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HomeMy WebLinkAbout068Michelle Farfan From: Sent: To: Cc: Attachments: Subject: Peter Bahls < peter@ nwwatershed.org > Monday, July 06, 2015 10:37 AM dwj o h n so n @ co j efferso n.wa.u s Barbara Moore-Lewis FW: NWI comment on DSEIS for proposed Pleasant Harbor Marina and Golf Resort development Dr. Richard Horner Brinnon letter L2-06-07,pdf; NWI letter Jan 5 2015.pdf Hi David, We will you please confirm that you received my attached letters on the DSEIS for the proposed Pleasant Harbor development and that these comments are being considered for the FSEIS? Thanks Peter Bahls, Executive Director Northwest Watershed I nstitute 3407 Eddy Street Port Townsend, WA 98368 Tel 360-385-6786 Fax 360-385-2839 www.nwwatershed.org From: Peter Bahls <peter@nwwatershed.org> Date: Monday, January 5, 2015 5:29 PM To: <dwiohnson @co.iefferson.wa.us> Subject: NWI comment on DSEIS for proposed Pleasant Harbor Marina and Golf Resort development Please see attached. Peter Bahls, Executive Director Northwest Watershed I nstitute 3407 Eddy Street Port Townsend, WA 98368 Tel 360-385-6786 Fax 360-385-2839 www.nwwatershed.org 1 RrcHaRo R. HonxrR, Pu.D. 230 Nw 55'n Srnper SEATTLE, WasumcroN 98107 TprnpuoNe: (206) 782-7 400 E-valL: rrhorner@msn.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. BACKGROUND AND EXPERIENCE 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 ofthe subject, including investigating the sources ofpollutants 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 Civiland 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 substantial course work and practical experience in aquatic biology and chemistry. For 12 years beginning in 1981 I was a full-time research professor in the University of Washington'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. Mv full curriculum vitae are attached. 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 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 Canalfrom the golf course resort area and the full treatment 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 golf course resort has any force behind it. Even if the resort can be held to zero discharge, the FEIS presents insufficient information, even for the level of 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 local roads 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 soiland 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 terrestrialrunoff 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 4l percent rise at one point on highway U.S. 101 (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 5l percent with the same respective comparisons. I was likewise unable to reproduce Table I l'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 andzinc, 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 undercarriages. 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 fall rains. 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. I would be please to discuss my comments with you and invite you to contact me if you wish. Sincerely, f2.',I*.,(;a,7@u*-- Richard R. Horner a Watershed lnstitute Northwest 3407 Eddy Street I Port Townsend, Washington 98368 voice 360.385.6786 fax 360.385.2839 emai, peter@nwwate rshed.org I www. nwwatershed.org January 5, 2015 David Johnson, Planner Jefferson County [by email to dwjohnson@co jefferson.wa.us] RE NWI comments on DSEIS for proposed Pleasant Harbor Marina and Golf Resort development 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 frl