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April 6,2015 APR Z 4 2015
GENERAL GUIDE FOR HOW TO PREPARE FINAL SEIS COMMENT RESPONSES
Pleasant Harbor Final SEIS
Following is a general guide for how to prepare responses to comments on the Pleasant Harbor
Draft SEIS. All comment letters are numbered for ease of reference, and each individual
comment in each of the letters has been numbered and assigned to a team member to craft a
response. For some comments, multiple team members have been identified to respond to
comments - in such cases, the first person/consultant identified is assumed to take the lead in
responding to the comment.
lf copies of Draft SEIS Sections or EIS Appendices are needed in order to respond to
comments, please contact Kristy Hollinger at EA Engineering (khollinqer@eaest.com).
1. Determine if a response to the comment is necessary. For example, if a comment is a
statement of like/dislike of a project or preference for one alternative over another, "your
comment is acknowledged for the record" is a sufficient response.
2. Determine if the Draft SEIS (Chapter or Technical Appendix) contains information or
analvsis that adequatelv responds to the comment. lf so, refer to the page(s)/section(s)
of the text and technical analysis where the information/analysis is presented and briefly
summarize. For example, "As described on page 3-5 of the DEIS, the height of the
proposed building is within the 12S-foot maximum height allowed by COR zoning."
3. lf the comment points out an error. omission or necessarv clarification to the DEIS that is
valid, acknowledge the error/omission/clarification, correct or amend the appropriate
section of the Draft SEIS, and refer to the Section of the Final SEIS where this
information has been corrected.
For the Frnal SE/S we will reprint the Draft, and highlight or underline new text that is
added to show what has changed between the Draft and the Final.
4. When there are several comments on the same topic, rather than providing a similar
response to each comment that shares the theme, provide a more complete response,
and then refer to this response in subsequent comments (be careful to address all
aspects of each comment, though). For example, "See the response to Comment 4 in
Letter 10 regarding the adequacy of the proposed water quality treatment facilities."
HT EA Engineering,
Science, and
Technology, lnc., PBC
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EA Engineering,
Science, and
Technology, lnc., PBC
2200 Sixth Avenue, Suite 707
Seattle, WA 98121
www.eaest.com
5. When updated information/analvsis has been included in the Final SEIS, summarize the
information/analysis contained in a separate chapter of the Final SEIS and, as
appropriate, hit the high points in the responses to comments and direct the commentor
to this chapter and the appropriate technical appendices for the complete response to
their comment.
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2200 Sixth Avenue, Suite 707
Seattle, WA 98121
www.eaest.com
Response to Letter 7, Comment 15: The original traffic counts and underlying analytical
assumptions were performed and conducted using conservative methods, including conducting
traffic counts for use in the analysis during a peak Labor Day weekend in 2006. As recent traffic
counts conducted by WSDOT (AnnualTraffic Report, 2014, WSDOT) remain between
approximately 22 percent and 35 percent below those documented and used along SR 10'1 in
the immediate project vicinity, the traffic level of service analysis and impact evaluation applied
in the SEIS analysis remains conservative and defensible. As the recent traffic counts
performed by WSDOT include all regional tolling, tourism, goods, movement travel, and other
unique characteristics of the SR 101 corridor, and these remain below SEIS analytical
assumptions, no evidence is found to warrant further level of service analysis.
Response to Letter 7, Gomment 16: An evaluation of construction traffic impacts associated
with building the Pleasant Harbor Resort is provided within the Pleasant Harbor SEIS
Transportation lmpact Study, Second Addendum Supplementto 11127107 FEIS, January 30,
2012, TENW, pages 10-12.
Response to Letter 7, Gomment 18: The original Transportation lmpact Study - Revised,
Pleasant Harbor ElS, Jefferson County, WA, TENW, August 28,2007, evaluated traffic impacts
of full project buildout. See also Response to Letter 7, Comment 15 above.
Response to Letter 7, Comment 19: SR 104, and specifically the portion of that section that
includes the Hood Canal bridge, is a part of the regional highway system and beyond the scope
of study for the SEIS. As this corridor is part of the Highways of Statewide Significance (HSS),
which include interstate highways and other principal arterials that are needed to connect major
communities in the state, it is exempt under State law from local or State level of service
standards.
Response to Letter 7, Comment 36: As the frequency of the transportation of biosolids is no
more than typical waste disposal of residential/resort communities, no separate analysis of truck
trips associated with this specific trip type is warranted.
Response to Letter 8, Comment 8: Natural occurrences or weather events that impact traffic
are not considered typical or frequent events, and therefore, do not require consideration under
SEPA review for tratfic impacts.
Response to Letter 9, Gomments 19/20: The transportation impact analysis leading back to
the DEIS considers both shuttle and non-shuttle impacts, and therefore, impact of airport trips
between the site and the airport are considered. As the highways beyond the study limits are
part of the Highways of Statewide Significance (HSS) system, they are exempt under State law
from local or State level of service standards and therefore, require no evaluation. The project
proposes to provide a common transfer location between Jefferson County and Mason Transit
HT EA Engineering,
Science, and
Technology,lnc., PBC
2200 Sixth Avenue, Suite 707
Seattle, WA 98121
www.eaest.com
systems. As both service providers currently serve the Brinnon community, no additional transit
impacts would be generated by service providers.
See also responses to Letter 7, Comments 15 and 19
Response to Letter 12, Comment 4: See responses to Letter 7, Comment 19 and Letter 8,
Comment 8.
Response to Letter 14, Comment 5: As a conservative approach, no reductions were made
for resort access via waterborne or airborne modes of transportation. lf resort access is
accomplished by these modes, they would be accommodated in the typical boat trip generation
and occasional float plane charter that is associated with a marina of this size.
Response to Letter 15, Gomment 3: As the WDFW boat launch access is an existing State
facility and this project would not increase demand for boat launching at this site, no mitigation
specific to any peak parking demands is required. As a new owner in Pleasant Harbor, the
applicant has been in conversations with WDFW regarding joint development of an overflow
area that could be used during these events, however, only information discussions have taken
place and no formal agreement or project mitigation is necessary.
Response to Letter 34, Gomment 2: See response to Letter 7, Comment 19.
Response to Letter 37, Comment 4: See response to Letter 7, Comment 15.
Response to Letter 38, Comment 2: See response to Letter 7, Comment 15.
Response to Letter 38, Comment 3: See responses to SEIS Public Scoping Comments in
Pleasant Harbor SEIS Transportation lmpact Study, Second Addendum Supplement to
11127107 FEIS, January 30,2012, TENW, page 18.
Response to Letter 38, Comment 4: TENW HAS REQUESTED COLLISION RECORDS lN
THOSE LOCATIONS NOTED AND WILL INCLUDE IN SEIS RESPONSE.
Response to Letter 40, Comment 4: See responses to Letter 7, Comment 15, Letter 8,
Comment 8, Letter 9, Comments 19/20 and, Letter 38, Comment 4.
Response to Letter 40, Comment 5: The original Transportation lmpact Study - Revised,
Pleasant Harbor ElS, Jefferson County, WA, TENW, August 28,2007 , evaluated traffic impacts
onto Duckabush Road and at the intersection of SR 101 and Duckabush Road and found no
substantial or significant traffic impacts would occur due to the project. As such, the Pleasant
Harbor Resort would not be required to address any real or perceived existing roadway
deficiencies noted in the comment letter.
2200 Sixth Avenue, Suite 707
Seattle, WA 98121
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Response to Letter 42, Comment 2: The comment refers to Black Lake Road, however, no
known road exists in the immediate site vicinity. For the purposes of this responses, it is
assumed the comment is referring to Black Point Road. As part of the project, Jefferson County
is requiring a roadway upgrade between SR 101 and the proposed main entrance near the
Rhododendron Road vicinity. The roadway section however, will not include a shoulder wide
enough to accommodate a multipurpose trail as County standards do not require such a facility.
An extensive separate trail system will be provided throughout the project site which would
provide for an independent and parallel nonmotorized travel separate from vehicle conflicts
along Black Point Road.
Response to Letter 49, Comment 5: See response to Letter 8, Comment 8.
Response to Letter 65, Gomment 4: See responses to Letter 38, Comments 3 and 4.
Response to Letter 65, Comments 7/8: The assumed average trip length for "commute" or
typical p.m. peak hour trips was 100 miles, while the more localized trip generated was
assumed at 75 miles in evaluating the reductions in green house gas emissions by TENW.
NOTE: TENW WAS NOT INVOLVED OR IS AWARE OF OTHER POTENTIAL VMT
CALCULAIONS MADE IN THE EIS. IT IS SUGGESTED THAT EA ADVISE OTHER
POTENTIAL CONSULTANTS TO PROVIDE ADDITIONAL RESPONSE AS NECESSARY.
Response to Planning Commission Public Comment 17: See responses to Letter 7,
Comment 19 and Letter 8, Comment 8.
Response to Planning Gommission Public Comment 18: See responses to Letter 7,
Comment 15, Letter 8, Comment 8, and Letter 38, Comment 4.
Response to Planning Gommission Public Comment 19: See verbal response offered
during the public comment period noted in transcript.
Response to Planning Commission Public Comment 21: See response to Letter 40,
Comment 5.
Response to Planning Commission Public Comment 24: See response to Letter 40,
Comment 5.
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Response to Letter 47, Gomment 4: See response to Letter 8, Comment 8.