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Northwest
Watershed lnstitute
3407 Eddy Street I Port Townsend, Washington 983.,68
voice 360.385,6786 fax 360,385.2839 li
ernail pete r@nwwatershed.org I www. nwwatershed.o rg
January 5,2015
David Johnson, Planner
Jefferson County
[by email to dwj ohnson@co.j efferson.wa.us]
RE NWI comments on DSEIS for proposed Pleasant Harbor Marina and Golf Resortdevelopment
Dear Mr, Johnson,
Please add the attached letter from Dr. Richard Horner, dated December 6,2007. Dr. Horner is a
stormwater expert that raised many significant issues and concerns regarding this project during the
FEIS review for the comp plan amendment. In reviewing the DSEIS, I see that the issues have not
been addressed or mitigated. For that reason, the DSEIS is not adequate.
Sincerely,
Peter Bahls
Director
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E-van: rrhorneriijtnrsn.com
December 6,2007
Board of County Commissioners
Jefferson County
P.O. Box 1220
Port Townsend, WA 98368
To Whom It May Concern:
I was requested by Northwest Watershed Institute to review the Brinnon Master Planned Resort (MPR)
proposal regarding the potential effects of stormwater runoff from the project on the water quality of
Hood Canal and the groundwater in the vicinity. I present my findings after stating my qualifications
to perform this review.
BACKGROLIND AND EXPERIENCE
FINDINGS
General Findings
As stated by section 3.3.7 of the Brinnon MPR Final Environmental Impact Statement (FEIS), the
basis of the stormwater management program is the Stormwater Management Manual for Western
Washington (Washington Department of Ecology [WDOE] 2005), together with the Low Impact
I have 30 years of experience in the urban stormwater management field and I I additional years of
engineering practice. During this period I have performed research, taught, and offered consulting
services on all aspects of the subject, including investigating the sources of pollutants and other causes
of aquatic ecological damage, impacts on organisms in waters receiving urban stormwater drainage,
and the full range of methods of avoiding or reducing these impacts. I received a Ph.D. in Civil and
Environmental Engineering from the University of Washington in 1978, following two Mechanical
Engineering degrees from the University of Pennsylvania. Although my degrees are all in engineering,
I have had substantialcourse work and practicalexperience in aquatic biology and chemistry. For 12
years beginning in l98l I was a full-time research professor in the University of Washinglon's
Department of Civil and Environmental Engineering. I now serve half time in that position and spend
the remainder of my time in private consulting through a sole proprietorship. Serving as a principal or
co-principal investigator on more than 40 research studies, my work has produced three books,
approximately 30 papers in the peer-reviewed literature, over 20 reviewed papers in conference
proceedings, and approximately 100 scientific or technical reports. My consulting clients include
federal, state, and local government agencies; citizens' environmental groups; and private firms that
work for these entities. My full curriculum vitae are attached.
To Whom It May Concern
December 6,2007
Page2
Development Technical Guidance Manual for Puget Sound (Puget Sound Action Team [PSAT] 2005).
The proponent goes on to state that the stormwater management plan will be designed to meet the
project's requirement for zero discharge of water to the Hood Canal from the golf course resort area
and the fulltreatment of all site water from the marina area before discharge to the harbor. I now give
my general impressions of this basic plan, to be followed with more detailed observations on each
point.
It is first necessary to recognize that application of the WDOE stormwater manual in no way
guarantees reaching a goal of zero discharge. That manual does not feature management practices
having strong capability to achieve zero discharge. The PSAT low impact development (LID) manual
shows how to design drainage features that could reach zero discharge. However, that manual has
none of the prescriptive requirements of the WDOE manual and is just a "how to" guide to employ
once the components of the stormwater management system are selected. Hence, it does not appear at
all that the zero-discharge goal for the golfcourse resort has any force behind it.
Even if the resort can be held to zero discharge, the FEIS presents insufficient information, even for
the levelof a rezoning application, for a reviewer, and the public at large, to judge wellthe prospects
for achieving the goal. While I recognize that more detail will be presented at a later stage of project
development, the public needs some more information beyond that given in the FEIS to have any
confidence that the project will function as advertised and to countenance a major rezone.
The marina portion of the project will not be held to the zero-discharge standard. While the FEIS
states that its discharge will receive "full treatment," it gives no information at all on what that
treatment might be and what is meant by "full." As with the plan for the resort, the public must be
given a more complete basis upon which to evaluate the quality of the plan at this point in project
development.
Outside of the immediate project area, the FEIS does not assess the water quality impacts of
anticipated traffic additions associated with the development. The Transportation Impact Study
indicates increases on a number of localroads and highways of hundreds of cars a day on average.
Automobiles emit or mobilize numerous pollutants that enter water bodies and degrade aquatic
ecosystems. The FEIS is inadequate as long as it does not give the public a means by which to
understand the full environmental impact before being willing to see rural zoning changed to
accommodate this project.
Further Observations
Zero Discharge from Resort
Achieving zero discharge depends on effective implementation of the types of site design and
stormwater management practices presented in the PSAT LID manual. Fundamentally, these practices
come down to infiltrating rainfall into the ground or harvesting water from roofs and other surfaces for
a use such as landscape irrigation or "gray water" system supply (e.g., toilet flushing). The FEIS states
that both of these methods will be used but not the role each would play. The intention is to store
runoff in existing "kettles," use it to meet "water demands" , and direct the excess into the ground (by
To Whom It May Concern
December 6,2007
Page 3
what means is not revealed). Even though I did not have much information to go on, I feel safe in
assuming that the project will have to make substantial use of infiltration to reach zero discharge.
Successful water quality protection by infiltration depends of having soils that will percolate water
rapidly enough to drain surface holding areas in time to prevent various problems that can occur with
excessive ponding times (generally, within 72 hours), but not so fast that contaminants will reach
groundwater and pollute it. The natural soils do not necessarily have to possess desirable soil pore
storage space and hydraulic conductivities themselves, but can be amended (usually, with organic
compost) to function well. However, clays cannot be sufficiently amended to provide enough pore
storage and hydraulic conductivity to percolate rapidly enough; and, conversely, coarse sands and
gravels cannot be amended to slow percolation enough to ensure groundwater protection.
The authors of Chapter 3 of the FEIS made no reference to the site soil and hydrogeologic data in
Appendix 4 and did not use it to assess in even the most rudimentary way what it means for the
prospective success of their plan. The data are very sparse, with the soils information consisting of
only the U.S. Department of Agriculture soil survey results. Soil survey data are generally not site-
specific enough for conclusive determinations of infiltration potential, which often varies considerable
in quite small distances. The reported data show very gravelly loamy sand predominating, which if
actually the case would tend to encourage the belief that water could be infiltrated successfully but
could penetrate too rapidly. Nevertheless, an informed judgment requires more site-specific data.
The public cannot be expected to accept a major rezone in their county until they are told enough to
gauge potential success. Insufficient soil storage and hydraulic conductivity will render zero discharge
an illusion. Overly rapid percolation will threaten groundwater, a potable supply source in a rural area,
and reach streams on the site and other nearby surface waters as seepage. There is heightened concern
about groundwater quality when a golf course is involved. Golf courses are large consumers of
fertilizer and pesticide chemicals, as well as irrigation water. The common water pollutant least
capable of interdiction in soils is nitrate-nitrogen, which is introduced to the surface in large quantities
with fertilization, from where it can be carried along with percolating irrigation or rain water to the
water table. Nitrate is the agent causing methemoglobinemia, generally in infants, when consumed
with drinking water. Pesticides reaching drinking supplies are obviously also a major health concern.
Treatment of Marina Discharge
The term "full treatment" as promised for the marina is simply meaningless. Different treatment
systems have varying efficiencies in treating different pollutants. In addition to terrestrial runoff from
upland areas, marinas are sources of allthe pollutants associated with engines and petroleum products,
cleaning agents, and household chemicals, used right on the water. Their potential for release and in
what quantities depend on marina activities, particularly how much maintenance is performed, but they
are always a factor. Also, it can be expected that a resort of this size will lead to greatly increased use
of the existing marina, which would itself increase pollutant loading. Some treatment systems can do
an excellent job in capturing these various pollutants, others are poor overall, and some are mixed
depending on the pollutant in question. The project proponents must state how they would handle and
treat marina discharge before the public can consider their plan.
To Whom It May Concern
December 6,2007
Page 4
Potential Trffic Impacts
Table I I of the Transportation Impact Study shows the "Statesman" alternative to increase traffic by 6
to 89 percent on the various roads and highways in the project vicinity, with a 41 percent rise at one
point on highway U.S. l0l (near Woodpecker Road). However, the origin of these figures is unclear
and probably in error. My calculations do not agree when comparing the cited "Statesman" alternative
traffic volumes with either the "Without Project" or "No Action" columns. For example, I got
increases of 875 and 225 percent comparing "Statesman" Black Point Road traffic with "Without
Project" and "No Action," respectively. I found the "Statesman" increase on U.S. l0l near
Woodpecker to be 69 or 51 percent with the same respective comparisons. I was likewise unable to
reproduce Table I I's percentages for the "Brinnon" and "Hybrid" alternatives. It would be
inappropriate, in my opinion, to go forward on this major action with such anomalies in key
information supplied in its support.
Motor vehicles are responsible for water body contamination from many sources. Brake pad and tire
wear introduce copper and zinc, respectively, both highly toxic to aquatic life. Wear of engine parts
contributes these and other toxic metals, like lead, cadmium, chromium, and nickel. Petroleum
products leak from engines, transmissions, and braking systems. Sediments drop onto roads from
chassis and undercaniages. These pollutants wash immediately into receiving waters during rainy
periods but also stay on and around roads for later wash off when rains come. It is reasonable to
assume that the roads around the resort and marina complex would experience the most elevated traffic
in the summer months. Even though there is not much rain then, the remnants would be in
concentrated form in the first flush of fallrains. Concentration of toxic materials, such as the various
metals in road runoff, is the condition most dangerous to aquatic life. The FEIS is an incomplete and
thoroughly inadequate document in not addressing these potential impacts at all.
SUMMARY
The Comprehensive Plan amendment application should be denied unless the Brinnon MPR proponent
can provide convincing evidence that: (l) zero discharge from the golfcourse resort can be achieved;
(2) soils are conducive to the intended infiltration either in their natural condition or after amendment;
(3) infiltration will not contaminate groundwater or result in below-ground delivery of pollutants to
surface receiving waters, with particular attention to golf course irrigation and rain water discharge; (4)
marina discharge will be treated with a specific system to reduce harbor contamination from that
source to the greatest extent possible; and (5) increased traffic will not degrade the water quality of
Hood Canal and its tributary waters or threaten the survival and well being of their resident and
anadromous aquatic organisms. This evidence must be made available to the public for another review
of the proposal before its official consideration.
Sincerely,
Richard R. Horner
I would be please to discuss my comments with you and invite you to contact me if you wish.
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