HomeMy WebLinkAbout0505309 Shilshole Avenue NW
Suite 200
Seattle, WA 98107
206.789.9658 phone
206.789.9684 fax
memorandum
date
to
from
November 9, 2011
David Johnson, Jefferson County Planner
Jeff Caton, Director of ESA's Renewable Resources Group
subject Review of Climate Action Committee Report: Pleasant Harbor Marina
Dear Mr. Johnson,
NOV 1 0 Zp11
JEFFERSON COUNTY
www.esassoc.com
At your request ESA has reviewed the draft Climate Action Committee Report on the Pleasant Harbor Marina and
Golf Resort & Spa, and we have the following comments on its content and organization.
In general the document is not well organized and unfocused in its purpose, logic, and conclusions. If the
true purpose of the report is to assess the greenhouse gas (GHG) emissions associated with the project and
to identify mitigation measures for reducing those emissions, then there are several shortcomings and
missing components.
a. The Summary section at the end presents statements and figures that are not previously presented
in the report, such as the expected percent reductions in GHG emissions associated with
construction and operation strategies. There is no discussion of how GHG emissions are
measured or any technical analysis provided to back up these claims so it is impossible to assess
their veracity. At minimum, an adequate analysis would define the boundary of analysis, present
an estimate of the carbon footprint of the proposed project (baseline) along with quantified
measures for reducing GHG emissions associated with the construction and operation, using
generally accepted assumptions and methodologies for analysis.
b. In addition, the Summary makes general claims or statements that are vague, confusing or
superfluous, such as "based on ecological foundations that provide solutions from standard GHG
emissions" or "setting new standards to follow." Such statements make ift difficult to assess the
true value of the report as a technical analysis.
c. Several attachments are referenced but not provided. It would be particularly useful to see
Attachment 5 regarding energy.
2. The report claims that the list of measures put forth by Jefferson County Climate Action Committee for
reducing GHG emissions, included as Attachment 1, was used as a guideline for developing GHG
reduction measures. Appendix Ihighlights the measures that are purportedly included in the project's
construction and operations plans. However, there is no discussion of how each of the highlighted
measures would apply to the project, nor is there any presentation or quanitfication of how those
measures would reduce emissions.
3. Several "Steps" included in the report outline measures that are generally effective in reducing overall
GHG emissions (e.g., transportation demand management, water reuse, recycled materials) but there is no
presentation or discussion of their GHG-reduction impact.
4. The use of terms such as "Carbon Credits", "Industry Standards" and "North American Green House Gas
Emissions Solutions" is confusing and in some cases misleading, reflecting perhaps a technical
misunderstanding of the issues and best practice approaches to mitigating climate change.
a. Such terms are not defined by the author and there is nothing in the report that supports the claim
that the project achieves "Carbon Credits. " The term "carbon credit" is generally understood to
mean a tradable certificate or permit representing the right to emit carbon dioxide. Carbon
reductions (or GHG emissions reductions) would perhaps be a better term to describe what the
plan for mitigating the project's GHG emissions.
b. It is not clear, as mentioned in the Summary, how the Pleasant Harbor Resort project, or any of
the proposed measures for reducting GHG emissions, relates to the Western Climiate Intitiative,
or how "carbon credits" could be generated through the reduction measures alluded to in the
report.
Attached are a few resources that the applicant might find useful in responding to a requet for additional data.
Additionally, ESA would be happy to assist you or the applicant in providing the information necessary to satisfy
Jefferson County's requst for greenhouse gas enisson quantification and potential reduction measures
It has been our pleasure to review these documents for you. Please do not hesitate to contact me if you need
clarification on any of our observations or have questions about our review.
Attachments:
Guidance for Ecology Greenhouse Gas Emissions in SEPA Reviews
Table of Tools
King County SEPA GHG Emissions Worksheet