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HomeMy WebLinkAbout009Michelle Farfan From: Sent: To: Cc: Subject: Attachments: David W. Johnson <djohnson@cojefferson.wa.us> Tuesday, January 2'J., 20L4 9:46 AM Swenson, Karen; peckassoc@comcast.net David W. Johnson Tech Report response to comments GeoEngineersResponseToComments-Jan19-10.pdf I found the Geoengineers memo from Ut9/2010 that responds to County comments (attached). I will confirm that this addresses Donna's comments. David Wayne Johnson - LEED Green Associate Associate Planner - Port Ludlow Lead Planner Department of Community Development Jefferson County 360.379.446s Mission: To preserve and enhance the quality of lfe in Jefferson County by promoting a vibrant economy, sound communities and a healthy environment. ;t Srtvf PAPER - Pleqse do not print this e-moil unless obsolutely necessory All e-mail may be considered subject to the Public Records Act and as such may be disclosed to a third-party requestor. LETU $NHHru A$$SCIATE 1 1550 Woodridge Drive SE, Port 0rchard, WA 98366, Teleph0ne: 360.769-8400, Fax 360-769-8700 Memorandum www.geoengineers.com lo: From: Date: File: Subject: Vicki Morris, Vicki Morris Consulting Services JoelW. Purdy, LG, LHG/Wayne S. Wright, PWS January L9,2070 12677-O0L-O8 Pleasant Harbor - Review of Jefferson County Staff and Peer Review Team Comments This memorandum presents GeoEngineers' review of Jefferson County staff and Peer Review Team comments as forwarded to us by you in an email dated January t,2OLO. We were instructed to evaluate the comments' appropriateness and explain how we will respond. The following list of comments was organized by technical report, then by reviewer. The review comments were copied from the original emailed file and our responses are provided immediately after each comment. Habltat Management Plan Comments from an email (Seotember 22. 2009) Donna Frostholm (Associate Planner/Wetland Soecialist) with Jefferson County Develooment Review Division. sent to David W. Johnson regarding Brinnon MPR - HMP Comments and Recommendations. The HMP states that the proposed project should not have significant impacts on tenestrlai wlldlife species because vegetated areas and corridors will remain, and additional information is needed to support these statements. Aerial photographs currently show most of thc project rrca, cspccially Section 1, as vegetated with trees and shrubs, with feu/ barriers to terrestrlal wildlife mov€ment through the project area. Other figures in the report show that most of the proiect area will be developed with roads, structures, and a golf course. The applicants should provide data on the amount of each habitat type present under existing conditions and post-construction conditions. This comment will be addressed in the final report and will include pre- and post-impervious surface areas to be provided by the civil engineer for the project. The HMP indicat€s that protected areas and marine environment pollution control strategies wil! be implemented for maintaining shoreline use by tribes. The detalls for these strategies should be cleady identified in this section of the HMP. lf these details exist, we can include in the report. lf not, the marine environment pollution control strategies section,/sentence in the report needs to be changed to either say the control strategies will be developed or to take that sentence/section out of the report completely. Under the discussion of Wildtife Corridors (page 15), the first bullet indicates that veSetation will remain within undisturbed withln Section 1. The figures in th€ HMp show that much vegetation will be removed to construct the proiect. This bullet needs to be clarified. lt abo confllcts with the last bullet, which states that an effort wlll be made to retain trees throughout the site. The final report will be revised to be congruent with the current design. The report should say vegetation corridors (not areas) will be undisturbed. GroENc TNEERO Memorandum to Vicki Morris, Vicki Morris Consulting Services January 19, 2010 Page 2 The HMP states lhat the on-site wetland hydrology will not be altered as stormwater and lrrigatlon will be captured and treated to Class A standards beforc being discharged to on-site infiltration systems. The location of the on-site infiltration systems should be shown on a figure in the HMP. The final report will reference the locations of on-site infiltrations systems to be provided by the civil engineer for this project. This information was not available at the time of the draft report. Additional information is needed on the wildlife habitat corridors within the golf course. lt is not clear what type of habitats will be retained, which wildlife species would be encouraged to use the corridors, and what wildlife species will be discouraged from using the corridors. This will be addressed in the final report by clarifying existing information. The discussion of Wetland C in the HMP states that the buffer will be reduced by no morc than 25 perc€nt, yet the flgures show a buffer reduction of much more than 25 percent. The buffer reductlon areas shown on Figure 14 do nol add up to the square footate in the legend. The buffer reduction on Figure 14 does not account fur the buffer reduction for construction of Fainuay 1. Thereforq the buffer addition area is less than the buffer reduction area, resulting ln a less than 1:1 buffer averaglng ratio. This area of buffer reduction will be addressed by our evaluation of the final site plan. This will be addressed in the final report. The dlscussion of Wetland D in the HMP states that the buffer will be reduced by no more than 25 percent, yet the figures in the HMP show a buffer reduction of much more than 25 percent. The buffer addition areas do not add up to the square footage in the Figure 14 legend. This comment will be address by our evaluation of the finalsite plan and will be incorporated into the final report. Figures 9 and 1O show some of the plantint areas coincident with project development. This comment will be address by our evaluation of the final site plan and will be incorporated into the final report. The HMP states the square footage of lmpervious surftce removal at each stream, but does not indicate what the rquare foota8e of impewious surhce will be for development within the streams and stream buffers. The square footage of irnpacts and mitigataon should be presented for each stream. This comment will be address by our evaluation of the final site plan and incorporated into the final report. The HMP references the critical areas stewardship program (CASPI. The lext of the wettand mitiSation plan and HMP state that the wetland and stream buffers will be reduced by no rnore than 25 percent, which would be pennitted as an administrative buffer rcduction that &es not require a CASP. The wetland mltlSatlon plan and the HMP that have been submltted are appropriate for wetland and stream buffer reductions that do not exceed 25 percent. lt should be noted that CASPS can be used for some rural residential single-family development and rural village centers, but not for mastar planned resorts. We reference the program as a guideline, but recognize that it is not required. We will revise the report to make this more clear. Memorandum to Vicki Morris, Vicki Morris Consulting Services January L9,20!0 Page 3 The ilMP states that "wet cells" will bE con$tructed to treat water. The locatbn of the wetland cells should be shown on a figure. This comment will be addressed by our evaluation of the final site plan and the stormwater treatment report. This will be addressed in the final report. Much of the discusslon in the HMP fior Noise Quality and Constructlon lmpacB, Golf Course Deslgn and Man88€ment Practices, and Occupational Phase indkate actiom that could be taken as mltigatlon (e.9., establlsh a $ertillzer schcdule, develop a monitoring program, buiH bird boxes). Ctarificatlon is needed as to whetherthe projea proponents wlll commit to implementlng those actlvltles. We will reference this information from other reports when available. This will be addressed in the final repoft. Substantive cut and fill operatlons are proposed as part of thls proposal, Addltlonal lnformation about the extent and location of cut and flll operatlons are needed to determlne lf the potentia I impacts to flsh and wildlife conservation areas havt been adequately addressed in the HMP, The Grading Plan will be referenced in the final report. We will need to review the information pertaining to this comment that is included in the Grading Plan. General Comments Comments in a letter dated November 30. 2009 from Gerald Steel. the attorney for the Brinnon Group and Brinnon MPR Ooposition and addressed to David Wayne Johnson. Project Lead Planner. CnITTCAT.ABEAS Th€ SEIS should prcvide anupdated w€tland delincdion. The wetland delineation should be valid for S-years and since the wetlands were delineated in April 2006 the delineation does not need to be updated at this time. We will reference the Corps concurrence in the final reports. An effort to contact David Wayne Johnson was unsuccessful to confirm the S-year time period. We will notify the team as soon as this is confirmed with Jefferson County. Comments in a letter dated November 30. 2009 from Deoartment of EcoloEy (DOE) and addressed to David Wayne Johnson. Project Lead Planner regarding their review of the environmental checklist. SEPA REGIONAL PROJECT [EAD: Sarah Lukas (3601407-2159 Shorelands/Wedands the proposbd supplemental document should include analysis of all impacts to waters of the state of Washington. the Final Environmental lmpact Statement (FEIS) disclosed that several kettle wetlands as well as Pleasant llarbor will be lrnpacted by this proposal. This information is already included in the reports. To analpze impacts to shorelands, I recommend the SE|S include site specific mapsdetalllng the. proposed devblopment activities within shoreline jurlsdlction. I recommend that the site plans be consistent with the reguirem€ns of WAC 173-27-f80{9}, to recelve substantive comments. The technical repofts contain these figures. Memorandum to Vicki Morris, Vicki Morris Consulting Services January 19, 2010 Page 4 According to the Washington C,oastal Atlas eel grass beds are present withln the Harbor. I recommend the StlS be supplemented wlth an eel grass surveyto document current condltions. lf in-water work is proposed (marina reconstruction), then an eelgrass survey will be needed within the impact area. We will review the shoreline atlas for eelgrass beds in the immediate vicinity of the marina. Wetlands should be mapped and all lmpacts should br disclosed. Proximity to proposed buildlngs should be clearly defined. lf there are any direct impacts to wetlands proposed lhe appllcant will be required to receive authorilatlon from Ecology prior to any constructlon actlvltles, This information is already included in the reports. Conceptual Wetland and Wetland Buffer Mltlgatlon PIan Comments from an email dated AuEust 13. 2009 from Donna Frostholm (Associate PlanneruWetland Specialist) with Jefferson County Development Review Division. sent to David W. Johnson regarding Brinnon MPR - Wetland Comments and Recommendations. Wetland Hvdroloov. Currently, the natural processes occurring within the project area provlde a sufficient amount of water to the 3 orr-site wetlands to support wetland conditions, These wetlands are typically inundated for a portion of the year, with much, if not a ll, of the surface water gone in the drler tlme s of the year. Thc draft mitigation plan states that water levels within the wetland mitigation area and the existing wetlands will be manipulated to receive reclaimed water from the golf course. The draft mitigation plan also refers to the amount of water entering the wetlands post-construction as greater than current conditions and refers to it as "enhanced" hydrologic patterns. The Jefferson County Code (JCC) considers alteration of wetland hydrology to be a regulated activity. lf wetland hydrology ls manlpulated post-construction {meaning that wetland hydrology is not present due to natural processes and/or the hydrotoglc budget is not similar to that under existing conditiorts), then the alteration is subject to the critical areas requirement in the JCC. tt should be noted that the FE|S states Wetlands C and D wi.ll not be altered b,y the proposal. These comments will be addressed in final report. The draft Groding ond Droinoge Technicol Engineering Report lndicates that kettles wlll be used for stormwater control, but does not specify which kettles. Two of the kettles are not wetland and Wetland B ls proposed to be filled. However, two kettles in the project area are wetland (Wetlands C and D), and are protected underJCC critlcal areas requirements. The applicants should clearly lndlcate which kettles are to be used for stormwater control. As noted above, alterations to Wetlands C and D are to be avoided. Wetlands C and D do not correspond to Kettles C and D. This will be clarified in the final report. Figure 3 of the draft mitigation plan shows construction of an overflow stream between Wetlands C and D. Currently, borh Wetlands C and D are keltle wetlands that do not have a surfuce water connection, and Wetland C is located at the bottom of steep slopes. The draft rnitigation plan does not addr€ss construction of an overflow stream to th€se wetlands, although alterations to the existing environment would be substantfue. Based on Figure 3, it appears that the intent is to dlrect excess water from Wetland C east to Wetland D via a proposed overllow stream post-constructlon. lt ls lmportant to not€ that Wetland D extend$ off-site to the east and that steep dopes are mapped as occurring east of the Wetland D. The applicants cannot "enhance' wetland that ls not on thelr property nor car they create conditlons where more water may be directed towards slopes that are not wlthin the project area. The appllcans should clarify what ls belng proposed. These comments will be addressed in the final report. Note, Wetlands C and D are not kettle wetlands. Memorandum to Vicki Morris, Vicki Morris Consulting Services January t9,2O7O Page 5 Wetlands C and D as well as the mititation area rely on precipitation, surface water runoff, and subsurface flow to support wetland hydrology and maintain wetland conditions. Given the extent of alterations proposed in the project area (incltrding cut and fll[, the appllcants need to provlde additlanal information about hydrologlc conditions at these 3 wetlands post-constructlon. This should include, but is not limitcd to, an Essessment as to how the geomorphology and drainage patterns will be altered by development in the drainage are for the wetlands. As noted above, if development activities result in altered hydrologic conditions within the wetlands and wetland buffers, then the proposed activity is subject to regulatory review to JCC requirements for critical areas. This will be clarified in the report, but we will not conduct a separate analysis since a lot of geotechnical work has already been completed. This was looked at and hydrologl to the wetlands were tied to stormwater runoff from the fairways of the golf course. After treatment, water would flow into these wetlands at pre-construction volumes and rates. Wetlond B tlmpgs Ared. The applicants are proposin8 to use a non-wetland kettle on the property as a mitigation for impacts to Wetland B. Based on my review of the draft mltlgatlon plan, I have the following comrnents: 1. Grading is addressed on page 11 of the draft mitigation plan and the bottom mitlgatk n kettle elevations are highlighted in yellow (in the text of the report). The raised height of the kettle bonorn in the toxt does not appear to match alevatlons shown on Flgures 8 and 9. Based on infonnatjon in the draft mitigatk n plan, the applicants are proposlng to place at least 5 feet of clay and silt (or "clay-rich" soil) in the wetland rnitiSation area with an additional 12 incfies of hydric topsoil, which would be placed over the clay and silt layer. The slopes to the mitigation area are steep and the applicants should corrfirm that the heaw equlpment needed to compact the Glay and Eoll layer can access the mltltatlon area, The percent csmpaction should be specified in the mitlgatlon plan, ln the final mltlgation plan to be approved by the County, a detailed grading plan of the mltlgatlon area should be included. There is an existing road to the bottom of the kettle for equipment access. The percent compaction will be identified by the site civil engineer and added to the final mitigaiton plan. 2. The draft mitigation plan states that the top 12 lnches of hydric soll at the mitigation site will come from the lop 24 inches of soil in Wetland B. Typically, only the upper 6 to 12 inches of the soil profile ls topsoil; below that is subsoil, which is less likely to support vegetation, Based on the soil description from the wetland delineation report prepared for thls proJect {and recetued by Jefferson County on August 4, 20(re}, it appears that only the upper 6 inches of soil at Wetland B would be consldered usable as topsoil at the mitigation site. Since the mitigation area is twice the size of the impact area, the applicant should specifo in the rnitlgation plan where the necessary topsoil will come from for use in the mitigation area, There is no reference to the lop 24 inches of soil from Wetland B. The depth of hydric soils in Wetland B is variable. However, as much of the hydric topsoil will be recovered as practical. The report will be revised to state this clearly. Kettle areas do not always have "typical topsoil conditions" Duff, and other organics can accumulate at increased rates due the the closed depression (this is why wetlands commonly form in these areas). Topsoil may be that deep in the kettle. Let's check the boring logs if Vinnie took some in this area. 3. The draft mltigation plan states on page 11 that natlve specles from Wetlands B, C, and D will be used. The JCC considers alteration of wetland vegetatlon a regulated acllvlty. Use of native plants from Wetland B are appropriate for use ln the mlllgation area, However, plants from Wetlands C and D and associated buffers cannot be removed for use elsewhere ln the proJect area. The text of the mitigation plan should be revised accordlngly. This will be addressed in the revised report. Page LL is not referring to salvaging plants but is referring to the specificatron of species for planting which will reflect the same species in the wetlands. Memorandum to Vicki Morris, Vicki Morris Consulting Services January 79,2OtO Page 6 4. The draft mitigation plan indicates that salvaged plants from the project area will be used to replant the mitlgation area. While lt is accrptrbla to usc arlvrged plants, it should be noted that it is generally ttressful for large, well-established vegetatlon to be transplanted and that there ls a greater potential for plant mortality {as compared with installation of young vegetation). Much of the project area conslsts of large trees wlth a well- developed underctory. Many of the treet on the property are much too large to transplant, and it ls unlikely that the most of the shrubs on the slte would survhe being transplanted, The ffiitiSation plan should address survival of transplanted vegetation, identify those portions of the buffer mltlgation area to be planted on a flgure, present the on-center spacing wlthln these ptanting areas, and evaluate whether plants obtalned from a nursery will be needed to e$tablish native vegetation in the lS&foot buffer. See comment above. There is no intention of salvaging plants. lf there is mention of salvaging, we will revise the report to state this clearly. 5. The mitigation plan should address who is responsible for removing non-native and/or lnvasive species from the mitigation area and address disposal of undesirable vegetation. This will be addressed in the final report. Statesman will be responsible as the applicant. 6. A goal of the mltigatlon plan is to provide on-site. ln-kind compenJatory mitigation. Wetland B is well vegetated and has no open water areas durlng the drier months of the year. The mitigetion proposal, however, includes an open water component that is not proposed for planting. The draft mitigatlon plan needs to be revised to address this discrepancy. Wetland B has seasonal open water areas that are unvegetated and the proposed mitigation wetland will have seasonal open water areas where vegetation is unlikely to become established. The plan does provide on-site, in-kind compensatory mitigation. 7. The first bulleted performance standard listed on page 18 should be revised to state that no more than 10 percent coverage of exotic and undesirable species shall be present throughout lhe monitoring period, not just at the end of the monitoring period. This comment will be addressed in the final report. 8. A perforrnance standard should be added to address wetla nd hydrology (thet matches the goals of the of the mltlgatlon proposal). This comment will be addressed in the final report. 9. The mitlgatlon plan needs to be submitted to .leffurson County no later than December 31 of each monitoring year. The draft mltigation plan should be revised to chriry that monitoring plans rnust be submitted by the end of the calendar year, This comment will be addressed in the final report. 10. The mitigation plan should state that the outer edge of the wetland buffers will be staked prior to beginnlng any ground-disturblng activitles. This comment will be addressed in the final report. 11. The mitigation plan should state that sih funcing and orange barrier fencing wlll be lnstalled along the outer edge of the wetland buffers prlor to beglnning any ground-disturbing activities. We do not want to specify using silt fenceing since there are other less disturbing to the habitat and higher-functioning best management practices that exist and will be used. A Temporary Erosion and Sediment Control Plan that will specify best management practices will be developed by others prior to construction. Memorandum to Vicki Morris, Vicki Morris Consulting Services January L9,2OtO Page 7 12. The mitigatlon plan should state that the project biologist will be on-site during plant installation to ensure that healthy plants are being installed as per an approved plan. This comment will be addressed in the final report. Wetlsnds C ond D lBuffer Rsductiod. The applicanB are proposinE to reduce a portion of the wetland buffers at Wetlands C and D. 1. The text of the mltlgatlon plan states that the buffer reductions would not be greater than 25 percent of the standard buffer wldthg yet the figures in the report show buffer reductions well beyond 25 percent. The mitigation plan must be revised to address this discrepancy and bring the proposed buffer reduction into compliance with JCC requirements. This comment will be addressed in the final report and figures. 2. Some of the total square footage calculations ln the legend of several figures do not match the area calculations shown in the drawlnS on Figure 10. The figures need to be corrected. This comment will be addressed in the final report and figures. 3, There is a net decrease in the Wetland C buffer area (543 square feet), as proposed in the draft mltlSatbn plan. Also, there ls a buffer reductlon shown on the flgures at Wetland C to construct Falnrvay l that has not been a€counted for ln the draft mitlgatlon plan. The applicants need to state why the fainrays cannot be located outside of the wetland buffers and provide more information as to how a net decreare in wetland buffer area could comply with JCC buffer reduction reguirements as they pertain to functlons and values. This comment will be addressed in the final report and figures. 4. A mix of natlve and non-natlve specles are currently present ln the buffers for Wetlands C and D. The draft mitigation plan only shows the locations of paved or gravel roads for re-planting as part of the buffer reduction. Thedraftmititationplanshouldindicatetheplantcompositlonoftheaddltlonal bufferareas. lf areasconsisting of non-native species are present ln the buffer addition areas, then the draft mitigation plan should address these areas. This comment will be addressed in the final report. WglknlFundions and Volues. Following are my comrnents pertaining to wetland functions and values. 1. Figure 3 shows wildlife corridors on the golf course. No lnformation is provided ln the draft mitigation plan as to what habitat features, if any, will be placed within a wildlife corridor or what constitutes a wildllfe corridor. The draft mitiBation plan does not idenilry what type of wildlife would be expected to use the wildlre corridors to move f rom wetland-to-wetland. This information is provided in the habitat management plan and will be referenced in the mitigation plan. 2, Fencing is proposed to prevent the people from entering lnto the mitigation site, but no mention of fencing is proposed to protect Wetlands C and D and associated buffers, The mit[tation plan should also address protection of these wetlands. These areas will be signed, but no fencing is proposed along the fairways. This will be clearly stated in the mitigation report. 3, To fully understand the potentlal irnpacts to wetland area, wetland functlons and values, and wetland processe$, the applicants rrced to provide information on the extent of cut ehd ftllproposed wlthin the projeet area. We will refer to the Grading Plan to address comment this in the final report. Memorandum to Vicki Morris, Vicki Morris Consulting Services January !9,2O7O Page 8 The draft repon should be revised to address all potentlal lmpacts of the proposed development and re-submitted for County review. The extent of impacts should be based on what was present€d in the fElS, Note that a flnal mitiSat,on plrn will be needed for project permittlng that would includa, but is not limited to, detailed planting plans and specifications, detailed plans specifying type and location for habitat features noted in the text of the mitigation plan, fencing specifications, revised construction schedule, and updated monitoring schedule. lmpacts addressed in the report are specific to wetlands and buffers. Additional impacts to other habitats are addressed in the habitat management plan. Comments from a memorandum dated September 21. 2009 from ESA Adolfson. sent to David W. Johnson regardingPleasant Harbor - Comments on Wetland and Buffer Mitigation Plan. Thc plan contains minima! infonnalion about impact evoidilhce and minirnization, $o sorw addhional discustisu is warranted to indlcate that the appliciltt has rnet tlE mi:igBtion sequencing test. Thi$ "lest- could be ar irsue th$ Ecology or other stakehotrders may usk rbout during rhf EIS processt us the proiect is reguired to follow the stm&rd mitigrtion $€queDce. Th* said, this is not your typical wcrland fill situatian since Wetlrnd B is loorted in lhe bonom of a deep depres$on and one coukl argue that usiug this area as $ wsler fiourte for the developruent srte i$ woflh rhc radcoff(assuming thut lhe wsler ulic anolysi.r bqrrs that out). Sequencing is addressed in the mitigation approach section. We will revise the plan to include a separate section for mitigation sequencing. The proposed mitigation gener:ally compensates for lhecxpcctcd irrpactl in that the applicant would be creating a wttland ftat is {rpparently) veTy similar to the one being filled,'l'lris is f, typical on+ite, in-*inC rnitigatiur rppruach. A question rhat may be nlsed during EIS revlcw ls wflether the proposed mitigarion is the bcst option ftn thc nitc, Ths ieplacurnerrt wctlurrd will bc ur the trclturn sf a I l&fooldeep natural depression, which, elthough shnilqr to thc wctland to bc flllcd, would $corn to havc limited'ccological or cultuml value, Are better rnitigation options avsilsble? The Mitiprion PIen merno indicatcs thal thc applicanl exarnine.rl sevEn polentirl site* befom selecting this option, but it is not cJear what critcria were used to rnakc the desision. Rrhtps sorne uddirinnal discrrssion of this osscssnmnt vrould lelp clarify the decision criteria That said, the propmcd approach &ppear$ to salisfy regulatory requirernents. The comment is noted. The proposed mitigation was chosen to closely replicate the impacted wetland as well as address local and federal regulations. This is the best option to maintain a diversity of habitat at the site. The buffer addition arefl$ on Wetlmds C and D replace the buffer reduction arcas at the required l: I ratio, but may not be optitnal in lenns of their locatisn. Fnorn the figures, it appears lhat thc$es buffer additions may provide only limited added protecrion to the respective wellondri. The buffer addition areas have been placed where natural runoff flows overland before entering the wetland areas, thus enhancing the protecitve functions of the buffer. Memorandum to Vicki Morris, Vicki Morris Consulting Services January 79,2070 Page 9 The plan $lotes thot one of the goals is tocrleate "undi*turbed conidors befircen riveni. ritrcsms, qetland system$, intoct uplond hrbitmr. and other naural &rer$." bu it is not irnmedintcly ctear that thc pmposcd approoch supports this aim- Furrhurdiscossion of this groal, und illustration* of proposed corridors (or revisiorrs to thc sirc plan if worranted) would be hclpful. The undisturbed corridors are further discussed in the habitat management plan, which also includes a figure that depicts the proposed corridors connecting wetland, stream, upland and shoreline habitats. Use of the word "undisturbed" is the sticking point. From Page 3 of 22- File lcomments-PH-DraftTechnicalReports-Sep22-09.pdf County Staff Comments Golf Course Development - GeoEngineers Page 3 & 4 - mitigation measures identified here should be included in the SEIS These mitigation measures will be included in the SEIS. Is there a training program or plan for educating course personnel? The final repoft will reference training or education opportunities, if applicable. Page 7, Application BMPs- what is a hooded boom and what does it look like? The term hooded boom will be described in final. Page 8, Turf Management BMPs - Give an example of timing of application to minimize leaching and votalization, slowvs, quick release, etc. The final report will describe Earth Renew examples and cite their proposal. Page 8, Turf Management BMPs - thnee bullet points are duplicated here. Duplicate bullets will be deleted. Page 10, Cultural and Physical Controls - How do you remove dew on non-mowing days during disease-conducive periods? The final report will include a description of the process. Page LZ,IPM principals(ples) suggest keeping a record of the following items: - Delete the last sentence of the last bullet point. Garth would not be doing the application, We do not understand this comment. "Principles" is the correct usage. Page A-1 - Add'Name of Applicator" to the log sheet A column for name of applicator will be added to log sheet. Memorandum to Vicki Morris, Vicki Morris Consulting Services January 1-9,20!O Page 10 From PaEe 4 of 22- File lcomments-PH-DraftTechnicalReports-Seo22-09.pdf County Staff Comments Water Quality Monitoring Plan - Subsurface Group Page 2,2nd PP - 802 seasonal and permanent seasonal residential dwellings? Shouldn't it be 890? The final repoft will include the proper number, consistent with the SEIS documents. Page 3, 3'd PP, last sentence - "is will be" The final report will include the correction (deletion of "is"). Page 7,2no PP, 3'0 sentence - Tables 3 and 5, should be 4 and 5. Last sentence - Table 5, should be 6. The text in the report will be corrected. Page 8, 2nd PP, 3'd sentence - "approving" should be approved. The final report will include the edit. From Pages 6 through 8 of 22- File lcomments-PH-DraftTechnicalReports-Sep22-09.pdf Neil Harrington- Jefferson County Water Ouality Program Manager Comments from JCPH on Water Quality Monitoring Plan Brinnon MPR dated August 2008: a a Please provide a site plan that represents the areas ofundisturbed vegetation for Black Point properties and Maritime Village, (28% and73Yo rcspectively) We will ask the civil engineer for this information. From Pg 2, pxagraph under Fresh Water: will the storm water treatment system be sized to include the referenced runoff from Hwy 101? The final report will include a reference to the stormwater report detailing the treatment of HWY 101 runoff. lrom Page J, the second paragraph: the statement that me oevelopmeil ls not expected to increase pollutants in the harbor or Hood Canal should be closely evaluated. We have concems about the ability of the planned treatment systems for wastewater and storm water to protect surface waters from water quality impacts due to pesticides and herbicides. Also we are concerned about the emerging class of chemicals that include pharmaceuticals, personal care products and cleaning agents. There is no proposed baseline data that can make this statement accurate, lacking comprehensive pre development sampling. The final report will include a reference to the stormwater report referencing proposed treatment for these constituents. Baseline data is to be established with the implementation of the sampling plan (see Table 7). a Memorandum to Vicki Morris, Vicki Morris Consulting Services January t9,2O7O Page 11 a a a o a a The final report will be revised to include the intent that the DOE will be notified if state contaminant levels are exceeded. In general, in the discussion regarding Methods, starting on pg 4, the base line data proposed do not seem adequate considering the remote locations in comparison to the project. We would recommend, again, that base line sampling be conducted pre development in the same locations as are proposed for during and after development thereby providing adequate comparison for change. See table 7, Proposed Monitoring Schedule, which propose baseline monitoring. Additionally, no sampling is being proposed in marine shoreline areas other than the Marina. Given the utilization of the shoreline along the perimeter of Black Point by listed salmonid species, we are concemed about the influence of ground and surface water quality on that area, We would like to see base line data developed for both areas with on going monitoring to protect these species from any known water quality degradation resulting from the project. Pg. 3, bullet 3: should include standards for not only Ecology but also Washington State Department of Health. Washington State Department of Health (DOH) water quality standards apply to drinking water not to stormwater. DOE, with assistance from DOH, is working on a new Reclaimed Water Rule WAC 173- 219 that refers to Class A and Class B water quality standards. The rule has not been finalized. Pg. 3 bullet 5: notification should be to Jefferson County and the Department of Ecology. An additional monitoring point could be added to the plan to include marine shorelines, though water quality there would be influenced by multiple factors other than the usage of Pleasant Harbor. This needs to be discussed further within the team. We believe there is a DOE monitoring station just offshore of this location. We can ask the applicant if they wish to do so. Appendix A was not attached for review. Appendix A will include standard operating procedures developed by DOE and guidelines developed by Puget Sound Water Quality Action Team for sampling in Puget Sound (a total of ten documents). Why do some of the sampling parameters proposed differ from those that exist for the Dabob and Hamma Hamma datasets, ie: chlorophyll, fluorescence and light transmission. The parameters listed in Tables 4 and 5 are those that the multi-parameter field unit measures. We will discuss with the team whether other parameters should be added. Memorandum to Vicki Morris, Vicki Morris Consulting Services January t9,2Ot0 Page 72 Pg. 6, Sampling procedures: this paragraph is vague. We would like to see a process that allows for any future sampling protocol to be approved by Jefferson County Water Quality Division prior to implementation. The paragraph refers to specific procedures establish by DOE. The adaptive management section of the Water Quality report specifically discussed that Jefferson County will be consulted regarding modifications. Pg. 9, Adaptive management: Water quality monitoring report should be submitted annually for review to Jefferson County. Based on analysis of results, comparison of existing data sources, and consultation with the other state agencies and the responsible party for the property, Jefferson County may initiate modifications. The monitoring plan must provide adequate protection over time, given the sensitive nature of the site and the acknowledged threatened status of the Hood Canal and its biota. The requirement for the monitoring plan shall be a recorded document to the properry title, and run with the land. Requirement to implement the plan should be the sole responsibility of the land owner in perpetuity. The provision for consultation with Jefferson County is included in the current discussion. The requirement for the Water Quality MP to be a recorded document is an issue for a lawyer and likely should not be addressed in this technical report. From PaEe 11 of 22- File lcomments-PH-DraftTechnicalReports-Seo22-09.pdf SvR Design Comoany- Peg Staehel, ASLA and Amalia Leighton. PE Memorandum #l August 5. 2009 . r - A Draft Water Quality Monitoring Repoft has been prepared identifuing 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. The final report will include clarifications of monitoring responsibilities. . y - A Draft Golf Course Be$ 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. The final report will include references to the 2005 Stormwater Manual Memorandum to Vicki Morris, Vicki Morris Consulting Services January t9,2OtO Page 13 From PaEe l through 14 of 14- File 4comments-WQMonitoringPlan-BillPersich-Aug7-09.pdf Bill Persich P 6 of 14,2"d paragraph Stormwater will be captured on site, treated for nitrogen, and stored to be used for irrigation; excess will be allowed to infiltrate to recharge the aquifer (SubSurface Group 2008). Comment [b2]: Wtrat specific treatment process will be used to remove nitrogen. The final report will include references to the Stormwater Report that discusses the treatment processes. Page 9 of 14, Sampling Parameters section Proposed sampling parameters for stormwater runoff and treated waters at Black Point include the following: Comment Ibl0]: If this water witl be used to infiltrate an aquifer that will be used uttimately for drinking water, DOH (Craig Reilly) may require a spectrum of tests consistent with drinking water sta nda rds (WAC 2 46-290-310). Again, DOH and WAC 246-290-310 refer to water quality standards for drinking water. Unless the water is to be injected directly into the aquifer, drinking water standards do not apply. Page 9 of 14, Sampling Parameters section . Temperature 'pH. Dissolved oxygen . Pesticides, herbicides . Nitrogen (nitrate and ammonia)- nutrients Comment [bl1]: Should add nitrite and organic nitrogen . Phosphorus (total)- nutrients Nitrite can be added to the list of parameters. Testing for Nitrogen (nitrate, nitrate and ammonia) will provide adequate screening and indications of nitrate contamination. lf nitrogen contamination becomes an issue, other forms of nitrogen can be added. We are not clear what form of "organic nitrogen" they are referring to in the comment above. Please let us know if you require any clarification of our comments above. JWP:WSW:mb Disclaimer: Any electronic form, facsimile or hard copy ofthe original document (email, text, table, andlor figure), if provided, and any attachments are only a copy of the odginal document The original document is stored by GeoEngifleers, lnc. and will seNe as the official document of record. C0pyright@ 2010 by GeoEngineers, lnc. All ilghts reserved.