HomeMy WebLinkAbout070David W. Johnson
From:
Sent:
To:
Jim Pearson
Thursday, December 03, 2009 5:20 PM
David W. Johnson
Brinnon Master Planned Resort Development Agreement, Low lmpact DevelopmentSubject:
David,
This is a Development Agreement comment, not an SEIS comment.
This comment is based on the project description and information in the Programmatic EIS related to stormwater
management, low impact development, aquifers, water use, and water rights. lt is considers the growing body of
information and technical standards related to the use of Low lmpact Development as a stormwater management
strategy, including the Washington Department of Ecology Stormwater Management Manual for Western Washington
(February 2005) and the Puget Sound Action Team / Washington State University Pierce County Extension Low lmpact
Development Technical Guidance Manual for Puget Sound (January 2005). Finally, it should be noted that the
Washington State Pollution Control Hearings Board has ruled that Low lmpact Development Best Management Practices
must be incorporated into the State's Phase 1 and 2 NPDES Permits since it represents a Known and Reasonably-
Available Technology. The project will require an NPDES Construction Permit since it will disturb more than an acre of
land.
Based on these considerations the Development Agreement should include a section that requires the use of Low lmpact
Development to the greatest extent feasible in site assessment, site planning, development, and design of stormwater
management facilities. The Development Agreement should require the use of appropriate LID Best Management
Practices, including retaining natural vegetation, minimizing site disturbance and impervious surfaces, distributing and
disconnecting stormwater management facilities, amending site soils, and the use of permeable pavements and
bioretention.
Jim Pearson
Jefferson County Public Works Department
623 Sheridan Street
Port Townsend, WA 98368
(360) 385-e162
(360) 385-9234 Fax
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