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HomeMy WebLinkAbout005Michelle Farfan From: David W. Johnson <dwjohnson@co jefferson.wa.us> Sent: Monday, February 01, 2010 9:16 AM To: Al Scalf; Stacie Hoskins Subject: FW: Forestry Consultant Response to Comments Attachments: RMG_ResponseToCountyComments-Jan31.10.pdf Can we review these responses and talk about them at tomorrow's afternoon meeting? From: VMorrisCS@aol.com [mailto:VMorrisCS@aol.com] Sent: Sunday, January 31, 2010 10:31 AM To: David W. Johnson Cc: peckassoc@comcast.net Subject: Forestry Consultant Response to Comments David: Attached is the Resource Management Group response to Jefferson County staff comments on the draft Forestry Report prepared for the Pleasant Harbor Marina and Golf Resort property. How is your review coming along of other responses sent 1/20/10? Craig is still working on the site plan alternatives. The project architect has been out on vacation, so it has been slow to obtain the electronic files needed. He and I will be meeting on Monday to work on the narrative descriptions. 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 Resource Management Group... RMG 13520 Military Rd SE ♦ Rainier, WA 98576 (253) 377-7751 • ResourceMgmtGroup@msn.com RMG Response to County Staff Comments on the Pleasant Harbor MPR Draft Forestry Report — 1/31/10 age 21 — "The system looked at the property from a forestry standpoint." We are concerned iat the report evaluates the site as a working forest, or from a timber management perspective rhich it obviously is not suited for or currently used for. This point of view has skewed the :port by shifting the value of the trees from one where the trees are important for "the screening f facilities and amenities..., the preservation of natural features, historic sites," and "be esigned to blend with the natural setting and,... screen the development and its impacts from the Jjacent rural areas (BoCC Ordinance 01-0128-08 #63 U)" to one where the importance is more a "resource," i.e., timber. RMG response p-21: The report describes the current condition of the vegetation on the site with emphasis on the trees because BoCC Conditions "s" and "w" appeared to us to include this emphasis. The inventory divides the plant communities into mapped areas of like tree cover and condition and provides a description of those communities. This inventory could be used to plan the layout of the resort by utilizing the inventory maps and descriptions to save specific types or sizes of trees and understory. However, the FEIS and subsequent resort layouts indicate that the majority of the resort south of Black Point Road will be cleared and graded to create the golf course, building sites, created wetlands, and irrigation pond. The FEIS and interim alternative show significant clearing and grading at the marina. The preferred alternative eliminates clearing and grading at the marina site, thus preserving the current treed buffer along Highway 101. A perimeter buffer has been provided for the resort in which all desirable vegetation will be saved and enhanced as needed. The report inventory could be used in conjunction with the grading plan and site plan to determine areas where earthwork cuts and fills are sufficiently small to preserve healthy stands of trees and shrubs. It may be helpful to modify the report title from "Forestry Report" to "Forest Report". A subtle change but one that may produce a different and more accurate understanding of the true purpose of the report for some readers who may see the two terms as dissimilar in meaning. Page 22 —This inventory is helpful in understanding the different areas with vane eves o 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. RMG response p-22: See response to p-21 above. RMG response to Staff Comments / 1/31/2010 page 1 of 1 477 Resource Management Group... RMG 13520 Military Rd SE ♦ Rainier, WA 98576 (253) 377-7751 • ResourceMgmtGroup@msn.com com 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. RMG response p-33: The report inventory describes the existing conditions on the site. The site plans in the FEIS, the interim alternative, and the preferred alternative illustrate perimeter buffers, wetland creation, wetland preservation, and the irrigation pond. By overlaying the inventory map and the site plans, information regarding the possible extent to which evergreen trees and understory could be preserved within the alternative site plan concepts can be determined. Comparison of economic benefit perhaps should be omitted from the report. Also see the RMG response to the paragraph that follows County staff comments on p-34 below. e report concludes with the idea of "complete restoration of the site (page 33)." In other ords, 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 RMG response p-33: The FEIS provided an illustration of the extent of clearing and grading necessary to achieve the objectives of the proposal. That illustration showed that it would be necessary to clear the majority of the site for grading. That illustration also showed perimeter buffer areas to be retained where healthy mature trees could continue to provide screening. The buffer area and other areas including wetland and stream buffers could retain mature trees. Replanting areas throughout the resort after grading would restore native species. This is the extent to which it is possible to retain trees on the site and still meet the objectives of the site development proposal. 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 SETS 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. RMG response P-34: The site plan and grading plans show areas of native vegetation to be retained. The inventory map illustrates the vegetation that exists in the areas to be retained. A characterization of the content of these retention areas could be made to describe the RMG response to Staff Comments / 1/31/2010 Page 2 of 2 Resource Management Group... RMG 13520 Military Rd SE ♦ Rainier, WA 98576 (253) 377-7751 • ResourceMgmtGroup@msn.com percentage of significant trees for the SEIS. These buffer areas would be preserved in perpetuity within the Development Agreement. 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. RMG response: Our final report will review the location of healthy, mature trees in relation to conceptual site plans for the alternatives being evaluated in the SEIS for the purpose of identifying areas where a balance can be achieved between tree retention and meeting the objectives of the proposal to develop an 18 -hole golf course and 890 residential units within a Master Planned Resort on the property. A basic environmental consideration that has not been address in either this reportor any of er 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. RMG response: Evaluating changes in hydrology on the site as a result of tree removal is being addressed in one or more technical reports prepared by other members of the consultant team (for example, the Grading and Drainage Technical Engineering Report prepared by Craig Peck). Hydrological analysis is not within the scope of work for the Forestry Report. 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 30ard of County Commissioners conditions of approval...." That is a reasonable conclusion, but t is not a vegetation management plan. RMG response: It is true that the report has a strong focus on hazard trees. For reasons of health and safety, trees in this condition comprise the largest part of the list of higher priority issues regarding vegetation that is currently found on the site. It is also important to recognize that careful planning and continuing management of the forest communities and other plant RMG response to Staff Comments / 1/31/2010 0 , Resource Management Group... RMG 13520 Military Rd SE ♦ Rainier, WA 98576 (253) 377-7751 • ResourceMgmtGroupaa msn com communities that will remain and be protected on the site during and following construction, is critical to meeting a number of the BoCC objectives. To that end, we included some basic information (a "Prescriptive" Plan) for a vegetation management plan that we felt would be useful to help guide formation of an actual vegetation management plan at a future time. Until such time as the final development footprint is agreed upon by all parties, it may be premature to construct the final plan itself. However, to present some important concepts that may be valuable to formation of the final plan seemed in -context as the report was titled. After review we think that additional language could be added in "Section 1.0 Purpose" and "Section 2.0 Introduction" to better link these sections of the report to the ideas presented in "Section 4.0 Assessing the Desired Future Condition, Long -Range Planning" and later portions of the report, as well. This may help readers to better understand the concept of long range goals for vegetation management as a continuum that begins in the more immediate work of assuring safety on the construction site for both the human element and the plants that will remain following completion of the development, and concludes with the assurance that natural features will be incorporated and retained to the extent feasible as desired by the BoCC. It may also be helpful to modify the title of the Report to present a more focused picture of the two elements of context presented within the report. A couple of suggestions might be: Prescription for a Final Vegetation Management Plan (Or perhaps) Prescription for Achieving and Maintaining the BoCC Desired Vegetation Condition RMG response to Staff Comments / 1/31/2010 Page Ar ci;