HomeMy WebLinkAbout004Michelle Farfan
From:
David W. Johnson <dwjohnson@co jefferson.wa.us>
Sent:
Wednesday, January 20, 2010 12:37 PM
To:
Donna Frostholm
Subject:
FW: Pleasant Harbor Technical Team Response to Comments
Attachments:
Craig PeckResponseToComments-Janl9-l0.pdf; GeoEngineersResponseToComments-
Janl9-10.pdf; H.R.EsveltResponseToComments-Jan4-10.pdf;
MikeReadResponseToScopingComments-1-Janl2-10.pdf,
MikeReadResponseToScopingComments-2-Janl2-10.pdf;
ScottBenderResponseToScopingComments-1-Janl4-2010.pdf;
ScottBenderResponseToScopingComments-2-Janl4-10.pdf;
ScottBenderResponseToStaff&PeerReviewComments-Janl4-2010.pdf;
VinniePerroneResponseToComments-Janl4-10.pdf
FYI —Tech Team Response to County comments.
From: vmorriscs@aol.com [mailto:vmorriscs@aol.com]
Sent: Wednesday, January 20, 2010 9:21 AM
To: David W. Johnson
Cc: peckassoc@comcast.net; Garth@statesmancorporation.com; AMackie@perkinscoie.com
Subject: Pleasant Harbor Technical Team Response to Comments
David
On January 3 and 4, 1 distributed to members of the Pleasant Harbor Marina and Golf Resort technical team pdf files of
Scoping comments received in November 2009, and pdf files of County staff and Peer Review Team comments
prepared between July and September 2009. 1 asked the team to review these comments to determine which need to be
addressed in their final reports, and which may not (with an explanation for the latter). As of today, I have received replies
from all members of the technical team except the Cultural Resources consultant. I am still working with the Forestry
consultant on their responses; I will send these to you as soon as they're available. I have attached all other replies for
your review in advance of when you, Stacie, Craig and I will meet to confirm the consolidated list of requests for report
revisions.
If you plan to prepare a Final Scoping Memorandum to confirm issues to be addressed in the technical reports and SEIS,
you could begin drafting that now with this input. I would like to review and contribute to the Scoping memo after we meet.
In addition to responding to Scoping comments, County staff and Peer Review Team comments in their reports, technical
team members will need the following items to be added to the consolidated list of requirements to be addressed in their
final reports:
Uniform introductory text (Craig, you and I to rework from draft provided by Garth).
2. Narrative description and illustration of the three alternatives to be evaluated in the SEIS.
3. My requests re: the format/content of the Potential Impacts sections (to address impacts during construction and in
the developed condition of the project, distinctions between alternatives, and significant unavoidable adverse impacts [if
any]).
4. My requests re: the format/content of the Mitigation Measures sections (to address Incorporated Features, Applicable
Regulations, and Other Recommended Mitigation Measures).
Craig is working on the site plans for the alternatives now. When these are available, he and I will meet to develop draft
narrative descriptions, after which we will schedule our meeting with you and Stacie.
Let me know if there is anything else you need at this time, and/or if you see this sequence proceeding differently.
Vicki
Vicki Morris Consulting Services
7732 18th Avenue NE
Seattle, WA 98115-4426
206.522.8057
Cellular: 206.501.8227
FAX: 206.523.4648
Crai A.
Pec &
Associates
114024 01h Avenue E.
Tacoma, Washington 98446
technical assistance
253-840-5482
253-200-4523 FAX
peckassocCo.corn cast. net
TO: Vicki Morris
FROM: Craig Peck
RE: Response to Comments on Draft Technical Report — Grading and Drainage
Pleasant Harbor Marina and Golf Resort
Response to Scoping Comments
PDF 1-1 through 1-10: Hood Canal Environmental Council (Andrea Mitchell 11/27/09)
Bullet 5, p. PDF 1-2. Existing surface water flow patterns have been verified using topographic mapping,
onsite drainage basin, stream corridor, and onsite geologic reviews.
Bullet 6, p. PDF 1-2. Response to Dr. Horner's letter is provided below where it was submitted as
Attachment 3 to Andrea Mitchell's 11/23/09 submittal (PDF 1-50 through -53).
Bullet 7, p. PDF 1-2. Washington State Department of Ecology, Stormwater Management Manual
(Ecology Manual) provides coefficients to be used dependent on soils and type of use. Jefferson County
requires use of the Ecology Manual. Statesman proposes to use soil supplements to improve the
permeability of the golf course; however, values dictated by Ecology will be used develop conservative
values for runoff.
Bullet 1, p. PDF 1-3. The Washington State Department of Ecology developed and requires the use of a
continuous rainfall model (WWHM3) to predict runoff. This model has been used to calculate runoff
flows and volumes for each of the sub -basin within the project site. The model predicts the occurrence
of runoff by probability to include the 100 and 500 year events. Local rainfall amount values have been
developed by Ecology. The rainfall value for the South Black Point has been used. Streams that flow
through the marina area of the project site will be treated as flow through conditions meaning that
existing channel conditions will not be disturbed.
Bullet 2, p. PDF 1-3. The Ecology Manual provides a menu of soil conditions and local rainfall to be used
to calculate runoff. This method predicts runoff from varying conditions including saturated and dry
soils.
Bullet 4, p. PDF 1-5. The golf course will be graded to direct runoff to the interior of the site to be reused
for irrigation or infiltrated. Natural fertilizers and soil amendments will be used to reduce the nutrients
in runoff.
Bullet 5, p. PDF 1-5. Runoff will be treated in accordance with the requirements of the Ecology Manual
PDF 1-12 through 1-17: Gerald Steel (11/30/09)
Stormwater Management paragraph, pp. PDF 1-14 and 1-15. The golf course will be graded to direct
runoff to the interior of the site and not allowed to flow directly to Hood Canal. The Ecology Manual no
longer uses "single event" storms as the basis for runoff quantity and quality design. The continuous
model developed by Ecology is believed to better predict runoff conditions in Western Washington and
the WWHM3 model uses local rainfall conditions. Methods for "full" treatment of runoff are outlined in
the Manual for use during design. The Manual does not prescribe future conditions of climate change.
PDF 1-18 through 1-22: Bob Foster (11/30/09)
Paragraph 3, p. PDF 1-18. The Ecology Manual uses local area rainfall predictions. The South Black Point
area has a higher predicted rainfall amount than does the marina area. The South Black Point area has
been used to calculate runoff for the entire MPR area to produce conservative results. Only the local
rainfall amount was used for runoff analysis as prescribed by the Manual was used, not weather data
from 13 miles distant.
Federal and State regulations require a construction stormwater permit under the National Pollutant
Discharge Elimination System (NPDES) and State Waste Discharge General Permit for Stormwater
Discharges Associated with Construction that is site-specific for erosion and sedimentation control for all
phases of construction including the earthwork. Contingency plans are to be included for emergency
sediment control. Cleared areas are to be left open for only short periods of time before cover is
required. These periods are shortest in the wet months of the year. This site contains many drainage
sub -basins that contain runoff on the site, thus reducing the risk of sediment laden runoff from leaving
the property. The Ecology letter dated November 30, 2009, outlines the basic conditions of these
regulations.
PDF 1-23 through 1-26: Ecology (11/30/09)
Water Quality Issues, pp. PDF 1-24 and 1-25. Acknowledged, an NPDES permit is required and a
Stormwater Pollution Prevention Plan will be prepared.
PDF 1-36 through 1-41: Andrea Mitchell (11/23/09) Attachment 1— 7/16/09 letter
Bullet 4, p. PDF 1-37. The Ecology Manual prescribes methods to be used to control and treat runoff in
urbanizing areas. These methods will be used for the final engineering design of the site.
Bottom half of p. PDF 1-38, top half of p. PDF 1-39. The stormwater design and/or construction at the
Fish & Wildlife area was not adequate for the runoff that occurs at that site. I am not aware how or who
designed it or the methods used for the design. The system failed in this case.
Bottom half of PDF 1-39. Development of the marina area is no longer proposed. Remodeling of the
marina area may reduce impervious surfaces and provide treatment for collected runoff. Control and
treatment of highway runoff near the marina is not proposed. This runoff is the responsibility of WSDOT.
PDF 1-42 through 1-49: Andrea Mitchell (11/23/09) Attachment 2 — Gerald Steel letter (1/19/09)
Paragraph at the bottom of p. PDF 1-46. The infiltration rates for the soils on the site have been
determined by Vinnie Perrone, Ph.D., P.E., Geotechnical Engineering consultant and are shown in the
Geotechnical Investigation report (December 9, 2008). Areas containing soils and subsoils with higher
infiltration rates have been proposed for the infiltration galleries. Year -around irrigation is proposed.
Site soils are adequate for the runoff being applied. The statement that infiltration must be "...hundreds
of times greater than the natural rate...." is not substantiated by site soil test results.
PDF 1-50 through 1-53: Andrea Mitchell (11/23/09) Attachment 3 — Richard Horner letter (12/06/07)
Zero surface water runoff from the golf course directly to Hood Canal will be created by grading the golf
course to direct runoff toward the interior of the site rather than allowing surface water to flow south
into Hood Canal. Surface water must continue into the wetland along the east side of the site to
maintain the hydrologic conditions within the wetlands. The marina area is no longer proposed for
development.
Increased traffic along Hwy 101 could degrade surface water quality as a result of highway runoff
conveyed to Pleasant Harbor by culverts and intermittent streams that flow down the bank east-
southeast of the highway.
PDF 1-54 through 1-55: Jefferson Transit (11/17/09)
TENW and I have worked together to approximate the conditions requested by Jefferson Transit. A
roadway into the site at Black Point Road and around the proposed parking lot south of Black Point Road
with an exit to Hwy 101 could provide the transit stop, rider shelter, and bus parking (layover)
requested. The fundamentals of this design are shown on the current site plan.
PDF 2-65: Washington State Parks & Recreation Commission (10/30/09)
Paragraph 3, p. PDF2-65. Access from Hwy 101 to the State Facilities will be maintained.
Paragraph 4, p. PDF2-65. Resort visitors may use the boat launch and the State park. An estimate of the
number of users will be prepared and the potential impacts of that use will be predicted.
Response to Staff and Peer Review Team Comments
PDF 1-2: County Staff Comments re: the Economic Benefit Report (9/22/09)
1 will work with Garth on this issue.
PDF 1-3: County Staff Comments re: the draft Grading and Drainage Report (9/22/09)
Final grading quantities will be developed for the SEIS.
Explanation of kettle reconfiguration will be better described.
I will complete coordination with Vinnie Perrone, Geotechnical Engineering consultant.
Maritime Village construction phasing and excavation quantities will be revised for the SEIS.
Statement taken from the Scott Bender report: Water Supply and Groundwater Impact Analysis.
PDF1-10 through 1-12: SvR Comments (8/05/09)
The Western Washington Hydrology Model (WWHM3) is being used.
Zero discharge will be achieved with grading, not runoff calculations.
A table containing the information suggested may be considered if it will truly better inform the reader.
A summary of the 300+ pages of calculation output will be prepared, if those pages are included in the
report. Site grading creates new sub -basins.
1. Pre -developed and existing conditions are the same.
2. Description could be provided if necessary for the understanding of the reader.
3. Project phases and sequences will be described. Current calculations are for build out.
4. a. Discussion to be provided.
b. Gravel processing area(s) to be better described.
c. Area of clearing is provided as areas of cut and fill. Boundary can be identified better.
d. Impacts to be described.
5. Phases to be identified and impact of each to be described.
6. All phases to be described.
7. a. Existing runoff quantities for those areas discharging offsite will be better identified.
b. Coordination between final reports will be improved.
8. Wetlands are not being used to infiltrate stormwater. Existing etlands will receive runoff sufficient
to maintain their conditions. Created wetlands will receive runoff adequate to maintain them.
9. Rainfall harvesting will occur to provide irrigation. Irrigation will contribute to aquifer recharge.
10. See comment above.
11. Minimum requirements will be discussed.
12. A stormwater collection system layout in the SEIS is not proposed. A conceptual plan could be
produced if determined to be necessary. A conceptual plan could be developed for each phase if
determined to be necessary.
13. A summary of WWHM3 data for each basin could be provided if determined to be necessary.
14. A general discuss of grading changes to sub -basin could be provided if determined to be necessary.
15. Jefferson County code requirements will be mentioned.
16. HIS mitigating conditions will be described.
A phasing and sequencing plan will be developed and described in the SEIS.
PDF 1-12. Donna Frostholm Comments (9/22/09)
The extent of clearing and cut and fill is shown on the earthwork map. The areal extent is provided as a
percentage of the site and in acres. A description of areas with fill slopes that could drain offsite will be
provided. Potential impacts to fish and wildlife are described in reports prepared by GeoEngineers.
4
H. R. ESVELT ENGINEERING
Environmental Engineering
January 4, 2010
Ref: Pleasant Harbor Marina and Golf Resort
Wastewater Reclamation Plant EIS Process Description
Sub: Response to County Staff, Peer Review Team and public input Comments
From: H. Richard Esvelt, P.E.
PDF 1-2 and 1-3 Draft Technical Reports -- County Staff Comments dated 9/22/09
Page 13 A & B. — corrections made.
PDF 2 — Bill Persich Comments on the Wastewater Reclamation Plant Process (WRP)
Description
Page I Table A — WRP Design Data: (1. Notes added following Table A)
Comments bl, b2 and b3 — Annual Average Flow does not reflect equivalent residential unit (ERU)
flow contribution, but is an average of the monthly flows shown below in the list. The ERU unit
flows and loadings are reflected in the High Season Average (June thru Sept), which is the only
season of the year when full occupancy is project. Seasonal occupancy was estimated by project
planners.
Based upon a High Season Average flow of 0.18 mgd is 210 gallons per day per ERU, which at 2.5
PE per ERU is 84 gpd per PE. The High Season Average loading of 450 lbs BOD & TSS per day is
0.52 lb BOD & TSS per day per ERU, which at 2.5 PE per ERU is 0.2 lb BOD & TSS per PE.
WRP process and system design is based upon the Maximum 3 -day Equalized Weekend flows and
loadings.
Page I 1 Table B — Chlorine System Feed concentration (1. Change made)
Comment b5 — (no comment on b4) —I agree, I will take this up with WDOH. It should also read
`design', not `minimum'.
Page 12 Table B — Sludge Dewatering (1. appropriate — final report, change made)
Comment b6 —'Thickener' should have read `Dewatering Feed Pump'
Page 13 3.1.13. Irrigation with treated effluent that does not meet Class A Reclaimed Water
Requirements (1. appropriate — final report, change added)
Comment b7 — irrigation will be by drip irrigation of landscaped areas or subsurface percolation
system.
6450 N.E. Brigham Rd., Bainbridge Island, WA 98110 206-842-7988 FAX 206-780-0811
SEIS Scoping Comments
Page 5 — Pharmaceuticals and hormones present in recycled wastewater should be removed. (3. Will
not be included in the revised report).
To date, as far as the author knows and I read the relevant periodicals, there currently is no means to
remove these components from wastewater and no regulatory agency has approached the question
(though there is a great deal of interest in the subject). These components do break down over time.
First, to answer other comments, treated wastewater will NOT be injected into the aquifer after
treatment and the nutrient nitrogen will be removed to meet drinking water requirements. Treated
and disinfected wastewater will be used to irrigate golf course grasses and for fire control in natural
areas around the course, where a portion of these noted components will be taken up by the grass
and natural vegetation. The cut grass will likely be composted to add further breakdown of the
grass. Any wastewater that percolates through the soil will be further treated with the biological
mix in the soil matrix, which could be a removal mechanism for pharmaceuticals and hormones
present in wastewater.
2
Subj: Re: Pleasant Harbor SETS Scoping Comments for Review: PDF File 2
Date: 1/12/2010 9:54:21 A.M. Pacific Standard Time
From. mikeread@tenw.com
To: VMorrisCS6a aol.com
CC: peckassocacomcast. net
VMorrisCS(oaol.com wrote:
Mike:
This message is a continuation from the Scoping comments PDF File 1 message. There is
one comment in the second PDF File for which your review and feedback is requested, as
follows:
PDF 2-5 through PDF 2-43 Barbara Moore -Lewis 11/19/09 e-mail message and
attachments:
Attachment 1: Letter from the Brinnon Group on the Scoping Process dated 11/30/09 (PDF
2-5 thru 2-9).
Please review and reply re: comments at the bottom of page 3 / top of page 4 of this letter
(PDF 2-8 and 2-9) regarding traffic accident data reporting and construction truck trips. We
can incorporate and respond within our final report.
Thank you,
Vicki
Vicki Morris Consulting Services
7732 18th Avenue NE
Seattle, WA 98115-4426
206.522.8057
Cellular: 206.501.8227
FAX: 206.523.4648
Michael Read, PE
Principal
Transportation Engineering Northwest
PO Box 65254
Seattle, WA 98155
Office - 206.361.7333 ext. 101
Mobile - 206.999.4145
Fax - 206.361.7333
Tuesday, January 12, 2010 AOL: VMorrisCS
Page 1 of 1
Subj: Pleasant Harbor SEIS Scoping Comments for Review: PDF File 2
Date: 1/14/2010 6:53:33 P.M. Pacific Standard Time
From: scoff@benderllc.com
To: vmorrisCS@aol.com, scott@benderllc.com
Cc: peckassoc@comcast. net, scott@benderllc.com
Vicki — responses to part 2. Scott
From: VMorrisCS@aol.com [mailto:VMorrisCS@aol.com]
Sent: Sunday, January 03, 2010 6:11 PM
To: scott@benderllc.com
Cc: peckassoc@comcast.net
Subject: Pleasant Harbor SEIS Scoping Comments for Review: PDF File 2
Scott:
This message is a continuation from the Scoping comments PDF File 1 message. The list of comments
for which your review and feedback is requested in this second file of SEIS Scoping comments is as
follows:
As with PDF File 1, there are several e-mail messages in this file that raise the same (or similar) issues
with regard to the amount of water that will be needed for the resort, "definition of the aquifer," and
saltwater intrusion concerns. Please confirm that the issues raised in these comments have been
addressed in your report, to respond to comments submitted by Hendricks (PDF 2-1), Foszcz (PDF 2-2),
Lewis (PDF 2-3), Murdoch (PDF 2-4), and Swarts (PDF 2-59).
Addressed in report.
PDF 2-5 through PDF 2-43 Barbara Moore -Lewis 11/19/09 e-mail message and three attachments:
Attachment 1: Letter from the Brinnon Group on the Scoping Process dated 11/30/09 (PDF 2-5 thru 2-9).
Attachment 2: Waterworks Consultants Memo dated 7/17/09 -- Technical Review of the draft Water
Supply and Groundwater Impact Analysis report (version dated 11/20/08) (PDF 2-10 through 2-18).
Attachment 3. Saltwater Intrusion Topic Paper (2005) (PDF 2-19 through 2-43).
Please review all three of these attachments and advise Jefferson County and me whether there are
issues not yet addressed in your draft report that should be added.
I have previously reviewed the Waterworks report, which is the basis for all of the duplicate
emails you have sent in these three emails and is copied in the Brinnon Group scoping
process letter above. I have responded to it and submitted my letter to Ecology as part of
the water right process.
PDF 2-44 through PDF 2-58 Barbara Moore -Lewis 11/03/09 e-mail message and three
attachments: These items are duplicative of the above submittals and therefore do not require separate
review.
OK
Thank you,
Vicki
Vicki Morris Consulting Services
7732 18th Avenue NE
Seattle, WA 98115-4426
206.522.8057
Cellular: 206.501.8227
FAX: 206.523.4648
GEOENGINEERS Memorandum
1550 Woodridge Drive SE, Port Orchard, WA 98366, Telephone: 360.769-8400, Fax: 360-769-8700 www.geoengineers.com
To: Vicki Morris, Vicki Morris Consulting Services
From: Joel W. Purdy, LG, LHG/Wayne S. Wright, PWS
Date: January 19, 2010
File: 12677-001-08
Subject: Pleasant Harbor - Review of Jefferson County Staff and Peer Review Team Comments
This memorandum presents GeoEngineers' review of Jefferson County staff and Peer Review Team comments
as forwarded to us by you in an email dated January 1, 2010. We were instructed to evaluate the comments'
appropriateness and explain how we will respond.
The following list of comments was organized by technical report, then by reviewer. The review comments
were copied from the original emailed file and our responses are provided immediately after each comment.
Habitat Management Plan
Comments from an email (September 22 2009) Donna Frostholm (Associate Planner/Wetland Specialist)
with Jefferson County Development Review Division, sent to David W. Johnson regarding Brinnon MPR — HMP
Comments and Recommendations.
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.
This comment will be addressed in the final report and will include pre- and post -impervious surface
areas to be provided by the civil engineer for the project.
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.
If these details exist, we can include in the report. If not, the marine environment pollution control
strategies section/sentence in the report needs to be changed to either say the control strategies will
be developed or to take that sentence/section out of the report completely.
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 NMP 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 final report will be revised to be congruent with the current design. The report should say
vegetation corridors (not areas) will be undisturbed.
Memorandum to Vicki Morris, Vicki Morris Consulting Services
January 19, 2010
Page 2
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.
The final report will reference the locations of on-site infiltrations systems to be provided by the civil
engineer for this project. This information was not available at the time of the draft report.
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.
This will be addressed in the final report by clarifying existing information.
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.
This area of buffer reduction will be addressed by our evaluation of the final site plan. This will be
addressed in the final report.
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.
This comment will be address by our evaluation of the final site plan and will be incorporated into the
final report.
Figures 9 and 10 show some of the planting areas coincident with project development.
This comment will be address by our evaluation of the final site plan and will be incorporated into the
final report.
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.
This comment will be address by our evaluation of the final site plan and incorporated into the final
report.
The HMP references the critical areas stewardship program (CASP). The text of the wetland mitigation plan and HPNP
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.
We reference the program as a guideline, but recognize that it is not required. We will revise the
report to make this more clear.
Memorandum to Vicki Morris, Vicki Morris Consulting Services
January 19, 2010
Page 3
The HMP states that "wet cells" will be constructed to treat water. The location of the wetland cells should be shown on
a figure.
This comment will be addressed by our evaluation of the final site plan and the stormwater treatment
report. This will be addressed in the final report.
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.
We will reference this information from other reports when available. This will be addressed in the
final report.
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.
The Grading Plan will be referenced in the final report. We will need to review the information
pertaining to this comment that is included in the Grading Plan.
General Comments
Comments in a letter dated November 30. 2009 from Gerald Steel, the attorney for the Brinnon Group and
Brinnon MPR Opposition and addressed to David Wayne Johnson, Proiect Lead Planner.
CRITICAL AREAS
The SEIS should provide an updated wetland delineation.
The wetland delineation should be valid for 5 -years and since the wetlands were delineated in April
2006 the delineation does not need to be updated at this time. We will reference the Corps
concurrence in the final reports. An effort to contact David Wayne Johnson was unsuccessful to
confirm the 5 -year time period. We will notify the team as soon as this is confirmed with Jefferson
County.
Comments in a letter dated November 30. 2009 from Department of EcoloP-v (DOE) and addressed to David
Wayne Johnson, Proiect Lead Planner regarding their review of the environmental checklist.
SEPA REGIONAL PROJECT LEAD: Sarah Lukas (360) 407-7459
Shorelands/Wetlands
The proposed supplemental document should include analysis of all impacts to waters of the state
of Washington. The Final Environmental Impact Statement (FEIS) disclosed that several kettle
wetlands as well as Pleasant Harbor will be impacted by this proposal.
This information is already included in the reports.
To analyze impacts to shorelands, I recommend the SETS include site specific maps detailing the
proposed development activities within shoreline jurisdiction. I recommend that the site plans be
consistent with the requirements of WAC 173-27-180(9), to receive substantive comments.
The technical reports contain these figures.
Memorandum to Vicki Morris, Vicki Morris Consulting Services
January 19, 2010
Page 4
According to the Washington Coastal Atlas eel grass bed's are present within the Harbor. I
recommend the SEIS be supplemented with an eel grass survey to document current conditions.
If in -water work is proposed (marina reconstruction), then an eelgrass survey will be needed within
the impact area. We will review the shoreline atlas for eelgrass beds in the immediate vicinity of the
marina.
Wetlands should be mapped and all impacts should be disclosed'. Proximity to proposed buildings
should be clearly defined. If there are any direct impacts to wetlands proposed, the applicant will be
required to receive authorization from Ecology prior to any construction activities.
This information is already included in the reports.
Conceptual Wetland and Wetiand Buffer Mitigation pian
Comments from an email dated August 13 2009 from Donna Frostholm (Associate Planner/Wetland
Specialist) with Jefferson County Development Review Division sent to David W. Johnson regarding Brinnon
MPR - Wetland Comments and Recommendations.
Wetland Hydrology. 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.
These comments will be addressed in final report.
The d raft 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 Weiland 6 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.
Wetlands C and D do not correspond to Kettles C and D. This will be clarified in the final report.
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 wouldbe 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.
These comments will be addressed in the final report. Note, Wetlands C and D are not kettle
wetlands.
Memorandum to Vicki Morris, Vicki Morris Consulting Services
January 19, 2010
Page 5
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.
This will be clarified in the report, but we will not conduct a separate analysis since a lot of
geotechnical work has already been completed. This was looked at and hydrology to the wetlands
were tied to stormwater runoff from the fairways of the golf course. After treatment, water would flow
into these wetlands at pre -construction volumes and rates.
Weiland 8 flmpacr Areo). 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,
There is an existing road to the bottom of the kettle for equipment access. The percent compaction
will be identified by the site civil engineer and added to the final mitigaiton plan.
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 its 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.
There is no reference to the top 24 inches of soil from Wetland B. The depth of hydric soils in
Wetland B is variable. However, as much of the hydric topsoil will be recovered as practical. The
report will be revised to state this clearly. Kettle areas do not always have "typical topsoil conditions"
Duff, and other organics can accumulate at increased rates due the the closed depression (this is
why wetlands commonly form in these areas). Topsoil may be that deep in the kettle. Let's check the
boring logs if Vinnie took some in this 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.
This will be addressed in the revised report. Page 11 is not referring to salvaging plants but is
referring to the specification of species for planting which will reflect the same species in the
wetlands.
Memorandum to Vicki Morris, Vicki Morris Consulting Services
January 19, 2010
Page 6
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.
See comment above. There is no intention of salvaging plants. If there is mention of salvaging, we
will revise the report to state this clearly.
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.
This will be addressed in the final report. Statesman will be responsible as the applicant.
6. A goal of the mitigation plan is to provide on-site, in-kind compensatory mitigation. Wetland 8 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.
Wetland B has seasonal open water areas that are unvegetated and the proposed mitigation wetland
will have seasonal open water areas where vegetation is unlikely to become established. The plan
does provide on-site, in-kind compensatory mitigation.
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.
This comment will be addressed in the final report.
8. A performance standard should be added to address wetland hydrology (that matches the goals of the of the
mitigation proposal).
This comment will be addressed in the final report.
9. The mitigation plan need's 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.
This comment will be addressed in the final report.
10. The mitigation plan should state that the outer edge of the wetland buffers will be staked prior to beginning any
ground -disturbing activities.
This comment will be addressed in the final report.
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.
We do not want to specify using silt fenceing since there are other less disturbing to the habitat and
higher -functioning best management practices that exist and will be used. A Temporary Erosion and
Sediment Control Plan that will specify best management practices will be developed by others prior
to construction.
Memorandum to Vicki Morris, Vicki Morris Consulting Services
January 19, 2010
Page 7
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.
This comment will be addressed in the final report.
Wetlands C and D (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.
This comment will be addressed in the final report and figures.
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.
This comment will be addressed in the final report and figures.
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.
This comment will be addressed in the final report and figures.
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 replanting 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.
This comment will be addressed in the final report.
Wettand 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.
This information is provided in the habitat management plan and will be referenced in the mitigation
plan.
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.
These areas will be signed, but no fencing is proposed along the fairways. This will be clearly stated
in the mitigation report.
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.
We will refer to the Grading Plan to address comment this in the final report.
Memorandum to Vicki Morris, Vicki Morris Consulting Services
January 19, 2010
Page 8
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.
Impacts addressed in the report are specific to wetlands and buffers. Additional impacts to other
habitats are addressed in the habitat management plan.
Comments from a memorandum dated September 21, 2009 from ESA Adolfson, sent to David W. Johnson
reP,arding Pleasant Harbor - Comments on Wetland and Buffer Mitigation Plan.
The plan contains minimal information about impact avoidance and min'3nization, sosome additional
discussion is warranted to indicate that the applicant has met the natigation sequencing test. This "test"
could be an issue that Ecology or other stakeholders may zsk about during the EIS process, as the pr(J"t
is required to follow the standard mitigation sequence. That said, this is not your typical wetland fill
situati:)n since Wetland R is located in the bottom of a deep depression and one could argue that vishig
this ar.-a as a water source for the development site is worth the tradcoff (assuming that the water use
analysis bears that otit).
Sequencing is addressed in the mitigation approach section. We will revise the plan to include a
separate section for mitigation sequencing.
The proposed mitigaticri generally compensates for the expected impacts in that the applicant would be
creating a wetland that is {apparently) very similar to the one being filled, This is a typical on-site, in-kind
mitigation upprouch. A question that may be raised during EIS review is whether the proposed nitigatioa
is the best option for the ,ilc. The replacement wetimW will bc at flit: lbottum of a I 10 -foot -deep natural
depmr sion, which, although similar to the wetland to be filled, would secin to have limited ecological or-
cultural
rcultural value, Are bf,-ttUT mitigation options available? The Mitigation Plan memo indicutcs 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 dixcus.sinn of the assessment would help clarify the
decision -riteria. That 4aid, the PTOPOsed approach appears to satisfy regrialatory requirements.
The comment is noted. The proposed mitigation was chosen to closely replicate the impacted
wetland as well as address local and federal regulations. This is the best option to maintain a
diversity of habitat at the site.
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 terms of their location. From the figures, it appears that theses buffer additions
may provide only limited added protection to the respective wetlands.
The buffer addition areas have been placed where natural runoff flows overland before entering the
wetland areas, thus enhancing the protecitve functions of the buffer.
Memorandum to Vicki Morris, Vicki Morris Consulting Services
January 19, 2010
Page 9
The plan states that one of the goals is to create "undisturbed corridors between rivers, streams, wetland
systems, intact upland habitats, and other natural ureas," but it is not immediately clear that the proposed
approach supports this a nn. Further discusion of this goal, and illustrations of proposed corridors (or
revi.sions to the site plan if warranted) would be helpful.
The undisturbed corridors are further discussed in the habitat management plan, which also includes
a figure that depicts the proposed corridors connecting wetland, stream, upland and shoreline
habitats. Use of the word "undisturbed" is the sticking point.
From Page 3 of 22- File lcomments-PH-DraftTechnicalReports-Sep22-09.pdf County Staff Comments
Golf Course Development — GeoEngineers
Page 3 & 4 — mitigation measures identified here should be included in the SEIS
These mitigation measures will be included in the SEIS.
Is there a training program or plan for educating course personnel?
The final report will reference training or education opportunities, if applicable.
Page 7, Application BMPs — what is a hooded boom and what does it look like?
The term hooded boom will be described in final.
Page 8, Turf Management BMPs — Give an example of timing of application to minimize
leaching and votalization, slow vs. quick release, etc.
The final report will describe Earth Renew examples and cite their proposal.
Page 8, Turf Management BMPs — three bullet points are duplicated here.
Duplicate bullets will be deleted.
Page 10, Cultural and Physical Controls - How do you remove dew on non -mowing days during
disease -conducive periods?
The final report will include a description of the process.
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.
We do not understand this comment. "Principles" is the correct usage.
Page A-1 — Add "Name of Applicator" to the log sheet
A column for name of applicator will be added to log sheet.
Memorandum to Vicki Morris, Vicki Morris Consulting Services
January 19, 2010
Page 10
From Page 4 of 22- File lcomments-PH-DraftTechnicalReports-Sep22-09.pdf County Staff Comments
Water Quality Monitoring Plan — Subsurface Group
Page 2, 2"d PP — 802 seasonal and permanent seasonal residential dwellings? Shouldn't it be
890?
The final report will include the proper number, consistent with the SEIS documents.
Page 3, 3`d PP, last sentence — "is will be"
The final report will include the correction (deletion of "is").
Page 7, 2"° PP, 3T° sentence — Tables 3 and 5, should be 4 and 5. Last sentence — Table 5, should
be 6.
The text in the report will be corrected.
Page 8, 2"d PP, 3`d sentence — "approving" should be approved.
The final report will include the edit.
From Pages 6 through 8 of 22- File lcomments-PH-DraftTechnicalReports-Sep22-09.pdf Neil Harrington -
Jefferson Count Water Quality Program Manager
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)
We will ask the civil engineer for this information. .
From Pg 2, paragraph under Fresh Water: will the storm water treatment system
be sized to include the referenced runoff from Hwy 101 ?
The final report will include a reference to the stormwater report detailing the treatment of HWY 101
runoff.
Prom rage 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 storm 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.
The final report will include a reference to the stormwater report referencing proposed treatment for
these constituents. Baseline data is to be established with the implementation of the sampling plan
(see Table 7).
Memorandum to Vicki Morris, Vicki Morris Consulting Services
January 19, 2010
Page 11
• Pg. 3, bullet 3: should include standards for not only Ecology but also
Washington State Department of Health.
Washington State Department of Health (DOH) water quality standards apply to drinking water not to
stormwater. DOE, with assistance from DOH, is working on a new Reclaimed Water Rule WAC 173-
219 that refers to Class A and Class B water quality standards. The rule has not been finalized.
• Pg. 3 bullet 5: notification should be to Jefferson County and the Department of
Ecology.
The final report will be revised to include the intent that the DOE will be notified if state contaminant
levels are exceeded.
• 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.
See table 7, Proposed Monitoring Schedule, which propose baseline monitoring.
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.
An additional monitoring point could be added to the plan to include marine shorelines, though water
quality there would be influenced by multiple factors other than the usage of Pleasant Harbor. This
needs to be discussed further within the team. We believe there is a DOE monitoring station just
offshore of this location. We can ask the applicant if they wish to do so.
• Appendix A was not attached for review.
Appendix A will include standard operating procedures developed by DOE and guidelines developed
by Puget Sound Water Quality Action Team for sampling in Puget Sound (a total of ten documents).
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.
The parameters listed in Tables 4 and 5 are those that the multi -parameter field unit measures. We
will discuss with the team whether other parameters should be added.
Memorandum to Vicki Morris, Vicki Morris Consulting Services
January 19, 2010
Page 12
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.
The paragraph refers to specific procedures establish by DOE. The adaptive management section of
the Water Quality report specifically discussed that Jefferson County will be consulted regarding
modifications.
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.
The provision for consultation with Jefferson County is included in the current discussion. The
requirement for the Water Quality MP to be a recorded document is an issue for a lawyer and likely
should not be addressed in this technical report.
From Page 11 of 22- File lcomments-PH-DraftTechnicalReports-Sep22-09.pdf SvR Design Company -
Peg Staehel. ASLA and Amalia Leighton, PE Memorandum #1 August 5, 2009
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.
The final report will include clarifications of monitoring responsibilities.
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.
The final report will include references to the 2005 Stormwater Manual.
Subj: Re: Pleasant Harbor SEIS Scoping Comments for Review: PDF File 1
Date: 1/12/2010 9:51:40 A.M. Pacific Standard Time
From: mikeread(@tenw.com
To: VMorrisCS(a)aol.com
CC: peckassoc(a)comcast.net
Vicki.-
Per
icki:Per your request, I have made my first stab at reviewing the issues you have noted below. My responses
are in blue.
VMorrisCS(a)aol.com wrote:
Mike
I have identified the following letters of comment that Jefferson County and I would like you to review in
relation to the content of the Transportation Impact Study you have prepared for the Pleasant Harbor
Marina and Golf Resort. I am resending the County's pdf files of SEIS Scoping comments in order to
assure that the page numbers I have referenced correlate accurately to the electronic files to which I
refer. There is no difference in the content of these files from what you may have previously received from
Garth. Page numbers preceded by 1- are in the Part 1 pdf file (attached). I will send the Part 2 pdf file
separately, along with the list of comments for your review in that file.
PDF 1-1 through 1-10 Hood Canal Environmental Council (Andrea Mitchell) letter dated 11/27/09
Please review comments on pages 2, 5 and 6 of this letter, as follows:
Page 2: the first, third and sixth bullet items on this page
First bullet is not traffic related, can be addressed in a final report, and I would need to see the
previous letter to respond to the sixth bullet.
Page 5: the last bullet item on this page.
Addressed in final report.
Page 6: the top five bullet items on this page.
Addressed in final report.
PDF 1-12 through 1-17 Gerald Steel letter dated 11/30/09, representing the Brinnon Group
Please review the Traffic Planning comments at the bottom of pages 3 / top of page 4 of this letter (PDF
1-15 and 1-16), and the Parking and Road Standards comments on page 4 (PDF 1-16).
Addressed in final report.
PDF 1-17 through 1-29 Jefferson County Department of Public Works memo dated 11/30/09
1 don't think this letter requests revisions to the Transportation Impact Study, but please check your
Mitigation Measures section(s) to be sure the County's requests are identified. It might also be helpful for
you to provide input to the draft Development Agreement to be sure these issues are addressed in the
locations requested by the Public Works Department. I have attached the draft Development Agreement
to this message. You can track changes in that file and return it to Sandy Mackie and me.
I will review the DA later this week or next, but yes I generally agree with your interpretation that
these are just restatements of already known mitigation measures.
PDF 1-50 through 1-53 Attachment 3 to Andrea Mitchell 11/23/09 transmittal: Richard Horner
letter dated 12/06/07
Please review the Potential Traffic Impacts comments at the top of page 4 of this letter (PDF 1-53), and
coordinate your response with Craig, as it seems that the issue Mr. Horner is raising is related to
pollutants in stormwater runoff from area roadways that would be generated by the increase in vehicles
attributable to the resort.
I suggest that I can provide response to a small portion of the comment letter, but a majority of it
is stormwater related.
PDF 1-54 through 1-55 Jefferson Transit letter dated 11/17/09
1 have asked Craig to respond re: the current status of communications with Jefferson Transit. I assume
that you and he have the same information re: this. If not, please coordinate your response with Craig.
The last known coordination was that we jointly developed a concept to incorporate provisions for
on-site transit in the vicinity of the overflow parking and have gotten approved egress for transit
back out onto SR 101 through our Plan for Approval (PFA) with WSDOT south of Black Point
Road. As such, I believe we have gotten all of the necessary conceptual design and access
approvals done and we would just need to package that up in a formal submittal into a report or in
response to the Transit Agency.
Please advise by the week of January 11th whether the issues identified in these comments: 1) have
already been addressed in your draft report, 2) are appropriate to address in your final report, or 3) are
outside the scope of the standard of practice for a technical report on your subject prepared at this stage
of a project (i.e., in support of an EIS). Please provide this response with regard to each item listed above
(rather than a general response). Your input will be used in discussions with the County to determine the
final scope of work for your technical report.
Feel free to contact me if you have any questions re: this request
Thank you,
Vicki
Vicki Morris Consulting Services
7732 18th Avenue NE
Seattle, WA 98115-4426
206.522.8057
Cellular: 206.501.8227
FAX: 206.523.4648
Michael Read, PE
Principal
Transportation Engineering Northwest
PO Box 65254
Seattle, WA 98155
Office - 206.361.7333 ext. 101
Mobile - 206.999.4145
Fax - 206.361.7333
Subj: Pleasant Harbor SEIS Scoping Comments for Review: PDF File 1 SECOND
Date: 1/14/2010 6:47:15 P.M. Pacific Standard Time
From: Scott@benderllc.com
To: vmorrisCS@aol.com
Cc: peckassoc(dcomcast.net, scott@benderllc.com
Vicki — responses to part 1. Scott
From: VMorrisCS@aol.com [mailto:VMorrisCS@aol.com]
Sent: Sunday, January 03, 2010 6:08 PM
To: scott@benderllc.com
Cc: peckassoc@comcast.net
Subject: Pleasant Harbor SEIS Scoping Comments for Review: PDF File 1
Scott:
I have identified the following letters of comment that Jefferson County and I would like you to review in
relation to the content of your Water Supply and Groundwater Impact Analysis technical report. I am
resending the County's pdf files of SEIS Scoping comments in order to assure that the page numbers I
have referenced correlate accurately to the electronic files to which I refer. There is no difference in the
content of these files from when you first received them from Garth. Page numbers preceded by 1- are in
the Part 1 pdf file (attached). I will send the Part 2 pdf file separately, along with the list of comments for
your review in that file.
PDF 1-1 through 1-10 Hood Canal Environmental Council (Andrea Mitchell) letter dated 11/27/09
Please review the third bullet item on page 3 of this letter re: the availability of potable water and saltwater
incursion issues.
Addressed in report
PDF 1-11 Kathleen Boutiette e-mail message dated 11/30/09
This is the first of several identical (or very similar) e-mail messages that raise issues re: the amount of
water that will be needed for the resort, and "definition" of the aquifer. Others include: PDF 1-18 (Foster),
PDF 1-22 (Ellie), PDF 1-30 (Newman; PDF 1-31 (Bond), and PDF 1-35 (Alfano). When you have
considered the comments in Ms. Boutiette's e-mail message, you will have addressed these other
comments, as well.
Addressed in report
PDF 1-12 through 1-17 Gerald Steel letter dated 11/30/09, representing the Brinnon Group
Please review the saltwater intrusion comments on page 2 of this letter.
Addressed in report
PDF 1-23 through 1-26 Ecology letter dated 11/30/09 (transmitted by Sonia Mendoza)
Please review the Water Resources comment at the bottom of page 2 of the November 30th letter (PDF
1-25). Is this an accurate statement?
This is true.
Is the "cost reimbursement process for water right decisions" described in your report?
No.
I would like to have this information for inclusion in the SEIS
OK, we are very close to getting the permit, hopefully we can have it by the time we write the report. It is
a very sensitive process, so all I would say is that it is favorably progressing.
PDF 1-36 through 1-41 Andrea Mitchell 11/23/09 e-mail transmittal, Attachment 1: 7/16/09 letter
Please review the first
- Ecology has considered the Brinnon Group protest, and is incorporating their comments in their decision
and monitoring requirements
and last bullet items on page 1 of this letter (PDF 1-37),
- maybe these are potential sources on a list, but the site will go through best management practices, the
soil is well suited for natural retardation of contaminants if need be
and the second bullet item on page 2 of this letter (PDF 1-38).
There are many comments on water use estimates being low. They are not. The 2020 Engineering
report is an older one for this project, but is reliable. Our total demand uses their numbers and seasonal
occupancy estimates for the resort. It is the seasonal thing that most people forget to use in their
analyses. Also, we rely on 175 gallons per day in all calculations, not the 73 gallons per day we hope to
achieve after demonstrating water use over a minimum of three years.
PDF 1-42 through 1-49 Attachment 2 to Andrea Mitchell 11/23/09 transmittal: Gerald Steel letter
dated 1/19/09 re: Brinnon Group Opposition to Approval of Water Right Permit Application
You may have already reviewed and addressed in your report the issues raised in this letter, due to how
long ago it was prepared and originally submitted.
I do not believe I have seen this letter (which I should have gotten from Ecology). But yes these issues
have been corrected or are being addressed by Ecology. Some of them are addressed in the report.
PDF 1-50 through 1-53 Attachment 3 to Andrea Mitchell 11/23/09 transmittal: Richard Horner
letter dated 12/06/07
Please review the water quality and infiltration issues raised on page 3 of this letter (PDF 1-52) and
discuss with Craig.
Craig said he would be happy to address this (!) Actually I am not sure if there is a good enough section
on this (infiltration of chemicals) in any of our reports. It is part of a lot of disciplines. I think Craig and I,
and maybe Rick should have a brief in each of our reports. Please advise.
Please advise by the week of January 11th whether the issues identified in these comments: 1) have
already been addressed in your draft report, 2) are appropriate to address in your final report, or 3) are
outside the scope of the standard of practice for a technical report on your subject prepared at this stage
of a project (i.e., in support of an EIS). Please provide this response with regard to each item listed
above. Your input will be used in discussions with the County to determine the final scope of work for your
technical report.
Feel free to contact me if you have any questions re: this request.
Thank you,
Vicki
Vicki Morris Consulting Services
7732 18th Avenue NE
Seattle, WA 98115-4426
206.522.8057
Cellular: 206.501.8227
FAX: 206.523.4648
Subj: Pleasant Harbor SEIS Scoping Comments for Review: PDF File 1 SECOND
Date: 1/14/2010 6:47:15 P.M. Pacific Standard Time
From: scott@benderllc.com
To: vmorrisCS@aol.com
Cc: peckassoc(a)comcast. net, scott@benderllc.com
Vicki — responses to part 1. Scott
From: VMorrisCS@aol.com [mailto:VMorrisCS@aol.com]
Sent: Sunday, January 03, 2010 6:08 PM
To: scott@benderllc.com
Cc: peckassoc@comcast.net
Subject: Pleasant Harbor SEIS Scoping Comments for Review: PDF File 1
Scott:
I have identified the following letters of comment that Jefferson County and I would like you to review in
relation to the content of your Water Supply and Groundwater Impact Analysis technical report. I am
resending the County's pdf files of SEIS Scoping comments in order to assure that the page numbers I
have referenced correlate accurately to the electronic files to which I refer. There is no difference in the
content of these files from when you first received them from Garth. Page numbers preceded by 1- are in
the Part 1 pdf file (attached). I will send the Part 2 pdf file separately, along with the list of comments for
your review in that file.
PDF 1-1 through 1-10 Hood Canal Environmental Council (Andrea Mitchell) letter dated 11/27/09
Please review the third bullet item on page 3 of this letter re: the availability of potable water and saltwater
incursion issues.
Addressed in report
PDF 1-11 Kathleen Boutiette e-mail message dated 11/30/09
This is the first of several identical (or very similar) e-mail messages that raise issues re: the amount of
water that will be needed for the resort, and "definition" of the aquifer. Others include: PDF 1-18 (Foster),
PDF 1-22 (Ellie), PDF 1-30 (Newman; PDF 1-31 (Bond), and PDF 1-35 (Alfano). When you have
considered the comments in Ms. Boutiette's e-mail message, you will have addressed these other
comments, as well.
Addressed in report
PDF 1-12 through 1-17 Gerald Steel letter dated 11/30/09, representing the Brinnon Group
Please review the saltwater intrusion comments on page 2 of this letter.
Addressed in report
PDF 1-23 through 1-26 Ecology letter dated 11/30/09 (transmitted by Sonia Mendoza)
Please review the Water Resources comment at the bottom of page 2 of the November 30th letter (PDF
1-25). Is this an accurate statement?
This is true.
Is the "cost reimbursement process for water right decisions" described in your report?
No.
I would like to have this information for inclusion in the SEIS
OK, we are very close to getting the permit, hopefully we can have it by the time we write the report. It is
a very sensitive process, so all I would say is that it is favorably progressing.
PDF 1-36 through 1-41 Andrea Mitchell 11/23/09 e-mail transmittal, Attachment 1: 7/16/09 letter
Please review the first
- Ecology has considered the Brinnon Group protest, and is incorporating their comments in their decision
and monitoring requirements
and last bullet items on page 1 of this letter (PDF 1-37),
- maybe these are potential sources on a list, but the site will go through best management practices, the
soil is well suited for natural retardation of contaminants if need be
and the second bullet item on page 2 of this letter (PDF 1-38).
There are many comments on water use estimates being low. They are not. The 2020 Engineering
report is an older one for this project, but is reliable. Our total demand uses their numbers and seasonal
occupancy estimates for the resort. It is the seasonal thing that most people forget to use in their
analyses. Also, we rely on 175 gallons per day in all calculations, not the 73 gallons per day we hope to
achieve after demonstrating water use over a minimum of three years.
PDF 1-42 through 1-49 Attachment 2 to Andrea Mitchell 11/23/09 transmittal: Gerald Steel letter
dated 1/19/09 re: Brinnon Group Opposition to Approval of Water Right Permit Application
You may have already reviewed and addressed in your report the issues raised in this letter, due to how
long ago it was prepared and originally submitted.
I do not believe I have seen this letter (which I should have gotten from Ecology). But yes these issues
have been corrected or are being addressed by Ecology. Some of them are addressed in the report.
PDF 1-50 through 1-53 Attachment 3 to Andrea Mitchell 11/23/09 transmittal: Richard Horner
letter dated 12/06/07
Please review the water quality and infiltration issues raised on page 3 of this letter (PDF 1-52) and
discuss with Craig.
Craig said he would be happy to address this (I) Actually I am not sure if there is a good enough section
on this (infiltration of chemicals) in any of our reports. It is part of a lot of disciplines. I think Craig and I,
and maybe Rick should have a brief in each of our reports. Please advise.
Please advise by the week of January 11th whether the issues identified in these comments: 1) have
already been addressed in your draft report, 2) are appropriate to address in your final report, or 3) are
outside the scope of the standard of practice for a technical report on your subject prepared at this stage
of a project (i.e., in support of an EIS). Please provide this response with regard to each item listed
above. Your input will be used in discussions with the County to determine the final scope of work for your
technical report.
Feel free to contact me if you have any questions re: this request
Thank you,
Vicki
Vicki Morris Consulting Services
7732 18th Avenue NE
Seattle, WA 98115-4426
206.522.8057
Cellular: 206.501.8227
FAX: 206.523.4648
Page 1 of 2
Subj: RE: Pleasant Harbor County Staff and Peer Review Comments for Review - FIRST
Date: 1/14/2010 6:25:10 P.M. Pacific Standard Time
From: scott(u1benderlic.com
To: vmorriscs@_aol.com
CC: peckassoc(a�comcast.net, scott@benderllc.com
Hi Vicki - this is the first response for the three emails you sent me. The responses are
brief, like I believe you asked for, please feel free to ask for additional information or
clarification.
Thanks, Scott
From: vmorriscs@aol.com [mailto:vmorriscs@aol.com]
Sent: Monday, January 04, 2010 1:38 PM
To: scoff@benderllc.com
Cc: peckassoc@comcast.net
Subject: Pleasant Harbor County Staff and Peer Review Comments for Review
Hello again, Scott.
I have identified the following sets of comments received from Jefferson County staff and members of the
Peer Review Team for your review in relation to the content of your Water Supply and Groundwater
Impact Analysis report. I am resending the comment files that you likely received from Craig in October in
order to assure that the page numbers I have referenced correlate accurately to the electronic files to
which I refer. (I renamed the files for clarity in this process.) There is no difference in the content of the
attached files from when you first received them. Page numbers preceded by 1- are in the File 1
comments pdf document (attached). File 3 (comments prepared by Bill Persich, Brown and Caldwell)
also pertain to your technical report and therefore is attached.
PDF 1-2 and 1-4 Draft Technical Reports -- County Staff Comments dated 9/22/09
There are two very minor comments on page 2 of the County staff comments under your report title.
I would also like you to review and consider the first paragraph under the heading Summary & General
Comments on page 4.
® Recharge conditions to the aquifer due to removal of vegetation have been addressed.
Stormwater runoff will be addressed by Craig. The typos will be fixed. At the bottom and
on page 3 are geotechnical questions that I assume have been passed on to Vinnie.
PDF 1-17 Susan Porto e-mail message dated 8/20/09
Three bullet items.
m I believe these items have been addressed, but given the frequency of similar comments I
will expand upon in the report.
PDF File 3 Bill Persich comments on the Water Supply and Groundwater Impact Analysis report.
Bill had relatively few comments in this document: see pages 1, and 15 through 17 of your report (PDF 3
pages 4 and 18 through 20).
® Most of these comments come from an incomplete understanding of the project by the
reviewer. A few of these can be expanded upon in the report.
Concurrent with your review of SEIS Scoping comments (sent 1/03/10), please reply by the week
of January 11th whether the issues identified in the County staff and Peer Review team comments: 1) are
appropriate to address in your final report; 2) can now be addressed based on additional information
provided by Statesman since your draft report was prepared (e.g., the Earth Renew proposal); or 3) are
not necessary or appropriate in your professional opinion (or not necessary based on something you
know that may not have been apparent to County staff and peer reviewers). If you think some of the
comments are unnecessary to address, please provide an explanation for your point of view. Please
Thursday, January 14, 2010 AOL: VMorrisCS
Page 2 of 2
provide this response with regard to each comment you review. Your input will be used in discussions with the
County to determine the final scope of work for your technical report.
Feel free to contact me or Craig if you have any questions re: this request.
Thank you,
Vicki
Vicki Morris Consulting Services
7732 18th Avenue NE
Seattle, WA 98115-4426
206.522.8057
Cellular: 206.501.8227
FAX: 206.523.4648
Thursday, January 14, 2010 AOL: VMorrisCS
Page 1 of 2
Subj: RE: Pleasant Harbor County Staff and Peer Review Comments for Review - FIRST
Date: 1/14/2010 6:25:10 P.M. Pacific Standard Time
From: scott a().benderllc.com
To: vmorriscs(o)aol.com
CC: peckassoc(o)comcast. net, scott .bend erllc.com
Hi Vicki - this is the first response for the three emails you sent me. The responses are
brief, like I believe you asked for, please feel free to ask for additional information or
clarification.
Thanks, Scott
From: vmorriscs@aol.com [mailto:vmorriscs@aol.com]
Sent: Monday, January 04, 2010 1:38 PM
To: scoff@benderllc.com
Cc: peckassoc@comcast.net
Subject: Pleasant Harbor County Staff and Peer Review Comments for Review
Hello again, Scott.
I have identified the following sets of comments received from Jefferson County staff and members of the
Peer Review Team for your review in relation to the content of your Water Supply and Groundwater
Impact Analysis report. I am resending the comment files that you likely received from Craig in October in
order to assure that the page numbers I have referenced correlate accurately to the electronic files to
which I refer. (I renamed the files for clarity in this process.) There is no difference in the content of the
attached files from when you first received them. Page numbers preceded by 1- are in the File 1
comments pdf document (attached). File 3 (comments prepared by Bill Persich, Brown and Caldwell)
also pertain to your technical report and therefore is attached.
PDF 1-2 and 1-4 Draft Technical Reports -- County Staff Comments dated 9/22/09
There are two very minor comments on page 2 of the County staff comments under your report title.
I would also like you to review and consider the first paragraph under the heading Summary & General
Comments on page 4.
e Recharge conditions to the aquifer due to removal of vegetation have been addressed.
Stormwater runoff will be addressed by Craig. The typos will be fixed. At the bottom and
on page 3 are geotechnical questions that I assume have been passed on to Vinnie.
PDF 1-17 Susan Porto e-mail message dated 8/20/09
Three bullet items.
• I believe these items have been addressed, but given the frequency of similar comments I
will expand upon in the report.
PDF File 3 Bill Persich comments on the Water Supply and Groundwater Impact Analysis report.
Bill had relatively few comments in this document: see pages 1, and 15 through 17 of your report (PDF 3
pages 4 and 18 through 20).
® Most of these comments come from an incomplete understanding of the project by the
reviewer. A few of these can be expanded upon in the report.
Concurrent with your review of SEIS Scoping comments (sent 1/03/10), please reply by the week
of January 11th whether the issues identified in the County staff and Peer Review team comments: 1) are
appropriate to address in your final report; 2) can now be addressed based on additional information
provided by Statesman since your draft report was prepared (e.g., the Earth Renew proposal); or 3) are
not necessary or appropriate in your professional opinion (or not necessary based on something you
know that may not have been apparent to County staff and peer reviewers). If you think some of the
comments are unnecessary to address, please provide an explanation for your point of view. Please
Thursday, January 14, 2010 AOL: VMorrisCS
Page 2 of 2
provide this response with regard to each comment you review. Your input will be used in discussions with the
County to determine the final scope of work for your technical report.
Feel free to contact me or Craig if you have any questions re: this request.
Thank you,
Vicki
Vicki Morris Consulting Services
7732 18th Avenue NE
Seattle, WA 98115-4426
206.522.8057
Cellular: 206.501.8227
FAX: 206.523.4648
Thursday, January 14, 2010 AOL: VMorrisCS