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HomeMy WebLinkAbout041Pe May 23,2013 TO:Karen Swenson, Garth Mann, Craig Peck cc: David Wayne Johnson FROM Alexander W. Mackie SEIS Karen: The Draft SEIS is a thorough approach to a complex subject-well done. The notes below reflect thoughts and observations. Rather than a redlined version I have merely identified page and issue. as the technical response resides in others. Fact Sheet Page iv Under "Local or County Approvals" I would include: o Local mitigation agreements (MOUs) Page v Energy and Natural Resources o Garth, I understand you and Joe are meeting with the PUD on this and on operational issues Chapter 2 Section 2.3 Under "Site Description" I would add" Pleasant Harbor owns property west of U.S. Hwy 101 that is not included in the master planned resort and is not included in this SEIS review. Section 2.3 "SEIS" "Existing Utilities - Water" (Page 2-14) We need to address the well protection areas around the two existing wells serving others to make sure we are consistent with easement restrictions concerning development around existing public water supplies. (A map showing the well locations, recorded easements and list of restrictions would be important here to show the project is consistent with the requirements.) Section 2.5 (Page2-23) "Parking" - Maritime Village Garth: We make reference in a number of places about relocating the marina slip owners parking from behind the Marina store to the new location. Is this consistent with slip owners' understanding under their purchase agreements? Section 2.6, Separate Actions (Page2-37) In first sentence, change "may be subject" to'lvould be subject" to additional environmental review. . .. rkins I Coiel RE: I 57 57 7 -00061LEG AL268 I 8893 I In the next sentence revise as follows: "Agency decisions regarding the nature of environmental review under SEPA ..." Chapter 3 Section 3.2-l "Affected Environment, 2007 EIS" (Page 3.2-l) "Surface Water, Hydrologic Setting" Regarding mention in first sentence of "five unnamed streams." There are a variety of references to three or five streams. I believe two of the "streams" originate in springs west of U.S. Hwy l0l. The other three are well defined water courses that on the Pleasant Harbor site originate at U.S. Hwy 101 culverts and have carved the defined channels, but have no independent source other than stormwater. I am not suggesting a change in conditions, only a clarification that the channels owe their existence solely to stormwater if that is in fact the case. Section 3.2-l "Affected Environment, SEIS" (Page 3.2-9) "Stormwater" Because of the discussion of both stormwater and wetlands throughout the SEIS, it may be proper here to state that no untreated stormwater is directed to the wetlands in violation of water quality standards. Section 3.2-3 "Mitigation Measures" "BoCC Conditions" (Page 3.2-15) - unfinished work o Water Quality Monitoring Plan . Neighborhood Water Policy Garth, Whut is the schedule for update and who is responsible? Section 3.4 "Fish and Wildlife" o Fish-Several intermittent streams (See comment regarding "five unnamed streams" above.) Section 3.5-3 "Mitigation Measures" "BoCC Conditions" Tunicate Monitoring Agreement (page 3.5-8) Gorth, lhhat is the schedule for update and who is responsible? Section 3.7-1 (Page 3.7-2) "Wetlands" Is it clear the water being discharged to the wetlands meets requirements that no untreated stormwater be discharged directly to wetlands? Or is that a USCOE and not WDOE requirement and therefore not applicable because these are not under Federal jurisdiction? We will be under close scrutiny with respect to critical areas and wetland discharges are always a point of contention, so we need to make sure our discharges are compliant with all regulations-and if so, say so. Section 3.8 "Energy and Natural Resources" As I understand, Garth is meeting with the PUD to address this issue in the near future. s7 57 7 -0006/LEGAL268 l 8893 l .| Section 3.9-3 "Transportation" "Mitigation Measures" "SEIS" o Page 3.9-11 Jefferson Transit MOU (should be attached) Section 3.1I "Housing and Employ,rnent" Page 3.11-7 "The affordability of the employee housing shall be negotiated in the Development Agreement between the Applicant and the County." I am not sure this should be in the Development Agreement. At the time of the preliminary plat approval one of the conditions of approval could be required employee housing for that section as issues of number of employees and affordability will change over the duration of the development. (Garth you need to weigh in on this one.) If you want to have an overall term on this point in the Development Agreement, we can add such a provision, but it will need to deal with affordabilify over time. The alternative is simply to have satisfaction of the condition at the time of building permit approval tied into the preliminary plat approval, which will phase in the housing affordability with the phases of your project. Section 3.16-2 "Utilities" "lmpacts" "Sewer" "Operational Impacts" Page 3.16-6 "Creation of a multi-purpose utility district is proposed to own, operate and maintain the new wastewater treatment and conveyance systems." Garth: I believe this has changed and the proposal is to contract with an existing public operator in one fashion or another. This point should be covered in both the sewer operation plan and the water operation plan presently under development. The sentence needs to reflect what is specifically proposed. If a new district is in fact proposed, state approvals need to include approval of sewer and water districts and the nature and scope of the districts detailed here. Section 3.17 "Public Services" MOUs o Page 3.17-5 Brinnon Fire Department o Page 3.17-ll Brinnon School District o Page 3.17-13 Jefferson County HealthCare Garth-you need to make sure the MOUs represent the most recent agreements. Karen: As I noted, this is a very complete document. I understand the Sewer and Water plans may be delayed a bit past your release schedule. It is critical to the overall program that those documents be reviewed as part of this SEIS. I have asked Garth and Craig to confirm the schedule with you so they can be included. I see you have appendices for them in the draft and trust the delays will be minimal. -J- 57577 -0006/I-EGAL268 I 8893. I I also understand that Garth has elected to go with the second construction alternative as the preferred alternative. If that is true, I believe it would be appropriate for the public and agencies to comment on the second option as the preferred alternative--particularly since some of the reports only focused on the second alternative. I did not see any detailed discussion of the zoning ordinance and as it implements the comprehensive plan and enables the project-specific elements discussed, I do not see the need for a detailed discussion, but I think you should have a section on compliance. As I believe you are aware, JT Cooke is no longer with our firm. To make sure I have the correct copies, please forward to me copies of the draft Zoning Ordinance and Development Agreement drafts you are working with. I will try and update the Development Agreement to coincide with present plans in time to include both with the SElS-recognizing that both could be changed through the review process. 57 577 -0006/I-EG AL268 I 8893, -4-