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HomeMy WebLinkAbout017David W. Johnson From: Sent: To: Cc: Subject: Attachments: Swenson, Karen [kswenson@eaest.com] Thursday, February 27,2014 3:06 PM David W. Johnson Craig Peck (peckassoc@comcast. net) Secondary Peer Review Secondary Peer Review Summary Memo.doc, Cultural Resource Assessment Comment Matrix.docx; Economic Benefit Comment Matrix.docx; Forestry Report Comment Matrix.docx; Geotechnical lnvestigation Comment Matrix.docx; Golf Course BMPs Comment Matrix.docx; Grading and Drainage Comment Matrix.docx; Habitat Management Plan Comment Matrix.docx; Neighborhood Water Supply Plan Comment Matrix.docx; Prescriptive Vegetation Management Plan Comment Matrix.docx; Wastewater Reclamation Comment Matrix.docx; Water Quality Monitoring Plan Comment Matrix.docx; Water Supply and Groundwater Comment Matrix.docx; Wetland Mitigation Plan Comment Matrix.docx; Draft Technical Report Comments .pdf; PH-WastewaterReclamationPlantProcess-Jul22-09-draft(BP review).doc; PH-WaterSupply&GroundwaterlmpactAnalysis-Dec17-08-draft(BP review).doc; PH- WQMon itoring Plan-Aug 1 8-08-draft(BP review). doc; Porto comments on NWS P. pdf ; water quality monitoring EH comments.pdf Here is the Secondary Peer Review Memo and associated matrices for the County's review to fulfill Task 4 of Phase 1 of our scope: "Compare final round of peer review/county comments on technical studies to final draft of all technical studies. Draft memo to County regarding adequacy of revisions." As noted in the attached memo, we reviewed the comments from the County or peer review consultants in relation to the original reports, noted how the technical consultant/author responded to these comments, and compared these to thefinal reporttobeincludedintheSEIS. Finally,weevaluatedifanyoftheresponses,orlackthereof,affectedthe adequacy of the Draft SEIS. We prepared a comment matrix for each of the reports (attached) to indicate where comments were only partially addressed or not addressed in the final report - these comments are noted in yellow and blue, respectively. We have also attached the original comments from County staff and the peer review consultants, including the embedded comments by Brown & Caldwell in three of the reports (noted as BP review in the file name, for the reviewer Bill Piersch). We have not attached the original reports to this e-mail due to size constraints. The County delivered these original reports to EA via a DVD the last week of January, We can post these to our FTP site if desired. Similarly, the County also provided us with the responses to the comments from the original authors/consultants on that DVD. These responses are included in the response column within each of the attached matrices. These written comment responses (generally in memo or e-mail format) can be posted to our FTP site as well. Let me know if you have any questions. Thanks, llare*w stttt*wtotw ETI Karen Swenson, AICP Senior Planner 2200 Sixth Avenue, Suite 707 | Seattle, WA 98121 206.452.5350 x 1716 kswenson@eaest,com 1 225 Schilling Circle, Suite 400 HuntValley, MD 21031 Telephone: 4'105847000 Fay': 410771-1625 EA Engineering, Science, and Technology, lnc. MEMORANDUM TO DavidJohnson,JeffersonCountyCommunityDevelopmentDepartment,', :- '' FROM: Karen Swenson, Project Manager FEB z 7 2014 DATE: February 27,2074 tffrtn$0il [0tlil]] [[DSUBJECT: Pleasant Harbor Resort SEIS Technical Report Secondary Peer Review Peer Review Scope Per Task 1.4 of our scope of services for the Pleasant Harbor Resort SEIS, we have completed the second round of peer review of the technical documents that have been developed for the SEIS. These technical documents include: o Grading and Drainage Plan (Craig Peck; September 2008 and }l4ay 2012) . Habitat Management Plan (GeoEngineers; August 2008 and January 2012) o Wetland Mitigation Plan (GeoEngineers; August 2008 and January 2012) o Golf Course Best Management Practices (GeoEngineers; August 2008 and January 2012) o Wastewater Reclamation Plant (Esvelt Engineering; April2009 and June 2013) o Water Quality Monitoring Plan (GeoEngineers; August 2008 and June 201l) o Neighborhood Water Supply Program (Subsurface Group; December 2009 and February 2010) o Geotechnical Report (Subsurface Group; November 2008) o Forestry Report (Resource Management Group; August 2009 and September 2009)o Water Supply and Groundwater Impact Analysis Report (Subsurface Group; November 2008) o Prescriptive Vegetation Management Plan (Resource Management Group; August 2009)o Cultural Resource Assessment (Western Shore Heritage Services; December 2006)o Economic Benefit Report (April 2009 and March 2014) Each of these reports/plans was reviewed by County staff or peer review consultants in the fall of 2009. These comments are attached, including the comments embedded in the reports edited by Brown & Caldwell, one of the County's peer review consultants. The technical consultants/ authors of these reports then responded to these comments generally in the form of a memo and an updated report. We reviewed these comments in relation to the original reports, noted how the technical consultant responded to these comments, and compared these to the final report to be included in the SEIS. Finally, we evaluated if any of the responses, or lack thereof, affected the adequacy of the Draft SEIS. We prepared a comment matrix for each of the reports to indicate where comments were only partially addressed or not addressed in the final report. No comments on the August 2008 Transportation Impact Study (TIS) Addendumprepared by David Johnson Jefferson County DCD February 27,2014 Page2 Transportation Engineering Northwest were included in the packet of 2009 County/peer review comments. We understand this second round of peer review for Transportation was conducted internally by County staff and is separate from this peer review conducted by EA. A 2012 Second TIS Addendum, which was also reviewed by County staff, is included in the SEIS. Technical Report Status The following reports were updated in response to the County/peer review comments. These include: o Grading and Drainage Plan (Craig Peck; May 2012) o Habitat Management PIan (GeoEngineers; January 2012) o Wetland Mitigation Plan (GeoEngineers; January 2012) o Golf Course Best Management Practices (GeoEngineers; January 2012) o Wastewater Reclamation Plant (Consultares/Esvelt; June 2013) o Water Quality Monitoring Plan (GeoEngineers; June 201l) o Neighborhood Water Supply Program (February 2010) The 2009 Forestry Report appears to still be in draft form (titled "Post Review Edits"), with red text referring to additional detail to be added relating to figures and photos. No written response to comments was generated by the technical consultant, Resource Management Group. In general, the comments on this report were questions of report intent, rather than the specific methodology or findings of the report. The following reports were not updated in response to the 2009 County/Peer review comments: o 2008 Water Supply and Groundwater Report (an Addendum Memo was completed in 2012, and written responses to comments were completed in February 2014) o 2008 Geotechnical Report (a Soil and Earth Impact & Mitigation memo was completed by Vinnie Perrone on January 2012; no substantive comments were made regarding this report) o 2006 Cultural Resource Assessment (a Plan for Archeological Monitoring and Inadvertent Discovery was completed in 2012; only one substantive comment was made that was added to the SEIS but did not change the report) o 2009 Economic Benefit Report (a completely new Economic report was completed in March 2014 andtherefore previous comments no longer apply) o 2009 Prescriptive Vegetation Management Plan (no specific/substantive comments were made regarding this plan) County/Peer Review Comments and Author Responses Some of the County/peer review comments were minor in scope (punctuation, typos, correction of references), while other comments addressed potential missing information. As mentioned above, for the reports that were updated, the technical consultant generally responded to the County/peer review comments in written form and noted whether a change to the report was/will be made or why a change was not made due to difference in professional opinion or explanation David Johnson Jefferson County DCD February 27,2014 Page 3 of the project. No responses to comments were drafted by the authors of three reports, as these minor comments no longer applied (Economic Benefit Report), were minor in nature (Cultural Resource Assessment) or were subjective (Prescriptive Vegetation Management Plan). A matrix has been prepared for each report for which comments were only partially addressed or not addressed (see attached). Those comments that were only partially addressed are highlighted in yellow and those comments that were not addressed are highlighted in blue. Each matrix indicates the original comment, the name of the commenter (if known), the response (by the technical consultant), and what changes were made to the document, if any. The reports for which a matrix was prepared include: Grading and Drainage Plan Habitat Management Plan Golf Course Best Management Practices Wastewater Reclamation Plant Water Quality Monitoring Plan Neighborhood Water Supply Program Water Supply and Groundwater Report Prescriptive Vegetation Management Plan Geotechnical Investigation Forestry Report Cultural Resource Assessment The Water Quality Monitoring Plan appears to be revised from a multi-page full report by GeoEngineers (August 2008) to a simpler, more prescriptive plan drafted by the Subsurface Group (June 2011). Therefore, it appears that a substantial number of the comments on the preliminary text at the beginning of the 2008 report no longer apply, since this text was deleted in future drafts. In addition, a written response was not drafted by the plan's author for each comment, but changes to the document were completed where noted. This is so noted in the comment matrix for the Water Quality Monitoring Plan. A substantial number of the County comments focused on the Wetland Mitigation Plan. All of these comments were addressed in the final Wetland Mitigation Plan and responded to by GeoEngineers in memo format. Thus no matrix was drafted for this report since all comments were addressed. Next Step With the exception of the Wetland Mitigation Plan, most reports have remaining comments or questions that were only partially addressed or not addressed. County staff has the opportunity to review the attached comment matrices and determine if the response by the technical consultant/author is sufficient in addressing their question or concern (if partially addressed), and/or whether those comments or questions that were not addressed in the updated reports are critical to the review and success ofthe proposed project. The remaining comments (highlighted in blue or yellow) do not affect the adequacy of the SEIS Attachment A Report Author/Consultant Original Report Date CountylPeer Review Comments? Author/Consultant Response? Updated Report Date Grading and Drainage Plan Craig Peck September 2008 Yes Yes May 2012 Habitat Management Plan GeoEngineers August 2008 Yes Yes January 2012 Wetland Mitigation Plan GeoEngineers August 2008 Yes Yes January 2012 Golf Course Best Management Practices GeoEngineers August 2008 Yes Yes January 2012 Wastewater Reclamation Plant H.R. Esvelt Engineering April2009 Yes Yes June 2013 (appendix to 2014 Sewer Plan) Water Quality Monitoring Plan August 2008 Yes June 2011 (draft form with Jefferson County Water Quality Dept. comments) Neighborhood Water Supply Program Subsurface Group December 2009 Yes Yes February 2010 Geotechnical Report Subsurface Group November 2008 Yes, very minor/not substantive Yes Not updated; Soils and Earth Addendum - January 2012 Forestry Report Resource Management Group August 2009 Yes No September 2009 (draft form titled Post-Review edits, but no direct response to comments) Water Supply and Groundwater Impact Analysis Report Subsurface Group November 2008 Yes Yes Not updated; Groundwater Impact Addendum - February 2012 Prescriptive Vegetation Management Plan Resource Management Group August 2009 Yes, one comment but not substantive No Not updated GeoEngineers (ori ginal); Subsurface Group (revision) Yes, but not to all comments Attachment A Report Author/Consultant Original Report Date County/Peer Review Comments? Author/Consultant Response? Updated Report Date Cultural Resource Assessment Western Shore Heritage Services December 2006 Yes No; one comment incorporated into SEIS, other two comments were not substantive Not updated; Archeological Monitoring Plan and Inadvertent Discovery Protocol -March20l2 Economic Benefit Report Unknown April2009 Yes, minor No New report by new consultant (Wright Johnson LLC, March 2014) so comments no longer apply Transportation Report Transportation Engineering Northwest 1't TIS Addendum - August 2008 Yes, via email from County Public Works Yes, via e-mail to County Public Works 2nd TIS Addendum - January 2012 (County reviewed for adequacy; not part of this secondary peer review) Partially addressed; I Not addressed Cultural Resource Assessment No.Comment Commenter Response Changed? L.lnclude this Mitigation Measure in the SEIS: Page ii- "WSHS recommends creating a construction buffer to protect this archaeological site that is located adjacent to the project area on Washington State lands to avoid any unnecessary disturbance. County Comments Mitigation measure added to the SEIS Cultural Resource section No change to report needed 3.Page 4 - 1't PP - "approximately 14000 - L2000 BP (BC?) Typo? County Comments BP means "Before Present" which is a standard time reference for cultural resources, rather than BC No change to report needed L 2.Page 1 - lntroduction, 2no PP - the County did not review the plan of field investigations. County Comments The report was not updated Partially addressed; I Not addressed Economic Benefit Report fhe Economic Benefit of Pleosont Horbor Marino and Golf Resort report has been completely revised since the initial report was reviewed by the County. The new report was drafted by a different consultant with new data. These comments no longer apply to the current report. 1. No.Comment Commenter Response Changed? 1.We question the figure of 3378.36 for the Male median annual income. lt seems inconsistent with the figure for Female. Could this be 33378.36? Check this. County Comments A new report has been created by a different consultant with new data. This comment no longer applies. 2.Footnote on page one is different that the information following the "*'t'r"note County Comments A new report has been created by a different consultant with new data. This comment no longer applies. 3.Page 3, 2nd PP - what is the 57 in income annually in relation to the 287 FTE jobs? County Comments A new report has been created by a different consultant with new data. This comment no longer applies. Forestry Report Pleasant Harbor Marina and Golf Course BP-200' Sub-Areo (7.7% of totol BP areal The 200 foot Hood Canal Shoreline setback area falls under jurisdiction of the Washington State Shoreline Management Act. This area is reserved for potential dedication as conservancy. The area will be the subject of restoration effort in the proposed Statesman MPR; in compliance with Jefferson County BoCC Condition "s" (additional details please see Section 3.s on page 3) 5.2,1 Sub-Area Size Calculation and Distribution To establish the relative impact to the Black Point Area by each defined sub-area, the sub-areas were delineated on aerial photos and a dot grid proportion system was used to calculate acreages within each sub-area unit. For details of these calculations please refer to Table 3. Table 3 1 Residual 2nd growth timber with capability to grow to maturity without modification (steeper slopes) 2 Residual 2nd growth timber within 200 feet of shoreline , rehab required to repair roads and other clearings 3 Prior harvest occurred without sufficient reforestation due to camp facility creation a Converted in use from forest to campground (includes roads, parking areas, camping sites, buildings, recreation areas, etc TABLE 3 /ACREAGE CALCULATION SHEETlmpact stand dot tvpe lD count dot factor Type acres Tvpe %of total acres Group acreage total Grouo %of total acres -Minimal impact-t Forested BP-1 176 47.',10 21/1%47.10 21.41o/o -Lisht impact-2 Shoreline 200'reserve BP- 200'63 16.86 7.66%16.86 7.66% -Medium to Heaw impact-3 Medium lmpact BP-2 BP-2 52 13.92 6.33% Medium imoact (Glacial Kettle areas)BP-2K 97 25.96 11.08% Heaw lmpact BP-2b 276 73.87 33.58%113.75 51.70% -Heaviest impact-a Converted from forest use (Roads, parking, camping, buildings, etc., not incl. anv BP200' restoration) BP-3 158 42.29 19.22o/o 42.29 19.22o/o Total % of impacted area rated Medium to Heaviest 74.54o/o Total % of impacted area rated Minimalto Lisht 29.07% TOTAL 822 220.00 100.00%220.00 100.00% 24 2/27120t3 4:49 PM Forestry Report Pleasant Harbor Marina and Golf Course Based on the percentage of the total Black Point Area contained within the more heavily impacted BP Sub-area groups, it should be apparent to even the casual reader of this report that the entire Black Point area has been subject to significant degradation from development associated activities over the last approximately thirty or more years. An estimated 52.8% of the area falls within the "heavy" to "converted" (BP-2B and BP-3) use impact groups. The percentage of impact in the whole area Black Point Area climbs to7O.9% with the inclusion of all but the forested (BP-1) and Shoreline reservation (BP-200') sub-areas. 7.0 DrscusstoN 7.1 Maritime Commercial Uplands A review of on-site issues identified in the Maritime Commercial and Residential portions of the property leads clearly to a realization that both past and current uses have led to many of the pathological and mechanically damaged trees found present on the site. Local knowledge and historical evidence found in photographs of the Pleasant Harbor area indicate that the sheltered area of the harbor was used as a log dump beginning perhaps as early as the 1930's and continued thru the mid 1960's into the early 1970's, before becoming a Marina (Figure 1). Sh orel i n e (W ate rfrontl Log Dump / Marina Operation As seen on the aerial photo shown in Figure 1, historical log dumping and rafting operations encompassed a significant area within Pleasant Harbor. As seen more recently in Figure 9, old pilings still remain where log rafts and boom sticks were once tied and remnants of horizontal log bulkheads can be seen by the waterside swimming pool, as support for the fill surrounding the pool area where log loaders used to work. 25 2127120L3 4:49 PM Forestry Report Pleasant Harbor Marina and Golf Course Figure 9 / Remaining pilings and bulkhead from historical log dump operation / Photo: RMG These structures as well as concentrations of bark and other woody debris that now lie buried underneath fill materials will continue to decay and settle making unstable areas. Remnants of cables are found throughout the site and tree damage associated with cables being tied to them was observed. ln some cases cable damage has provided openings in the cambium layer of the tree bole enabling disease entry points. Heavy truck traffic (loaded log trucks) as well as construction related equipment used during the development of the marina both contributed to significant soil compaction. Cut banks created during road construction and other activities have done mechanical damage to many trees. TidalAction Over time tidal and wave action has contributed to undermining of supporting soil from trees along the shoreline (Figure 10). These leaning trees are potential hazards to near shore marine or boating activity, beach users. 26 2127l2O!3 4:49 PM I,tta . i- h t ! I Forestry Report Pleasant Harbor Marina and Golf Course Figure 10 / Tree leaning towards dock / Photo: RMG Tree Patholoov General pathological groupings observed on the property are as follows: o Root Diseases o Laminated Root Rot (Gs) o Conifer Rust Fungi o Canker Diseases A more complete study of pathogen biological origin and development can be found in literature referred to in the Appendix. See also Table 1 for Sub-unit presence of pathogens. 27 2/2712073 4:49 PM "l I '.1 { ! ''. Forestry Report Pleasant Harbor Marina and Golf Course Most prevalent is the root disease, "Laminated Root Rot". s'6 This type of infection may be randomly dispersed throughout a stand or may be grouped in "disease centers". The presence of this root disease as mentioned in the results section of this report and in Table 1 is prevalent throughout both the Marina and Maritime Village areas. lt is also likely that the pathogen may exist in the Black Point area but resides in a dormant state in older root material remaining from the previous forest. The Laminated Root Rot pathogen may remain virulent for as long as fifty years in pieces of root material left on site following logging.T ln that state it will continue to threaten a contribution to the process of infecting health trees in situations where new roots from subsequent stands reach old root material and the process begins anew. Danoer Trees The cumulative impact of forest disease combined with mechanical impacts that have occurred during active log handling, road construction and in more recent years during construction of the marina have created a situation within the Maritime property that is potentially hazardous. Field evaluation of trees within the Maritime area leads to the recognition of significant numbers of trees having moderate to high failure potential. Hazard levels are defined in this report using concepts drawn from Tree Hazards in Recreotion Sites in British Columbiog and in Lonq-Ranoe Plannino for Developed Sites in the Northwest.s Operations necessary to mitigate hazardous tree health and safety issues should begin with removal of most hazardous trees. Hazard ratings identifying various degrees of hazard are defined in Table 5 parts a, b, and c on the following page. Hazard trees are found not only in the upland areas of the property but also along the waterfront where there is extensive vehicle and foot traffic as well as marine activity. Safe removal of hazard trees may require a variety of methods and equipment depending on the individual tree's location, characteristics, and situation. Some tree hazard mitigation efforts may be as simple as contracting with an experienced tree climber on a tree by tree basis to climb individual trees and remove them section by section. Other trees may require more elaborate means employing heavy equipment such as excavators and/or boom trucks. Any of these methods will require considerable safety areas around the work zone. Additional treatment suggestions are presented in the RMG report titled Prescriptive Veaetotion Manaoement Plan Pleosont Harbor Marina ond Golf Course Resort.lo 'Thies, Walter G., Sturrock, Rona N., 1995, Lominated Root Rot in Western North Americo, (USDA Forest Service, Pacific Northwest Research Station, General Technical Report PNW-GTR-349) (Published in cooperation with Natural Resources Canada, Canadian Forest Service)t Allen, E. A., Morrison, D. J., Wallis, G. W., 1966, Common Tree Diseases of British Columbio, (Natural Resources Canada, Canadian Forest Service) p.20-23 'op. cit., Thies, p.15 'Wallis, G. W., Morrison, D. J., Ross, D. W., 1987, Tree Hozords in Recreotional Sites in British Columbio, (British Columbia Ministry of Environment and Parks, Canadian Forestry Service, Joint Report No. 13) ' Harvey, R. D. Jr., Hessburg, P. F. Sr., 1992, Long-Ronge Planning for Developed Sites in the Pocific Northwest: The Context of Hazord Tree Monagement, (USDA Forest Service FPM-TP039-921 pt7-L8 to RMG, 2009, Prescriptive Vegetotion Monogement Plon, Pleosont Horbor Morino ond Gotf Course, (Report prepared for Statesman Corporation) 28 2127/2073 4:49 PM Value 1 Verv low failure potential sound trees not likely exposed to weather extremes Value 2 Low failure potential , minor defects may be present. weather sheltered or unsheltered but sound moderate defects shallow soil high water table exposure to weather extremes Value 3 Medium failure potential Value 4 Value 1 . serious defects. limited root anchorage. dead trees or root disease. multiple defects . only smalltree parts involved . no chance failed parts will cause damage on impact Hiqh failure potential S damage . only smalltree parts failo indirect impact in occupied areas, or failure will occur when area is unoccupiedo if damage occurs target is low value Value 2 Minor damage Value 3 Medium damage . small trees or tree parts sufficient to cause moderate damageo moderate target value. target likely to sustain only moderate damage Value 4 Extensive damage o medium to large trees or tree parts . high target value including high value property and damage likely to be severer potentialto injure or kill people Forestry Report Pleasant Harbor Marina and Golf Course Table 5a. Tree Failure Potential Table 5b. Tree Failure Table 5c. Risk Class Allocation m11 RISK CLASS TREATMENT PRIORITY 8 Very hish 7 Hish 6 Moderate 2-5 Low 11 Op. cit., Harvey, p17-18 t'rbid, p17-18 " rbid, ptz-t8 29 2127/20L3 4:49 PM Forestry Report Pleasant Harbor Marina and Golf Course Laminated Root Rot lPhellinus weiriil "pockets" are the most prevalent tree health issue on the property and occur throughout the Maritime Commercial and Maritime Residential areas. As these "pockets" of disease continue to increase in size over time via root grafting under the soil surface, additional trees become infected and eventually weaken and die. Mitigation of entire infection pockets is not as easily accomplished as removal of individual obviously infected or dead trees may be. Visibly infected hazardous trees in these infected areas can be removed by harvest. To stop the spread of disease and subsequent creation of additional hazard trees over time, additional trees from the perimeter of the infection area (approximately 50 feet past visible infection) must also be removed to minimize further expansion of the disease in the sta nd.1a Mitioation Methods for Lominoted Root Rot Based on control methods recommended in previously mentioned publicationsls'16 and relying on the experience of Washington Timberland Management, lnc. in treating root rot infestations in Western Washington, it can be concluded that four basic options are available from which to choose to treat Laminated Root Rot infections. A fifth option may also be available in time. 1. Destruction of infection areas (pockets) thru harvest of all infected trees and at least two trees outside the visible influence of the infection, followed by return visits to eradicate any further spread. This will minimize the ability of the pathogen to transfer from host tree to host tree by transporting thru root grafts in the sub soil. This method will create holes in the forest but leave other areas intact. Replanting could follow with a resistant species of tree. 2. Selective logging of larger forest areas in which the pathogen is active, followed by return visits to eradicate any further spread. Further harvest to salvage dying trees may leave under stocked areas that would need reforestation with a resistant species. This is not a great deal different than option #1. 3. Final harvest of the entire forest (clear cut) which would be followed with replacement of the forest with a resistant species. 4. Remove all trees and stumps, and redevelop the site per the MPR and BoCC conditions. This option would serve to more permanently interrupt the root grafting process and eliminate much of the transport potential relied on by the root rot pathogen for further infection. Resistant and non-susceptible species would be used in landscaping. Ia Op. cit., Thies, p19-25 "rbid, p21 15 Op. cit., Allan, p20-23 30 212712073 4:49 PM Forestry Report Pleasant Harbor Marina and Golf Course 5. Chemical inactivation may offer promise for future management, especially with high- value trees, provided environmental risk associated with use of registered chemicals can be successfu lly addressed.lT ln the end, the goal of hazard tree evaluation and hazard management on this MPR site, including Laminated Root Rot hazards, is to strike an appropriate balance between various priorities. o Protect public safety o Maintain sustainability of the forest and recreation resource o Comply with BoCC objective "t)" to "retain evergreen trees and understory in a condition as undisturbed as possible" o Protect public and private property o Minimize cost. The comments to follow consider these priorities in conjunction with preliminary understandings of the scope of activities planned by Statesman Corporation at the Pleasant Harbor MPR site. Sub-area MC-1 in the Maritime area could be left intact except to respond to recommendations that any root rot infected areas be treated in line with a developed long term "Vegetation Management Plan" as outlined in the precursory "Prescriptive Vegetation Management Plan".18 The objective would be to protect the remaining stand from further spread of the disease and the public from further hazard. This area could be replanted with Western Redcedar or hardwoods that would be more resistant to infection. AS mentioned previously, the Laminated Root Rot (P. weirii) pathogen has a life of approximately 50 years within pieces of root material that remain in the soil. lf during that extended time an unaffected tree's roots finally touch a portion of old infected root material, it is exposed and may well become infected and reinitiate the process". One treatment for dealing with areas of severe rot root infection is mechanical stump removal and ripping of the soil with heavy equipment to break the potential transmission route of the pathogen through root grafts2o. lt is important to note that proposed development of the Maritime Commercial and Residential areas would supply a number of benefits to the site that inhibit or destroy the disease or inhibit its spread. Mass grading and other construction based movement of fill material serves to severely interrupt root based pathogen transmission pathways. t'op. cit., Thies, p23 " RMG, 2O09, Prescriptive Vegetotion Monogement Plan, Pleosont Horbor Morino and Golf Course, (Report prepared for Statesman Corporation) le Op. cit., Thies, p15-15 'o rbid, p21 31 2127/20L3 4:49 PM Forestry Report Pleasant Harbor Marina and Golf Course Foundations and other constructed features can serve to block pathogen transmission on a permanent basis. Landscaping offers a chance for new and health re-vegetated and root rot resistant areas to be created 7.1 Maritime Village Due to the many similarities between the Maritime Commercial area and the Maritime Residential area many of the discussion points would be the same as they relate to the standing trees or forest located in this area of the overall project. For purposes of this report both the Commercial and Residential segments of the Maritime Village area have been combined in this portion of the discussion. One feature of the Maritime Village area not found covered in the Maritime Commercial area discussion is the expansive gravel parking area along Highway 101. This area is referred to as Sub-area MR-2 in the "Results" section of this report and is partially shown in the foreground of Figure 8. This area is worth reviewing as it clearly demonstrates extensive intrusion and the conversion in use from a previously forested area to an area with no forestry use as all. This area includes a Real Estate office and its parking area. 7.2 Black Point Golf Course and Resort ln reviewing the Black Point Area the extensive impacts this property has been subjected to are very apparent. As previously shown in Table 3, "Minimal lmpact" timber stands are the smallest portion of the existing forested areas that remain on the Black Point property. This remaining area of timber equates to approximately 2L.47% of the total Black Point Area acreage. One possible reason for this area remaining less impacted is its topography or steepness. lt is probable that the value of this timber, when harvest last occurred, was not worth taking to market due to smaller average tree size and a location on steep slopes that in some cases exceed normal ground based harvest equipment limitations. A second timbered area containing larger trees is composed of that portion of the Black Point property located within 200 feet of the high tide line on the shoreline of Hood Canal. The 200 foot shoreline buffer area is approximately 7.65% of the total BP area. This buffer area will be restored to a more natural state where needed and protected as part of the proposed Statesman development plans, in compliance with Jefferson County BoCC condition "s". Timber stands on other some other portions of the property were tree covered in past years but are now stocked with only brush and smaller trees (Table 3, "Medium to Heavy lmpact"). These were most likely stocked with trees of higher value at the time of last harvest and thus became the target of logging efforts. ln reviewing available aerial photography, one can see logging impacts in these areas in the form of skid trails within the Black Point area, including within the Kettles. These remaining forested areas are not without impacts or intrusions from the surrounding development of the campground. Many have trails, parking areas on the edge and old skid roads and landing areas within. 32 2/27/2073 4:49 PM These options really divide naturally into two main categories: Forestry Report Pleasant Harbor Marina and Golf Course The remaining forested area of "Minimal lmpact" (BP-1) is in direct contrast to the "Light lmpact" area (BP-200), the areas of "Medium to Heavy lmpact" (BP-z, BP-2K, BP-28), and the area of "Heaviest lmpact" (BP-3). All of these other sub-areas of the overall Black Point property are presented in the Results Section and tabulated in Table 3. These disturbed portions of the property all show varying degrees of impact, from moderate thru outright conversion to a use "not compatible with growing forests". The more impacted areas from Medium to Heaviest comprise approximately 70.9o/o of the property. They have three treatment options within the framework of the MPR and the BoCC conditions: o Clean up and mitigate as much of the past impact as possible and allow those areas to revert to a more natural state o Clean up the site as above and reactivate as a permitted campground o Redevelop the property per the MPR zoning and the proposal submitted by The Statesman Corporation. 1. Development and restoration of the campground could occur in a layout similar to the footprint of the existing campsite and RV Park. 2. Redevelopment could shape the current site into a resort in line with the MPR zoning of the area. ln looking at option categories 1 and 2 above and considering the likelihood of creating a viable forest that would provide sustainable natural environment values in a reasonably near future time, the Black Point area is most likely too heavily impacted by existing development and the extensive presence of poor quality trees and invasive species to be able to be economically reestablished with a value in excess of the economic return available from more development focused target uses. Development of the site as the MPR zoning allows would enable a relatively complete restoration of the entire site. This restoration would facilitate re-establishment of significant and healthy green belts and buffers. Reinstatement of open spaces between the proposed fairways and other resort areas would most likely enhance and increase the amount of natural vegetation as compared to its current impacted condition. Repair of previous development features such as roads and camp areas lying within the first two hundred feet above the shoreline of Hood Canal would add significantly to the total positive impact development would lend to a reinvigorated Black Point environment. 33 2127120L3 4:49 PM Forestry Report Pleasant Harbor Marina and Golf Course For successful redevelopment into a MPR facility, site conditions would necessitate considerable mass grading and mandate extensive erosion control efforts. With current available clearing and grading technology, grinding of organic and woody debris harvested from the site would generate ample "hog fuel" for use in slope stabilization and site protection from storm water or runoff issues. The use of locally created "hog fuel" in the site surface stabilization and protection process would also aid in preventing further depletion from the site of the organic value of this material. This has potential to aid in rebuilding depleted soils on the property, During land clearing done in preparation for a mass grading operation, prospective stumps and trees meeting specification for use as "Large Woody Debris" (LWD) could be processed and saved for future rehabilitation use both on and off the property. Habitat trees having potential for placement and use in restoration work in wetlands would be identified and sheltered. Sufficient native species of brush, shrubs or trees could be identified and transferred and held in a potential on site nursery area for use in later reestablishment work. Early identification of potential transplant nursery areas would allow for small nursery grown and selected onsite natural trees to be transplanted to the holding site at an earlier point in time and allowed to mature for later movement to final planting locations as the development process moved along. 8. RECOMMENDATIONS The original request to RMG was to evaluate the existing forest communities in the Maritime Commercial and Residential areas as well as on the Black Point Golf Resort property. These forest communities are all located within the MPR proposal and thereby subject to Jefferson County BoCC conditions, five of which relate specifically to preparation of this Report. The five conditions have been detailed previously in this Report in the "Description" section on page 3 and 4. An operational course of action that would begin the process of charting a functional path to compliance with these BOCC requirements would follow the template presented in the Prescriptive Veqetotion Monaqement Plan21 Combining the Prescriptive Veqetotion Manaqement Plan template, the information presented in this report, and the proposed/approved site development plan, while maintaining an appropriate focus on adherence to the BoCC conditions of approval; a site specific vegetation management operational plan could then be created. Within this operational plan, individual segments of the planned development and their potential impacts on existing and future forest vegetation could be evaluated and a proper prescriptive plan of action could be designed. This 21 op. cit., RMG 34 2/27/20L3 4:49 PM Forestry Report Pleasant Harbor Marina and Golf Course approach would serve to insure that appropriate actions specifically intended to comply with the Jefferson County BoCC criteria would be implemented. For example, buffer and greenbelt areas (BoCC, item "s") would be individually evaluated, delineated, and protective measures would be designed. Other BoCC conditions such as building placement (BoCC item "v"), and identification and protection of significant trees (BoCC item "w") would also have specific plans addressing their needs. The protective measures would then be set in place prior to, and remain during construction. Long term protection measures whose efficacy would be designed to extend indefinitely past the completion of the project development phase could also be designed and put in action. Proper identification of "significant trees", and hazardous conditions as identified in this Forestry Report, combined with good record keeping and adherence to a final Vegetation Management Plan will provide a basis for long term management, safety and enhancement of the forested/vegetative communities within the MPR 35 2127120t3 4:49 PM APPENDIX Table #t I Mmren usT oF FoREsT sPEclES lsusJecr ro FURTHER nevrsrol] A listing of forest trees and shrubs commonly observed on site: Gonifer Trees Douglas-fi r (Pseudotsuga menziesii) Western Hemlock (Tsuga heterophylla) Western Redcedar (Thuja plicata) Pacific Yew (Iaxis brevifolia) Western White Pine (Pinus monticola) Broadleaf Trees Black Cottonwoo d (Popul us trichocarpa) Red Alder (Alnus rubra) Bitter Cherry (Prunus emarginata) Bigleaf Maple (Acer macrophyllum) Pacific Madrone (Arbutus menziesii) Broadleaf Shrubs Red-Flowering Currant (Ribes sanguineum) Scotch Broom (Cytisus scoparius) Vine Maple (Acer circinatum) Salal (Gaultheria shallon) Evergreen Huckleberry (Vaccinium ovatum) Forestry Report Pleasant Harbor Marina and Golf Course 36 212712013 4:49 PM Forestry Report Pleasant Harbor Marina and Golf Course APPENDIX Table 1 /re Thumbnails to be included later / table subject to further reviewl LOG 2638 at hlghway 2639 2 close of dead tree 2640 3un dercut slope above B&Q Hwy 101 2641 4 52642 2643 6 Waterside - canker or wire scar 2644 7 as #6 close u 2645 8 beach/bank erosion - undercut cedar stump 2647 2648 2649 2652 10 11 12 14 15 old log dump pee! 2650 13 large undercut tqq past dump 2651 closer (w/Jim) closer 2653 2654 17 view NE Jim on old road below OHT 2655 18 beach side to SW 2656 2659 2660 2662 19 22 23 25 26 down beach NW to marina dock 2657 20 water/wave undercut on Madrone 2658 21 rock armor on new dock 2661 24 view from beach to marina build w/ dead trees above 2663 2664 27 to NW along N edge- o[ hapoq 2665 28 another view as in 24-26 2666 29 dead trees on water view from dock 1 Photo !D ption /list number Notes 2667 30 view SW into harbor to dead tree by hwy (see 1-2) 2670 33 view from dock to dead tree at water edge 2676 39 steep undercut banUtrees @ water edge 2671 ol #37 crotch beh!nd maring btdg 40 41 U gen view over new dock to marina buildings 35 rock armor on new dock ramp (see 21:Zg) 36 broken dead top fell behind marina bldg 37 weak 38 close 2672 2673 2674 2677 2678 2675 2668 2669 31 B&B boats at dock 32 view from dock to trees in #'s24-26 &28 2679 42 dead alder leaning over parking area above buildinqs parking area cut roots expo.43 44 U2680 2681 severe root ove side of area area45 46 close of dead 2682 2683 dead tree above build above road near build water side of 37 2/2712013 4:49 PM 1 area54 55 56 Anemic tree laminated root road edgeuriedbatroots 2691 2693 2692 dead Madrone limb over 58 roxim of dock to OHT tree line 2694 2695 under cut Madrone at OHT line boat shows left edge of #61 - dead trees severe root damaqe at of parking area 59 64 60 63 61 62 66 67 dock view of shore to NE near prop llne dock to pqop, line aqea at E of malina / dead trees conk bird in bole 2696 2705 2697 2704 2698 2703 2699 2702 2700 2701 as #60 with dead trees near OHT line old boat roadabovedead shows left of #62 - sick trees & undercut trees bird on dock Forestry Report Pleasant Harbor Marina and Golf Course 2684 47 bird hotes in live snag nea!:buildings up-per parking 2685 48 severe lean in e tree rds 2686 49 ca nker on tree 2687 dead limbs viewed from parking spots 2688 51 dead limbs viewed from 2689 52 dead crown 2690 53 mechanicalda / install street 2706 69 mechanicalda 2707 70 same as #69 2708 71 dead red alder with vehiclg parked undelneath (owner unknown) 2709 72 another view of #71 2710 73 canker / mechanical scar 2711 74 un delstory snag above parking area 2712 75 fixture in tree (damaged by fa!ling limb?) 2713 76 dead tree with large limbs hanging over parking area 2714 77 dead tree over area 271 78 old butt da 2716 79 insect bore holes / tree itchin 2717 80 insect bore holes / tree itchin 2718 81 dead road near RV 2719 82 e 2720 83 dead alder overhanging road edge at intersection 2721 84 edge at intersection 2722 at intersection 2723 86 dead tree with limbs at edge of parking area 2724 87 difference in crown appearance heatthylsick 2725 88 dead tree at edge of road 2726 89 new view of #88 2727 90 conks on tree at ed of 2728 91 conks on tree at ed ge of parking/rroad road272992 conks on tree at ed of 2730 limbs at of 2731 94 another view of #88 snag 38 area 2/27/20L3 4:49 PM alea Forestry Report Pleasant Harbor Marina and Golf Course 2732 95 view of tree crowns with dead tree in center / above road 2733 96 cut bank at area M trees at 2775 138 dead limbs over use area at 2776 139 laminated Root Rot fruit[ng body / tree tocated jus_t over hwy 101 2777 140 tree with fruitin aleaof ildingsofaboveareanamaribu 98 99 rools in cut for parking area. at ed2734 2736 2735 atdead tree above marina bu tree above marina buildings showing bird holes near base100 1 dead scut bank at eof hi and undercut 2737 2738 crown showing need!e loss and yellow color blown out of dead tree same as in #36 but shows structure roxi additional view of #1022739 2741 2740 't02 104 103 2744 107 2745 108 2746 109 2747 110 of conks on bole of dead tree above marina buildinClose2742 1 2743 106 mechanical damage with buildings below weak crotch behind marina bld 2748 2752 2749 2751 2750 111 12 113 114 11 w/ trees at dead area rootIed Close u ofconk on#126 with new beI manhind na itchi from insect wounds bultdlngsofvtewaboveareamarina grow over of honeysuckle vln_qnkeorfromscarca btdscrotchweakmanbehindna same as #119 different view 2764 2754 2763 2755 2762 2761 2760 2759 2758 2757 27 121 '120 118 119 stem behind marina 123 127 126 't25 tree with conk cut bank at 2753 116 broken 1'17 trees limbs over vehictes i1 load/parking area 124 another view of #123 I showing old rotten piling and pr,oximity to dock at RT 2765 Close u ofconk on#126 with root damage at edge of road cut same as #129 but different view 128 132 131 1302767 2769 2768 beach below starfish 129 tree / weakness / above road color over at bole scar - mechanical crown showi 2770 2774 2771 2773 2772 34 136 needle loss and area at 133 butt scar - mechanical 135 twin to 2778 141 dead crown in #139 39 2/27/2OL3 4:49 PM Forestry Report Pleasant Harbor Marina and Golf Course 2779 142 canker swelllng - ro!?Root 101 B&B well smaller dead trees above B&B access road 2780 2784 278i 2783 2782 143 147 144 146 145 scar on defective cedar undercut roots le base above B&B road 2785 148 trees with buried roots at hwy edge 0ust outside prop line) 2789 152 cedar with broken top S of B&B on rd to hlvy cedar (high!y defeclive)149 rotten 1 50 another view of #149 151 bird holes in snag by B&B 153 dead tree above B&B and Garth house '\il tree with conk at distance above boat launch 2788 2790 2791 2786 2787 e / root rot & mechanical root ot #1542792 2796 2793 2795 2794 156 157 tree with excessive lean towards B&B use areas canker/rot in upper bole near #157 dead trees below B&B at OHT 155 close u 159 at OHT line /butt 158 2797 160 needle loss and low colorcrown s icat damage neal B&B by picnic- tabte27981mechan at B&B'162 trees over bank trees above and between B&B and Garth house above road Old scar from broken. and / rot with weak 2800 2804 2801 2803 2802 163 167 164 165 under cut roots above Garth house oveanother view of #162 166 trees Garth house and B&B dock from DFW boat launch / dead trees up right from house Jim tired of thinking so hardl 2809 proximity tooviewharborutfromraDFWshmatreesrina boatsmpowrng closer view of #169 2806 2807 169 170 171 2805 168 172 view to harbor mouth from DFW ra area with dead trees below B&B / see #157-1592810 2811 173 174 area to S of B&B line with DFW dead trees above and of house2812 28',t3 175 176 same as #169-170 showin same as #171 but closer 40 2/27120L3 4:49 PM Partially addressed; - Not addressed Economic Benefit Report fhe Economic Benefit of Pleosont Horbor Morina ond Golf Resort report has been completely revised since the initial report was reviewed by the County. The new report was drafted by a different consultant with new data. These comments no longer apply to the current report. L No.Comment Commenter Response Changed? 1.We question the figure of 3378.35 for the Male median annual income. lt seems inconsistent with the figure for Female. could this be 33378.35? Check this. County Comments A new report has been created by a different consultant with new data. This comment no lonser apolies. 2.Footnote on page one is different that the information following the ":t*:*'note County Comments A new report has been created by a different consultant with new data. This comment no longer applies. 3.Page 3, 2nd PP - what is the 57 in income annually in relation to the 287 FTE jobs? County Comments A new report has been created by a different consultant with new data. This comment no longer applies. Partially addressed; I Not addressed Geotechnical lnvestigation No.Comment Commenter Response Changed? 2 Figures 3, 4 and 5 are missing from the Report County Comments These should be included: Fig 3: Maritime Village Section View Fig 4: Limits of Vashon Glacier Advance Fiq 5: Geoloqic Structures No change - these figures were included in the report L 1.Page 16, LL.2.4 Cut Slopes - Temporary Shoring is section 11.3 not 10.5 County Comments OK, will make correction Correction was not made; report was not updated Partially addressed; I Not addressed Grading and Drainage Technical Engineering Report No.Comment Commenter Response Changed? 1.Page 2-2 - "lt can be expected that approximately XX acres or 80 (?) percent of land will be cleared and graded." We need a final approximate figure for the SEIS. County Staff Final grading quantities will be developed for the SEIS. Yes - 152 acres or 67 percent 2.Page 2-2,1. B. last sentence - explain "the surface area of the reformed kettle would be approximately 50 percent of the area of the top of the current kettle." County Staff Explanation of kettle reconfiguration will be better described. Yes - The objectives have been removed. 3.Page 2-6, middle of the page - (Note for Supplemental Environmental lmpact Statement being prepared for the Pleasant Harbor Marina and Golf Resort-Vinnie) Need to address this. County Staff lwillcomplete coordination with Vinnie Perrone, Geotechnical Engineering consulta nt. Added "ln orderto minimize potentiol odverse impocts to odjocent residentiol uses in the ored' 4.Page 2-8 - What about the Marina excavation? Where does that fit into the phasing plan? County Staff Maritime Village construction phasing and excavation quantities will be revised for the SEIS. This is not specifically called out in the text, but is clearly outlined in Appendix A. 5.Page 3-13, 2"d PP - Please give a specific cite reference for the statement, "Preliminary results from those studies indicate that development will increase groundwater recharge by approximately 10 percent given the removal of vegetation...." County Staff Statement taken from the Scott Bender report: Water Supply and Groundwater lmpact Analysis. Yes-this paragraph has been removed. 6.o - The Grading and Drainage report does not reference Jefferson County Code in the text, but it is apparent that preliminary designs use the 2005 Department of Ecology Stormwater Manual for Western Washington. Stormwater runoff and treatment facility sizing calculations are included in the appendix. Calculations were made using the required Western Washington Hydrology Model software. SVR The Western Washington Hydrology Model(WWHM3)is being used. Makes several references to complying with all Jefferson County regulations, but never distinctly mentions Jefferson County Code. SWMWW is clearly called out. L 7 q - lt is unclear from the existing calculations if the development will be able to meet the requirements of zero discharge. Grading and Drainage report does not summarize the 300 page appendix containing the stormwater management facility sizing calculations. A SVR Zero discharge will be achieved with grading, not runoff calculations. A table containins the Zero discharge is addressed on page 3-10. No table has been prepared. ls it needed? Partially addressed; - Not addressed Grading and Drainage Technical Engineering Report No Comment Commenter Response Changed? 8 Section 1.1 - Pre developed and Existing Conditions descriptions combined SVR Pre-developed and existing conditions a re the same. Yes 10 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. SVR Project phases and sequences will be described. Current calculations are for build out. Appendix A provides a detailed description of project phases and sequences. a. Discussion to be provided. b. Gravel processing area(s) to be better described. c. Area of clearing is provided as areas of cut and fill. Boundary can be Site plan depicts gravel processing location. Figure 2-1 shows cut and fillareas. Text indicates that buffers would be established for any 11.Section 2.4 - Potential Construction lmpacts: a) No discussion how wetlands will be protected during gravel process b) No figure identifoing 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 SVR 2 table identifying the following information for each basin should be provided: Ll totol bosin size, 2)proposed impervious,3l proposed pollutont generating imperuious,4) proposed gross, 5) proposed pastu re/native, 6). proposed forest, 7 ) predeve loped (fore sted condition) runoff flow rote, Sl developed flow rote,9l average infiltrotion over basin oreo, 10) proposed type offlow controlfocility, 11) estimated size offocilities to meet lorested conditions/zero discharge to Hood Canal, ond 72) what stormwoter treatment will be provided if any.ln addltion, 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 8.1. Additional comments specific to the organization of the report are provided below. information suggested may be considered if it will truly better inform the reader. A summary of the 300+ pages of calculation output will be prepared, if those pages are included in the report. Site grading creates new sub- basins. 9.Section 2.2 - Proposed development description does not include land cover values for each section of development SVR Description could be provided if necessary for the understanding of the reader. Land cover values are not provided - are these needed? Partially addressed; I Not addressed Grading and Drainage Technical Engineering Report No.Comment Commenter Response Changed? report. Areas cleared are not quantified. d) No discussion of impacts during construction of Section 2 and Section 3. identified better d. Impacts to be described. protected areas. L2,Section 2.5- Mitigation measures for construction impacts during phasing are not identified. SVR Phases to be identified and impact of each to be described. More mitigation text was added, but it is not separated by phase. 13 Section 2.6 - Only Phase 1 development is discussed SVR All phases to be described. Yes L4.Section 3.1 - Existing Conditionsa) Site specific drainage basin predeveloped and existing condition runoff peaks and volumes are not identified for the existing basinsb) Runoff/lnfiltration/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 221. SVR a. Existing runoff quantities for those areas discharging offsite will be better identified. b. Coordination between final reports will be improved. Much of this text has been removed, but that does not address these comments. 15.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. SVR Wetlands are not being used to infiltrate stormwater. Existing wetlands will receive runoff sufficient to maintain their conditions. Created wetlands will receive runoff adequate to maintain them. Grading and Drainage Report text states that hydrologic impacts to wetlands would be minimized. Calculations regarding if wetland can meet SW requirements are not provided. Rainwater Harvesting - Address if rain water harvesting is feasible considering that aquifer recharge is providing water supply for the development. SVR Rainfa ll ha rvesting will occur to provide irrigation. lrrigation will contribute to aquifer recharge. Yes- comment clarifies 17 Reducing the Quantity of Stormwater to be infiltrated - See comment SVR See comment above Yes 3 16. Partially addressed; I Not addressed Grading and Drainage Technical Engineering Report No.Comment Commenter Response Changed? 9 above. 18.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. SVR Minimum requirements will be discussed. New text added discussing many of the requirements for the SWMWW, but never distinctly addresses the minimum requirements by name. 19 Phased Development - A proposed stormwater layout for each phase and the developed condition was not included. lt is unclear what the stormwater management will be for Sections 2 and 3 during construction and when the development is complete. SVR A stormwater collection system layout in the SEIS is not proposed. A conceptual plan could be produced if determined to be necessary. A conceptual plan could be developed for each phase if determined to be necessary. A proposed stormwater layout for each phase in not included. Does this info need to be added to this report? 20.WWHM results should be summarized in the text for each basin SVR A summary of WWHM3 data for each basin could be provided if determined to be necessary. WWHM results are not summarized for each basin. Does this info need to be added to this report? 2L No discussion of sub-basin limits changing from existing conditions to the proposed sub-basin limits. SVR A general discuss of grading changes to sub-basin could be provided if determined to be necessary. A discussion of sub-basin limit changes is not included. Does this info need to be added to this report? 22.Report does not reference Jefferson County Code requirements.SVR Jefferson County code requirements will be mentioned. See comment 6 4 Partially addressed; I Not addressed Grading and Drainage Technical Engineering Report No.Comment Commenter Response Changed? 23 Report does not reference FEIS Mitigating Conditions for subsequent project review, technicalcomments, and comment log. SVR FEIS mitigating conditions will be described FEIS mitigating conditions are described in the updated report, but not for these specific actions 24.The following reports would also be useful in identifoing information required of the SEIS:. Sequencing Plan for Construction Activities including phased development earthwork management plan and temporary and erosion and sediment control.o Arborist Report to identifo tree information including tree retention, tree harvesting, and understory health to support stormwater calculations and temporary erosion and sediment. SVR A phasing and sequencing plan will be developed and described in the SEIS. A phasing plan is included in the SEIS. A phased development earthwork management plan is not included. Does this info need to be added? A Forestry Report is included in the SEIS. 25 The draft Grading and Droinage Technicol Engineering Report indicates that kettles will be used for stormwater control, but does not specify which kettles. Two of the kettles are not wetland and Wetland B is proposed to be filled. However, two kettles in the project area are wetland (Wetlands C and D), and are protected underJCC critical areas requirements. The applicants should clearly indicate which kettles are to be used for stormwater control. As noted above, alterations to Wetlands C and D are to be avoided. Donna Frostholm The extent of clearing and cut and fill is shown on the earthwork map. The areal extent is provided as a percentage ofthe site and in acres. A description of areas with fill slopes that could drain offsite will be provided. Potential impacts to fish and wildlife are described in reports prepared by GeoEngineers. Appendix A specifies that kettles B and C would be filled. Page 2- 11 includes text noting that Kettle C would be filled to create a wetland, and 1-4 notes that Kettle B would be reconfigured by mass grading to create an irrigation pond. 5 Partially addressed; I Not addressed Cultural Resource Assessment No.Comment Commenter Response Changed? 1.lnclude this Mitigation Measure in the SEIS: Page ii- "WSHS recommends creating a construction buffer to protect this archaeological site that is located adjacent to the project area on Washington State lands to avoid any unnecessary disturbance. County Comments Mitigation measure added to the SEIS Cultural Resource section No change to report needed 3 Page 4 - 1't PP - "approximately 14000 - 12000 BP (BC?) Typo? County Comments BP means "Before Present" which is a standard time reference for cultural resources, rather than BC No change to report needed 1. 2.Page L - lntroduction, 2nd PP - the County did not review the plan of field investigations. County Comments The report was not updated Partially addressed; - Not addressed Forestry Report No.Changed?Comment Commenter Response L 1.Page 2L - "The system looked at the property from a forestry standpoint." We are concerned that the report evaluates the site as a working forest, or from a timber management perspective which it obviously is not suited for or currently used for. This point of view has skewed the report by shifting the value of the trees from one where the trees are important for "the screening of facilities and amenities..., the preservation of natural features, historic sites," and "be designed to blend with the natural setting and,...screen the development and its impacts from the adjacent rural areas (BoCC Ordinance 014128-08 #63 U)" to one where the importance is more as a "resource," i.9., timbgr. County Comments From EA:Thescopeofthe study as stated on page 5 was to "evaluate the forest's health and identiff hazardous trees" which would serve "as a precursor to more advanced stages of planning, permitting and development." No change to the text of the document due to understanding of purpose of the document 2.Page 22 - This inventory is helpful in understanding the different areas with varied levels of impact to the vegetation. An inventory such as this should be used to determine which areas are appropriate for development and where trees should be retained and protected. County Comments From EA: See response to #1 No change to the text ofthe document 3.Page 33 - "the Black Point area is most likely too heavily impacted by existing development and the extensive presence of poor quality trees and invasive species to be able to be economically reestablished with a value in excess of the economic return available from more development focused target areas." The "economic return" being timber vs. resort development which again reinforces the idea that the trees realvalue is economic rather than functional. BoCC Ord. 01-0128-08 states, "Evergreen trees and understory should remain as undisturbed as possible." The intent being on retention for screening, buffering and aesthetics rather than economic return. County Comments From EA: See response to #1 No change to the text of the document Partially addressed; I Not addressed Forestry Report No.Comment Commenter Response Changed? 2 4.The report concludes with the idea of "complete restoration of the site (page 33)." ln other words, it's better to clear the site and start over. I wonder if this is what the BoCC had in mind when they included those conditions in the ordinance. Their intent perhaps was not to remove the trees that are perfectly healthy, are mature enough to provide screening from adjacent uses, and maintain the value of the native environment and natural amenities. County Comments From EA: See response to #1 No change to the text ofthe document 5.The recommendations starting on page 34 envision a retention plan to be developed which would evaluate, delineate and propose protective measures to retain "significant trees" and provide long term management and protection. This envisions much more work on the project level after approval of the SEIS which should be used to identify which trees are to be retained and what impact the loss of other trees will have on the environment - neither of which has been discussed in this report. County Comments No change to the text of the document 6.The report reads like the authors were told what the objective was (clear the entire site for grading) and they had to find a way to justifo that objective, instead of using the inventory to identify the best areas for tree retention which would thereby dictate where development would occur. Having said that, Staff understands the practical aspects of creating a clear level space to build a golf course and that it is easier to start from scratch than it is to try to design the golf course around saving a few trees. The ideal objective would be a balance between the two. County Comments From EA: Alternative 2 in the SEIS retains more of the original topography than the original alternatives, thus saving more trees than originally envisioned. No change to the text ofthe document Partially addressed; - Not addressed Forestry Report No.Comment Commenter Response Changed? 3 7 A basic environmental consideration that has not been address in either this report or any other relates to hydrology. ln essence, whot impact will the removal most ol the trees have on the hydrology ol the site? How will this alteration in hydrology allect stormwoter runofi and treatment? These questions must be addressed in the SEIS. County Comments No change to the text of the document Partially addressed; - Not addressed Golf Course Development and Operations BMP Plan No.Comment Commenter Response Changed? L Page 3 & 4 - mitigation measures identified here should be included in the SEIS County Comments These mitigation measures will be included in the SEIS. Applicable BMPs are referenced in the Water Resources and Fish & Wildlife sections as mitigation measures to address identified significant impacts. Other BMPs (e.g., turf management) are not referenced since these are not applicable to identified impacts in the SEIS. L 2.ls there a training program or plan for educating course personnel? County Comments The final report will reference training or education opportunities, if applicable. Final report includes no additional text about educating course pers onnel 3.Page7, Application BMPs - what is a hooded boom and what does it look like? County Comments The term hooded boom will be described in final. Updated report includes no additional description of hooded booms. 4.Page 8, Turf Monogement BMPs - Give an example of timing of application to minimize leaching and votalization, slow vs. quick release, etc. County Comments The final report will describe Earth Renew examples and cite their proposal. Report does not include a more detailed description 5.Page 8, Turf Manogement EMPs - three bullet points are duplicated here. County Comments Duplicate bullets will be deleted. Two duplicate bullets remain: 1) Consider timing of the application, and 2) Limit the use of phosphorus 6.Page 10, Culturol ond Physical Controls - How do you remove dew on non-mowing days during disease- conducive periods? County Comments The final report will include a description of the process. No further explanation is provided in final report 7 Page L2,lPM 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. County Comments We do not understand this comment. "Principles" is the correct usaqe. Final report usage is still Pricipal (incorrect). Also, last sentence was not removed from bullet 8.Page A-1 - Add "Name of Applicato/' to the log sheet County Comments A column for name of applicator will be added to log sheet. Column was not added to final report 9.y - A Draft Golf Course Best Management Practices (BMPs) Plan has been prepared. BMPs are generally SVR The final report will include references to the 2005 No additional references to the 2006 SWMWW or specific BMPs Partially addressed; - Not addressed Golf Course Development and Operations BMP PIan No.Comment Commenter Response Changed? 2 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 Ma n ua I for Weste rn Wash ington. Definitive language should to be used. Stormwater Manual.have been added. Partially addressed; I Not addressed All other comments were addressed in the 2012 Habitat Management Plan Habitat Management PIan No.Comment Response Changed? The HMP states the square footage of impervious surface removal at each stream, but does not indicate what the square footage of impervious surface will be for development within the streams and stream buffers. The square footage of impacts and mitigation 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. Partially addressed. The total square footage of impacts to stream buffers is provided (i.e. sq. footage of impervious surface for development within the stream buffers), but not specified according to each stream. 2.The HMP indicates that protected areas and marine environment pollution control strategies will be implemented for maintaining shoreline use by tribes. The details for these strategies shall be clearly identified in this section of the HMP. lf these details exist, we can include in the report. lf not, the marine 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 entirely. No. Final report does not include any changes as indicated would be made by the'response'. 4.The HMP states that the on-site wetland hydrology will not be altered as stormwater and irrigation will be captured and treated to Class A standards before 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 infiltration systems to be provided by the civil engineer for this project. This information was not available at the time of the draft report. No. Locations on on-site infiltration systems are not shown or explained. 9.