HomeMy WebLinkAbout035Michelle Farfan
From:
Sent:
To:
Subject:
Attachments:
John Hurlbut <jhurlbut@wavecable.com >
Tuesday, April 09, 201-3 L0:52 AM
csmith@co jefferson.wa.us
Pleasant Harbor resort plan causes traffic problems
Riachard Horner.pdf; Read email.pdf; Map to Seatac.pdf; Collison Data.pdf
There are maior flaws in the traffic study being used to plan the Pleasant Harbor resort. These
problems will cause serious traffic problems for us. The study is supposed to:
. define environmental damage. make sure the developer pays the costs of highway and road changes, rather than us, the
taxpayerr occurotely plan for the massive increase in traffic (at least 4100 extra trips a DAY during the
summer)
The study does not do these things. When we've tried to point the problems out to the county
staff and to the developer's consultants, they've shugged off our concems.
We would like your help to stress our concerns and to get a realistic traffic plan.
c smith@c o j effers on. wa. us
If you have any questions please let us know.
Following are concerns about the transportation study:
In discussing the data used in this study, University of Washington
Professor Richard Horner said,
"It would be inappropriate, in my opinion, to go forward on this major action with such
anomalies in key information supplied in its support."
(attached PDF).
The consultant paid by the developer, Michael Read, says that the
EIS, approved in 2008 and based on data going back to 2000, is a
"recently reviewed and approved EIS." He further goes on to Soy,
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ou can forward this email to Jefferson Director Carl Smith
concerns:
"...there was no reason to update existing conditions analysis as there has been no changes to
conditions in the area."
He goes on to show concern about the developer's financial issues, rather than for the accuracy of
data and assumptions used in the report. (affached PDF of email chain)
Issues:
1. Subject: How people get to Brinnon from SeaTac
Assumption: The basic assumption of the study is that people will drive north from SeaTac,
across 104, and down Center Road. All the traffic analysis in the study is of this route.
Problems with this assumption:
o Most people will go south through Olympia. (see attached Google Maps)
o To go north means to go through downtown Seattle traffic, take a ferry (with long
summer wait times) either in downtown Seattle or in Edmonds, come across the Hood
Canal Bridge (which is sometimes open for ship traffic), and then come across 104
and down Center Road, through Quilcene and over Mt. Walker.
Impact of the problems:
o Traffic counts along Hood Canal are seriously miscalculated.
o Pollution from vehicle emissions is one of the largest sources of pollution in the
Canal. Miscalculating the number of trips along the canal underestimates the
pollution cases by this "green" development and there is no mitigation in the study for
it.
o There are points along 101 between Olympia and Brinnon, such as the Lake Cushman
Road, which are bottlenecks in the summer. The study itself admits that Department
of Transportation counts l5 miles south of Brinnon already show traffic increasing by
a third in August. There is no mitigation in the study for this. Traffic mitigation
apparently will be paid for with our tax dollars.
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2. Subject: How people will get to Pleasant Harbor
Assumption: The study says that about 300 people coming to conferences each day will ride
a shuttle bus to the resort.
Problems with the assumption:
o Traffic counts are minimizedby assuming that people coming to conferences will be
willing to ride a 40 foot shuttle bus on the route described above, rather than to rent
cars and have the freedom to stop wherever they want and to extend their visit to see
the National Park and Forest, Seattle, Victoria, and other tourist attractions. The study
says that about ll4 of the approximately 260 people riding the shuffle bus will bring
their spouses...and not want a vehicle?
o The study says that a shuttle bus will make four round trips to SeaTac a day. There
are no supporting facts to show that people will take planes that arrive at the times of
the shuttles. County staff estimate that the trip will take about 5 hours. Given traffic
issues and pickup times, 4 trips a day doesn't seem possible with one bus.
2
o 4 buses of 40 people (full) does not equal 300 people a day (equals 160).
Impacts of the problems:
o Same as in Problem #l: increased pollution in the Canal from a "green" development
and tax payer funded mitigation of traffic problems.
3. Subject: Traffic mitigation suggested in the study for the Black Point intersection
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Assumption: that traffic issues can be mitigated by minor changes to the entrance to the
Black Point Road
Problems with the assumption:
o Since much of the traffic is coming from the south, mitigation for that traffic is
lacking, particularly at the intersection with the Lake Cushman Road.
o Traffic plans do not show the distance from the Black Point entrance to the deadly
curye south of the Black Point entrance, which has serious loss of sight due to the
Duckabush hill (southbound) so that cars and trucks going 50 mph do not have
enough time to slow down when there is backed up traffic, even with the turnout
lanes. Worse is the sight distance for northbound traffic to the people turning left
across the main lane.
o Professor Horner estimates that traffic will increase by about 70Yo near Woodpecker
Road.
Impact of problems:
o Traffic congestion
o Traffic injuries and fatalities
4. Subject: Collision data used in traflic study
Assumption: That you can determine needed traffic mitigation by looking at just collisions
in intersections between vehicles.
Problems with the assumption:
o Most collisions, particularly fatalities, do not happen in intersections on l0l. (see
attached DOT data).
o Collisions are underestimated if you do not include collisions with animals or
motorcycle accidents.
Impact of problems:
o The developer does not pay for the required mitigation if you do not include all the
collisions, particularly the fatalities (motorcycle at MacDonald Creek, tanker
explosion on Duckabush hill, etc). Taxpayers foot the bill.
o Necessary traffic mitigation isn't done in a timely manner.
5. Subject: Dates of data used in traffic study
Assumption: The study uses traffic data from as long ago as 2000 and assumes that nothing
has changed in traffic patterns in that time.
Problems with the assumption:
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" There is no evidence that traffic is the same as it was 13 years ago, or even 5 years
ago. We need up to date data.
o Data for the traffic between Brinnon and SeaTac on the preferred southern route is not
included in the traffic study.
o We need accurate vehicle counts on every route. There seems to be data that truck
traffic has increased on l0l recently.
Impact of problems:
o Inadequate mitigation because of inadequate data on routes, traffic volume, traffic
types
o Tax payer assumes cost of traffic mitigation
o Environmental damage to Hood Canal from vehicle emissions, oil, and gas.
To prepare this analysis, we used the following documents, in addition to those already mentioned:
. November 27,2007 Final Environmental lmpact Statement (FEIS): FEIS. August 28,2007 Appendix 6 to the November 27 , 2007 FEIS, prepared by Transportation
Engineering NorthWest, LLC: Appendix 6. August28,2008 Addendum Supplement to the November 27,2007 FEIS (we can send you a
PDF; not on line). January 30,2012 Second Addendum to the November 27 ,2007 FEIS: Second addendum. Washington Department of Transportation traffrc counts to 2011 (we can send you a PDF; it
is 60 pages)
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RrcrLq,RD R. HonxsR, Pn.D.
230 NW 55" SrRpsr
SEATTLE, WesunqcroN 98107
TprppuoNp : (206) 7 82-7 400
E-vatl: rrhorner@msn.com
December 6,2007
Board of County Commissioners
Jefferson County
P.O. Box 1220
Port Townsend, WA 98368
To Whom It May Concern:
I was requested by Northwest Watershed Institute to review the Brinnon Master Planned Resort (MPR)
proposal regarding the potential effects of stormwater runoff from the project on the water quality of
Hood Canal and the groundwater in the vicinity. I present my findings after stating my qualifications
to perform this review.
BACKGROUND AND EXPERIENCE
I have 30 years of experience in the urban stormwater management field and I I additional years of
engineering practice. During this period I have performed research, taught, and offered consulting
services on all aspects ofthe subject, including investigating the sources ofpollutants and other causes
of aquatic ecological damage, impacts on organisms in waters receiving urban stormwater drainage,
and the full range of methods of avoiding or reducing these impacts. I received a Ph.D. in Civil and
Environmental Engineering from the University of Washington in 1978, following two Mechanical
Engineering degrees from the University of Pennsylvania. Although my degrees are all in engineering,
I have had substantial course work and practical experience in aquatic biology and chemistry. For l2
years beginning in l98l I was a full-time research professor in the University of Washington's
Department of Civil and Environmental Engineering. I now serve half time in that position and spend
the remainder of my time in private consulting through a sole proprietorship. Serving as a principal or
co-principal investigator on more than 40 research studies, my work has produced three books,
approximately 30 papers in the peer-reviewed literature, over 20 reviewed papers in conference
proceedings, and approximately 100 scientific or technical reports. My consulting clients include
federal, state, and local government agencies; citizens' environmental groups; and private firms that
work for these entities. My full curriculum vitae are attached.
FINDINGS
Gencral Findings
As stated by section 3.3.7 of the Brinnon MPR Final Environmental Impact Statement (FEIS), the
basis of the stormwater management program is the Stormwater Management Manual for Western
Washington (Washington Department of Ecology [WDOE] 2005), together with the Low Impact
To Whom It May Concem
December 6,2007
Page2
Development Technical Guidance Manual for Puget Sound (Puget Sound Action Team [PSAT] 2005).
The proponent goes on to state that the stormwater management plan will be designed to meet the
project's requirement for zero discharge of water to the Hood Canal from the golf course resort area
and the full treatment of all site water from the marina area before discharge to the harbor. I now give
my general impressions of this basic plan, to be followed with more detailed observations on each
point.
It is first necessary to recognize that application of the WDOE stormwater manual in no way
guarantees reaching a goal of zero discharge. That manual does not feature management practices
having strong capability to achieve zero discharge. The PSAT low impact development (LID) manual
shows how to design drainage features that could reach zero discharge. However, that manual has
none of the prescriptive requirements of the WDOE manual and is just a "how to" guide to employ
once the components of the stormwater management system are selected. Hence, it does not appear at
all that the zero-discharge goal for the golfcourse resort has any force behind it.
Even if the resort can be held to zero discharge, the FEIS presents insufficient information, even for
the level of a rezoning application, for a reviewer, and the public at large, to judge well the prospects
for achieving the goal. While I recognize that more detail will be presented at a later stage of project
development, the public needs some more information beyond that given in the FEIS to have any
confidence that the project will function as advertised and to countenance a major rezone.
The marina portion of the project will not be held to the zero-discharge standard. While the FEIS
states that its discharge will receive "full treatment," it gives no information at all on what that
treatment might be and what is meant by "full." As with the plan for the resort, the public must be
given a more complete basis upon which to evaluate the quality of the plan at this point in project
development.
Outside of the immediate project area, the FEIS does not assess the water quality impacts of
anticipated traffic additions associated with the development. The Transportation Impact Study
indicates increases on a number of local roads and highways of hundreds of cars a day on average.
Automobiles emit or mobilize numerous pollutants that enter water bodies and degrade aquatic
ecosystems. The FEIS is inadequate as long as it does not give the public a means by which to
understand the full environmental impact before being willing to see rural zoning changed to
accommodate this project.
Further Observations
Zero Discharge from Resort
Achieving zero discharge depends on effective implementation of the types of site design and
stormwater management practices presented in the PSAT LID manual. Fundamentally, these practices
come down to infiltrating rainfall into the ground or harvesting water from roofs and other surfaces for
a use such as landscape irrigation or'ogray water" system supply (e.g., toilet flushing). The FEIS states
that both of these methods will be used but not the role each would play. The intention is to store
runoff in existing ookettles," use it to meet "water demands" , and direct the excess into the ground (by
To Whom It May Concern
December 6,2007
Page 3
what means is not revealed). Even though I did not have much information to go on, I feel safe in
assuming that the project will have to make substantial use of infiltration to reach zero discharge.
Successful water quality protection by infiltration depends of having soils that will percolate water
rapidly enough to drain surface holding areas in time to prevent various problems that can occur with
excessive ponding times (generally, within 72 hours), but not so fast that contaminants will reach
groundwater and pollute it. The natural soils do not necessarily have to possess desirable soil pore
storage space and hydraulic conductivities themselves, but can be amended (usually, with organic
compost) to function well. However, clays cannot be sufficiently amended to provide enough pore
storage and hydraulic conductivity to percolate rapidly enough; and, conversely, coarse sands and
gravels cannot be amended to slow percolation enough to ensure groundwater protection.
The authors of Chapter 3 of the FEIS made no reference to the site soil and hydrogeologic data in
Appendix 4 and did not use it to assess in even the most rudimentary way what it means for the
prospective success of their plan. The data are very sparse, with the soils information consisting of
only the U.S. Department of Agriculture soil survey results. Soil survey data are generally not site-
specific enough for conclusive determinations of infiltration potential, which often varies considerable
in quite small distances. The reported data show very gravelly loamy sand predominating, which if
actually the case would tend to encourage the belief that water could be infiltrated successfully but
could penetrate too rapidly. Nevertheless, an informed judgment requires more site-specific data.
The public cannot be expected to accept a major rezone in their county until they are told enough to
gauge potential success. Insufficient soil storage and hydraulic conductivity will render zero discharge
an illusion. Overly rapid percolation will threaten groundwater, a potable supply source in a rural area,
and reach streams on the site and other nearby surface waters as seepage. There is heightened concern
about groundwater quality when a golf course is involved. Golf courses are large consumers of
fertilizer and pesticide chemicals, as well as irrigation water. The common water pollutant least
capable of interdiction in soils is nitrate-nitrogen, which is introduced to the surface in large quantities
with fertilization, from where it can be carried along with percolating irrigation or rain water to the
water table. Nitrate is the agent causing methemoglobinemia, generally in infants, when consumed
with drinking water. Pesticides reaching drinking supplies are obviously also a major health concern.
Treatment of Marina Discharge
The term "full treatment" as promised for the marina is simply meaningless. Different treatment
systems have varying efficiencies in treating different pollutants. In addition to terrestrial runoff from
upland areas, marinas are sources of all the pollutants associated with engines and petroleum products,
cleaning agents, and household chemicals, used right on the water. Their potential for release and in
what quantities depend on marina activities, particularly how much maintenance is performed, but they
are always a factor. Also, it can be expected that a resort of this size will lead to greatly increased use
of the existing marina, which would itself increase pollutant loading. Some treatment systems can do
an excellent job in capturing these various pollutants, others are poor overall, and some are mixed
depending on the pollutant in question. The project proponents must state how they would handle and
treat marina discharge before the public can consider their plan.
To Whom It May Concern
December 6,2007
Page 4
Potential Trffic Impacts
Table I I of the Transportation Impact Study shows the "Statesman" altemative to increase traffic by 6
to 89 percent on the various roads and highways in the project vicinity, with a 4l percent rise at one
point on highway U.S. l0l (near Woodpecker Road). However, the origin of these figures is unclear
and probably in error. My calculations do not agree when comparing the cited "Statesman" alternative
traffic volumes with either the "Without Project" or "No Action" columns. For example, I got
increases of 875 and 225 percent comparing "Statesman" Black Point Road traffic with "Without
Project" and "No Action," respectively. I found the "Statesman" increase on U.S. l0l near
Woodpecker to be 69 or 5l percent with the same respective comparisons. I was likewise unable to
reproduce Table I I's percentages for the "Brinnon" and "Hybrid" alternatives. It would be
inappropriate, in my opinion, to go forward on this major action with such anomalies in key
information supplied in its support.
Motor vehicles are responsible for water body contamination from many sources. Brake pad and tire
wear introduce copper and zinc, respectively, both highly toxic to aquatic life. Wear of engine parts
contributes these and other toxic metals, like lead, cadmium, chromium, and nickel. Petroleum
products leak from engines, transmissions, and braking systems. Sediments drop onto roads from
chassis and undercarriages. These pollutants wash immediately into receiving waters during rainy
periods but also stay on and around roads for later wash off when rains come. It is reasonable to
assume that the roads around the resort and marina complex would experience the most elevated traffic
in the summer months. Even though there is not much rain then, the remnants would be in
concentrated form in the first flush of fall rains. Concentration of toxic materials, such as the various
metals in road runoff, is the condition most dangerous to aquatic life. The FEIS is an incomplete and
thoroughly inadequate document in not addressing these polential impacts at all.
SUMMARY
The Comprehensive Plan amendment application should be denied unless the Brinnon MPR proponent
can provide convincing evidence that: (l) zero discharge from the golfcourse resort can be achieved;
(2) soils are conducive to the intended infiltration either in their natural condition or after amendment;
(3) infiltration will not contaminate groundwater or result in below-ground delivery of pollutants to
surface receiving waters, with particular affention to golf course irrigation and rain water discharge; (4)
marina discharge will be treated with a specific system to reduce harbor contamination from that
source to the greatest extent possible; and (5) increased traffic will not degrade the water quality of
Hood Canal and its tributary waters or threaten the survival and well being of their resident and
anadromous aquatic organisms. This evidence must be made available to the public for another review
of the proposal before its official consideration.
I would be please to discuss my comments with you and invite you to contact me if you wish.
Sincerely,
fuZl--fia, /6-*,*--
Richard R. Horner
FW: FW: Pleasant Harbor TIS l-30-12
Black Point x
David W. Johnson Mar 19
to me, Jim
Barbar4
After discussing Mike's response to our queries, Karen and I are satisfied that they have been addressed sufficiently to produce the preliminary draft ofthe SEIS
From: Michael Read [mailto:mikeread@tenw.com]
Scnt Thunday, March 14, 2013 6: 16 PM
To: David W. Johnson
Cc: oeckassoc@comcast.net: Garth Mann
Subjcct: Re: FW: Pleasant llarbor TIS l-30-12
David:
remain very conservative.
construction scheduled and revisions to the sit€ plar/construction phasing.
findings and conclusions regarding off-site mitigation, site access and WDFW access revisions remain valid with or without implementation of the shuttle bus.
hour shuttle bus work shifu to accommodate the demand, which assumes a 4-hour round trip between the site and SeaTac Airport.
Michael Read, PE I Principal
TENW PO Box 65254, Seattle, WA 98155
mikeread@tenw.com I Office: 206-361-7333 (x l0l )lCell: 206-999-4145
On3/1412013 I l: 12 AM, David W. Johnson wrote:
Mike,
Could you please review the comments from Jim Pearson and Karen Swenson and provide us with an addendum to the TIS to address these issues?
Thanksl
From: Swenson, Karen Imailto:kswenson[Deaest.com]
Sent Thursday, March 14,2013 l2:01 PM
To: David W. Johnson
Cc: Schipanski, Rich
Subjcct: RE: Pleasant Harbor TIS l-30-12
base the project's impacts on 2006 traffic volumes? Does it use a 2% growth rate (as noted in Attachment A) to get to the base year (2011 or.2012)1
The buildout year appears to be 2017, which is a l0 year buildout from the 2007 FEIS. Should this date be revised?
Also, although oflesser concem, the collision data also is not updated in the updated transportation report, which is fiom 2003-2005 in the DEIS.
Just questions to raise for Public Works and TENW..
Thanks,
Karen
From: Jim Pearson
Scnt: Tuesday, March 12,2013 9:58 AM
To: David W. Johnson
Cc: Mike Read - TENW; Statesman - Garth Mann
Subject: RE: Pleasant Harbor TIS l-30-12
Thanks for the opportunity to review the revised Transportation Impact Study.
as Port Townsend and the Olympic National Park, it is unlikely that the mid-day shuttle trips would carry 40 p,xisengers.
fIWYlOl / Black Point Road intersection and the improvements to the Black Point Road structure and roadway width. This is acknowledged in the TIS.
Jim Pearson
Jefferson County Public Works Deparunent
623 Sheridan Steet
Port Townsend, WA 98368
(360) 38s-9162
(360) 385-9234 Fax
From: David W. Johnson
Sent: Monday, March I l, 2013 3:28 PM
To: Jim Pearson
Cc: David W. Johnson
Subject Pleasant Harbor TIS l-30-12
Attached.
David Wayne Johnson - LEED Green Associate
Associate Planner - Port Ludlow Lead Planner
Department of Community Development
Jefferson County
360.379.4465
1nh3 50 Beck Rint Rd, Brinnsr, WA 98320 to SdUeTacana lntrndiotd Arport - Google Map
Di re cti ons to Se atd e -Ta com a I ntema ti ona I Ai rport
17801 lntemational 81ld, Seattle, WA 98158
110 ml - about 2 hours 0 mlns
Go**gle
?60 Black Point Rd, Brinnon, WA 98320
1. Head wesil on Black Point Rd toward Old Black Point Rd
2. Tum left onto US-101 S
Aboutlhour6mlns
3. Make a U-tum
About 58 secs
4. Keep left at the fiork, follory signs for l-5 iUOlympta/Seatde and merge onto l€ N
About 48 mins
5. Take exit 15tl to merge onto l-105 S/WA618 W toward Burlen
6. Continue onto WA.5l8 W
About 1 mln
7. Take the exit toward Sea-Tac Alrport
About 1 min
8. Merge onto Airport Expressray
About 1 min
9. Slight right onto Departures Dr
About 1 min
Seattle-Tacorra lnte rnatlonal Arport
17801 lntemational Blvd, Seaftle, WA 98158
go 423 ft
total 423 ft
go 56.3 ml
total56.4 mi
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total 107 mi
go 0.5 mi
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total 108 mi
go 0.8 mi
total 109 mi
go 0.8 mi
total 110 mi
go 0.4 mi
total 110 mi
These dhoctions are for planning purposes only. You nay flnd lhat construction projects, traffic, w eather, or other events may cause
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31 L7 376 554Not at lntersection or Driveway 4 2 3 7 1 4 1 2 78 25 25 18 2L 20 31 L7 25 27 TL 220 45 29 39 31 32 39 25 28
4 2 4 7 2 5 7 2 I 22 29 291 60 38 50 35 lu 48 35 i9 38 20 a7 720Totol373229293747223275
18 9 5 8 L 6 5 L 67 111** At Driveway 4 3 4 6 5 5 3 3 8 3 /u 8 6
1 L 1 1 1 5 7r7 25 20 16 18 25 29 20 18 16 10 797 313*t* At lntersection 8 L2 7 19 15 9 t7 8 7 9
577 825Not at lntersection or Driveway 2 L 3 7 2 2 3 L 27 30 39 31 38 39 32 16 24 2L t7 287 35 55 67 58 53 67 57 43 50 32
2 2 7 4 8 2 2 4 26 78 83 92 82 83 704 78 67 77 43 787 7,249Total742544263594636353629/u2
1 1 2 2i* At Driveway
37 40 30 31 43 53 43 47 54 37 tuD 619*+* At Intersection 1 L 2 L7 22 26 23 31 14 23 27 L4 11 208
Not at lntersection or Driveway L 2 2 1 1 7 56 64 59 45 43 51 4t 39 33 30 467 96 105 L07 LLz to7 143 103 96 118 64 1,051 1,519
772 707 7,462 2,740Totol22277,9 73 86 85 68 74 65 64 65 47 47 669 133 745 737 743 750 796 747 738
2,650 4,709GRAND TO|AL 6 6 s 7 72 7 2 4 6 2 57 746 772 756 760 7il 752 722 133 772 85 7,402 277 266 279 260 277 348 260 2/t4 287 764
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UNDER 23 LNITED STATES CODE _ SECTION 409, THIS DATA CANNOT BE USED IN DISCOVERY OR AS EVIDENCE
AT TRIAL IN ANY ACTION FOR DAMAGES AGAINST THE WSDOT, OR ANY JURISDICTIONS INVOLVED IN THE DATA