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From: David W. Johnson <dwjohnson@cojefferson.wa.us>
Sent: Thursday, August 06, 2009 8:12 AM
To: Al Scalf; Stacie Hoskins
Subject: FW: Peer review comments on draft EIS Outline and 4 Technical Reports
Attachments: memo re outline and tech reports 8.5.09.doc; Memol_Peer Review Technical Reports
2009-08-05.pdf
FYI
From: Lloyd Skinner [mailto:LSkinner@esassoc.com]
Sent: Wednesday, August 05, 2009 5:21 PM
To: David W. Johnson
Cc: Peg Staeheli
Subject: Peer review comments on draft EIS Outline and 4 Technical Reports
Hi, David —
Attached you will find a memo with comments on the draft outline of the Supplemental EIS for the Pleasant Harbor
proposal, and a memo from SvR addressing the technical reports for Grading and Drainage, Golf Course BMPs, Water
Quality, and Groundwater. Review of water supply and wastewater technical reports from Bill Persich has not yet been
completed; I'm sending these along because I thought you'd rather see them now than wait for everything at once.
I'm heading out on vacation tomorrow, back at the end of next week. I should be able to pick up email during my
vacation, however, so feel free to send me emails and I'll try to respond promptly.
Thanks!
- Lloyd
Lloyd Skinner, AICP
Senior Vice President j Northwest Regional Director
ESA Adolfson
5309 Shilshole Ave NW, Suite 200
Seattle, WA 98107
206.789.9658 / 206.789-9684 fax
(skinner@esassoc.com
r ESA 5309 Shilshole Avenue NW www.adolfson.com
Suite 200
Seattle, WA 98107
206.789.9658 phone
206.789.9684 fax
memorandum
date August 5, 2009
to David Wayne Johnson
from Lloyd Skinner
subject Pleasant Harbor
Review of Draft Outline of EIS
We received the draft outline of the Pleasant Harbor Marina and Golf Resort Master Planned Community
Supplemental Environmental Impact Statement at the July 20 site meeting. The outline is very helpful in
anticipating how the project impact analysis will be put together for County and public review. I have several
comments and suggestions for the draft outline for the County's consideration.
Treatment of each element of the environment. I see from the outline that each element of the environment is
followed by an italicized comment referring to one or more Board of County Commissioners conditions. I
recommend that the discussion of each element of the environment include a standard SEPA-style discussion of
the site's existing conditions, a discussion of the probable impacts of each alternative, and a discussion of possible
mitigation measures to address impacts identified. If the discussion then moves to an assessment of how the
proposal complies with the relevant condition(s) adopted by the Board of County Commissioners, I think that
would be fine. I would just caution that the outline as drafted implies that the discussion under each element of
the environment would ONLY address compliance with the BoCC condition(s). In my mind, that would fall short
of the complete discussion expected for a project -level EIS.
Construction impacts. I do not see a reference in the outline to construction impacts. Construction impacts can
be addressed within the discussion of each element of the environment (the impacts discussion is divided into
"construction" and "operations" sections), or alternatively a separate Construction Impacts section is prepared for
an EIS. For this large-scale construction project, the assessment of construction impacts will be an important
consideration. Issues such as construction phasing, extent of disturbance by phase for staging, clearing, grading,
and facility construction, and control of stormwater, traffic, and dust, for eample, should be addressed. It might
make more sense for a construction project of this scale to include a separate construction impacts section.
Description of the Proposal and Alternatives. The outline lays out the main sections of the EIS well. As a
minor comment that does not relate to EIS adequacy, to reduce the number of sections in Part 2.0, Description of
the Proposal and Alternatives, I suggest that we combine sections 2.2 through 2.6 (Location, History and
Background, The MPR Proposal — Principal Features, Proposed Zoning Ordinance, and Proposed Development
Agreement) into a single section, with these issues becoming sub -headings.
Technical Reports. Peg Staeheli/SvR has prepared comments on four technical reports; these are attached to this
memo. Bill Persich/Brown and Caldwell has not yet completed his review of technical reports; I will forward his
comments shortly.
DESIGN COMPANY
MEMORANDUM #01
DATE: August 5, 2009
TO: Lloyd Skinner, AICP ESA Adolphson
FROM: Peg Staeheli, ASLA
Amalia Leighton, PE
RE: Review of Technical Reports Prepared for SEIS
Pleasant Harbor Master Planned Resort — Peer Review
SvR Project No. 09025
This memorandum is to summarize our review of the following technical reports prepared
for the Pleasant Harbor Master Planned Resort Supplemental Environmental Impact
Statement (SEIS):
1. GRADING AND DRAINGE: Pleasant Harbor Marina and Golf Resort —
Grading and Drainage Technical Engineering Report DRAFT, Prepared by
Craig A. Peck & Associates, September 4, 2008
2. GOLF COURSE BMP: Draft Report Golf Course Development and Operation
Best Management Practices Plan, Brinnon Master Planned Resort, Prepared by
GeoEngineerings August 18, 2008
3. WATER QUALITY: Water Quality Monitoring Plan, Brinnon Master Planned
Resort, Prepared by GeoEngineerings August 18, 2008
4. GROUNDWATER: Water Supply and Groundwater Impact Analysis — Draft
Hydrologic Analysis, Pleasant Harbor Marina and Golf Resort, Prepared by
Subsurface Group, LLC November 20, 2008
During the review of the documents provided project area limits and layouts were
inconsistent. We recommend that when all draft reports are revised the same project limits
and descriptions are provided with a reference date.
These documents were reviewed to identify if information was provided to meet the items
Civil Engineering
listed in the Jefferson County Board of County Commissioners Conditions to be Met and
Landscape Architecture
documentation shown in the SEIS. SvR reviewed Section 3.3.1 Surface Water and 3.16.3
Environmental Restoration
Stormwater Management.
Planning
• a — The Grading and Drainage report does not reference Jefferson County
Code in the text, but it is apparent that preliminary designs use the 2005
1205 Second Avenue
Department of Ecology Stormwater Manual for Western Washington.
Suite 201
Stormwater runoff and treatment facility sizing calculations are included in the
Seattle, WA 98101
appendix. Calculations were made using the required Western Washington
Hydrology Model software.
Phone: 206.223.0326
. q — It is unclear from the existing calculations if the development will be able
Fax: 206.223.0125
to meet the requirements of zero discharge. Grading and Drainage report does
svr@svrdesign.com
not summarize the 300 page appendix containing the stormwater management
facility sizing calculations. A table identifying the following information for
Memorandum #01 - Review of Technical Reports Prepared for SEIS
' Pleasant Harbor Master Planned Resort — Peer Review
August 5, 2009
Page 2 of 3
each basin should be provided: 1) total basin size, 2) proposed impervious, 3)
proposed pollutant generating impervious, 4) proposed grass, 5) proposed
pasture/native, 6).proposed forest, 7) predeveloped (forested condition) runoff
flow rate, 8) developed flow rate, 9) average infiltration over basin area, 10)
proposed type offlow control facility, 11) estimated size offacilities to meet
forested conditions/zero discharge to Hood Canal, and 12) what stormwater
treatment will be provided if any. In addition, it is does not appear that the
existing sub -basin boundaries are being maintained. Proposed development
information lists more proposed basins than the number of existing basins
identified in Figure B.1. Additional comments specific to the organization of
the report are provided below.
r — A Draft Water Quality Monitoring Report has been prepared identifying
monitoring approach, locations, and parameters. However, it is not identified
who will be responsible for the monitoring and reporting during the various
phases of construction and who will take over the monitoring when
construction is complete.
y — A Draft Golf Course Best Management Practices (BMPs) Plan has been
prepared. BMPs are generally discussed. Specific BMPs need to be assigned
that will be employed after construction that will meet the stormwater
requirements in the 2005 Department of Ecology Stormwater Manual for
Western Washington. Definitive language should to be used.
In addition, SvR has the following general comments and questions following the review
of Grading and Drainage Report.
1) Section 1.1 — Pre developed and Existing Conditions descriptions combined
2) Section 2.2 — Proposed development description does not include land cover
values for each section of development
3) Section 2.2 — Proposed Development section (2.2) only describes the first phase
approach. No other information is included for subsequent phases in Section 1 or
for work in Section 2 and 3.
4) Section 2.4 - Potential Construction Impacts:
a) No discussion how wetlands will be protected during gravel process
b) No figure identifying limits of gravel process. Limits identified in plan do not
seem to match scale of earthwork described in the report. More detail needs to
be provided.
c) Stockpiling areas "multiple stockpiles of wood debris approximately 25 feet
high and 100 feet in diameter will exist for each area cleared" were not
identified in the report. Areas cleared are not quantified.
d) No discussion of impacts during construction of Section 2 and Section 3.
5) Section 2.5- Mitigation measures for construction impacts during phasing are not
identified.
6) Section 2.6 — Only Phase 1 development is discussed
7) Section 3.1 — Existing Conditions
a) Site specific drainage basin predeveloped and existing condition runoff peaks
and volumes are not identified for the existing basins
b) Runoff/Infiltration/Groundwater — This paragraph is not consistent with data
presented in the Subsurface Group 2008 Report. Potential evapotranspiration
for the site was calculated to be approximately 24 inches (Page 3 of 22).
Memorandum #01 - Review of Technical Reports Prepared for SEIS
Pleasant Harbor Master Planned Resort — Peer Review
August 5, 2009
Page 3 of 3
8) Wetlands — Wetlands are going to be used to provide retention of stormwater prior
to infiltration to meet flow control requirements of the proposed development.
General sizing information including stormwater runoff volumes contributing to
the wetlands should be included. Calculations need to indicate if the created and/or
enhances wetland areas are adequate to meet the stormwater management
requirements.
9) Rainwater Harvesting — Address if rain water harvesting is feasible considering
that aquifer recharge is providing water supply for the development.
10) Reducing the Quantity of Stormwater to be infiltrated — See comment 9 above.
11) Report does not outline how the proposed development will meet the minimum
requirements outline in the 2005 Department of Ecology Stormwater Manual for
Western Washington. Most information is included it is just not organized well.
12) Phased Development - A proposed stormwater layout for each phase and the
developed condition was not included. It is unclear what the stormwater
management will be for Sections 2 and 3 during construction and when the
development is complete.
13) WWHM results should be summarized in the text for each basin.
14) No discussion of sub -basin limits changing from existing conditions to the
proposed sub -basin limits.
15) Report does not reference Jefferson County Code requirements.
16) Report does not reference FEIS Mitigating Conditions for subsequent project
review, technical comments, and comment log.
The following reports would also be useful in identifying information required of the SEIS:
• Sequencing Plan for Construction Activities including phased development
earthwork management plan and temporary and erosion and sediment control.
• Arborist Report to identify tree information including tree retention, tree
harvesting, and understory health to support stormwater calculations and
temporary erosion and sediment.
FA09\09025 Pleasant Harbor Peer Review\Communication\Memos and Letters\Memol—Peer Review Technical Reports.doc