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HomeMy WebLinkAbout032BMPR - SEIS — Draft Technical Reports — County Staff Comments — 9-22-2009 Draft Technical Reports — County Staff Comments (The comments below are in addition to the comments from other agencies supplied separately) Forestry Report — Resource Management Group Page 21 — "The system looked at the property from a forestry standpoint." We are concerned that the report evaluates the site as a working forest, or from a timber management perspective which it obviously is not suited for or currently used for. This point of view has skewed the report by shifting the value of the trees from one where the trees are important for "the screening of facilities and amenities..., the preservation of natural features, historic sites," and "be designed to blend with the natural setting and,... screen the development and its impacts from the adjacent rural areas (BoCC Ordinance 01-0128-08 #63 U)" to one where the importance is more as a "resource," i.e., timber. Page 22 — This inventory is helpful in understanding the different areas with varied levels of impact to the vegetation. An inventory such as this should be used to determine which areas are appropriate for development and where trees should be retained and protected. Page 33 — "the Black Point area is most likely too heavily impacted by existing development and the extensive presence of poor quality trees and invasive species to be able to be economically reestablished with a value in excess of the economic return available from more development focused target areas." The "economic return" being timber vs. resort development which again reinforces the idea that the trees real value is economic rather than functional. BoCC Ord. 01- 0128-08 states, "Evergreen trees and understory should remain as undisturbed as possible." The intent being on retention for screening, buffering and aesthetics rather than economic return. The report concludes with the idea of "complete restoration of the site (page 33)." In other words, it's better to clear the site and start over. I wonder if this is what the BoCC had in mind when they included those conditions in the ordinance. Their intent perhaps was not to remove the trees that are perfectly healthy, are mature enough to provide screening from adjacent uses, and maintain the value of the native environment and natural amenities. The recommendations starting on page 34 envision a retention plan to be developed which would evaluate, delineate and propose protective measures to retain "significant trees" and provide long term management and protection. This envisions much more work on the project level after approval of the SEIS which should be used to identify which trees are to be retained and what impact the loss of other trees will have on the environment — neither of which has been discussed in this report. The report reads like the authors were told what the objective was (clear the entire site for grading) and they had to find a way to justify that objective, instead of using the inventory to identify the best areas for tree retention which would thereby dictate where development would occur. Having said that, Staff understands the practical aspects of creating a clear level space to build a golf course and that it is easier to start from scratch than it is to try to design the golf course around saving a few trees. The ideal objective would be a balance between the two. BMPR - SEIS —Draft Technical Reports —County Staff Comments —9-22-2009 A basic environmental consideration that has not been address in either this report or any other relates to hydrology. In essence, what impact will the removal most of the trees have on the hydrology of the site? How will this alteration in hydrology affect stormwater runoff and treatment? These questions must be addressed in the SEIS. Prescriptive Vegetation Management Plan — Resource Management Group This report should be called a "Tree Hazard Management Report" since that's what it's really focused on and concludes that a "Vegetation Management Plan unique to Pleasant Harbor Master Planned Resort development site would help to enable achievement of Jefferson County Board of County Commissioners conditions of approval...." That is a reasonable conclusion, but it is not a vegetation management plan. Water Supply and Groundwater Impact Analysis Page 10 — typo — "The location of the section is shown is (on? — typo?) Figure I L" Page 13, last sentence — (UDC Section 3.6.5) should be JCC 18.22. 100 Article III Cultural Resource Assessment — Chambers, Schumacher, Gill & Hartmann Include this Mitigation Measure in the SEIS: Page ii — "WSHS recommends creating a construction buffer to protect this archaeological site that is located adjacent to the project area on Washington State lands to avoid any unnecessary disturbance. Page 1 — Introduction, 2"d PP — the County did not review the plan of field investigations. Page 4 —1St PP — "approximately 14000 —12000 BP (BC?) Typo? The Economic Benefit of Pleasant Harbor Marina and Golf Resort We question the figure of 3378.36 for the Male median annual income. It seems inconsistent with the figure for Female. Could this be 33378.36? Check this. Footnote on page one is different that the information following the """note * "note Page 3, 2"d PP — what is the $7 in income annually in relation to the 287 FTE jobs? Final Geotechnical Investigation — Subsurface Group LLC Page 16, 11.2.4 Cut Slopes — Temporary Shoring is section 11.3, not 10.5 2 BMPR - SEIS — Draft Technical Reports — County Staff Comments — 9-22-2009 Figures 3, 4 & 5 are missing from the Report. Grading and Drainage Report — Craig Peck Page 2-2 — "It can be expected that approximately XX acres or 80 (?) percent of land will be cleared and graded." We need a final approximate figure for the SEIS. Page 2-2, 1. B. last sentence — explain "the surface area of the reformed kettle would be approximately 50 percent of the area of the top of the current kettle." Page 2-6, middle of the page — (Note for Supplemental Environmental Impact Statement being prepared for the Pleasant Harbor Marina and Golf Resort -Vinnie) Need to address this. Page 2-8 — What about the Marina excavation? Where does that fit into the phasing plan? Page 3-13, 2nd PP — Please give a specific cite reference for the statement, "Preliminary results from those studies indicate that development will increase groundwater recharge by approximately 10 percent given the removal of vegetation...." Golf Course Development — GeoEngineers Page 3 & 4 — mitigation measures identified here should be included in the SEIS Is there a training program or plan for educating course personnel? Page 7, Application BMPs — what is a hooded boom and what does it look like? Page 8, Turf Management BMPs — Give an example of timing of application to minimize leaching and votalization, slow vs. quick release, etc. Page 8, Turf Management BMPs — three bullet points are duplicated here. Page 10, Cultural and Physical Controls - How do you remove dew on non -mowing days during disease -conducive periods? Page 12, IPM principals(ples) suggest keeping a record of the following items: - Delete the last sentence of the last bullet point. Garth would not be doing the application. Page A-1 — Add "Name of Applicator" to the log sheet Wastewater Reclamation — Rick Esvelt BMPR - SEIS — Draft Technical Reports — County Staff Comments — 9-22-2009 Page 13 A. — Third bullet point change info to into. Page 13 B. — Are grapes and orchards to be irrigated? Attachment C, page 1 D. — "parrellel"? Typo? Water Quality Monitoring Plan — Subsurface Group Page 2, 2nd PP — 802 seasonal and permanent seasonal residential dwellings? Shouldn't it be 890? Page 3, 3rd PP, last sentence — "is will be" Page 7, 2nd PP, 3rd sentence — Tables 3 and 5, should be 4 and 5. Last sentence — Table 5, should be 6. Page 8, 2nd PP, 3rd sentence — "approving" should be approved. Summary & General Comments We would like to see some best available science (affect on hydrology) explain, demonstrate and account for how much extra water will need to be treated and how it will be treated by the removal of trees and amount of cutting, filling, excavation and grading that is proposed (80 % of the site?). Compliance with the BoCC conditions of approval, although necessary, should not be the primary focus of the SEIS, but rather the identification and mitigation of probable significant adverse environmental impacts, and to inform the decision makers and public of reasonable alternatives (WAC197-11-400). We have observed a tendency by applicants who require an EIS to design a development first and then craft the EISs to fit the finished design as a reluctant afterthought. A better approach that would save time, money and build a more sustainable and higher quality development would be to use a conceptual design to outline the elements of the EIS which in turn would influence the final design of the development plan. This is an approach that is difficult for most conventional developers to understand, but is actually becoming more of a standard practice. In other words, you use the environmental analysis to help design the final product, instead of trying to justify it. The EIS is much more than just the sum of its technical reports, which are basically the raw scientific data and basic assumptions and conclusions that can be drawn from that data. There must be great care and skill taken to weave together the different environmental elements into a comprehensive whole that can be used to clearly define what the development will look like, 4 BMPR - SEIS — Draft Technical Reports — County Staff Comments — 9-22-2009 how it will react with and function within the environment, and what elements need mitigation and monitoring. David W. Johnson From: Neil Harrington Sent: Friday, July 17, 2009 5:07 PM To: Tami Pokorny; Susan Porto; David W. Johnson Subject: Black Point WQ Plan Attachments: JCPH Brinnon MPR comments v tsp.doc Hi David, Here are our (JCPH's) comments on the Black Point MPR water quality monitoring plan. Thanks! Neil Harrington Jefferson County Water Quality Program Manager (360) 385-9411 615 Sheridan St. Port Townsend WA 98368 Comments from JCPH on Water Quality Monitoring Plan Brinnon MPR dated August 2008: + Please provide a site plan that represents the areas of undisturbed vegetation for Black Point properties and Maritime Village, (28% and 73% respectively) + From Pg 2, paragraph under Fresh Water: will the storm water treatment system be sized to include the referenced runoff from Hwy 101? From Page 3, the second paragraph: the statement that the development is not expected to increase pollutants in the harbor or Hood Canal should be closely evaluated. We have concerns about the ability of the planned treatment systems for wastewater and stone water to protect surface waters from water quality impacts due to pesticides and herbicides. Also we are concerned about the emerging class of chemicals that include pharmaceuticals, personal care products and cleaning agents. There is no proposed baseline data that can make this statement accurate, lacking comprehensive pre development sampling. • Pg. 3, bullet 3: should include standards for not only Ecology but also Washington State Department of Health. + Pg. 3 bullet 5: notification should be to Jefferson County and the Department of Ecology. • In general, in the discussion regarding Methods, starting on pg 4, the base line data proposed do not seem adequate considering the remote locations in comparison to the project. We would recommend, again, that base line sampling be conducted pre development in the same locations as are proposed for during and after development thereby providing adequate comparison for change. ■ Additionally, no sampling is being proposed in marine shoreline areas other than the Marina. Given the utilization of the shoreline along the perimeter of Black Point by listed salmonid species, we are concerned about the influence of ground and surface water quality on that area. We would like to see base line data developed for both areas with on going monitoring to protect these species from any known water quality degradation resulting from the project. ■ Appendix A was not attached for review. ■ Why do some of the sampling parameters proposed differ from those that exist for the Dabob and Hamma Hamma datasets, ie: chlorophyll, fluorescence and light transmission. Pg. 6, Sampling procedures: this paragraph is vague. We would like to see a process that allows for any future sampling protocol to be approved by Jefferson County Water Quality Division prior to implementation. Pg. 9, Adaptive management: Water quality monitoring report should be submitted annually for review to Jefferson County. Based on analysis of results, comparison of existing data sources, and consultation with the other state agencies and the responsible party for the property, Jefferson County may initiate modifications. The monitoring plan must provide adequate protection over time, given the sensitive nature of the site and the acknowledged threatened status of the Hood Canal and its biota. The requirement for the monitoring plan shall be a recorded document to the property title, and run with the land. Requirement to implement the plan should be the sole responsibility of the land owner in perpetuity. SAr 5309 Shilshole Avenue NW www,adolfson.com ► i; Suite 200 Seattle, WA 98107 206.789.9658 phone 206.789.9684 fax memorandum date August 5, 2009 to David Wayne Johnson from Lloyd Skinner subject Pleasant Harbor Review of Draft Outline of EIS We received the draft outline of the Pleasant Harbor Marina and Golf Resort Master Planned Community Supplemental Environmental Impact Statement at the July 20 site meeting. The outline is very helpful in anticipating how the project impact analysis will be put together for County and public review. I have several comments and suggestions for the draft outline for the County's consideration. Treatment of each element of the environment. I see from the outline that each element of the environment is followed by an italicized comment referring to one or more Board of County Commissioners conditions. I recommend that the discussion of each element of the environment include a standard SEPA-style discussion of the site's existing conditions, a discussion of the probable impacts of each alternative, and a discussion of possible mitigation measures to address impacts identified. If the discussion then moves to an assessment of how the proposal complies with the relevant condition(s) adopted by the Board of County Commissioners, I think that would be fine. I would just caution that the outline as drafted implies that the discussion under each element of the environment would ONLY address compliance with the BoCC condition(s). In my mind, that would fall short of the complete discussion expected for a project -level EIS. Construction impacts. I do not see a reference in the outline to construction impacts. Construction impacts can be addressed within the discussion of each element of the environment (the impacts discussion is divided into "construction" and "operations" sections), or alternatively a separate Construction Impacts section is prepared for an EIS. For this large-scale construction project, the assessment of construction impacts will be an important consideration. Issues such as construction phasing, extent of disturbance by phase for staging, clearing, grading, and facility construction, and control of stormwater, traffic, and dust, for eample, should be addressed. It might make more sense for a construction project of this scale to include a separate construction impacts section. Description of the Proposal and Alternatives. The outline lays out the main sections of the EIS well. As a minor comment that does not relate to EIS adequacy, to reduce the number of sections in Part 2.0, Description of the Proposal and Alternatives, I suggest that we combine sections 2.2 through 2.6 (Location, History and Background, The MPR Proposal — Principal Features, Proposed Zoning Ordinance, and Proposed Development Agreement) into a single section, with these issues becoming sub -headings. Technical Reports. Peg Staeheli/SvR has prepared comments on four technical reports; these are attached to this memo. Bill PersichBrown and Caldwell has not yet completed his review of technical reports; I will forward his comments shortly. + DESIGN COMPANY MEMORANDUM #01 DATE: August 5, 2009 TO: Lloyd Skinner, AICP ESA Adolphson FROM: Peg Staeheli, ASLA Amalia Leighton, PE �u� p TO asa�tap 0 RE: Review of Technical Reports Prepared for SEIS Pleasant Harbor Master Planned Resort — Peer Review SvR Project No. 09025 This memorandum is to summarize our review of the following technical reports prepared for the Pleasant Harbor Master Planned Resort Supplemental Environmental Impact Statement (SEIS): 1. GRADING AND DRAINGE: Pleasant Harbor Marina and Golf Resort — Grading and Drainage Technical Engineering Report DRAFT, Prepared by Craig A. Peck & Associates, September 4, 2008 2. GOLF COURSE BMP: Draft Report Golf Course Development and Operation Best Management Practices Plan, Brinnon Master Planned Resort, Prepared by GeoEngineerings August 18, 2008 3. WATER QUALITY: Water Quality Monitoring Plan, Brinnon Master Planned Resort, Prepared by GeoEngineerings August 18, 2008 4. GROUNDWATER: Water Supply and Groundwater Impact Analysis — Draft Hydrologic Analysis, Pleasant Harbor Marina and Golf Resort, Prepared by Subsurface Group, LLC November 20, 2008 During the review of the documents provided project area limits and layouts were inconsistent. We recommend that when all draft reports are revised the same project limits and descriptions are provided with a reference date. These documents were reviewed to identify if information was provided to meet the items listed in the Jefferson County Board of County Commissioners Conditions to be Met and Civil Engineering Landscape Architecture documentation shown in the SEIS. SvR reviewed Section 3.3.1 Surface Water and 3.16.3 Environmental Restoration Stormwater Management. Planning • a — The Grading and Drainage report does not reference Jefferson County Code in the text, but it is apparent that preliminary designs use the 2005 1205 Second Avenue Department of Ecology Stormwater Manual for Western Washington. Suite 200 Stormwater runoff and treatment facility sizing calculations are included in the Seattle, WA 98101 appendix. Calculations were made using the required Western Washington Hydrology Model software. Phone: 206.223.0326 • g — It is unclear from the existing calculations if the development will be able Fax; 206.223.0125 to meet the requirements of zero discharge. Grading and Drainage report does svr(dsvrdesign.com not summarize the 300 page appendix containing the stormwater management facility sizing calculations. A table identifying the following information for Memorandum #01 - Review of Technical Reports Prepared for SEIS Pleasant Harbor Master Planned Resort — Peer Review August 5, 2009 Page 2 of 3 each basin should be provided: 1) total basin size, 2) proposed impervious, 3) proposed pollutant generating impervious, 4) proposed grass, 5) proposed pasture/native, 6).proposed forest, 7) predeveloped (forested condition) runoff flow rate, 8) developed flow rate, 9) average infiltration over basin area, 10) proposed type offlow control facility, 11) estimated size offacilities to meet forested conditions/zero discharge to Hood Canal, and 12) what stormwater treatment will be provided if any. In addition, it is does not appear that the existing sub -basin boundaries are being maintained. Proposed development information lists more proposed basins than the number of existing basins identified in Figure B.1. Additional comments specific to the organization of the report are provided below. r — A Draft Water Quality Monitoring Report has been prepared identifying monitoring approach, locations, and parameters. However, it is not identified who will be responsible for the monitoring and reporting during the various phases of construction and who will take over the monitoring when construction is complete. y — A Draft Golf Course Best Management Practices (BMPs) Plan has been prepared. BMPs are generally discussed. Specific BMPs need to be assigned that will be employed after construction that will meet the stormwater requirements in the 2005 Department of Ecology Stormwater Manual for Western Washington. Definitive language should to be used. In addition, SvR has the following general comments and questions following the review of Grading and Drainage Report. 1) Section 1.1 — Pre developed and Existing Conditions descriptions combined 2) Section 2.2 — Proposed development description does not include land cover values for each section of development 3) Section 2.2 — Proposed Development section (2.2) only describes the first phase approach. No other information is included for subsequent phases in Section 1 or for work in Section 2 and 3. 4) Section 2.4 - Potential Construction Impacts: a) No discussion how wetlands will be protected during gravel process b) No figure identifying limits of gravel process. Limits identified in plan do not seem to match scale of earthwork described in the report. More detail needs to be provided, c) Stockpiling areas "multiple stockpiles of wood debris approximately 25 feet high and 100 feet in diameter will exist for each area cleared" were not identified in the report. Areas cleared are not quantified. d) No discussion of impacts during construction of Section 2 and Section 3. 5) Section 2.5- Mitigation measures for construction impacts during phasing are not identified. 6) Section 2.6 — Only Phase 1 development is discussed 7) Section 3.1 —Existing Conditions a) Site specific drainage basin predeveloped and existing condition runoff peaks and volumes are not identified for the existing basins b) Runoff/Infiltration/Groundwater — This paragraph is not consistent with data presented in the Subsurface Group 2008 Report. Potential evapotranspiration for the site was calculated to be approximately 24 inches (Page 3 of 22). Memorandum #01 - Review of Technical Reports Prepared for SEIS Pleasant Harbor Master Planned Resort — Peer Review August 5, 2009 Page 3 of 3 8) Wctlands — Wetlands are going to be used to provide retention of stormwater prior to infiltration to meet flow control requirements of the proposed development. General sizing information including stormwater runoff volumes contributing to the wetlands should be included. Calculations need to indicate if the created and/or enhances wetland areas are adequate to meet the stormwater management requirements. 9) Rainwater Harvesting — Address if rain water harvesting is feasible considering that aquifer recharge is providing water supply for the development. 10) Reducing the Quantity of Stormwater to be infiltrated — See comment 9 above. 11) Report does not outline how the proposed development will meet the minimum requirements outline in the 2005 Department of Ecology Stormwater Manual for Western Washington. Most information is included it is just not organized well. 12) Phased Development - A proposed stormwater layout for each phase and the developed condition was not included. It is unclear what the stormwater management will be for Sections 2 and 3 during construction and when the development is complete. 13) WWHM results should be summarized in the text for each basin. 14) No discussion of sub -basin limits changing from existing conditions to the proposed sub -basin limits. 15) Report does not reference Jefferson County Code requirements. 16) Report does not reference FEIS Mitigating Conditions for subsequent project review, technical comments, and comment log. The following reports would also be useful in identifying information required of the SEIS: • Sequencing Plan for Construction Activities including phased development earthwork management plan and temporary and erosion and sediment control. • Arborist Report to identify tree information including tree retention, tree harvesting, and understory health to support stormwater calculations and temporary erosion and sediment. FA09\09025 Pleasant Harbor Peer Review\Communication\Memos and UttersWemol_Peer Review Technical Reports.doc David W. Johnson From: Donna Frostholm Sent: Thursday, August 13, 2009 1:30 PM To: David W. Johnson Subject: Brinnon MPR - Wetland Comments and Recommendations David: I have reviewed the Wetland and Weiland Buffer Mitigation Plan, Draft Report prepared by Geolingineers, Inc (dated August 21, 2008), and on August 11, 2009, 1 conducted a site visit to verify the wetland categories using the 2004 Wetland Rating System. As part of preparing these comments, I also reviewed the Grading and Drainage Technical Engineering Report (prepared by Craig A. Peck & Associates, September 4, 2009 Draft) and the Final Environmental Impact Statement (FEIS) prepared for the proposed Brinnon Master Planned Resort (dated November 27, 2007). Based on my site visit and review of the submitted materials and FEIS, I have the following comments: Wetland Category. I agree with the wetland ratings for Wetlands B, C, and D. I also agree that Wetlands B and D require a 150 -foot buffer and Wetland C requires an 80 -foot buffer. Mitiaotion Plan. The draft mitigation plan addresses compensation for the permanent loss of Wetland B and buffer reductions at Wetlands C and D. I reviewed the draft mitigation plan for compliance with Jefferson County Code (JCC) requirements, as they pertain to wetlands and wetland buffers. Wetland Hydroloov. Currently, the natural processes occurring within the project area provide a sufficient amount of water to the 3 on-site wetlands to support wetland conditions. These wetlands are typically inundated for a portion of the year, with much, if not all, of the surface water gone in the drier times of,the year. The draft mitigation plan states that water levels within the wetland mitigation area and the existing wetlands will be manipulated to receive reclaimed water from the golf course. The draft mitigation plan also refers to the amount of water entering the wetlands post -construction as greater than current conditions and refers to it as "enhanced" hydrologic patterns. The Jefferson County Code (JCC) considers alteration of wetland hydrology to be a regulated activity. If wetland hydrology is manipulated post -construction (meaning that wetland hydrology is not present due to natural processes and/or the hydrologic budget is not similar to that under existing conditions), then the alteration is subject to the critical areas requirement in the JCC. It should be noted that the FEIS states Wetlands C and D will not be altered by the proposal. The draft Grading and Drainage Technical Engineering Report indicates that kettles will be used for stormwater control, but does not specify which kettles. Two of the kettles are not wetland and Wetland B is proposed to be filled. However, two kettles in the project area are wetland (Wetlands C and D), and are protected under JCC critical areas requirements. The applicants should clearly indicate which kettles are to be used for stormwater control. As noted above, alterations to Wetlands C and D are to be avoided. Figure 3 of the draft mitigation plan shows construction of an overflow stream between Wetlands C and D. Currently, both Wetlands C and D are kettle wetlands that do not have a surface water connection, and Wetland C is located at the bottom of steep slopes. The draft mitigation plan does not address construction of an overflow stream to these wetlands, although alterations to the existing environment would be substantive. Based on Figure 3, it appears that the intent is to direct excess water from Wetland C east to Wetland D via a proposed overflow stream post -construction. It is important to note that Wetland D extends off-site to the east and that steep slopes are mapped as occurring east of the Wetland D. The applicants cannot "enhance" wetland that is not on their property nor can they create conditions where more water may be directed towards slopes that are not within the project area. The applicants should clarify what is being proposed. Wetlands C and D as well as the mitigation area rely on precipitation, surface water runoff, and subsurface flow to support wetland hydrology and maintain wetland conditions. Given the extent of alterations proposed in the project area (including cut and fill), the applicants need to provide additional information about hydrologic conditions at these 3 wetlands post -construction. This should include, but is not limited to, an assessment as to how the geomorphology and drainage patterns will be altered by development in the drainage are for the wetlands. As noted above, if development activities result in altered hydrologic conditions within the wetlands and wetland buffers, then the proposed activity is subject to regulatory review to JCC requirements for critical areas. Wetiond H (impact Areal. The applicants are proposing to use a non -wetland kettle on the property as a mitigation for impacts to Wetland B. Based on my review of the draft mitigation plan, I have the following comments: 1. Grading is addressed on page 11 of the draft mitigation plan and the bottom mitigation kettle elevations are highlighted in yellow (in the text of the report). The raised height of the kettle bottom in the text does not appear to match elevations shown on Figures 8 and 9. Based on information in the draft mitigation plan, the applicants are proposing to place at least 5 feet of clay and silt (or "clay -rich" soil) in the wetland mitigation area with an additional 12 inches of hydric topsoil, which would be placed over the clay and silt layer. The slopes to the mitigation area are steep and the applicants should confirm that the heavy equipment needed to compact the clay and soil layer can access the mitigation area. The percent compaction should be specified in the mitigation plan. In the final mitigation plan to be approved by the County, a detailed grading plan of the mitigation area should be included. 2. The draft mitigation plan states that the top 12 inches of hydric soil at the mitigation site will come from the top 24 inches of soil in Wetland B. Typically, only the upper 6 to 12 inches of the soil profile is topsoil; below that is subsoil, which is less likely to support vegetation. Based on the soil description from the wetland delineation report prepared for this project (and received by Jefferson County on August 4, 2006), it appears that only the upper 6 inches of soil at Wetland B would be considered usable as topsoil at the mitigation site. Since the mitigation area is twice the size of the impact area, the applicant should specify in the mitigation plan where the necessary topsoil will come from for use in the mitigation area. 3. The draft mitigation plan states on page 11 that native species from Wetlands B, C, and D will be used. The JCC considers alteration of wetland vegetation a regulated activity. Use of native plants from Wetland B are appropriate for use in the mitigation area. However, plants from Wetlands C and D and associated buffers cannot be removed for use elsewhere in the project area. The text of the mitigation plan should be revised accordingly. 4. The draft mitigation plan indicates that salvaged plants from the project area will be used to replant the mitigation area. While it is acceptable to use salvaged plants, it should be noted that it is generally stressful for large, well-established vegetation to be transplanted and that there is a greater potential for plant mortality (as compared with installation of young vegetation). Much of the project area consists of large trees with a well- developed understory. Many of the trees on the property are much too large to transplant, and it is unlikely that the most of the shrubs on the site would survive being transplanted. The mitigation plan should address survival of transplanted vegetation, identify those portions of the buffer mitigation area to be planted on a figure, present the on -center spacing within these planting areas, and evaluate whether plants obtained from a nursery will be needed to establish native vegetation in the 150 -foot buffer. 5. The mitigation plan should address who is responsible for removing non-native and/or invasive species from the mitigation area and address disposal of undesirable vegetation. 6. A goal of the mitigation plan is to provide on-site, in-kind compensatory mitigation. Wetland B is well vegetated and has no open water areas during the drier months of the year. The mitigation proposal, however, includes an open water component that is not proposed for planting. The draft mitigation plan needs to be revised to address this discrepancy. 7. The first bulleted performance standard listed on page 18 should be revised to state that no more than 10 percent coverage of exotic and undesirable species shall be present throughout the monitoring period, not just at the end of the monitoring period. 8. A performance standard should be added to address wetland hydrology (that matches the goals of the of the mitigation proposal). 9. The mitigation plan needs to be submitted to Jefferson County no later than December 31 of each monitoring year. The draft mitigation plan should be revised to clarify that monitoring plans must be submitted by the end of the calendar year. 10. The mitigation plan should state that the outer edge of the wetland buffers will be staked prior to beginning any ground -disturbing activities. 11. The mitigation plan should state that silt fencing and orange barrier fencing will be installed along the outer edge of the wetland buffers prior to beginning any ground -disturbing activities. 12. The mitigation plan should state that the project biologist will be on-site during plant installation to ensure that healthy plants are being installed as per an approved plan. Wetlands C and R (Buffer Reduction). The applicants are proposing to reduce a portion of the wetland buffers at Wetlands C and D. 1. The text of the mitigation plan states that the buffer reductions would not be greater than 25 percent of the standard buffer widths, yet the figures in the report show buffer reductions well beyond 25 percent. The mitigation plan must be revised to address this discrepancy and bring the proposed buffer reduction into compliance with JCC requirements. 2. Some of the total square footage calculations in the legend of several figures do not match the area calculations shown in the drawing on Figure 10. The figures need to be corrected. 3. There is a net decrease in the Wetland C buffer area (543 square feet), as proposed in the draft mitigation plan. Also, there is a buffer reduction shown on the figures at Wetland C to construct Fairway 1 that has not been accounted for in the draft mitigation plan. The applicants need to state why the fairways cannot be located outside of the wetland buffers and provide more information as to how a net decrease in wetland buffer area could comply with JCC buffer reduction requirements as they pertain to functions and values. 4. A mix of native and non-native species are currently present in the buffers for Wetlands C and D. The draft mitigation plan only shows the locations of paved or gravel roads for re -planting as part of the buffer reduction. The draft mitigation plan should indicate the plant composition of the additional buffer areas. If areas consisting of non-native species are present in the buffer addition areas, then the draft mitigation plan should address these areas. Wetland Functions and Values. Following are my comments pertaining to wetland functions and values. 1. Figure 3 shows wildlife corridors on the golf course. No information is provided in the draft mitigation plan as to what habitat features, if any, will be placed within a wildlife corridor or what constitutes a wildlife corridor. The draft mitigation plan does not identify what type of wildlife would be expected to use the wildlife corridors to move from wetland -to -wetland. 2. Fencing is proposed to prevent the people from entering into the mitigation site, but no mention of fencing is proposed to protect Wetlands C and D and associated buffers. The mitigation plan should also address protection of these wetlands. 3. To fully understand the potential impacts to wetland area, wetland functions and values, and wetland processes, the applicants need to provide information on the extent of cut and fill proposed within the project area. The draft report should be revised to address all potential impacts of the proposed development and re -submitted for County review. The extent of impacts should be based on what was presented in the FEIS. Note that a final mitigation plan will be needed for project permitting that would include, but is not limited to, detailed planting plans and specifications, detailed plans specifying type and location for habitat features noted in the text of the mitigation plan, fencing specifications, revised construction schedule, and updated monitoring schedule. Let me know if you have any questions, Daym l F4'dlth404 !'V .?associate Aanner%Wettand Specialist Jefferson County Development Review Division 621 Sheridan Street ,Pori 7_Ownsen4 Washington 98368 &OSth4C'T? 0co je fer50n.'w(L 360.379.4466 All e-mail sent to this address will be received by the Jefferson County e-mail system and maybe subject to Public Disclosure under Chapter 42.56 RCW. David W. Johnson From: Susan Porto Sent: Thursday, August 20, 2009 2:48 PM To: David W. Johnson Subject: Pleasent Harbor Hydro Report David, With respect to the Water Supply and Groundwater Impact Analysis for the Pleasant Harbor Marina and Golf Resort received April 1, 2009, 1 have the following comments: The water supply well is developed below sea level and will seemingly always either be susceptible to seawater intrusion or potentially cause intrusion to the wells along the south and east coast of Black Point. I wonder why the investigatory wells were not drilled at or below the existing water supply well, that would then provide better information about the deep geology and water quality surrounding the water well. I have concerns that the evaluation does not address how low rainfall years would affect their assumptions. Could the development handle a year where rainfall was like this year? What are their draught contingency plans? Susay. Porto R.S. Jeff rsov- aouwtd Public Ftealth PROM 360. 3059404 i=Ax 360. 3.4487 ALwa [e}t WgrtLl�g dor R 5R fEr G Ft QLtKeC_I r5o{% CpLt� CONFIDENTIALITY NOTICE: This e-mail message, including any attachments, is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure, or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message. David W. Johnson From: Lloyd Skinner ILSkinner@esassoc.com] Sent: Monday, September 21, 2009 2:13 PM To: David W. Johnson Subject: FW: Memos to Jefferson County Attachments: PH-WastewaterReclamationPlantProcess-Jul22-09-draft(BP review).doc; PH- WaterSupply&GroundwaterlmpactAnalysis-Dec17-08-draft(BP review).doc; PH- WQMonitoringPlan-Aug18-08-draft(BP review).doc; PH-GeotechRpt-Dec9-08draft- Ju123-09rev(BPreview).docm; PH-GeothermalHeating&Cooling-Jul15-09-draft(BPreview).doc; PH-Grading&DrainageRpt-Sept4-08-draft (BP review).doc Hi, David — Attached are review comments from Bill Persich, P.E., a senior engineer at Brown and Caldwell. His comments are both in embedded notes and in "track changes" format within each of the technical reports prepared by the applicant for the Pleasant Harbor Marina and Golf Resort development. Memos that Bill reviewed are the following: • Wastewater Reclamation Plant Processes • Water Supply and Groundwater Impact analysis ■ Water Quality Monitoring • Geotechnical Report ■ Geothermal Heating and Cooling • Grading and Drainage In general, Bill's comments note issues such as areas where an assumption differs from standard practice at Washington's Department of Ecology, or where the analysis raised a question for him as a senior reviewer that may warrant further clarification. I believe that addressing these review comments will strengthen the technical memos in anticipation of a public review Draft EIS. - Lloyd Lloyd Skinner, AICP Senior Vice President I Northwest Regional Director ESA Adolfson 5309 Shilshole Ave NW, Suite 200 Seattle, WA 98107 206.789.9658 / 206.789-9684 fax Iskinner esassoc.corn IDSA Ano1,fson _14 memorandum date September 21, 2009 to David Wayne Johnson/Jefferson County from Lloyd Skinner/Margaret Clancy 5309 Shilshole Avenue NW Suite 200 Seams, WA 98407 206.769:9¢68 phone 206.789.9584 fax subject Pleasant Harbor - Comments on Wetland and Buffer Mitigation Plan www.adolfsompom We have reviewed the document entitled.Br•innnu Master Planned Resort — Draft Wedairrl and Wetland Brttf`er Mitigation Plan (File No. 12677-001-06) prepared by GeoEngineets, Inc. August 21, 2008 as requested. The applicant proposes to compensate for the loss of one isolated, Category III 'kettle' wetland by creating a similar wetland in the bottom of another kettle (Wetland B would be covered with an impermeable layer olid `filled' with water for use as a control. pond). The.applicant also proposes to add buffer area adjacent to Wetlands C and D to make up for buffer reductions that are necessary to accommodate two golf course f4irways (holed ##2 and #6). Overall, the mitigation plan seems adequate and is generally consistent with regulatory requirements. There might be opportunities for the prco ect to benefit from a more creative or visionary mitigation approach. Here is a brief summary of our findings: • The plan contains minimal information about impact avoidance and minimization, so some additional discussion is warranted to indicate that the applicant has met the mitigation sequencing test. This "test" could be an issue that Ecology or other stakeholders may ask about during the EIS process, as the project is required to follow the standard mitigation sequence. That said, this is: not your typical wetland fill situation since Wetland B is located in the bottom of a deep depression and one could argue.that using this area as a water source for the development site is worth the tradeoff (assuming that the water use analysis bears that out). • The mitigation plan contains a reasonable level of detail about the site, the expected impacts, the basic mitigation approach, and the monitoring/ maintenance procedures. There are no major or glaring. omissions in terms of mitigation content at this stage of the process. • The amount of mitigation that "would be provided is,consistent-with County required mitigation ratios. • The proposed mitigation generally compensates for the txNcted impacts: in that the applicant would be creating a wetland that is (apparently) very similar tn.the one being filled', This<is a typical on' -site, in-kind mitigation approach. A.question that may be raised :during EIS review is whether the proposed mitigation is the best option for the site. The'replacement wetland will be: at the bottom of a i.10 -foot -deep natural depression, which, although similar to the wetland to be filled, would 'seem. to: have Iimited:ecological or cultural value. Are better mitigation options available? The Mitigation Plan memo indicates that the applicant examined seven potential sites before selecting this option, but it is not clear what criteria were used to make the decision. Perhaps some additional discussion of this assessment would help clarify the decision criteria. That said, the proposed approach appears to satisfy regulatory requirements. • The buffer addition areas on Wetlands C and D replace the buffer reduction areas at the required 1:1 ratio, but may not be optimal in terns of their location. From the figures, it appears that theses buffer additions may provide only limited added protection to the respective wetlands. The plan :states that one: df'the.:goals r tot re4telundisturbed corridors between rivers, titreains, wetland systems, intact upland habitats. And other natural areas•," but it is not immediately clear that the proposed approaA supports this aim. Further discussion of this goal„and illustrations of ptopo.5e1corridors (or revisions to the site pian ifwarran(ed) would be helpful, 2: David W. Johnson From: Donna Frostholm Sent: Tuesday, September 22, 2009 10:45 AM To: David W. Johnson Subject: Brinnon MPR - HMP Comments and Recommendations David: I have reviewed the Habitat Management Plan, Draft Final Report (HMP) prepared by GeoEngineers, Inc (dated August 22, 2008) for the Brinnon Master Planned Resort. As part of preparing these comments, I also reviewed the Wetland and Wetland Buffer Mitigation Plan, Draft Report (prepared by GeoEngineers, Inc, dated August 21, 2008) and the Final Environmental Impact Statement (FEIS). Based on my review, I have the following comments. The HMP states that the proposed project should not have significant impacts on terrestrial wildlife species because vegetated areas and corridors will remain, and additional information is needed to support these statements. Aerial photographs currently show most of the project area, especially Section 1, as vegetated with trees and shrubs, with few barriers to terrestrial wildlife movement through the project area. Other figures in the report show that most of the project area will be developed with roads, structures, and a golf course. The applicants should provide data on the amount of each habitat type present under existing conditions and post -construction conditions. The HMP indicates that protected areas and marine environment pollution control strategies will be implemented for maintaining shoreline use by tribes. The details for these strategies should be clearly identified in this section of the HMP. Under the discussion of Wildlife Corridors (page 16), the first bullet indicates that vegetation will remain within undisturbed within Section 1. The figures in the HMP show that much vegetation will be removed to construct the project. This bullet needs to be clarified. It also conflicts with the last bullet, which states that an effort will be made to retain trees throughout the site. The HMP states that the on-site wetland hydrology will not be altered as stormwater and irrigation will be captured and treated to Class A standards before being discharged to on-site infiltration systems. The location of the on-site infiltration systems should be shown on a figure in the HMP. Additional information is needed on the wildlife habitat corridors within the golf course. It is not clear what type of habitats will be retained, which wildlife species would be encouraged to use the corridors, and what wildlife species will be discouraged from using the corridors. The discussion of Wetland C in the HMP states that the buffer will be reduced by no more than 25 percent, yet the figures show a buffer reduction of much more than 25 percent. The buffer reduction areas shown on Figure 14 do not add up to the square footage in the legend. The buffer reduction on Figure 14 does not account for the buffer reduction for construction of Fairway 1. Therefore, the buffer addition area is less than the buffer reduction area, resulting in a less than 1:1 buffer averaging ratio. The discussion of Wetland D in the HMP states that the buffer will be reduced by no more than 25 percent, yet the figures in the HMP show a buffer reduction of much more than 25 percent. The buffer addition areas do not add up to the square footage in the Figure 14 legend. Figures 9 and 10 show some of the planting areas coincident with project development The HMP states the square footage of impervious surface removal at each stream, but does not indicate what the square footage of impervious surface will be for development within the streams and stream buffers. The square footage of impacts and mitigation should be presented for each stream. The HMP references the critical areas stewardship program (CASP). The text of the wetland mitigation plan and HMP state that the wetland and stream buffers will be reduced by no more than 25 percent, which would be permitted as an administrative buffer reduction that does not require a CASP. The wetland mitigation plan and the HMP that have been submitted are appropriate for wetland and stream buffer reductions that do not exceed 25 percent. It should be noted that CASPs can be used for some rural residential single-family development and rural village centers, but not for master planned resorts. The HMP states that "wet cells" will be constructed to treat water. The location of the wetland cells should be shown on a figure. Much of the discussion in the HMP for Noise Quality and Construction Impacts, Golf Course Design and Management Practices, and Occupational Phase indicate actions that could be taken as mitigation (e.g., establish a fertilizer schedule, develop a monitoring program, build bird boxes). Clarification is needed as to whether the project proponents will commit to implementing those activities. Substantive cut and fill operations are proposed as part of this proposal. Additional information about the extent and location of cut and fill operations are needed to determine if the potential impacts to fish and wildlife conservation areas have been adequately addressed in the HMP. Let me know if you have any questions. Don+U , Frostho� Associate PCanner/WeMandSpeciaCist Jefferson County DevetoMent Review Division 621 Sheridan Street Port Tawnsencl -Washington 98368 d�ros thoCm@co��,�erson. tiva. us 360.379.4466 Department of Community Development is open to the public from 9:00 to 4:30 Monday through Thursday. Note that DCD is now closed on Friday. All e-mails sent to this address will be received by the Jefferson County e-mail system and may be subject to Public Disclosure under Chapter 42.56 RCW.