned shorelines is a specific policy of the Shoreline Management Act. On the south side of the Master Plan area where the property is designated "natural," the shoreline area is owned by the developer, not the public, and the sensitive nature of the area and potential for damage to shellfish beds in the bay to the south support closing this shoreline to public use. On the marina side, where DNR owns the tidelands and has leased the shorelines to the applicant for use as a marina, the recreational access opportunities are maximized. The marina is already approved and will not be increased in overall size or capacity. The owners, in cooperation with WDFW, are proposing a float replacement program to eliminate the Tunicate, which is an invasive species presently found along the wooden docks. The Maritime Village provides an expanded opportunity for the public, both boating and non-boating, to enjoy the shorelines. The impacts of public use are already present due to the marina and its related activities. The Shoreline Master Program designation of “suburban” shows the area was planned by the County as an area where an added level of public activity associated with the public use and access to the shoreline is expected. The mitigation for such areas of increased activity is to assure that water quality concerns are met during the permitting process, and that the County specifically adopts noise regulations respecting the fact that a portion of the harbor is commercial and a portion is residential. The residential noise regulations at Chapter 173-60 WAC provide an accepted level of noise versus protection, which is adequate to regulate commercial activities adjacent to residential areas and should be incorporated into any shoreline permit. The resort may also provide some additional use of the harbor by Kenmore Air, which is another component of public access to publicly-owned shorelines. The air service may now fly into any marina area on an occasional or charter basis. As such, the use is already a permitted use (or at least not prohibited) and provides a reasonable means of accommodating the limited number of guests in a year who may wish to use the site on a charter basis, as they do now. If a proposal is made for regularly scheduled service on any basis, a new shoreline permit would be required and the impacts and limitations of such use discussed at that time. There is no proposal in the current application for increased air service to the site. See Section 3.11.1 for further information on float plane traffic. PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-72 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) 3.6.7 Shoreline Mitigation Summary • Public access and facilities shall be provided at the marina and Pleasant Harbor. • Public access to the southern shoreline should be curtailed and direct access eliminated. • All stormwater generated in the upland marina area shall be captured and treated to County standards before discharge to the aquifer. • All surface water on constructed surfaces in the golf course area shall be captured and treated for recycling or treated in accordance with adopted County stormwater manuals, and infiltrated on site. Zero discharge to Hood Canal from the developed golf course/resort area is required. 3.6.8 Shorelines: Responses to DEIS Comments Responding to comments by Jefferson County Public Health (284), WDFW (306). The southern beaches are to be closed and possibly incorporated into a conservation easement for permanent protection. The development on the marina side is within the footprint of the existing development and is providing public access and priority shoreline uses in areas of existing development. Hood Canal is under pressure from increasing recreational and residential use, raising concerns for water quality. Project-specific mitigation is designed to address and mitigate projected impacts. Jefferson County land use plans, including rural regulations surrounding the resort area, septic, road, and other building and development regulations are in place to address planned development intensity. The County is currently updating its Shoreline Master Program, which is to be completed in 2009. The Pleasant Harbor area is already developed with marinas and residences. The Jefferson County septic upgrade program is one response to the issue of older septic systems, as is the requirement to readdress the adequacy of septic facilities at sale or transfer. The resort proposal is in response to the growing popularity of Hood Canal and the increased demand for facilities in the area, as well as an economic center that could create additional pressure to locate (at rural levels) in the area. Enforcement of the County GMA, health, land use, critical area and shoreline regulations all provide mechanisms to address the increasing demands for use and activity in the South Jefferson County area. Public information programs are required to inform the public of these limitations. The cut and fill activities contemplated for the resort are well back from the water’s edge and adjacent bluffs, and the fill is targeted to existing kettles. Project-specific grading plans will assess the specific needs of the project, but preliminary review of the site by geotechnical engineers indicate the site stable and suitable for the fill. The concerns for the stability of the bluff are an area of concern for the entire project and will be the subject of specific consideration during project review for all phases. The site is adjacent to two designations, "Conservancy" and "Suburban," with a natural designation just south at the mouth of the Duckabush River. The only development near shorelines is located adjacent to the suburban shorelines. 3.7 Fish and Wildlife The County Scoping Notice addressed Fish and Wildlife as a separate consideration and specifically requested the project site be analyzed for several items: (1) endangered species, (2) specific terrestrial animals (eagles, elk, osprey, bears, and frogs), (3) specific water-dependent animals (seals, porpoise, shrimp, geoduck, oysters, clams, stickleback, salmon, and orcas), and (4) a construction stormwater management plan. 3.7.1 Endangered Species and Listed Species The site analysis was done for endangered species and listed species and the results were detailed in a site-specific Fish and Wildlife Habitat Assessment, July 20, 2006, contained at DEIS Appendix 7. PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-73 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) The endangered species potential was evaluated and determined that the project would not affect terrestrial species. The fringe riparian area along the south boundary provides significant protection for wildlife using the bay and the forested edge, as well as snags that eagles and other raptors may use for perching and feeding and these areas are to be protected in the plan. The forested fringe left in the current application is significantly larger and provides habitat protection and use for a wide range of species. At the project level, a habitat inventory should be taken of specific significant trees to ensure that habitat protections are maintained. 3.7.2 Hood Canal-Based Species The marine/estuarine species of Hood Canal (shrimp, clams, geoducks, oysters, Dahl’s porpoise, and orcas) are not expected to be impacted from the development, due to the protection of the southern bluffs from human intrusion and the treatment of water to avoid contaminated discharge from the site. The water quality in Pleasant Harbor, as it pertains to the proposed development, will be monitored and adaptive management programs will identify additional mitigation as required. 3.7.3 Terrestrial Species The site was evaluated for terrestrial habitat. The site is cut off from the balance of the peninsula by US HWY 101, but is still used by a variety of species, including birds, deer, and coyote. Large animals, including elk, may occasionally visit the site, but there is no evidence of regular use due to the highway. The site was examined for use by threatened or endangered species, but no nesting sites were found. The riparian edge, wetlands, and buffers do provide good habitat and will be protected. See generally Appendix 7, Fish and Wildlife Habitat Assessment. 3.7.4 Habitat Mitigation • The riparian edge along the south shore shall be identified and protected prior to any construction • Existing wetland buffer vegetation surrounding protected wetlands shall be marked and protected prior to any construction • All proposals shall maintain a 50-foot buffer of riparian vegetation along streams a-f except where crossing a and b. • The aforementioned mitigations shall be required for all such actions in the construction stormwater management plans for all phases 3.7.5 Fish and Wildlife: Responses to DEIS Comments Responding to comments by Jefferson County Public Health (284), Skokomish Indian Tribe (365), WDFW (306), Mitchell (212), Luckett (318), Lopez (272), Russell (282). The proposal recognizes that Hood Canal is home to six federally-listed threatened or endangered species (Puget Sound Chinook Salmon, Hood Canal Summer Chum Salmon, Puget Sound Steelhead, Bull Trout (Coastal Puget Sound), Southern Orca Whales, and Stellar Sea Lions). Further, both the Duckabush and Dosewallips Rivers are considered important systems in the maintenance and rehabilitation of affected runs. The property planned for the resort drains to Pleasant Harbor on the north and at the mouth of the Duckabush River to the south. Mitigating measures identified in this FEIS will be implemented to protect the southerly beach adjacent to important tidelands and the mouth of the Duckabush River, which is important not only for shellfish, but for all stages of salmon and fish life cycles. The Dosewallips River is located northerly of the site and out of any direct runoff or physical impact. The impacts there are secondary, with increased public use of facilities in Brinnon and the public PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-74 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) beaches. The MPR is required to coordinate with state agencies on educational programs and techniques to assure proper use of public lands. The resort is located in an area of existing development, minimizing intrusion of such a facility on the undeveloped and more significant habitat to the east, and away from the shoreline, minimizing direct impact to the southern beaches. The applicant is proposing to save substantial natural and open space on the site and to achieve the riparian buffers noted. The construction of a Master Planned Resort will inhibit use of the site by larger mammals, but as noted particularly the elk are not noted in the Black Point area, but farther north in the river plains. Any Master Planned Resort of a size and scale to support sewer and no offsite discharge would require significant site development and is an unavoidable consequence of the development of the site. Project-level review is directed to protection of riparian habitat on the south boundary, the vegetation buffer along US HWY 101, appropriate vegetation and tree buffers along the Pleasant Harbor shoreline, and the maintenance of functions and values of the wetland and stream critical areas in the appropriate sub basins. An adaptive management program to address water quality and upland issues is planned to be part of the marina water quality program at the project level to address issues as they may arise in the future. The Duckabush River delta is considered an important shrimp nursery area, and important habitat and nursery for juvenile stages of Dungeness crab. The sensitivity of the area for shellfish and sea life of all kinds reinforces the importance of maintaining a riparian buffer along the southern shoreline, assuring retention and treatment of all water affected by construction or development to assure water quality of all waters and seeps on the peninsula affecting or affected by the development. The sensitivity of the area was also the rationale for closing any efforts to access or use the southern beaches. Reference is made to an Osprey nest in the Pleasant Harbor area. Plans to protect the nest, as appropriate, will be addressed at the project level if the nest is still active or capable of providing support to local populations. No evidence of eagle nesting or roosting was identified onsite. The retention of a significant riparian area on the south shore will retain existing snags for perching. 3.8 Rural Character and Population (including housing density, mixed retail and rental affordability) 3.8.1 Characterization Rural character on Hood Canal includes a mixture of open spaces and more densely packed residential and tourist areas, including both public and private facilities. The Maritime Village and golf resort area occupy areas that have historically been tourist oriented with a great deal of tourist activity, particularly during the summer. The resident population is estimated to be between 200 and 300 people, given a mix of staff (including summer staff) and limited permanent population, a summer residency of between 1200 and 1500 people at peak summer occupancy, and about one-fifth that number during shoulder and slow periods. A number of very popular campgrounds, including Dosewallips State Park located a few miles north, contribute to local summer activity as it has nearly 400,000 visitors per year. The overall density of the resort is approximately 3.5 units per acre, similar to the historic density of Black Point, but with much greater open space. The provision of RV housing for construction workers and staff rental housing is designed to reduce pressure on the limited housing availability in the Brinnon subarea. The resort is expected to create an increased interest in the Brinnon area of the canal for residential development. But outside the resort area, such demand is at rural levels of density and services as defined in the Brinnon Subarea Plan. The resort is prohibited from providing urban sewer and water PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-75 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) services to the rural areas, except for areas of identified health problems. (For example, the development of the Master Planned Resort sewer system would provide Black Point residents with failing septic systems an alternative where the failing system is at risk of contaminating Hood Canal, but such limited use of the sewer system is only for solving existing problems and not in enabling new development.) The County is developing a shellfish protection district to address water quality and the sale of existing homes will trigger review and probably upgrade of older septic systems. The resort is proposed to have limited onsite retail capability (as distinguished from the BSAP model which has a significant retail component in a resort village west of US HWY 101). This decision was intentional to achieve the objective of the BSAP for the resort to provide an economic boost for Brinnon businesses, as well as simply providing a fully self-contained resort. The resort is expected to bring additional small commercial and service businesses to Brinnon, consistent with the Brinnon Subarea Plan, and subject to project-specific, site-specific environmental reviews and mitigation. 3.8.2 Rural Character and Population: Responses to DEIS Comments Responding to comments from Hood Canal Environmental Council (275 and 385), Jefferson County Public Health (284), Murdoch (139), Von Christierson (148), Dimino (193), Mitchell (212), Peterson (260), Russell (245 and 304), Russell (282), Mitchell (297). Rural character concerns principally address the impact of a large facility on a rural community, including changing the character of the area, impacts to a rural way of life, and the economic consequences of increased valuation on existing populations. Preference is expressed for a much smaller facility, which could fit under the "no action” alternative. But such facility would not be the urban "Master Planned Resort" that the County envisioned through the Brinnon Subarea in the Brinnon Subarea Plan. The Plan sets out a concept and detailed description of why a Master Planned Resort is appropriate at Black Point. Vision: For over a century, Brinnon served as an outdoor recreation based retirement and tourist community. This plan serves as a road map ... to make the changes necessary for Brinnon's future success. BSAP at p. 1. Master Planned Resorts: See BSAP at pp. 45, 46, including: Resort—could be comprised of the former NACO Campground and RV Park property, an 18-hole golf course, with clubhouse facilities and hotel/inn with conference and health/athletic facilities; with on-site advanced stormwater and wastewater treatment systems integrated into the golf course. BSAP at p. 45. The Statesman proposal provides the golf course and athletic amenities in a hotel resort with 890 rooms in cabin, villa, and townhouse settings, for tourist and conference use. Statesman did not add the 25 residential units along the south water’s edge as suggested by the conceptual master plan, preferring instead to have that area dedicated to open space and riparian buffer. Likewise, the Statesman proposal limits the commercial retail development suggested for the 7 acres on the east of US HWY 101 and did not incorporate the properties west of US HWY 101 into the Master Planned Resort, respecting the potential for significant traffic issues at that location if substantial additional traffic were added to the proposed resort site. PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-76 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) The hotel resort facilities need to be of sufficient size to support the sewer water treatment and stormwater capture and treatment requirements imposed to protect the environment of the area and achieve the advanced onsite stormwater and wastewater treatment systems incorporated into the proposal in response to the policy guidelines. The Statesman proposal was reduced to 890 units through the preliminary review process. At this level, the project can fund both the construction and the operation of the major facilities required. Reduction in size would prevent the facility from achieving the economies necessary to construct and operate such facilities. The suggestion that the County should revert to the "no action” alternative is contrary to the goal to "promote recreational and tourist development consistent with the character of Brinnon," BSAP Goal G1.0, p. 48, and the policy of achieving that goal: P1.1 Encourage the proposal of a Master Planned Resort for Black Point to foster economic development in Brinnon consistent with the vision illustrated in this Subarea Plan. BSAP at p. 48. The applicant is required to develop a "buy local" program to give local vendors the opportunity to participate at both the construction and operation supply level. Details of such a program will be worked out with the EDC and WSU extension program to facilitate local participation at the time of specific Master Plan approval. The Subarea Plan envisioned the resort as an economic boost to the Brinnon Subarea and identified Brinnon as a Rural Village, providing services and facilities to the area. Brinnon does have challenges with respect to the flood hazard areas and lack of services. The County regulations need to assure that new development is in areas safe and able to accommodate new growth. The Brinnon rural village would provide a range of services and facilities that complement the MPR. Increasing boat pressure, increasing population pressures, and increasing tourist pressures are all projected for the area, and cumulative impacts will occur. The purpose of the detailed project-level planning and permitting process is to identify how the resort may facilitate the pressure and mitigate impacts properly attributable to the resort’s development. The potential for cumulative impacts is acknowledged, but is also a product of the increasing demand for facilities and services, independent of the resort, and the competing goals of improving economic development and increasing public access to public lands on the one hand and the need to make sure environmental protection is assured on the other. The project permitting phase is identified as the best way to achieve these goals in context of specific proposals and mitigations. The rural character of Brinnon is based upon historical build out patterns in an area of large river watersheds and attractive Hood Canal waterfront. Future characteristics are determined by the County Comprehensive Plan and implementing regulations. The Plan did acknowledge the potential for a Master Planned Resort in the area and has the tools to continue to regulate development in an environmentally appropriate manner within its current regulatory framework. The present land use designations anticipate growth in the area at 1-5, 1-10, and 1-20 units per acre and other allowed rural uses. That development is anticipated to occur with or without the resort, but may occur more rapidly as a result of the resort. The other alternative, however, is that pressure on the larger tracts may be reduced, as those who desire to use the area would have resort and short-term rental housing available, reducing the need to purchase and develop property to enjoy the area on a regular basis. The project does propose an onsite temporary housing program to address the issue of worker housing and limited rental resources in Brinnon. At project-level approvals, the specifics of the number and timing of workers and worker housing and other demands will be addressed. Cumulative and community impacts are difficult to assess, but it is fair to say that the inclusion of a resort at Brinnon will have a direct and marked effect on the overall character of the community. Beginning in 1998 the Jefferson County Comprehensive Plan specified efforts to create an economic PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-77 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) change in the South County. The Brinnon Subarea process was commenced and the community vision expressed in that document was for a Master Planned Resort. The plan contemplated a series of changes that were viewed as being in the pubic interest, and the Statesman Master Planned Resort is only a first step in what could be a larger implementation of that vision. Other property owners in the MPR area shown in the Brinnon Subarea Plan, may elect to join the Master Planned Resort, by amendment, and could upgrade their current rural facilities to urban facilities in conjunction with upgrades to the Master Planned Resort sewer, water, and other facilities. (These facilities may not serve rural uses outside the resort, as the urban services are to be "fully contained.") Alternatively, property owners in the area, under current rural rules may seek to develop compatible rural-scale facilities under rural tourist and small business regulations, without becoming part of the Master Planned Resort. Both types of activity may bring the additional economic and employment resources to Brinnon envisioned by the Subarea Plan. How such development plays out is speculative at this juncture, until the other property owners make specific plans for their individual properties. Any new plan or project is subject to environmental review under regulations in place, including SEPA environmental review. Concerns about sustainability and the relationship with Brinnon also pose a range of issues that may be foreseen generally, but the specific execution of plans and projects await individual property owner’s responses. The Brinnon Plan envisioned an increase in economic and housing activity in the Brinnon Subarea, principally within the guidelines of rural village and rural development outside of other property owners choosing to join the Master Planned Resort, now or in the future. The FEIS does address job and temporary housing, recognizing it as an issue, and providing mechanisms for specific review and approval at the project level. The project does not guarantee that employees must live onsite, and in fact the integration of resort staff and local residents into a single community, and not the "we-they” of competing factions, is an objective of both the proposal and the Brinnon Subarea Plan. One objective of the resort is to create the critical mass to bring additional facilities and services to the community, located consistent with standards for appropriate development in the area. Questions about enforceability of covenants and conditions are addressed at the project level. The FEIS, the development regulations established if the Comprehensive Plan amendment is approved, and finally the specific mitigation and conditions of approval at the project level all provide a matrix and framework for the community to realize the controls necessary to achieve the goals set forth for the project. There is a high level of community sentiment both for and against the resort. The community vision is captured in the Brinnon Subarea Plan, which looks to a non discharge resort that can provide recreation and resort opportunities, as well as economic development. The scale is at a level within allowed traffic levels of service, and is limited by need for adequate water and sewer facilities as approved by state and local agencies. The location is an area with Canal tracts to the south, the rural village of Brinnon to the north, and significant pre-GMA development in the Black Point/Pleasant Harbor area. At an average density of less than four units per acre, and retention of many trees and buffers to substantially shield much of the resort from public view, the scale of the proposal fits the general area while providing the desired amenities meeting the Comprehensive Plan’s objectives. The Master Planned Resort needs to be an economic entity large enough to support the many amenities and protections demanded by the community for approval. Character and scale are protected by preserving open space and buffers, and keeping overall density at below four units per acre (the low end of urban range and within line of the existing development along Hood Canal in the area). PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-78 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) 3.9 Archeological and Cultural Resources 3.9.1 Characterization Archeological and cultural resource interests resulted in coordinated meetings with local tribal interests. The site was examined and the details are set forth in the Cultural Resource Assessment, at Appendix 8. The result of the search identified no specific sites in either the marina or golf course area. The southern shoreline abutting Hood Canal is a significant environmental and cultural area due to the need to protect adjacent fishing and shellfish grounds. As noted previously, the master plan proposes to close this beach to resort use. 3.9.2 Archeological and Cultural Resources: Responses to DEIS Comments Responding to comments of the Skokomish Indian Tribe (365, 372, and 374), Germaine (129). Project-level work, and specifically land clearing and grading plans will be required to have a cultural resources monitoring program in place to coordinate review for potential artifacts or sites of cultural significance and a program of appropriate response should such sites be identified. The discussions with the tribes reflected in the cultural resources section of Tribal comments continue to reflect the project proponent’s planned approach. 3.10 Critical Areas The Scoping Notice asked the applicant to examine the five listed critical areas under the County critical area ordinance, which include (1) wetlands, (2) aquifer recharge areas, (3) fish and wildlife conservation areas, (4) frequently flooded areas, and (5) geologically hazardous areas. Critical areas are governed by the County's critical area requirements. The purpose of the master plan review and the required development agreement is to assure that critical area regulations are followed in the development of the master plan, and that the master plan is approved with a single set of guidelines to assure that the overall plan is carried out under a single set of rules. Development agreements are commonly used to provide a degree of continuity for long-term projects. The Legislature has given authority for such agreements (RCW 36.70B.170) and the County details are at JCC 18.15.126(2) and 18.40.850-.890. The key requirements are that the plans be consistent with regulations, in place at the time of approval, and that the agreement specify the duration for the implementation of such rules. 3.10.1 Wetlands A detailed wetland assessment was made and the results are contained in the Wetland Delineation at Appendix 9. The site has three wetlands on the golf course side and none on the marina side. The confirmed wetlands in the golf course area are identified as Wetlands “B,” “C,” and “D.” The wetlands are Category II and no specific threatened or endangered species were found during the wetland delineation process. The site critical areas/wetlands are shown on Figure 3-19. The wetlands to be protected have well established native buffers that need to be protected at all times. The wetland to be removed does have some vegetation, but is also affected by vestiges of logging, roads, and infrastructure and as such is disturbed, marginal habitat in places, and susceptible to modification and restoration to improve both function and value. Wetland ”B,” which is approximately 0.475 acres (see wetland report, Appendix 9),is proposed to be converted from a wetland to a control pond for treated process water from the wastewater treatment system and irrigation return flow to provide a source of water reuse and golf course irrigation to reduce the overall water consumption of the site. Wetlands “C” and “D” will remain unaltered. The criteria for wetland protection and mitigation are set forth in the County Code for critical areas which governs replacement ratios and buffer management. PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-79 November 27, 2007 The Scoping Notice requested the applicant address wetlands as an element of review. The wetlands have been reviewed and delineated (Appendix 9) and by issuance of a March 27, 2007 letter, the USCOE has made a determination that the wetlands are not jurisdictional for purposes of USCOE permit review. Wetlands are regulated as a critical area under the state’s Growth Management Act, RCW 36.70A.060, and local regulations are to assure that functions and values of the wetland system are maintained. Court and Growth Board cases make it clear that wetlands may be altered or moved to accommodate a specific project, so long as the actions are reasonably necessary and the overall subbasin functions and values are retained. Figure 3-19 Protected Areas Map As described in Appendix 9, site investigations have confirmed three Category II wetlands: “B,” C,” and “D” as depicted on the map in App. D to the Wetland Report and further described therein on pp. 9-11. Wetlands “C” and “D” are to be retained, and “B”, which has only seasonal ponding in a large glacial FINAL EIS - (Site Specific Amendment MLA 06-87) PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-80 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) depression known as a kettle, will be filled to provide adequate storage on site for the wastewater treatment system, and the functions and values replaced, on site, in a fashion to ensure the functions and values are retained as provided by the County Code. The onsite wetlands were delineated using the updated (2004) wetland rating manual as required by JCC 18.15.325(1)(2). Standard wetland buffer widths are currently 100 feet from a Class II wetland and 50 feet from a Class III wetland (JCC 18.50.340(5)). Since the Master Plan is proposing to use Wetland “B” as a part of the water treatment recycling center program, the wetland at the bottom of this kettle will be filled, and an appropriate mitigation plan will be developed in accordance with Jefferson County Code. The general standard for mitigation is found in the Code which states: The overall goal of mitigation shall be no net loss of wetland function, value and acreage. JCC 18.15.350. The projected impacts to wetlands could occur both during construction and during operation of the resort. During construction the hydraulic and structural integrity of wetlands and buffers to be saved must be marked and protected. Water quality entering wetlands and buffers must be protected to avoid turbidity. Water quantity entering wetlands and buffers must be assured to avoid a change in function and value for wetlands being preserved. The wastewater treatment and water use and recycling detailed in Section 3.3 above demonstrates the preferred approach to water management on the site. With water conservation and recycling as a major component of the proposed mater plan, the use of the kettle area as a storage basin for water the water recycling process is unavoidable to retain necessary water onsite. Wetland “B” is the only area on the site capable of holding the water and providing necessary storage for the system to function. As such, the project would be reviewed per the compensatory mitigation requirements of JCC 18.15.350(2): Table 3-11 Required Replacement Ratios for Compensatory Wetland Mitigation Wetland Category Creation and Restoration(1) Enhancement(2) I 6:1 12:1 II or III • Forested • Scrub-Shrub • Emergent 3:1 2:1 2:1 6:1 4:1 4:1 IV 1.25:1 2.5:1 Notes: (1) The first number in the ratio specifies the acreage of wetlands to be created, and the second number specifies the acreage of the wetlands proposed to be altered or lots. The replacement ratios are derived from Department of Ecology Publication No. 97-112 (1998): “How Ecology Regulates Wetlands” (2) Enhancement of existing wetlands may be considered as compensation, but above ratios must then be doubled. JCC 18.15.350(2), Table 3-5 (current version). In considering wetland mitigation, preserving the existing functions and structure of wetlands “C” and “D” will be important. Alternate sites for wetland mitigation need to be identified and demonstrated. If PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-81 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) enhancement of these wetlands is the selected mitigation procedure, doubling of the replacement ratios is required or the creation of new wetlands and buffers on site consistent with the County code requirements and the more general charge that there be no net loss of critical area function and value when replacing habitat lost by development. Another mitigation alternative exists to offset the loss of the isolated Wetland “B.” Wetlands may be created as water features and incorporated into the golf course design with ecological considerations. The Trophy Lake Golf Course in Kitsap County is a good example to illustrate how this can be accomplished. By using a sand cap over the entire golf course, water is collected in the grass root system and directed toward the rough areas where a sand berm filters the water prior to allowing the runoff to flow downslope into created wetland areas (see attached figures from AES, 1999 4 ). Monitoring of the Trophy Lake Course has proved that fertilizer loading was stopped after the second year of grow-in and with proper golf course maintenance and operation, pollutant loading can be avoided which saves money and time for the golf course (AES 2001 5 ). Wildlife features can also be added to the golf course as described by Audubon International. More information on this organization can be found at: (http://www.auduboninternational.org/programs/signature/signaturelevels.htm). Jefferson County has adopted the King County model for golf course maintenance and the resort will be required to demonstrate compliance with the King County model or substantial equivalent in the management and operation of the golf course facility. A wetland mitigation plan will be developed in conjunction with the detailed design phase of the project and will be required at the outset of the grading plan in advance of final plat approval and project development when details of the construction will be available. It is common that mitigation plans be implemented prior to the planned filling activity, such as that of Wetland “B”. The site has only two areas suitable for enhancement to provide the necessary mitigation and these are both upland sites adjacent to wetlands. The uplands are disturbed as both were in the area of the RV camp that existed for many years. Natural topographic conditions may be enhanced to promote hydrology to support. In addition, site runoff can be collected, treated, and then released into created wetlands to further maintain hydrology and wetland characteristics and also to support onsite infiltration. JCC 18.15.350(3)(f). An alternative approach may be a cooperative compensation project for a significant wetland project in the area, but no such program presently exists, and would require participation by state agencies and the County. Absent a specific proposal from a governmental agency, the onsite solution appears to be the most feasible. Approval of site specific wetland mitigation plans will be required as part of the preliminary plat approval. 3.10.2 Aquifer Recharge Areas The County critical area regulations impose specific limits on projects that are designated (mapped) as critical area aquifer recharge areas. The Black Point property is mapped as an aquifer protection district, and the Master Planned Resort best management practices are taken from aquifer protection guidelines in the County to assure any potential impact to the aquifer is eliminated or minimized. The Black Point residential area is served by ground water, and prohibited uses in significant aquifer recharge areas are detailed as JCC 18.15.240-.255. None of the prohibited uses are to be included in the development of the golf course area, and the Master Plan approval requires the project to meet best management practices for use, treatment, and discharge of all waters used on the golf course. 4 Applied Environmental Services, Inc. 1999. Trophy Lake Golf Course & Casting Club Storm Water Quality Design Report. Prepared for OB Sports and Kitsap County Public Works Department. September 13, 1999. 5 Applied Environmental Services, Inc. 2001. Trophy Lake Golf Course & Casting Club 2001 Water Quality Monitoring Report. December 17, 2001. Prepared for Trophy Lake Golf & Casting Club and Kitsap County Public Works Department. PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-82 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) The fueling facilities at the marina are in areas that are not part of a well dependent water supply and no impact to potable water aquifer is anticipated. County rules do have special provisions for golf courses, which will be followed, and the Class A recycling regulations also have rules concerning existing potable water sites that will be incorporated into the reuse/recycling treatment and discharge plan for the site to be approved by WDOE as part of the water rights/wastewater discharge permit approval process. 3.10.2.1 Aquifer Protection Mitigation The stormwater management plan for the golf course shall demonstrate compliance with the County requirement for golf courses and stormwater management on aquifer protection districts. An approved preconstruction aquifer protection plan shall demonstrate retention of sheet flow water and ground wilts onsite. 3.10.3 Fish and Wildlife Conservation Areas The County critical area regulations, at JCC 18.15.283-.320, provide for setback from streams, including nonsalmon bearing streams. Several intermittent or seasonal stream channels have been identified on site (Type 5 under the County classification system). The streams are steep in gradient and blocked from fish passage due to structural barriers (see Fish and Wildlife Habitat Assessment at Appendix 7, p. 3). The project is to be developed with full buffers retained for all Type 5 streams. Stream crossings (a and b) will require mitigation to meet County standards. The creation of a complete and modern treatment system for stormwater on the developed portion of the marina site will reduce the discharge of turbidity or potential untreated or contaminated stormwater to the stream system and the net effect should be an improvement in water quality discharge. A 50-foot native vegetation buffer is required for all streams. The riparian edge along the southern shore is nearly 100 feet above the shoreline and does provide a heavily forested, natural edge for the shore, which is the preferred treatment for sensitive or relatively undisturbed shoreline edges. 3.10.4 Frequently Flooded Area The site has no flood plains or frequently flooded areas and these provisions do not apply. 3.10.5. Geologically Hazardous Areas The site has been reviewed with a thorough geologic hazard analysis. See DEIS Appendix 4. The principal geologic hazard feature on the site is the steep bluffs along the southern shore. The County ordinance requires setbacks for any structures or development from tall bluffs of at least 100 feet. The project is retaining a 200-foot vegetated edge along the steep slopes and eliminating potential road and trail traffic down or along the bluffs. The plan fully complies with all requirements and provides an extra margin of safety. The stormwater management plan shall require that all water from developed areas be captured in areas sufficiently removed from the bluff edge and are sized sufficiently to avoid discharge to or destabilization of the bluff in the event of wet seasons or upset. 3.10.6 Critical Area Mitigation Measures • Wetlands shall be protected from development (except Wetland B used for reuse and recycling) and a wetland buffer and mitigation plan shall be developed which demonstrates, under best available science principles, that the wetland functions and values of the resort area have been maintained through a combination of retained, enhanced, and constructed wetlands and buffers. The plan shall demonstrate no net loss to overall wetland area function and value. • An approved preconstruction wetland mitigation plan must demonstrate how loss of wetland habitat is offset, protection measures for water quality and quantity maintenance, and buffer PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-83 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) protection. Such protections must be in place prior to commencement of any grading onsite. The wetland mitigation report for Wetland B shall be approved and demonstrate how the overall system will operate, both during construction and operation to assure overall no net loss of function and value for the resort area wetland system. • The stormwater management plan for construction shall require all wetland areas (existing and new) meet the no net loss test and are in place prior to the removal of the Wetland B wetland. • The three northerly streams shall be set aside in a natural area, and development shall be limited to that necessary to provide adequate access and road right of way. All culverts carrying streams shall be fish passable where the stream has the potential to be fish bearing. • The two southerly streams shall be protected during construction and road crossings shall comply with adopted standards. • The resort shall be required to annually collect water quality monitoring data form the state water quality sampling station at Pleasant Harbor and submit a summary water quality report to the County. In the event that water quality shows any sign of deterioration, the County shall consult with the resort, the local residents, and the State (both WDOH and WDFW) concerning the source of the change. The resort permits shall require the resort to implement any mitigation measures determined necessary by the County to alleviate any water quality issues emanating from the resort properties. 3.10.7 Critical Areas: Responses to DEIS Comments Responding to comments of the Hood Canal Environmental Council (275 and 385), WDOE (381), Jefferson County Public Health (284), WDOE (281 and 375), Hal Beattie (133). Wetland B will be affected by construction of the large retention kettle. Wetlands C and D are not expected to be impacted by the proposed project. Wetland mitigation will be conducted to comply with state and local permitting requirements and will be based on no net loss of function and value. The FEIS requires a wetland mitigation plan to be in place and approved at the project level prior to construction on the site. Details as to the size, location, and nature of mitigation wetlands and buffers are required and will be addressed at the project-level review, under requirements of Jefferson County Code. The DEIS failed to mention the WDOE responsibilities in wetland modification. WDOE also has a permitting role in supervising and approving changes to waters of the state, including wetlands, and through their cooperative permitting process with Jefferson County, they will also be involved in the evaluation and approval of the wetland modification and conditions. An old heron rookery site was identified on State lands south and east of Pleasant Harbor. Project- specific plans will include identification of the site and mitigation if necessary consistent with the habitat management guidelines from Washington State Department of Fish and Wildlife. The entire area of the proposal will be evaluated at the project level to identify specific needs to protect fish and wildlife. The project may use special permits to adjust buffer widths consistent with County requirements to fit the state and local conditions. Floodplains. The project site does not have floodplains, but incidental development either in Brinnon or in the watersheds of the Duckabush or Dosewallips Rivers could affect or be affected by floodplains. Project-level review looks at both direct and indirect impacts and will be looking at related flood hazard issues. The Public Health Department pointed out that US HWY 101 does cross flood hazard areas, steep slopes, and other critical areas. Project-specific development review includes critical areas and direct and indirect impacts attributable to the project and proper mitigation where necessary and appropriate. PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-84 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) 3.11 Other Issues During public discussions several issues were raised which do not fall neatly into the format of the scoping notice but which should be addressed. 3.11.1 Existing and Proposed Float Plane Traffic in Pleasant Harbor It is possible that float plane traffic in Pleasant Harbor may increase as a result of the proposed development from people coming to visit the resort and attractions in the Hood Canal area, through various marketing endeavors and population growth in the general Hood Canal region. Currently, the average annual number of float plane flights into Pleasant Harbor by Kenmore Air is 5. In comparison to other resorts in the area, Alderbrook experiences approximately 30 flights per year and Port Ludlow at 20 flights per year, all serviced by Kenmore Air on a Chartered Service Package. The demand for float plane travel to destination resorts is limited and represents a very small niche market. Both Alderbrook and Port Ludlow serve a wider permanent population than Pleasant Harbor. While some resort-oriented travel may occur, it is expected to be incidental and not significantly greater than the present levels of service. 3.11.2 Military Operating Areas This is to acknowledge existing and proposed military operating areas near the proposed development. Notification and adherence to notices is imperative and will be strictly enforced by the US Navy. The Navy needs to extend the Northwest Range Complex operating area to provide multiple in-water environments that meet the evolving operational requirements for manned and unmanned vehicle testing in Washington State. The Northwest Range Complex is comprised of three marine ranging areas in the Pacific Northwest (Washington state): (1) The Dabob Bay Military Operating Area (MOA), two Hood Canal MOAs and the connecting waters known as the Dabob Bay Range Complex (DBRC); (2) the Keyport MOA; and (3) the Quinault Underwater Tracking Range (QUTR) MOA which is located within the Navy MOA W237A. The range extension is required in order to provide adequate testing area and volume in multiple marine environments to fulfill the NUWCDIVKPT mission of providing test and evaluation services in both surrogate and simulated war-fighting environments for emergent manned and unmanned vehicle program operations. The DBRC is the Navy’s premier site for proofing, research, and development of underwater systems such as torpedoes, countermeasures, targets, and ship systems. No testing of explosive warheads occurs, or is planned to occur, in the DBRC; explosive warheads are never placed on test units. Primary operations at the DBRC provide production acceptance (proofing) tests of underwater systems, research and development test support, and fleet tactical evaluations involving aircraft, submarines, and surface ships. These tests and evaluations of underwater systems from the first prototype and pre- production stages up through fleet operations (inception to deployment) ensure reliability and availability of underwater systems and their components to the fleet. The site also supports acoustic/magnetic measurement programs. These programs include underwater vehicle/ship noise/magnetic signature recording, radiated sound investigations, and sonar evaluations. In the course of these operations, various combinations of aircraft, submarines, and surface ships are used as launch platforms. Appendix 10 includes a figure outlining the Proposed DBRC Site Extensions and Typical Notice to Mariners. In order to provide compliance and mitigate for the military operations and activities that will occur near the proposed development, notices will be posted at the Maritime Village and marina. In addition, information regarding the military operating areas and examples of notices will be provided to purchasers and users at the resort. PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-85 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) 3.11.3 Other Issues: Responses to DEIS Comments Responding to comments by Stephens (127), Ross (132), Mitchell (212), Peterson (260), Hood Canal Environmental Council (275 and 385), John McDuff (97); Ian McFall (131), WDOE (281, 275, 276, 381). Project control and assuring the objectives of the plan are met in fact. The FEIS identifies a series of mitigation requirements that will be implemented through a combination of specific zoning regulations and a development agreement on phasing and project controls (to be developed if the Comprehensive Plan amendment is adopted) and then project-level review with supplemental environmental review based on specific engineering and technical issues and standards. Permit conditions and requirements run with the land and are conditions on any operator, should Statesman elect to transfer all or a portion of the facility to other owners. Questions are raised about the carbon footprint. The resort is a response to increasing demand for facilities to enjoy the natural amenities available in the area. Thus, on the one hand, it brings a significant number of people to the area who may not otherwise come. But it also provides a local area for those who want to enjoy the area and would otherwise have to drive in on a daily basis, or use public facilities and campgrounds without the sewer and water facilities present at the resort. The resort is committed to a green approach to development and operation, consistent with the area and feasible approaches for a sustainable resort. The issues are of concern and will be addressed in both the design and operation of the resort. Reducing impervious surfaces, providing shuttle and integrated public transit, and low energy utilization facilities all contribute to reducing the carbon footprint. The objective of the EIS was to identify potential adverse environmental impacts of the proposed amendment and identify whether the project meets the goals of the Comprehensive Plan and can adequately address the avoidance, minimization, or mitigation of identified environmental consequences. Through the DEIS and comments, the potential issues have been raised and means to address adequate mitigation at the project level are in place. One frequently addressed concern is that the resort provides only "low paying jobs" and as such would not be of any economic benefit to the community. The economic benefits are detailed in the EIS, and include: • Property Tax receipts from more than $300,000,000 in physical improvements to the Black Point property. • Sales tax receipts, B & O tax receipts, and hotel/motel tax receipts from the resort operations and from increased sales in the area. • Mitigation and impact fees paid by the applicant to address pubic service and public facility needs. • The creation of more than 100 jobs during construction and 200 jobs during operation. • Construction typically provides "family wage" jobs, and the resort has senior management and responsible positions in conference center, food service, facilities, marina management, and golf management that also fit the "family wage" jobs designation, as well as the seasonal and part-time jobs that provide employment opportunities for youth and for those who prefer the flexibility allowed. The assertion that "only low paying jobs" are present is simply not true. • The project is required to have a job and contract posting program that will provide opportunities for local vendors to compete for project jobs and contracts. • The memorandums of understanding with local agencies will provide some assurance that funds to mitigate concerns in the South County will be spent in the South County. PROBABLE SIGNIFICANT ADVERSE IMPACT REVIEW OF THE PROPOSAL CHAPTER 3 Pleasant Harbor Marina and Golf Resort Page 3-86 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) The site is undergoing voluntary clean up by the present owners, which should be completed shortly after the end of the year and is a prerequisite to Statesman taking title. Contact information is accurate. 57577-0001/LEGAL13724220.1 DESCRIPTION OF ALTERNATIVES REVIEWED AND IMPACTS CHAPTER 4 Pleasant Harbor Marina and Golf Resort Page 4-1 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) CHAPTER 4 – DESCRIPTION OF ALTERNATIVES REVIEWED AND IMPACTS This section describes the Alternatives evaluated under the DEIS. Relevant background pertinent to the planning process is included under the appendices. The alternatives to be considered are "no action" (assuming the Master Plan proposal is withdrawn or denied, and the area develops under current zoning), the Brinnon Subarea plan (BSAP), and the Hybrid plan. The Brinnon Subarea plan and Hybrid plan look to the development of the balance of the property within the area indicated in the Subarea Plan as appropriate for inclusion in a proposed Master Planned Resort. The Brinnon Subarea plan alternative assumes that the entire area is included within the Master Plan, and as such is subject to the Master Planned Resort limitations on resort-based urban development. The Hybrid proposal presumes that the lands outside the Statesman proposal develop under the current zoning, but that such development may be accelerated under the current proposal and developed on a timetable in concert with the Master Planned Resort. In evaluating the alternatives, many of the consequences of onsite development are similar. For example, the proposal, the Brinnon Subarea plan, and the hybrid model all presume significant resort development on the Black Point MPR property. The means of addressing development and environmental protection will be the same for issues such as overall site impacts, water and wastewater service and treatment, and protection of stormwater and critical areas and resulting protection of fish, shellfish, critical areas, water quality, cultural resources, and other scoped issues. The BSAP resort and hybrid alternatives east of US HWY 101 are all urban uses presuming urban water, wastewater, and stormwater control systems serving an urban intensity development. The location, configuration, and topography of the site allow for little variation for intense development. The BSAP alternative has urban uses west of US HWY 101; the Hybrid alternative examines rural tourist uses that may be permitted under current zoning if the Statesman proposal is constructed across the street. The no action alternative presumes the resort features do not get constructed and the proposal area is developed with a more locally-oriented development consistent with existing and allowed uses in rural zones. The review in the alternatives sections examine the differences, where impacts may be greater, lesser, or simply different from the proposal to permit an adequate evaluation of the land use choice and consequences of the proposal and alternate programs. The purpose of the alternative section is to examine reasonably probably alternatives, not maximum achievable densities or worst-case scenarios. 4.1 No Action Alternative In this No Action Alternative (Figure 4-1) Black Point would continue to develop as a single-family residential area, consisting of both year-round and seasonal residents, the latter gradually decreasing as more people take up permanent residence. However, as noted above, for purposes of comparison in this DEIS it is assumed that Black Point will fully develop with full-time residents. The underlying zoning for Black Point is rural residential, with minimum lot sizes of 5, 10 and 20 acres per dwelling unit. Of the 710 acres on Black Point, approximately 382 acres are in 1:5 zoning, 188 acres in 1:10, and 140 acres in 1:20. DESCRIPTION OF ALTERNATIVES REVIEWED AND IMPACTS CHAPTER 4 Pleasant Harbor Marina and Golf Resort Page 4-2 November 27, 2007 Figure 4-1 No Action Alternative – Current Zoning The golf course area of the master plan includes about 160 acres zoned RR 1-10; 31 acres zoned RR1-20; and the balance zoned 1-5, but already divided into smaller lots by previous platting and the County road. The Maritime Village area is zoned RR 1-5, but is already more heavily developed with the marina and existing lots smaller than one to 5. The No Action Alternative on the golf course site assumes a planned rural residential development with a golf course. See Figure 4-2. FINAL EIS - (Site Specific Amendment MLA 06-87) DESCRIPTION OF ALTERNATIVES REVIEWED AND IMPACTS CHAPTER 4 Pleasant Harbor Marina and Golf Resort Page 4-3 November 27, 2007 Figure 4-2 No Action Alternative –Planned Rural Residential Development (PRRD) The no action alternative assumes that the golf course and marina area continue development under the provisions of the Jefferson County Code now in place. The residential development in the golf course area would likely occur predominately along the southern shoreline, served by the existing water system and water rights, with approximately 24 new residential houses, and a small 9-hole golf course serving the local area similar to the Bayshore Golf Course in Mason County, as allowed in County Rural zones through a Planned Rural Residential Development (PRRD) process. The Tudor and Jupiter property across US HWY 101 to the west could develop as currently planned, with a 5,000 square foot, small-scale rural tourist facility (small restaurant, gift shop, and office) and the Jupiter site with a rural gas station and service facility for RVs and other vehicles. FINAL EIS - (Site Specific Amendment MLA 06-87) DESCRIPTION OF ALTERNATIVES REVIEWED AND IMPACTS CHAPTER 4 Pleasant Harbor Marina and Golf Resort Page 4-4 November 27, 2007 The marina area has several (6) existing lots that could be developed under the current zoning and shoreline program into single-family residences, for a total of 30 new residences for the Master Planned Resort area. FINAL EIS - (Site Specific Amendment MLA 06-87) The U.S. Census shows that the average number of people in each household is 1.9 within the Brinnon Subarea Plan. While many of the homes on Black Point and the nearby Hood Canal area are seasonal or second homes, the ratio of second homes to permanent residences is dropping as retirees choose to make Jefferson County their permanent home. Assuming that the split between seasonal and permanent homes for the new development would be approximately 50%, one half would be second homes. Under that circumstance, if all of the remaining lots on Black Point were developed with residences, it would result in an increase of a total of approximately 30 homes, but a permanent population increase in the area of only 15-20 people. Figure 4-3 No Action Alternative – Marina Area DESCRIPTION OF ALTERNATIVES REVIEWED AND IMPACTS CHAPTER 4 Pleasant Harbor Marina and Golf Resort Page 4-5 November 27, 2007 The boat launch, beach, parking area, and approximately 30 acres of forest owned by the WDFW would remain and likely see a modest increase in use commensurate with local population growth trends and regional increases in tourism. It is assumed that the cottage businesses in the immediate vicinity would continue operations, including the B&B, real estate office, vehicle/boat maintenance and repair shop, welding service shop, and vehicle and boat storage facility. Pleasant Harbor Marina would also continue operation and remain relatively unchanged, providing moorage and fuel services, and limited shopping and food service. The only new traffic would come from the PRRD development of the golf course area and the addition of a 5,000 square foot office and tourist service center on the Tudor property. The Jupiter property would have a service station and RV repair to serve tourists. Water for Black Point and Pleasant Harbor would continue to be provided either by the existing community wells or individual wells, and sewage and wastewater would continue to be treated by individual septic systems and drain fields. The alternative certainly has a significantly lower density and intensity from the Master Planned Resort. Looking at the overall impacts and differences in impacts from the Master Planned Resort, the impact of the no action alternative on the factors addressed in the scoping notice may be summarized as follows. Figure 4-4 No Action Alternative –Marina FINAL EIS - (Site Specific Amendment MLA 06-87) DESCRIPTION OF ALTERNATIVES REVIEWED AND IMPACTS CHAPTER 4 Pleasant Harbor Marina and Golf Resort Page 4-6 November 27, 2007 Fi 4 4 NAti Mi Figure 4-5 No Action Alternative – West of US 4.1.1 Shellfish The no action alternative would permit the development of individual lots along the southern shore of the master plan property, where homeowners would seek shoreline access and significant views. When compared with the proposed resort the overall impervious surface coverage would be much less for single-family homes and the small community golf course. Development under this alternative would be served by septic tanks, which have historically been a potential problem on Hood Canal. Mitigation for water quality in Hood Canal to protect fish and shellfish would have to be accomplished through buffers and setbacks. Under the PRRD model, which has been identified as a reasonable approach to development of such a large parcel, the lots would be long enough and deep enough FINAL EIS - (Site Specific Amendment MLA 06-87) DESCRIPTION OF ALTERNATIVES REVIEWED AND IMPACTS CHAPTER 4 Pleasant Harbor Marina and Golf Resort Page 4-7 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) (approximately 2 acres average size) to accommodate the house and related structures well back from the top of the bluff to permit retention of a band of native vegetation to help control runoff, and the septic tanks may be located well inland (within the smaller golf course property) to retain separation between the septic tanks and the beach. The residences would most likely retain ownership and access to the beach and would upgrade the present beach access at least for pedestrian access. The reestablishment of beach access to serve the plat and its residents would lead to some additional beach use adjacent to the Duckabush tidelands, over the proposal, but the shellfish beds have been operational adjacent to much higher existing density along US HWY 101 to the west over the past decades and the addition of 24 homes, with septics well upland, should not pose an additional problem if properly situated and maintained. The County’s proposed shellfish protection district provides additional attention and potential conditions to assure protection of water quality. There is no shellfish harvesting in the harbor, due to the presence of the marina. New homes would have to be located on septics and the current Maritime Village would remain on septic. This is a less desirable alternative than the sewer system, but authorized under both state and County regulations. Any sale of the homes or upgrade of the marina facilities would entail inspection of the septic tanks and drainfield systems and requirements for upgrade for those found inadequate. The no action alternative is not expected to have any discernable impact on shellfish if properly permitted. Mitigation to achieve shellfish protection under the no action alternative would include requirements to retain a vegetated buffer to protect the southerly bluff to control stormwater, and a requirement that septic tanks and drainfields be upgraded to meet current water quality protection standards. 4.1.2 Water The site presently has 28 acre feet of water rights per year remaining from past practices, which is sufficient to serve the proposed no action alternative. The pumping of that water to allowed limits has not created salt water intrusion risk in the past and given the water profile for the area (see Water Supply and Groundwater Impact Analysis at Appendix 5), no impact from the water use for domestic purposes is anticipated. The small golf course on the reserve tract would require approximately 31 acre feet of additional water rights, but the hydrologic report suggests that such water rights could be available for the site to achieve permitted uses. The additional lots within the MPR area, both on the water side and west across US HWY 101 will be served by individual wells and septic tanks and would have to locate such tanks well away from the shoreline in the marina area. The topography and proximity to the water make it likely that such development would occur on drainfields centrally located on Black Point away from the shorelines or streams to avoid potential contamination to the harbor. Both the Tudor and Jupiter sites would be served by individual exempt wells for residential purposes, but would have to secure a small water right to serve rural tourist, small-scale commercial uses. The hydrology report suggests that such water rights may be available to permit the development of these limited rural tourist uses. No significant adverse impact to the area water supply system or water quality is anticipated through the no action alternative. No additional mitigation is required beyond keeping septic systems well away from the water’s edge and requiring WDOE confirmation of existing water rights and approval for new water rights for the anticipated uses. See Table 2 of Water Supply and Groundwater Impact Analysis at Appendix 5. 4.1.3 Transportation The no action alternative is the alternative with the least traffic impact. Intersection controls at Black Point Road and US HWY 101 will need to be addressed to create safe turning movements for the anticipated additional traffic, the no action property, and the Black Point area DESCRIPTION OF ALTERNATIVES REVIEWED AND IMPACTS CHAPTER 4 Pleasant Harbor Marina and Golf Resort Page 4-8 November 27, 2007 as a whole. In addition, any plat approval requires the abutting Black Point Road to be brought up to County standards, so the no action alternative would be expected to upgrade the existing roadway deficiencies. Such a plat would have little if any internal circulation (except a common pathway to the beach along the existing trail/roadway serving the plat). The Maritime Village area would remain essentially unchanged, since the lots in existence are already less than allowed in the district and no subdivision upgrades would be expected. As such, development review in the Maritime Village area for new houses would be limited to individual septic and water source requirements under the County Health Code. The small-scale commercial services proposed on the Tudor and Jupiter properties along US HWY 101 would seek individual access points on US HWY 101 that are offset from Black Point Road. The State Highway Department controls access to US HWY 101 and any permit approval would require safe site distance and separation between the entrances. The offset access points eliminate any direct cross US HWY 101 movement, and the small size of the uses proposed would limit pedestrian or non motorized access to the very occasional crossing, as now occurs elsewhere generally along US HWY 101. Table 4-1 No Action Alternative: Trip Generation LOS comparison is at Table 3-9. 4.1.4 Public Services The public service demands from an increase in the overall housing density of 30 units in the Master Planned Resort area are significantly less than the planned resort, but with correspondingly less revenue from the development to support additional services. On a prorata basis, the addition of 30 homes is approximately 4-5% of the people in the overall service area and a corresponding increase in public service calls. Such increase is within the overall planned growth of the area through normal growth and attrition and no special action impacts have been identified and no specific mitigation is identified at this plan level. The analysis holds true for police, fire, emergency services, and schools. FINAL EIS - (Site Specific Amendment MLA 06-87) DESCRIPTION OF ALTERNATIVES REVIEWED AND IMPACTS CHAPTER 4 Pleasant Harbor Marina and Golf Resort Page 4-9 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) All new development (except single-family homes on existing lots) requires environmental review and as such public service demands on a project basis are reviewed and addressed. 4.1.5 Shorelines The Rural zone on Pleasant Harbor would limit the residential development to 5-6 additional homes only on existing lots. Special care needs to be taken with septic siting for such homes to assure a fully functioning system does not adversely affect Pleasant Harbor. No additional pressure on the shoreline other than that already present with the existing lots would be anticipated on the Pleasant Harbor side. The siting of individual homes by owners for their own use does not require a shoreline permit and as such, if the lots are simply sold (which requires no regulatory oversight), the lots could be developed simply with the controls of a building permit, which does address setback requirements, and septic and water approval through the health department. The “conservancy” shoreline to the south has a much lower density allowed than the marina area, but the no action PRRD alternative is achievable under the County zoning that fronts the southern shore on the Master Planned Resort side. The homes would need to be set well back from the bluff’s edge to meet geologic hazard limits and Hood Canal water quality concerns, and as such the biggest impact likely is the removal of additional vegetation along the shore to promote views and yards. The impact of additional buildings on the separate lots on the harbor may lead to a demand for additional single-purpose docks, and the shoreline trail on the south shore will require adequate design and controls to assure that it does not lead to contamination of the abutting shellfish beds. Shoreline permits are required as part of any subdivision development of the shoreline and would be able to impose appropriate construction and post-construction mitigation. 4.1.6 Fish and Wildlife Patches of natural habitat (trees and shrubs) remain on the Maritime Village side and can be protected to provide riparian protection for the existing intermittent stream beds. The old campground site was substantially disturbed during the RV resort use for nearly 20 years, but has regrown and provides habitat for small mammals, deer, and birds, but has no primary association with endangered species. See Fish and Wildlife Habitat Assessment, Appendix 7. The existing wetlands and buffers provide isolated wetland habitat, which in the no action alternative would be left undisturbed. The small 9-hole golf course will have more open space than the 18-hole course and will retain more open space and wetland buffers than the proposal. The alternative would have some greater impact on the natural habitat on the southern beachfront riparian edge. The no action alternative may have greater impact to Hood Canal front habitat and less impact in the central area. Given the zoning, however, and proximity to Hood Canal, development and resulting habitat impacts are to be expected. Mitigation would occur through project review and habitat mitigation plans. The fishery is not expected to be affected, assuming septic tanks are maintained well inland, and provision is made in the plat approval to avoid direct runoff to the bay of untreated storm or landscape water (conditions required of the Master Planned Resort). 4.1.7 Rural Character/Population The loss of the Master Planned Resort limits the economic development potential for the area as the key large parcel that could be devoted to major economic development will be turned over to very low density development. The losses would be felt in significantly reduced tax revenues, reduced demand for local services and supplies, reduced employment opportunities, and an inability to realize the vision of the Brinnon Subarea Plan of a major resort providing an economic center for the south county region to replace lost resource-related industries. DESCRIPTION OF ALTERNATIVES REVIEWED AND IMPACTS CHAPTER 4 Pleasant Harbor Marina and Golf Resort Page 4-10 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) 4.1.8 Archeological and Cultural Resources The Master Planned site has been examined for archeological and cultural resources, and no significant resources were found. The creation of 24 home sites and a small golf course will cover much of the same area, so project-level observations will be maintained during construction, but the likelihood of significant adverse impact is considered remote. No specific mitigation requirements would be required other than notification of appropriate offices should any new evidence be identified during construction. Such condition would be imposed during the plat approval phase for any no action proposal. 4.1.9 Critical Areas 4.1.9.1 Wetlands The development of a PRRD subdivision with shoreline lots and an internal golf course allows the development to retain the existing wetlands and buffers on the MPR site following the priority preference to avoid impacts to wetlands, rather than modification and mitigation which is required by the resort-based alternatives. No wetlands were identified on the marina, Tudor, or Jupiter sites. Stormwater control plans would assure protection of a buffer and water regime to maintain functions and values. Restoration would be possible through removal of invasive weeds and a weed protection program. 4.1.9.2 Aquifer protection The residential and septic use are permitted uses under the no action alternative in areas designed to serve as groundwater recharge areas and compliance with local health rules about setbacks from wellheads should be sufficient to avoid any material impacts. The stormwater and critical area rules will provide some protection for the small intermittent streams on the marina side, but additional capture and treatment facilities are required to avoid the direct runoff of untreated storm water that is now occurring. Such upgrades to stormwater control would be piecemeal, added in concert with the development or redevelopment of each site. This is considered a disadvantage over the proposal, which provides a comprehensive treatment, but over time the sites would be required to meet current stormwater requirements as properties develop or redevelop. No additional area-wide mitigation would be available where the property builds out on individual lots, unless the County elects to install public facilities. 4.1.9.3 Steep slopes New homes on the south shore would need to be set back the minimum distance to assure safe construction under the County geologic hazard regulations. On the marina side, existing lots may be developed, even where steep lots exist, where engineering reports demonstrate safety. No significant adverse impact is expected. The Tudor and Jupiter sites can be developed without material steep slope issues, but would be required to comply where slopes do exist. 4.1.9.4 Fish and wildlife habitat This has been addressed above. 4.1.9.5 Flood hazard Not present. 4.1.10 Community Impacts Under this Alternative, the local economy would continue its current trends of modest growth from tourism as the Puget Sound region as a whole grows. A variety of new businesses are allowed such as home businesses, cottage industries, and small-scale tourist recreation uses under the existing UDC. DESCRIPTION OF ALTERNATIVES REVIEWED AND IMPACTS CHAPTER 4 Pleasant Harbor Marina and Golf Resort Page 4-11 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) New business development would respond to resident town growth. The area would require substantially less in the way of public services and facilities, but would be more dependent upon residential property taxes due to the absence of a commercial tax base. 4.1.11 Summary of Impacts and Mitigation Issues under the No Action Alternative 1. The plat for the golf course side will require a native vegetation setback from the steep bluffs, a setback into the reserve area for septic tanks, a construction and operation plan for the trail to the south shore to protect shellfish beds, and approval of new water rights for the golf course. 2. The Maritime Village area will be required to upgrade stormwater control facilities as new development occurs, and to site structures consistent with the shorelines and steep slope setbacks. On-site wells would serve new uses, but septic facilities would have to be located off site, away from the shoreline to protect water quality in the harbor. Building permits and shoreline permits will provide adequate controls for the piecemeal development under the no action alternative. 3. The Jupiter and Tudor sites will be required to secure access permits for US HWY 101 to serve the new development and new water rights secured for commercial uses. DESCRIPTION OF ALTERNATIVES REVIEWED AND IMPACTS CHAPTER 4 Pleasant Harbor Marina and Golf Resort Page 4-12 November 27, 2007 4.2 Brinnon Subarea Plan Alternative The Brinnon Subarea Plan (BSAP) Alternative (Figure 4-6) includes the entirety of the area identified in the Brinnon Subarea plan as potentially suitable for a Master Planned Resort. Figure 4-6 BSAP Alternative from Subarea Plan The area in question is 310 acres in size and would also include the RV campground properties, the existing Pleasant Harbor Marina complex and marina to the north, and the Tudor and Jupiter properties west of US HWY 101 parcels opposite and immediately south of the Black Point Road intersection. FINAL EIS - (Site Specific Amendment MLA 06-87) DESCRIPTION OF ALTERNATIVES REVIEWED AND IMPACTS CHAPTER 4 Pleasant Harbor Marina and Golf Resort Page 4-13 November 27, 2007 Figure 4-7 BSAP Alternative – 18-Hole Golf Course and 24 Homes This alternative assumes that all ownerships agree to participate in a Master Planned Resort program, and thus have the properties limited to the uses permissible under the Master Planned Resort provisions of the GMA and the County regulations. In many ways the Brinnon Subarea development would resemble the current proposal as the marina and resort would be upgraded and served by sewer and a central water system. The biggest change FINAL EIS - (Site Specific Amendment MLA 06-87) DESCRIPTION OF ALTERNATIVES REVIEWED AND IMPACTS CHAPTER 4 Pleasant Harbor Marina and Golf Resort Page 4-14 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) would be on those properties outside of the present proposal, which could build out at urban resort densities and not be limited to rural-scale development identified in the no action and hybrid alternatives. For comparison purposes, the resort area has been reconfigured to a hotel-centered resort with density and intensity appropriate to the size and topography of the site. The marina expansion at Pleasant Harbor mirrors the expansion planned in the Master Planned Resort, as the site is very confining and few alternatives are available. Similarly, the marina to the north is constrained and little additional development is anticipated. The most significant change would be that both would move from wells and individual septic tanks to central water and sewer facilities, and on-site stormwater treatment and disposal would be substantially upgraded over the current conditions. Another change would be in the allowance of urban uses west of US HWY 101 on the Tudor and Jupiter properties (approximately 24 acres). Here the provision of sewer and water allows resort-level intensity of development and the provision of sewer and water, but also limits all uses to those appropriately serving the resort and its customers. The specifics area as follows: • Development of an 18-hole golf course, with an associated clubhouse and pro shop. The layout would be substantially similar to that of the Master Plan proposal due to topographic and critical area limits. • Construction of a 200-room hotel that would include a conference center, health/athletic facilities, restaurant and gallery. This facility would be located in approximately the same area as the central facility in the Master Plan proposal due to access and topographic concerns. • Six bed and breakfast units at the waterside lots. • Construction of 25 single-family and duplex units on 15 lots along the southern shore, which are the premium lots and would be used for the seasonal residents. • The marina complex would be remodeled to approximately 7,000 square feet of small retail spaces, with 20 hotel units above the retail, and the existing B&B would be retained and expanded to provide a more intimate inn-type setting for small groups. • The existing real estate office area would be developed into a 2,500 square foot gift shop and office and tour center, which would be the hub for local tours and third party vendors. • The parcel to the west across from the US HWY 101/Black Point Road intersection would be integrated into the Master Planned Resort and provide a resort village and the commercial center of the resort, including: • 20,000 square foot village center building (on the Tudor property) with restaurant, grocery, convenience, and gifts, as well as resort management and real estate sales office. • A 20-unit Inn on the highest point, providing views over the entire complex and a degree of privacy for smaller groups, 20 town houses near the village center, and a village gas and service facility (on the Jupiter site). • The 30 acre WDFW site would be included, with modest upgrades to the existing boat launch. Any proposed MPR would have to respond to the same site constraints and opportunities (e.g. topography, land forms), so it is expected that the design and layout of the golf course would be relatively similar to the Statesman proposal. Access to the golf course portion of the MPR would also necessarily be located in the northeast corner of the site, where it abuts Black Point Road. DESCRIPTION OF ALTERNATIVES REVIEWED AND IMPACTS CHAPTER 4 Pleasant Harbor Marina and Golf Resort Page 4-15 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) Elements in common with the Master Plan proposal: • Water quality and protection of Hood Canal would be of the highest priority. • Protection of the traveling public and safety on US HWY 101 will be of the highest priority. • A public water system and public sewer system with Class A recycled water system for irrigation would be required with no off-site discharge. (This is a requirement of the Brinnon Subarea Plan, which provides a Master Planned Resort is appropriate with an on-site system.) • Stormwater would need to be retained, treated to Puget Sound water quality standards (2005 Manual) and infiltrated on site to avoid offsite discharges. • Water rights would have to be secured, though the quantity would increase due to the increased urban service area and uses. • Traffic would require a controlled intersection or grade separation at US HWY 101. With the additional uses on both sides of the highway, increased right of way width and controls would be required to provide both pedestrian and vehicle safety. • The Pleasant Harbor Marina would build out on sewer and water. Marina activities would be within the framework of current approvals, but the facilities would be significantly upgraded to eliminate the Tunicate infestation and to improve storm water controls. Elements different from the Master Plan proposal: • Sewer and water service could be extended to the marina facility to the north and to the Tudor and Jupiter sites to the west, enabling urban levels of intensity, not rural as would exist under the no action, Master Plan/Hybrid proposal, where such lands are excluded from the urban services available inside the approved resort Master Plan. • The overall population, traffic, and intensity of development would be increased by the development of the resort village west of US HWY 101. Such facilities make the resort more self sustaining (that is, services and supplies may be obtained in the resort rather than in Brinnon), which may reduce some traffic trips, but may also divert tourist dollars from Brinnon to the resort. • The full build out model in the BSAP proposal takes advantage of the waterfront lots potentially available along the Canal shoreline for the seasonal tourist, and would require special attention to protect water quality in the Canal. Where the Tudor and Jupiter properties are included in the Master Planned Resort, the intensity west of US HWY 101 takes on a distinctly urban feel as the area becomes the commercial village center. A detail of the development which could occur under such model is shown in Figure 4-8. The specific elements of the scoping notice can be reviewed, then, in the context of the differences between the Brinnon Subarea Plan under review and the Master Plan alternative. 4.2.1 Shellfish The BSAP alternative within the Master Plan alternative would have substantially the same foot print as the Master Plan proposal and would be subject to the same conditions to eliminate off-site discharge and protect shellfish. The biggest difference would be the addition of housing along the southern shoreline. The use of this area as increased density and impervious surface would require plat and shoreline conditions to control storm water, including a 100-foot setback from the top of the bluff for any structure, and a 50-foot native vegetation strip to control stormwater discharge. The additional density west of US HWY 101 will significantly increase impervious surface and sewer and water use, but as long as all stormwater is infiltrated onsite and all waste water is treated to Class A recycled standards, no additional impact from the physical development is anticipated on shellfish. DESCRIPTION OF ALTERNATIVES REVIEWED AND IMPACTS CHAPTER 4 Pleasant Harbor Marina and Golf Resort Page 4-16 November 27, 2007 Figure 4-8 BSAP Alternative – West of US HWY 101 Construction period impacts, including cuts and fills and grading, would mirror the Master Plan proposal east of US HWY 101, and would be increased west of US HWY 101. The additional grading west of US HWY 101 is not anticipated to be material as most of the area has previously been logged and stormwater can be controlled prior to crossing US HWY 101 to provide protection to the waters of the harbor and Hood Canal. The increase in impervious surfaces and potential for increased storm water runoff will require that all stormwater from the new development be treated so no contaminated or turbid stormwater from the Hybrid areas enter the storm discharge ditches crossing the highway and entering the harbor. The best way to achieve this result is to require all stormwater within the BSAP alternative to be infiltrated onsite and eliminate off-site discharges, except the marina, where treatment is required before discharge. The mitigating conditions would be the same as the proposal, but the scope of coverage would be the FINAL EIS - (Site Specific Amendment MLA 06-87) DESCRIPTION OF ALTERNATIVES REVIEWED AND IMPACTS CHAPTER 4 Pleasant Harbor Marina and Golf Resort Page 4-17 November 27, 2007 full 310-acre site. These conditions will be enforced at the time of BSAP area development through plat or site plan review controls. 4.2.2 Water The BSAP area would be under the water system and sewer system limits of the Master Plan. Water rights would be a limiting factor as the addition of a restaurant and shops and would increase the overall water demand. Here again, as with the Master Plan alternative, the total water demand would be reduced by the use of a reuse recycling wastewater treatment facility, and the adaptation of rainwater harvesting techniques to limit total consumptive use to much less. According to the hydrogeology reports, the ground water in the area could accommodate the use without affecting other senior rights, or creating the risk of groundwater intrusion. Both points would be required to be demonstrated during the plat approval for any phase of the Brinnon Subarea Plan. The BSAP alternative provides the benefit of creating well locations farther upland than the Master Plan alternative if appropriate well locations can be sited west of US HWY 101 and such action would reduce any limited risk of salt water intrusion as a result of the increased water demand of the larger BSAP model. See Table 2 of Water Supply and Groundwater Impact Analysis at Appendix 5. 4.2.3 Transportation The biggest impact of extending the resort both north to the northerly marina and westerly across US HWY 101 is a significant increase in local traffic at the Black Point intersection. US HWY 101 access points will have to be limited to a single access point for the westerly properties at Black Point Road and speed and turning controls instituted to assure that the overall LOS of "C" is retained, as is adequate sight distance and queuing room. Provision must also be made for pedestrian crossing and to accommodate both crossing and through non motorized traffic (particularly bicycles). The configuration of US HWY 101 at this location, together with the inability to install a signal at this location, suggests that the only way to accommodate traffic successfully would be to prohibit a crossing movement and use an overpass to achieve east side west side connectivity. The traffic report shows the BSAP proposal as an overall matter can be accommodated by the existing roads and highways without the need for significant off-site changes. Table 4-2 Brinnon Subarea Plan Alternative: Trip Generation LOS comparison is at Table 3-9. 4.2.4 Public Services The BSAP alternative would decrease the overall population at the resort and increase the commercial service areas by about 100%, adding proportionally to the EMS, fire service, public health and safety demands, but not significantly different for schools and other services. Adequate potable water and fire flow will be required for all of the new structures and the Memorandum of Understanding (MOU) process identified for the Master Plan proposal would be in place to address the size and frequency of FINAL EIS - (Site Specific Amendment MLA 06-87) DESCRIPTION OF ALTERNATIVES REVIEWED AND IMPACTS CHAPTER 4 Pleasant Harbor Marina and Golf Resort Page 4-18 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) public service needs and would have to be approved prior to preliminary plat approval. The differences in the level of activity required are viewed as differences due to increased demand, but not different in kind from the Master Plan program, and the MOU process is an appropriate means of addressing specific mitigation requirements in view of specific plans proposed consistent with the Master Plan. 4.2.5 Shorelines The BSAP development looks to increased development on the west side of US HWY 101 and as such, with the stormwater, well, and sewer controls discussed above no significant adverse impact to the shorelines are anticipated. Both marinas would operate within previously approved permit levels and as such no material impact would be expected over the Master Plan proposal. Incremental use of the shoreline would be promoted by the introduction of additional residential units along the southern shoreline, which would be similar to the residential uses in the hybrid alternative and would require similar conditions. Access to the beach areas would be increased, which is a Shoreline priority, but careful controls would have to be imposed through the shoreline process to assure that water quality would be protected. The harbor shorelines would be subject to development very similar to the Master Plan proposal and no material differences, or different conditions would be anticipated. 4.2.6 Fish and Wildlife Fisheries-related issues are protected by the requirement to maintain and protect water quality through managed stormwater, water system, and sewer system developments that eliminate off-site discharge of water on the site. Much of the BSAP area has already been logged, cleared, and otherwise used for tourist and public use activities. As with the Master Plan proposal, the site has occasional use by local wildlife. Further, the proximity to US HWY 101 makes the site a hazard for wildlife crossing, so development that discourages wildlife in this particular area (with a busy intersection) would not have a material impact on wildlife migration or habitat areas. As with the Master Plan program/Hybrid alternative, the Tudor/Jupiter property development west of US HWY 101 would be required to provide buffer and screening from excess noise and light to adjoining undeveloped areas and would need to create and enforce a waste and garbage disposal program reflecting the fact that bears are found in the area. Such conditions would be imposed at the plat, binding site plan, and conditional use permit review period. 4.2.7 Rural Character/Population The Pleasant Harbor Master Planned Resort provides the basic economic boost to the community anticipated in the comprehensive plan and discussed in more detail in conjunction with the proposal. The BSAP alternative provides a different employment and revenue boost to the community, with substantially less resort development and the shift of commercial sales from Brinnon to the resort village center. The BSAP model would provide an employment base to serve the resort village similar to the proposed alternative, but here again, the increase in employment onsite would be offset by a reduction of employment in the facilities which would otherwise serve the project in the RVC and overall no significant net increase in overall population would be anticipated. The principal difference between the proposal and the BSAP model is that the proposal is financed by owners who purchase units and have them managed in a resort pool. The BSAP is dependent upon a single owner manager with a much smaller residential base to support the facility. Such facilities are much more susceptible to market swings and thus less likely to be funded in the first place and more likely to be closed in a significant economic downturn than one which has multiple owners in more than 800 units. DESCRIPTION OF ALTERNATIVES REVIEWED AND IMPACTS CHAPTER 4 Pleasant Harbor Marina and Golf Resort Page 4-19 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) 4.2.8 Archeological and Cultural Resources The BSAP sites added to the Master Plan would have to be examined as a prerequisite to building, but as no significant resources were found on the Master Planned Resort site, no change to cultural resources is expected under the BSAP proposal. 4.2.9 Critical Areas 4.2.9.1 Wetlands No wetlands are identified on the west side of US HWY 101 and thus no wetland impacts are expected. The golf course for the BSAP alternative will skirt the wetlands on the east side of US HWY 101 and the topography of the site, together with the need for a major pond to retain storm and recycled waters, mean that the conversion of one of the kettles to the waste water management and irrigation systems would likewise be required. As such, the wetlands impacts would be the same and similar mitigation requirements to replace lost wetlands and buffers would be imposed. Under County rules one difference is that the BSAP proposal which includes development of the south shore as a residential area, would not be able to create the larger patch buffer proposed for the Master Plan and would rely more on linear wetlands and buffers. A detailed wetland mitigation plan to identify specific impacts to wetlands and a demonstration that wetland and buffer replacement under County guidelines are feasible would be a requirement of preliminary plat approval. 4.2.9.2 Aquifer protection The addition of the west side properties allows the potential for wells to be located even farther from the water than those in the Master Plan proposal, increasing the ability to pump the aquifer without creating any risk of sea water intrusion. The golf course management under King County rules recognized by the County, or substantially equivalent, will also reduce the likelihood of ground water contamination and would be substantially similar to the Master Plan proposal. The elimination of septic tanks for the marina to the north, and for the Tudor and Jupiter properties, would have the benefit of eliminating septic facility impact to the aquifer, harbor, and canal. Such use would be beneficial to the marina, but of limited benefit to the Tudor and Jupiter properties, which are already substantially removed from the water’s edge. No material impact to the aquifer different from that of the Master Plan proposed is anticipated for aquifer protection. 4.2.9.3 Steep slopes The development of the south shore for residential purposes will require steep slope limitations on any development to protect the bluffs and public safety. The BSAP would recommend a building setback from steep slopes of 100 feet (closer than the Hybrid alternative due to the additional activity on the site) and the same native vegetation strip to control drainage. For the balance of the BSAP property, the County steep slope buffers would control development, whether under Master Plan, no action BSAP, or Hybrid alternatives. The principal constraint is a requirement to set back from the top of banks, which can be accommodated under all of the alternatives, including the BSAP proposal. 4.2.9.4 Fish and wildlife habitat This has been addressed above. 4.2.9.5 Flood hazard Not present. DESCRIPTION OF ALTERNATIVES REVIEWED AND IMPACTS CHAPTER 4 Pleasant Harbor Marina and Golf Resort Page 4-20 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) 4.2.10 Summary of impacts and mitigation requirements under the BSAP Alternative • All of the conditions of the proposed Master Plan would be included. • Additional services from the increased tourist area would be addressed in the MOU program, which must be in place by the time of preliminary plat approval. • The area would benefit from the northern marina being added to the sewer service area, eliminating a commercial septic from the harbor area. Summary of different impacts: • The traffic impacts of the greater commercial development west of US HWY 101 will be substantially greater as additional right of way, pedestrian, and traffic safety improvements will be greater than the Master Plan proposal and would likely require overpass crossings for both pedestrians and vehicles, a significantly limiting factor. • The property value reduction and shift of commercial revenues from the Brinnon commercial area to the resort owners reduces the efforts to expand commercial activity in Brinnon. • Water use is likely to be no impact, as in the proposal, as rainwater harvesting/recycling can serve the facility on a zero net increase to the aquifer. • Critical area protection, habitat protection, shellfish protection, and cultural resources will remain the same as the proposal. 4.3 Hybrid Plan The Hybrid Alternative (Figure 4-9) is the proposal with the balance of the properties and particularly those west of US HWY 101 developing under the County RR1-5 guidelines. RR-1-5 guidelines are restrictive with one unit per five acre the base density for residential purposes with very limited business allowed and multifamily prohibited. The land west of US HWY 101 is in a series of ownerships and is compressed against US HWY 101 with limited access possibilities due to the need to align intersections with Black Point Road and the general limitation on state highway access. Assuming approximately 24 acres in size, the range of alternatives for the Hybrid development west of US HWY 101 would be as follows: Four residential units with accessory units available for rental, one or more of which could be a small bed and breakfast to serve the traveling public. The area could include a small tourist information center, which could include a small gift shop as accessory use. Lands located off the US HWY 101 frontage may be developed into a small RV park to accommodate the small number of RV users who still use the Black Point site and will be displaced by the resort, and the RV park could have a small restaurant/convenience center associated with the RV park and generally rural, recreational, and tourist uses. The hybrid alternative looks at the development of the area, including the Master Planned Resort, so the Master Planned Resort impacts and mitigation previously discussed would be part of the analysis. The incremental impact of the Hybrid alternative is discussed below. As the Hybrid alternative is not part of the Master Planned Resort, the utilities and facilities must be rural, not urban, in nature, and any such development would be on individual wells and septic tanks. DESCRIPTION OF ALTERNATIVES REVIEWED AND IMPACTS CHAPTER 4 Pleasant Harbor Marina and Golf Resort Page 4-21 November 27, 2007 Figure 4-9 Hybrid Alternative –West of US HWY 101 4.3.1 Shellfish The hybrid alternative would be west of US HWY 101 and therefore have no direct contact with the harbor or Hood Canal. Nevertheless, the increase in impervious surfaces and potential for increased stormwater runoff will require that all stormwater from the new development be treated so no contaminated or turbid stormwater from the hybrid areas enter the storm discharge ditches crossing the highway and entering the harbor. This condition will be enforced at the time of Hybrid area development through plat or site plan review controls. FINAL EIS - (Site Specific Amendment MLA 06-87) DESCRIPTION OF ALTERNATIVES REVIEWED AND IMPACTS CHAPTER 4 Pleasant Harbor Marina and Golf Resort Page 4-22 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) 4.3.2 Water Under the Hybrid program the Master Plan would operate as identified in Chapter 3. The Hybrid area is outside the Master Planned Resort and thus limited to 5,000 gallons per day for residential uses (per existing lot or project) or approximately 10,000 gallons per day with the Hybrid area developed by two separate owners. A small public water supply would be required to serve the RV park and any environmental review of the park requires the applicant to demonstrate (1) adequate water is in fact available from wells at the time of development and (2) that such withdrawal will not affect the aquifer or create a potential for salt water intrusion. (Environmental review at the time of plat or binding site plan and conditional use approval would require supplemental reports on both topics before development approval would be granted.) The Hybrid facilities would not have access to the MPR sewer system and would be limited to septic tanks under the control and standards of the County Health Department. The Hybrid areas are several hundred to 1,000 feet away from the shoreline and properly functioning septic systems should pose no material health or safety issues. As with the Statesman and BSAP alternatives, there is a negligible aquifer impact due to the Hybrid alternative. Once water harvesting rights are acquired, there will be a slight positive impact to the aquifer as it will receive greater recharge than under predevelopment conditions. See Table 2 of Water Supply and Groundwater Impact Analysis at Appendix 5. 4.3.3 Transportation The key transportation issue is US HWY 101, which carries high levels of traffic during the summer time, though well within the allowed “C” levels of service required for State highways. The key mitigation will be a controlled intersection with left turn and passing lanes at an intersection serving both the resort and the westerly development, with both sides then served by frontage roads or internal circulation. Implementation of this condition will be through plat, binding site plan, and conditional use controls at the time of development. Even with these controls, the inability to signal US HWY 101 at Black Point Road will be a limiting feature. A pedestrian overpass would likely be appropriate, reflecting the amount of non-motorized traffic anticipated between the west areas and the resort, and road access points carefully sited to avoid crossing movements and providing adequate queuing for turning movements. Traffic access may well be a limiting factor in the hybrid alternative unless an overpass is provided as with the BSAP alternative. With the hybrid model proposed, the LOS for key intersections still remains within acceptable levels, assuming the intersection issues at Black Point Road are properly addressed. DESCRIPTION OF ALTERNATIVES REVIEWED AND IMPACTS CHAPTER 4 Pleasant Harbor Marina and Golf Resort Page 4-23 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) Table 4-3 Hybrid Alternative: Trip Generation P.M. Peak Daily Land Use ITE Land Use Code Size Enter Exit Trips Trips Resort Rentals - ITE All Suites Hotel 311 154 28 34 62 800 Condominiums/Townhouses 230 216 76 37 113 1,200 Recreational Homes/Adult Community 260 420 45 64 109 1,300 Golf Course 430 123 4 8 12 200 Specialty Retail 824 16.5 18 26 45 700 Low-Rise Apartments 221 100 45 22 68 700 Conference Facility (Salish Lodge) n/a 250 25 35 60 400 Marina (existing vested use) 420 311 35 24 59 900 RV Park 416 50 13 6 19 200 Recreational Homes 260 4 0 1 1 10 Gas Station with Convenience Store 945 4 27 27 54 1,000 Less Pass-by Trips (56%) -15 -15 -30 -600 Gross Total Trip Generation 301 269 570 6,800 Less Internal Trips - Assume 20% Total -60 -54 -114 -1,400 Marina (Existing Uses)-25 -35 -60 -400 Net Project Trip Generation 216 180 396 5,000 LOS comparison is at Table 3-9. 4.3.4 Public Services The public service demands of the Hybrid alternative would add additional tourist facilities to the community, which imposes police, EMS, and fire service demands, but not significantly different than the facilities presently in place in the Brinnon area being displaced by the Master Planned Resort. Adequate potable water and fire flow will be required for all of the new structures. Binding site plan conditions would identify the full scope of necessary services, but the increased demand is well within the planned development for the area and poses no new or unanticipated demands on the County system. The MOU approach used by the proposal to address public service demands is suggested for the hybrid approach as specific public service demands are very program dependent. The MOU provides a regulatory tool to assure that mitigation is appropriate and proportionate to the new demands created by the hybrid options. 4.3.5 Shorelines The Hybrid development looks to development on the west side of US HWY 101 and thus, with the stormwater, well, and septic controls discussed above, no significant adverse impact to the shorelines are anticipated. Incremental use of the shoreline would be promoted by the Hybrid alternative, but the additional use brought to the area by a 50-unit RV park is not considered material in light of the number of camping spaces already in the area through both the state park and national park system. 4.3.6 Fish and Wildlife The Hybrid area is characterized by some clearing and logging with patches of trees. No critical areas were identified from review of air photos. (See Figure 4-9.) The Tudor site does have trees onsite that provide habitat for common species (deer and birds). The sites are sandwiched between Mt. Jupiter Road and US HWY 101 and as such are not considered DESCRIPTION OF ALTERNATIVES REVIEWED AND IMPACTS CHAPTER 4 Pleasant Harbor Marina and Golf Resort Page 4-24 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) prime habitat. Development of the Hybrid alternative would reduce tree cover and would introduce activity for the RV park and commercial center. Site-specific wildlife assessment would be required, but the site does have the ability to buffer surrounding lands and topography creates a physical separation for activity on the lower shelf on the Tudor property from the less developed areas to the west. The Jupiter site is substantially cleared and little additional impact is expected. Much of the Hybrid area has already been logged and cleared on site. Further, the proximity to US HWY 101 makes the site a hazard should wildlife populate the area, so development that discourages wildlife in this particular area (with a busy intersection) would be a general benefit, rather than detriment. The RV park needs to provide buffer and screening from excess noise and light to adjoining undeveloped areas and needs to create and enforce a waste and garbage disposal program reflecting the fact that bears are found in the area. Such conditions would be imposed at the plat, binding site plan, and conditional use permit review period. 4.3.7 Rural Character/Population The Pleasant Harbor Master Planned Resort provides the basic economic boost to the community anticipated in the comprehensive plan and discussed in more detail in conjunction with the proposal. The Hybrid, non-resort rural development expected to develop in concert with the resort, but under rural rules, provides an incremental employment and revenue boost to the community, but at a very small scale (less than a dozen employees likely). 4.3.8 Archeological and Cultural Resources The Hybrid sites would have to be examined and as no significant resources were found on the Master Planned Resort site, no change to cultural resources is expected. 4.3.9 Critical Areas 4.3.9.1 Wetlands No wetlands are identified on the Hybrid side of US HWY 101 and thus no wetland impacts are expected. 4.3.9.2 Aquifer protection The residential and septic uses are permitted uses in areas designed to serve as groundwater recharge areas and compliance with local health rules about setbacks from wellheads should be sufficient to avoid any material impacts. The stormwater and critical area rules will provide some protection for the small intermittent streams on the marina side, but additional capture and treatment facilities are required to avoid the direct runoff of untreated storm water that is now occurring. 4.3.9.3 Steep slopes Access in the northern Hybrid area is affected by steep slopes (see Figure 4-5), but access and the frontage roads may be designed to avoid the steep slopes and achieve the necessary protection required by the critical area ordinance. These conditions would be imposed at plat, site plan review, and conditional use permit proceedings. 4.3.9.4 Fish and wildlife habitat This has been addressed above. 4.3.9.5 Flood hazard Not present. DESCRIPTION OF ALTERNATIVES REVIEWED AND IMPACTS CHAPTER 4 Pleasant Harbor Marina and Golf Resort Page 4-25 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) 4.3.10 Summary of Impacts and Mitigation Requirements under the Hybrid Alternative • The area east of US HWY 101 is subject to all mitigation outlined in Chapter 3. • The uses west of US HWY 101 must be limited in scale to uses consistent with small-scale resort and tourist service use under the rural zones of the Jefferson County Code. • The uses west of US HWY 101 shall be limited to onsite well and wastewater disposal and may not hook to urban utilities from the Master Planned Resort. • All development west of US HWY 101 shall be subject to development conditions identified in an approved stormwater management plan, wastewater disposal plan (septic approval under Jefferson County Health Code), and Public Works Department standards for roads and road frontage improvements. • All traffic access to US HWY 101 shall be supported by a detailed traffic study and approval of WSDOT and Jefferson County Department of Public Works for motorized and nonmotorized transportation. 57577-0001/LEGAL13724210.1 DESCRIPTION OF ALTERNATIVES REVIEWED AND IMPACTS CHAPTER 4 Pleasant Harbor Marina and Golf Resort Page 4-26 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) FEIS MITIGATING CONDITIONS FOR SUBSEQUENT PROJECT REVIEW, TECHNICAL COMMENTS AND COMMENT LOG CHAPTER 5 Pleasant Harbor Marina and Golf Resort Page 5-1 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) CHAPTER 5—FEIS MITIGATING CONDITIONS FOR SUBSEQUENT PROJECT REVIEW, TECHNICAL COMMENTS, AND COMMENT LOG 5.1 Conditions for Permit Approval in Any Phase of the Approved Proposed MPR The mitigation requirements of the FEIS are set forth below and shall be subject to review and approval as appropriate at all project permit phases. Shellfish. DEIS Section 3.2, pp. 3-2 – 3-11 Water Quality Mitigation, for Shellfish, as specified in DEIS at Section 3.2.7 • During construction (all permits). o Construction period NPDES general permits will need to be obtained from WDOE and conditions followed to control stormwater during construction to assure no offsite discharge. o All construction shall be covered by a stormwater management plan from Jefferson County to show how stormwater shall be collected and infiltrated to prevent any turbidity, sediment, or other contaminants from reaching the harbor or waters of Hood Canal. o All stormwater crossing newly constructed surfaces shall be captured and treated onsite before discharge, including the golf course side, where irrigation and stormwater shall be captured treated, retained, and infiltrated onsite with no offsite discharge. o A stormwater site plan that includes a construction stormwater pollution prevention plan shall be developed by the proponent and reviewed and approved by Jefferson County prior to conducting land disturbing activity on the site. • During operation (Maritime Village permits) o All stormwater from impervious surfaces shall be captured and treated to Puget Sound Water Quality standards (2005 edition) before discharge. o There shall be no discharge of sewage or contaminated bilge waters at the marina. Pump out facilities shall be provided and operational at all times. o Cleaning of fish or sea life shall be prohibited within the controlled access areas of the marina. o The Project permits shall incorporate shellfish protection district guidelines. o The marina shall contract for the right to inspect any vessel that in the opinion of management may jeopardize water quality. o The marina shall develop and manage an active boater education program appropriate to the marina setting to supplement the County program developed as part of the shellfish protection district. FEIS MITIGATING CONDITIONS FOR SUBSEQUENT PROJECT REVIEW, TECHNICAL COMMENTS AND COMMENT LOG CHAPTER 5 Pleasant Harbor Marina and Golf Resort Page 5-2 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) o All fueling operations shall be brought up to current codes and protection against leaks, and unauthorized discharges shall be provided as part of any permit issued for work on the marina side of the resort. This is a first priority for the project. Fueling permits for facilities shall also require a refueling plan approved by the local Fire Code official as part of the first permit and in place prior to the issuance of any certificate of occupancy for work at the marina or Maritime Village. o Fuel storage or transfer shall be prohibited on marina floats, docks, piers, and storage lockers. o Jefferson County will require a marina management program enforced by the operator that shall provide: o No storage shall be permitted on docks, including storage of oily rags, open paints, or other flammable or environmentally hazardous materials except emergency equipment as approved in the Emergency Service MOU. o Painting, scraping, and refinishing of boats shall be limited to minor repairs when in the water, which do not result in any discharge to the waters of the harbor. o Any minor repairs must employ a containment barrier that prevents debris from entering the marine waters. o Cleaning of fish or sea life shall be prohibited within the controlled access areas of the marina. o Notification and information about shellfish conditions, licenses, and limits will be available at the proposed development at specific locations, such as the marina, Maritime Village, and Conference Center. o The marina operations shall incorporate mitigation requirements appropriate under the County Shellfish Protection Plan, and shall integrate a boater education program into a marina public education plan, which shall be implemented and maintained for as long as the resort is in operation, as part of a resort habitat management plan. o The marina operations shall collect water quality data (from State sources as long as available or from approved testing plan should the state sources move or not accurately reflect Pleasant Harbor conditions), and shall be required to participate with the County Public Works Department in an adaptive management program to eliminate, minimize, and fully mitigate any changes arising from the resort and related Pleasant Harbor or Maritime Village. • During operation (Black Point Golf Course Lands) o Construction and grading permits shall require stormwater management plans to demonstrate no discharge to waters of Pleasant Harbor or Hood Canal of any contaminants, turbid waters, or sediments as a result of operations. o The stormwater management system for all phases shall capture, treat, and infiltrate or store for reuse all stormwater from impervious surfaces of the improved golf course areas. o The golf course shall be operated in accordance with the best practice standards of the King County golf course management guidelines, or substantial equivalent, including, but not limited to, American Golf Association standards. o The golf course/resort facilities will be required to participate in any adaptive management programs required by the County as a result of the water quality monitoring program described above and any changes caused by the resort operations. o A pet management plan shall be required to address pet waste issues. FEIS MITIGATING CONDITIONS FOR SUBSEQUENT PROJECT REVIEW, TECHNICAL COMMENTS AND COMMENT LOG CHAPTER 5 Pleasant Harbor Marina and Golf Resort Page 5-3 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) Additional Shellfish–related Conditions or Considerations Identified in DEIS: • The marina is permitted for 285 slips. • Existing Marina permit conditions and mitigations from Shoreline Substantial Development Permit SDP96-0009 are retained. §3.2.1.1 • Have spill prevention plans and spill containment facilities in place. §3.2.1.1 • Replace existing septic system for marina with a sewage treatment system that will provide irrigation water to golf course. §3.2.1.1 • Developer will work with State to facilitate and perform the work necessary to eradicate Tunicates where possible in the marina. §3.2.2 • Limit construction grading on the Marina side to new road alignment, development pads, and parking areas. §3.2.6 Additional Shellfish-related conditions Identified in Appendix 2 – Marina Impact Analysis: • There shall be no discharge of sewage in U.S. waters. Boat owners shall use holding tank pump out and potty-dump stations located at the marina. The marina shall have restroom and shower facilities on shore for marina residences. Water Resources (Use, Reuse, Management, Treatment, and Disposal). DEIS Section 3.3, pp. 3-11 – 3-33 Water Summary and Conditions, as specified in DEIS at Section 3.3.8 • Sewer service (onsite system) o Any project approval for the golf course area will require construction and operation permits for a wastewater treatment system for the project by WDOE and an operational plan in place as a condition of final plat approval and construction of any structures for occupancy or residency. o Any project approval for the Maritime Village remodel and upgrade shall include a demonstration that existing facilities can adequately serve the remodel areas. No additional residential units would be approved until the sewer system is installed and operating. • Water supply, groundwater, and rainwater harvesting o Any project approval for the resort shall contain a condition that the applicant demonstrates entitlement to sufficient water rights to serve the approved phase from WDOE (water rights, transfer, and/or rainwater harvesting rights and use conditions) prior to preliminary plat approval and construction of any facilities on the property. • Water quality o Stormwater management plans for clearing and grading and for construction and operation phases must be approved and systems in place prior to land disturbing activities to assure control of the stormwater as provided above. o The golf course project approval shall require the adoption of best management practices for the management of stormwater onsite and the reuse of water as irrigation water, with a condition that the system demonstrate no direct discharge to Hood Canal of any stormwater from impervious or golf course surfaces, and that the grass management program include specific BMPs to assure proper management of all elements of the golf course management system FEIS MITIGATING CONDITIONS FOR SUBSEQUENT PROJECT REVIEW, TECHNICAL COMMENTS AND COMMENT LOG CHAPTER 5 Pleasant Harbor Marina and Golf Resort Page 5-4 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) consistent with best available technology for management in aquifer sensitive areas or its substantial equivalent. o Approval of any permits for the marina redevelopment area shall be conditioned upon the approval of a stormwater management plan that intercepts and treats all stormwater from existing or new impervious surfaces to Puget Sound water quality management standards prior to discharge, and that the Maritime Village has a plan and facilities in place to deal with any upland upset that may threaten pollutant discharge to Pleasant Harbor. o The Project Engineer shall be responsible for ensuring that State and County stormwater management standards are met. Clearing, grading, implementation of the Construction Stormwater Pollution Prevention Plan, and construction of roads and stormwater management facilities shall be conducted under the supervision of the Project Engineer. The Project Engineer shall submit weekly reports to Jefferson County while construction is in progress. • Groundwater protection and saltwater intrusion o Preliminary plat approval for the golf course resort that requires water use in excess of current approved water rights. Preliminary plat approval shall require a hydrogeological report demonstrating that the additional water use does not pose a threat of saltwater intrusion to existing wells or sources of water supply. A hydrogeological report is required for each construction or development phase to demonstrate compliance with this condition. o Surface water and particularly irrigation water and potential migration to the harbor or Hood Canal were addressed in the section on water quality above. • Fire fighting flow o Adequate and sustainable fire flow will be provided by the Class A water system. The Class A water system will provide this level of service at all times. Additional Water Resources–related Conditions or Considerations Identified in DEIS: • Construction site stormwater runoff for the project is to be regulated at the state level by WDOE through the 2005 Stormwater Management Manual for Western Washington and at the local level by the Jefferson County Stormwater Management Plan. §3.3.7 • A Construction General Stormwater Permit is required for all development activities where more than one acre will be disturbed and stormwater will be discharged to surface water or to storm drains that discharge to surface water. • The project will require a construction Stormwater Pollution Prevention Plan (SWPPP). §3.3.7 • Low Impact Development – all water on the site will be collected and either used appropriately onsite, routed to the storage ponds, or infiltrated to the groundwater aquifer – a zero discharge criterion, except at the Maritime Village where zero discharge cannot be achieved because of topography. §3.3.7 Additional Water-Resources-related Conditions or Considerations Identified in Appendix 5 – Water Supply and Groundwater Impact Analysis: • The project will develop susceptibility ratings for the site and develop adaptive management procedures to maintain groundwater quality and quantity. • Groundwater and water quality monitoring will be performed at monitoring wells installed along the bluff and interior of the project site. FEIS MITIGATING CONDITIONS FOR SUBSEQUENT PROJECT REVIEW, TECHNICAL COMMENTS AND COMMENT LOG CHAPTER 5 Pleasant Harbor Marina and Golf Resort Page 5-5 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) Transportation. DEIS Section 3.4, pp. 3-34 – 3-49 Mitigation Measures Transportation Summary, as specified in DEIS at Section 3.4.4 • The following traffic mitigation measures will be required as part of a preliminary plat approval for each project phase. o Fully fund and construct associated improvements for Black Point Road to meet County standards from US HWY 101 to the project entrance. o Provide adequate sight distance to the east of the proposed main site driveways onto Black Point Road and the egress from Maritime Village onto US HWY 101 to improve and maximize entering and exit sight distance. o At the US HWY 101 and Black Point Road intersection, provide a southbound left-turn lane as part of project development in all scenarios except the no action alternative. With the Statesman proposal, the expansion of the existing T-intersection would also provide for a median refuge area for left turns from Black Point Road onto US HWY 101. o Provide a northbound right-turn pocket or taper at US HWY 101 at the Black Point Road intersection under the Statesman proposal. o Residents of the Maritime Village shall be given access to the golf course resort without traveling US HWY 101. A detailed traffic design to accommodate traffic on US HWY 101 returning to the resort must be developed, with further traffic analysis and design approval by WDOT and Jefferson County. o Reconstruct the Black Point Road approach to US HWY 101 with adjacent left turning lanes, a widened approach onto US HWY 101, and an “entry treatment” on Black Point Road at US HWY 101. The proposed site access concept would also include a consolidated intersection onto Black Point Road with a realignment of the WDFW boat launch at Pleasant Harbor. o Provide all access roads and internal roads available for public use to County road standards. Private drives may be to a lesser standard approved by the Pubic Works Department and emergency service providers during the preliminary plat phase if desired by the applicant. o Provide an internal pathway and circulation system within the site that would not impact County or State highways, would provide for pedestrian and bicycle circulation between the two main development districts, and would allow US HWY 101 bicycle traffic bypass through the resort (i.e. Black Point properties and Maritime Village). • In addition, the preliminary plat approval for the golf course portion of the resort should evaluate trip management plans as an alternative to simple roadway expansion. Such plans may include: o Provide a van or small shuttle bus for guests and tenants to utilize on an as-needed basis for use in group trip making, coordinated events, airport shuttle, and other miscellaneous traffic. All such services shall be coordinated with Jefferson Transit to schedule expanded service as necessary to the resort as well as consider joint opportunities to provide layover or transit service and facilities within the site. FEIS MITIGATING CONDITIONS FOR SUBSEQUENT PROJECT REVIEW, TECHNICAL COMMENTS AND COMMENT LOG CHAPTER 5 Pleasant Harbor Marina and Golf Resort Page 5-6 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) Public Services (includes Fire, Police, Medical Emergency; Schools; Economy, Housing, Employment). DEIS Section 3.5, pp. 3-49 – 3-62 Fire Protection and Emergency Service Mitigation, as specified in DEIS at Section 3.5.1.5 Any preliminary plat for the development of a portion of the resort shall require the following: • Ensure the onsite water system will provide for adequate sustainable fire flow. • All resort buildings to include internal sprinkler systems with FDC connections. • Incorporate Firewise site design standards in the layout of the proposed resort, as appropriate and approved by the local fire authority. • All subsurface parking will have to provide fire systems, including air handling, water, and emergency access and egress. • Install hydrants, two portable fire pumps with hoses and related fire suppression equipment at the marina and maintenance area as approved by the local fire authority. • Develop an “emergency action plan” with the Fire District in conjunction with predevelopment, development, and operation to assure clear lines of responsibility and response in the event of any incident requiring emergency response. • Any development of the existing marina complex as part of an MPR shall include improving emergency vehicle access to this portion of the resort. • Through a memorandum of agreement with District #4, provide the equipment necessary to mount rescue and fire fighting operations on any structure over 18 feet from ground level, including but not limited to the Condo-tel/Conference Center Building. • Enter into an “action plan” with the local fire authority at District #4 to assure coordinated control of additional services necessary to achieve an adequate level of service to the resort. • Provide a back-up electrical power supply to the resort to ensure continued operation of emergency systems and water supply during any outage. • Comply with the provisions of a memorandum of agreement with local service providers to address service equipment and personnel needs created by the resort, taking into consideration increased tax revenues from the resort activity. • Enter into a memorandum of understanding with the local fire authority to address the following issues: o “Firewise” design standards o “Emergency action plan” for predevelopment and operational service for each phase of development o Provide necessary facilities to mount rescue and fire fighting operations in all phases of the resort o “Action plan” for coordinated control and additional services Security Services Mitigation, as specified in DEIS at Section 3.5.2.2 • Project Level: Permit approval for both the marina and the golf resort shall address security-related issues, and shall include specific mitigation which may include: o Controlled access at the entry and exit points of the resort and docks. FEIS MITIGATING CONDITIONS FOR SUBSEQUENT PROJECT REVIEW, TECHNICAL COMMENTS AND COMMENT LOG CHAPTER 5 Pleasant Harbor Marina and Golf Resort Page 5-7 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) o Onsite security and surveillance systems for the protection of resort guests, residents, and property coordinated with local service providers to assure appropriate communication and control systems are in place. • Community level: Explore the use of a development agreement or other assurance to provide a mechanism for the County to provide some public safety funding to the Brinnon area from the revenues received from the resort to assure that the funds will not be diverted to the more populous north county. Health Services Mitigation, as specified in DEIS at Section 3.5.3.1 • Project-specific mitigation shall be addressed in the public services memorandum of understanding (MOU), which shall address reasonable site needs and the means of providing and paying for services. The MOU shall be in place prior to issuance of building permits for development of resort facilities. School Mitigation, as specified in DEIS at Section 3.5.4 • Estimates for planning purposes are that the project will increase the Brinnon School District by 5-10 students and the adjacent district for high school by 1-2 students in any given year. Specific mitigation agreements with the School will be addressed as part of the preliminary plat process for the golf course. Economy/Employment, DEIS Section 3.5.5.1 The FEIS requires the project sponsor to work with the County to provide a job log or similar capability to enable local companies and personnel to compete for project jobs and services. Housing, DEIS Section 3.5.6 • Because there is a limited rental housing market, it is proposed that the out-of-town construction crews may use the existing onsite 60-unit RV facility. This facility would be temporary and must be in place prior to commencement of construction of the infrastructure for the project. (Additional temporary housing could also include the B&B and Kaufman Home, see §3.5.9.) • The creation of new permanent and seasonal jobs for resort staff will impose an added demand for affordable local housing, and to offset that demand, 52 units of new multi-family apartments are proposed to be built onsite. Shorelines. DEIS Section 3.6, pp. 3-63 – 3-65 Shoreline Mitigation, as specified at Section 3.6.7: • Public access to the southern shoreline should be curtailed and direct access eliminated. • All stormwater generated in the upland marina area shall be captured and treated to County standards before discharge to the aquifer. • All surface water on constructed surfaces in the golf course area shall be captured and treated for recycling or treated in accordance with adopted County stormwater manuals, and infiltrated on site. Zero discharge to Hood Canal from the developed golf course/resort area is required. Additional Shoreline Conditions or Considerations Identified in DEIS (see also the conditions related to Shorelines in Sections 3.2.1 and 3.2.2 for shellfish mitigation, Sections 3.3.7 and 3.3.8 for water resources mitigation, and Section 3.10 for critical areas): FEIS MITIGATING CONDITIONS FOR SUBSEQUENT PROJECT REVIEW, TECHNICAL COMMENTS AND COMMENT LOG CHAPTER 5 Pleasant Harbor Marina and Golf Resort Page 5-8 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) • In the golf course area, no structures or golf facilities are to be constructed in the shoreline area. §3.6.2 • Any site-specific issues for water features as part of a wetland mitigation plan shall be approved prior to construction. §3.6.2 • The dock replacement program is subject to project-specific review. §3.6.2 • The residential noise regulations at Chapter 173-60 WAC provide an accepted level of noise versus protection, which is adequate to regulate commercial activities adjacent to residential areas and should be incorporated into any shoreline permit. §3.6.6 Rural Character/Aesthetics, DEIS Section 3.5.7, pp. 3-60 – 3-62 Rural Character/Population, DEIS Section 3.8, pp. 3-66 – 3-67 Rural Character/Aesthetics Mitigation, as specified in DEIS Section 3.5.9: • The key to the provision is that the Master Planned Resort not lead to suburban or urban level development in the surrounding area and that result is achieved through several techniques: o The retention of rural area zoning on the lands outside of the Master Planned Resort. o The additional public services shall serve the urban levels of intensity within the Master Plan area, the RVC level services in the RVC area, and the rural development in the surrounding area, and allow extension of urban level sewer utilities only in the event of a health hazard. The purpose of the regulatory restriction is to prevent a fundamental change in the overall development patterns planned for the area. Increasing the quality or quantity of services in such area as a result of the development is one of the economic benefits. o A water facility may serve both urban and rural uses as a water system is preferable to individual exempt wells. The water system shall not be used to serve uses in the rural area in excess of that allowed by County codes for rural area development. o The number of proposed residential units shall be no greater than 890 units, including both the resort residences and staff/affordable housing. o The proposal shall maintain natural open spaces along the shoreline bluffs along site perimeters as is practical with golf course layout, between fairways, and the upper portion of the development. o The proposal shall ensure retention of selected stands of significant trees along the bluff of the golf course to reduce the visibility of the site from the south. o The proposal shall provide landscaping between US HWY 101 and the new access road proposed on the upland side of the Maritime Village. o With the exception of the Condo-tel/conference center, with terrace lofts and the Maritime Village, all structures shall be kept to a maximum of two stories in height from higher grade elevations. o The overall project approval shall address light and glare to reduce the projection of evening lights off the golf course and marina properties. (Reduction does not mean lights cannot be seen, but that through shielding and proper placement and orientation, the offsite impacts are minimized.) FEIS MITIGATING CONDITIONS FOR SUBSEQUENT PROJECT REVIEW, TECHNICAL COMMENTS AND COMMENT LOG CHAPTER 5 Pleasant Harbor Marina and Golf Resort Page 5-9 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) o The proposal shall provide construction period housing and housing specifically dedicated to staff and local service personnel to reduce the impact on local housing. Rural Character/Population Mitigation, as specified in DEIS Section 3.8: • The resort is proposed to have limited onsite retail capability, but is expected to bring additional small commercial and service businesses to Brinnon, subject to project-specific, site-specific environmental reviews and mitigation. Archeological and Cultural Resources, DEIS Section 3.9, p. 3-67 Archeological/Cultural Resource Mitigation, as specified in DEIS Section 3.9 • The southern shoreline abutting Hood Canal is a significant environmental and cultural area, and is proposed to be closed to resort use. References the Cultural Resource Assessment. • The project proponent shall work with the Tribes and County to provide onsite monitoring during all construction to assure identification and management of any cultural resources identified. Critical Areas (wetlands, aquifer recharge, fish/wildlife conservation, steep bluffs), DEIS Section 3.10, pp. 3-67 – 3-72 Critical areas are regulated by Jefferson County as overlay districts, see JCC Chapter 18.15 at Article VI., and are additionally regulated under the state’s Growth Management Act, RCW 36.70A.060. Wetland Mitigations, as specified in DEIS Section 3.10.6, pp. 3-71 – 3-72 • Wetlands shall be protected from development (except Wetland B, which will be used for reuse and recycling). A wetland and wetland buffer mitigation plan shall be developed which demonstrates, under best available science principles, that the wetland functions and values of the resort area have been maintained through a combination of retained, enhanced, and/or created wetlands and buffers. The plan shall demonstrate no net loss to overall wetland area function and value. • An approved preconstruction wetland mitigation plan must demonstrate that loss of wetland habitat is mitigated, including protection measures for water quality and quantity maintenance, and buffer protection. Such protection must be in place prior to commencement of any grading onsite. The wetland mitigation report for Wetland B shall be approved and demonstrate how the overall system will operate, both during construction and operation to assure overall no net loss of function and value for the resort area wetland system. • The stormwater management plan for construction shall require all wetland areas (existing and new) meet the no net loss test and are in place prior to any alteration of the central kettle wetland. Additional Wetland Conditions or Considerations, identified in DEIS at § 3.10.1, pp. 3-67 – 3-70. • Wetland protection and mitigation criteria are specifically set forth in the County Code [see JCC 18.15.325 – 18.15.500]. • Because the Proposal would include altering one of the wetland kettles (Wetland “B” as identified as a Category II in the Wetland Delineation) for use in the water treatment/ recycling program, other wetlands would need to be created, restored, and/or enhanced, per the requirements of JCC 18.15.350(2), Table 3-5: o It is possible that additional onsite wetlands could be created, using ecological considerations, as water features and incorporated into the golf course design. (To protect the aquifer, golf courses are required to use Best Management Practices under the King County Model [see JCC 18.15.255(4)].) Per JCC 18.15.350(2), Category II wetlands to be created or restored require a FEIS MITIGATING CONDITIONS FOR SUBSEQUENT PROJECT REVIEW, TECHNICAL COMMENTS AND COMMENT LOG CHAPTER 5 Pleasant Harbor Marina and Golf Resort Page 5-10 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) replacement ratio of 3:1 if forested and 2:1 if scrub-shrub or emergent. Any water features proposed to be incorporated into the golf course design must demonstrate that the feature replaces functions lost at the impact site. o The site has two previously-disturbed upland areas adjacent to wetlands, both located near the RV camp, wherein the wetland buffers could be enhanced. Per JCC 18.15.350(2), Category II enhancement ratios 1 : are 6:1 if forested and 4:1 if scrub-shrub or emergent. o Another approach could be offsite wetland creation, restoration, or enhancement. Such an offsite alternative would require the identification of a significant wetland in the area to be enhanced, creation of a wetland, or restoration of a wetland. • A wetland mitigation plan will be developed in conjunction with the detailed design phase of the project and will be required at the outset of the grading plan in advance of final plat approval and project development when details of the construction will be available. It is common that mitigation plans be implemented prior to the planned filling activity, such as that of Wetland “B”. Aquifer Recharge Area Conditions or Considerations Identified in DEIS Section 3.10.2, pp. 3-70 – 3- 71 • Aquifer protection and mitigation criteria are set forth in the County Code [see JCC 18.15.240 – 18.15.255]. • The Black Point property within the Proposal has been mapped as an aquifer protection district. Additionally, the water source for the Black Point residential area is ground water. To protect the aquifer, the Proposal will abide by the County regulations, which include: o Prohibition of certain uses involving hazardous materials as specified in JCC 18.15.250 (the fueling facility at the Marina is in an area that is not dependent upon a well for its water supply and no impact to potable water aquifer is anticipated); o Complying with the protection standards identified in JCC 18.15.255, including the use of King County standards for Best Management Practices for Golf Course Development and Operations, per JCC 18.15.255(4). Additional Aquifer-related conditions Identified in Appendix 5 – Water Supply and Groundwater Impact Analysis (at pp. 11 and 15): • The critical aquifer recharge areas would best be located on the eastern part of the point, and possibly areas north of the site. This is demonstrated by groundwater heads in the center of the site being lower than those on the margins. • Additional work will be performed to develop susceptibility ratings for the site. An Aquifer Recharge Area Report will be prepared to quantify aquifer recharge and susceptibility. Based on the results of these studies, Adaptive Management procedures will be developed for maintaining groundwater quality and quantity. 1 The chart in the DEIS has a typographical error: the forested wetland enhancement ratio is 6:1, not 4:1, for Wetland Categories II and III. Additionally, the Chart is entitled as “Table 3-11” and this is also incorrect – it should be “Table 3-5”; however the citation below the chart at the bottom of p. 3-69 does correctly cite to Table 3- 5. FEIS MITIGATING CONDITIONS FOR SUBSEQUENT PROJECT REVIEW, TECHNICAL COMMENTS AND COMMENT LOG CHAPTER 5 Pleasant Harbor Marina and Golf Resort Page 5-11 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) • Reduction of the amount of water used by water saving fixtures and through use of harvested water for residential purposes will ultimately result in recharging more water to the aquifer than is presently occurring. This benefit is due primarily to the decrease in evapotranspiration at the site, that there will be relatively few impervious surfaces on the site compared to the overall property; that the majority of recharge occurs during the fall, water, and spring, and about one-half of the site receives irrigation, and that the underlying aquifer is not a major source of water supply. Fish/Wildlife Conservation Areas Mitigation, as specified in DEIS Section 3.10.6, p. 3-72 • The three northerly streams shall be set aside in a natural area, and development shall be limited to that necessary to provide adequate access and road right-of-way. All culverts carrying streams shall be fish passable where the preconstruction reports identify that a stream has the potential for fish passage if obstructions can be removed. • The two southerly streams shall be protected during construction using best management practices, and road crossings shall comply with adopted standards. • The resort shall be required to annually collect water quality monitoring data from the state water quality sampling station at Pleasant Harbor and submit a summary water quality report to the County. In the event that water quality shows any sign of deterioration, the County shall consult with the resort, the local residents, and the State (both WDOH and WDFW) concerning the source of the change. The resort permits shall require the resort to implement any mitigation measures determined necessary by the County to alleviate any water quality issues emanating from the resort properties. Additional Fish/Wildlife Conservation Areas Conditions or Considerations Identified in DEIS § 3.10.3, p. 3-71 • Fish and Wildlife Habitat protection and mitigation criteria are set forth in the County Code [see JCC 18.15.285 – 18.15.320]. • The site contains several intermittent or seasonal stream channels (Type 5 under the County classification system). Some of these are steep in gradient and blocked from fish passage due to structural barriers. Per JCC 18.15.315, Type 5 streams require a 50-foot buffer of native vegetation. The Proposal will comply with this requirement. Additionally, the creation of a complete and modern treatment system for stormwater on the developed portion of the marina site should result in an improvement in water quality discharge. • A habitat management plan will be prepared at the project-permitting phase to identify and address mitigation for any potential impacts to streams and associated buffers. • The resort shall be required to annually collect water quality monitoring data from the state water quality sampling station at Pleasant Harbor and submit a summary water quality report to the County. In the event that water quality shows any sign of deterioration, the County shall consult with the resort, the local residents, and the State (both WDOH and WDFW) concerning the source of the change. The resort permits shall require the resort to implement any mitigation measures determined necessary by the County to alleviate any water quality issues emanating from the resort properties. Frequently Flooded Areas, DEIS Section 3.10.4, p. 3-71. There are no floodplains or frequently flooded areas onsite. FEIS MITIGATING CONDITIONS FOR SUBSEQUENT PROJECT REVIEW, TECHNICAL COMMENTS AND COMMENT LOG CHAPTER 5 Pleasant Harbor Marina and Golf Resort Page 5-12 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) Geologically Hazardous Areas Conditions or considerations Identified in DEIS § 3.10.5, p. 3-71 • Geologically Hazardous Areas protection and mitigation criteria are set forth in the County Code - see JCC 18.15.260 – 18.15.280. Per JCC 18.15.275(5)(e), the standard buffer from the top, toe, and all edges of a landslide hazard area is 30 feet. • The principal geologic hazard feature on the site is the steep bluffs along the southern shore. The Proposal will provide an extra margin of safety by maintaining a 200-foot vegetated edge from the southern shoreline. Further, the stormwater management plan shall require that all water from developed areas be captured in areas sufficiently removed from the bluff edge and are sized sufficiently to avoid discharge to or destabilization of the bluff in the event of wet seasons or upset. Additional Geologically-Hazardous Area-related conditions Identified in Appendix 4 – Soils and Geology (pp. 14-15): • Limit the extent and duration of site clearing, grading and disturbance of existing ground surface and natural vegetation. This will be accomplished by staging the construction work to accomplish full build out in separate construction phases over a number of years. • Establish development setbacks from the crest of steep slopes, especially the coastal bluff area. • Avoid introducing any additional uncontrolled surface water into documented landslide areas and other steep slopes in the project area. Stormwater and groundwater infiltration systems would be designed to reduce groundwater flows toward the shoreline bluffs to reduce landslide hazards. • Limit development on long, steep slopes, especially slopes underlain by soils prone to erosion. • Erect silt fences around disturbed areas to minimize migration of displaced soils into undisturbed vegetation and structures. • Avoid wet weather grubbing, stripping, and grading where possible. • Hydro-seed cut slopes and fill berms as soon as practical; on steeper slopes use mulch, jute matting or synthetic fabric to aid re-establishment of vegetation. • Cover any stockpiled soils with visqueen especially during wet weather. • Employ water trucks and/or sprinkler systems to minimize dust and wind erosion during dry weather. • Construct haul roads with quarry spalls, asphalt, or recycled concrete and/or suitable road bedding. • Control surface water runoff with ditches, detention ponds and check dams • Line drainage ditches grass and/or quarry spalls to limit water erosion • Protect permanent cut slopes with rockery walls, ecology blocks, and engineered retaining wall structures. FEIS MITIGATING CONDITIONS FOR SUBSEQUENT PROJECT REVIEW, TECHNICAL COMMENTS AND COMMENT LOG CHAPTER 5 Pleasant Harbor Marina and Golf Resort Page 5-13 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) 5.2 Technical Comments The following are comments from Statesman’s consultants responding to questions that have arisen during the public review process of the DEIS. 5.2.1 Precipitation 10/9/07 Memorandum from Scott Bender, Subsurface Group LLC, responding to questions about the source of weather and rainfall data. 5.2.2 Water Supply 10/24/07 Memorandum from Scott Bender, Subsurface Group LLC, responding to questions about water supply sources. 5.2.3 Wastewater 11/14/07 Note from Troy D. Vassos, Ph.D., P.Eng., NovaTec Consultants, Inc., responding to questions about the wastewater treatment and reuse process. 5.2.4 Wetlands/Habitat 11/15/07 Memorandum from Wayne S. Wright, PWS, GeoEngineers, responding to questions about impacts to wetlands, kettles, and fish/wildlife habitat. 5.2.5 Elk Herd Wayne Wright’s note summarizing his 11/9/07 conversation with Greg Shirato, WDFW regarding resident elk herd crossing Hwy. 101. FEIS MITIGATING CONDITIONS FOR SUBSEQUENT PROJECT REVIEW, TECHNICAL COMMENTS AND COMMENT LOG CHAPTER 5 Pleasant Harbor Marina and Golf Resort Page 5-22 November 27, 2007 FINAL EIS - (Site Specific Amendment MLA 06-87) 5.3 County Comments Received After the Issuance of the DEIS DEIS and project comments have been logged by the County. The log is attached. The responses to comments have been grouped in the chapters referenced in the row entitled response to comments. Letters or comments for which specific responses were addressed have been identified in the new sections and are indicated with an asterisk* to the left of the name on the log. Comments that were more general in nature or repeated concerns previously addressed are acknowledge and were considered in preparation of the Final EIS. Those comments are included in the log with areas of interest indicated. The comment authors may find the responses to their comments or concerns under each FEIS sections of Chapter 3 indicated in the log heading. 57577-0001/LEGAL13743019.3