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HomeMy WebLinkAbout114Michelle Farfan From: Sent: To: Cc: Subject: Attachments: Jennifer L. Dadisman <jdadisman@geoengineers.com> Tuesday, November 24,2075 12:59 PM Hollinger, Kristy;'peckassoc@comcast.net'; Garth Mann 'djoh nson @co jefferson.wa.us'; Joe Ca I la g ha n; And reia B rown Draft SEIS Responses Pleasant Harbor Responses_20151124.pdf HiAII, Attached are our responses to the draft supplemental environmental impact statement (DSEIS). Let me know if you have any questions. Thank you, Jennifer Jennifer L. Dadisman, PWS Biologist I GeoEngineers, lnc. Telephone: 253 "7 22.2445 Fax: 253.383.4923 Email: idadisman@qeoenqineers.com 1 101 Fawcett Avenue, Suite 200 Tacoma, WA 98402 www.qeoengineers.com Disclaimer: Any electronic form, facsimile or hard copy of the original document (email, text, table, and/or figure), if provided, and any attachments are only a copy of the original document. The original document is stored by GeoEngineers, lnc. and will serve as the official document of record. Confidentiality: This message is confidential and intended solely for use of the individual or entity to whom it is addressed. If you are not the person for whom this message is intended, please delete it and notify me immediately, and please do not copy or send this message to anyone else. 1 Michelle Farfan From: Sent: To: Cc: Subject: Attachments: Jennifer L. Dadisma n <jdad isman@geoengineers.com > Tuesday, November 24,2015 12:59 PM Hollinger, Kristy;'peckassoc@comcast.net'; Garth Mann 'djoh nson@cojefferson,wa.us'; Joe Ca I lag ha n; Andreia Brown Draft SEIS Responses Pleasant Harbor Responses_201-51-124.pdf HiAII, Attached are our responses to the draft supplementalenvironmental impact statement (DSEIS). Let me know if you have any questions. Thank you, Jennifer Jennifer L. Dadisman, PWS Biologist I GeoEngineers, lnc. Telephone: 253.7 22.2445 Fax: 253.383.4923 Email: idadisman@qeoenqineers.com 1 101 Fawcett Avenue, Suite 200 Tacoma, WA 98402 www.qeoenqineers.com Disclaimer: Any electronic form, facsimile or hard copy of the original document (email, text, table, and/or figure), if provided, and any attachments are only a copy of the original document. The original document is stored by GeoEngineers, lnc. and will serve as the official document of record. Confidentiality: This message is confidential and intended solely for use of the individual or entity to whom it is addressed. If you are not the person for whom this message is intended, please delete it and notify me immediately, and please do not copy or send this message to anyone else. 1 Pleasant Hartor Diafi Supplemental Environmental lmpact Statement GeoEn$neers Response to Comments Se@mment TheOrFhashnffiUddand$eyhaEisdajudsdictonaldeEminationthatthcthrei&nffd 6mfl*Iut$rIrrnD.. codiffil,ff CqnMt RiDil. fo Coil[.it 2 Tb prosed prcjet E lGted within the Usual and kusbmd area of he Pot Gamble S'Kallam Trib. Tribal memb6 derend on th€ fish. shellfish 5d wildlift rEources within the prcjd ar€ ior their cuhural and eonomic well hing We are @nernd Sat habbt l6s and de6radation from Se prop6d proiet would ampacl salmon, shelhsh ahd other rmp&nt sf B rn Se ar€.. Th k*allaF and Dekabush h€6 and kkdetEs $rue as cril@lhab@lfor theaEned salmon and other f6h. shelmsh and wjldlfe rcpulabns valued by Se Tih. Therefore. we arc @ncerd that h€ prorcsd prcjd wld jqerdze Se Tribs trs9 flghb to Ihe proj*t is proFsing several minimization measur$ b limit Ftential imFcE b fish and wildlife in the Point Black ars. Although only a 15Gf@t bftr frcm S6 Ordinary Hi6h Wal6r (OHW) b r€quird acmrdin6 b JCC, $e prcjet is propsing6 2&f@t butrer wihin the gotf Fue area and is rephntingexistngdegraded riFrian ares wffin h shoreline butrerand willlimit ams bSeshoreline in the er€ ot 6e8oI@urse. lnadditon,SepodislevingwildlilemrndoE(areasof und6tuMve6e6ton)troughodSe6olf@uearea.The* Eri&E will lead to more $an 2m acr6 of relatMely uMisturH €geEton on .nd ofl sjte in addilon b the qistngand cr€ted redad feaur$. For more rnformation on f6h and wrldlfe minihia&n mesur6, se be Hab,bt MamEement Plan Repn (kEnone6, 2012)- lhe stu 6 also binEdesiEnd so kre will b no discMrg6 of runoff into Hd Gnaliallwaterwillb 6llsd. ftaH and rcusd. ln . Ibmbr 21, 2OOl joint SEPA @mment bter frcm Poant No Poinl Tr€ty 6uncil, Jam6t*n S'kllam, Pod Gamble S'Klallam and Skokomish TriB. re highlighH Se pren€ ot numerous *nsiive environmenblleaturE thatrculd b degladd by r6ofr development including unique kettle pon6 and streams. ln addnion, Sc Washington Depamem of Natural Reu16 landsft& hazad zone meps depd st€p. unsGbl6 slop6 ftinging h Bhck Point ketle rcn&. TE prosed prcjd rculd resuh rn the los ofapproximately2O.Tmq@retetofretlandar€andaponionof therellandbuffeEass6aaHwfthWetJandsCandO. The pq@lb creaE wedand area as a mitiglation mqsure dc not guaranlee Se sucGful replaGmenl and mrihEnane of this impotunt Mbib! Annul monitorinE of wetland cr€ton ar€s is not sufficient for deectng a ny adaptive mahagement thet mey E k pa( of the Frmn rquiremsE of fre proj*t tuice as much weiand will b crEH as will be impaded. approximaer 4l.4OO square fet ofwettrandwallbcreatdtomit6aleforrmpactstoapproximately20.693squaretetofredand- Thecrstdretailwillbmdfrordfor5 or more y€6 to ensure Satretland mnditons haw rn EEblishd. ItUe si@ is mlsucsful@rrdve m€sur6 wrllb bken b ensurethatapproxrmetet4l.4ooquerefetolweded66ublishd. Theprcjdwillrctr6ultinthel6sof bffe6es@i8tdwiu Wetands C ahd D; bufer averadng will b utilizd as allwd for in the JCC. Wetland C and O buffeE will be ducd in eme areas and WetlandCandDbuffeEwillbeincreasedinemeareassothereisnonetlossofwetlandbufferhabibt. SeeSeWetlandandWetlandBuffer Mitigatbn Plan Repon for more information (G€oEngnee6. 2012). Annual monturing is typicl of mitjEation sites; howerer, if th6 site is not deemd sudestulafter 5 yeaE of monitoring the Washingron Sbte OeFment of E@lo6/ wall likely not.elease the siE from monibring rquiremenb untlSe sic is su@ssful. The for6ted uplands b he nomwBtot Bl6ck Point representan impoGnt elk miEralion corridor &Gn rhe kilalliF snd Ducf€b6h riEr valleys- The propGd development wouE rsuh in Se loss of exis{ng upland wildlife habiEt and ahhough the areasofon4itehabiEtwouldberebined,wearecorcemdabutS6impactsbheelkmigrationcoridor. TheSDEISdidnot The prcjtrt is prosing sereral minimization measures to limfr rctenlal rmF6 to f sh and wildlife in he Point Black ar€. The prcid is leavngwildlife @.rido6 (areas ol und,sturH wgetation) Srcughon h Eotr cou6e area. Th6e corrEoB will hd b more than 20O acr.s of relativelyundisturbedvegeutbnonaodoffsteinadditionbSeexistingandcreatedweflandfeatures, lnadditaon,aren€willgoupalong tkprcj6tbundarytolimilelkacce$tothesit€- Aso.amrdingtotheprojstengner.enleguardsorsimilardevicewillbeins6lldat the entri6 b fufthor limit be ptental of elk @ming onto the proFlty Fq more informaton on fish and wildlife minimiaton measures, see k Habibt Mana6ement Plan ReFn(GsEngineers. 20U). 2 7 (We are suppGd Peck and Esvelt) The phn induk fte monbnngol waGr quality trom te sEE waEr quality empling sbtd at Pl@$nt Harbr b identry any imFcbonfishsEi6. Hrever,additonalmonftoringsationsbSonandoffsileandmor6prerenb&emeasursaren*dedb adquaElypro@twaterqual,tyandexEtngfshspei6. Wearecohcerndhatoo€degradaton6curefromseprojst,impacE tosp6wningandrefugish6btutwillbhrevecible. TheplEnd@snotprovideanyassuraneth.tw.terqualityi$u6rculd& adquably r€solvd. There should b no rmpacE to waEr quality as a rauh of Se propsd projet Ecaus all srormwaEr runoff will b 6lleted. treed and re$ed and not allod to b dBchargd to Hd Q ml. fte water qualg monitoring will ensure th5t sbrmwater and other rund is bing @llsted and will not €use polluton of Se Hod Canal wate6- lf degradation is identf,ed dudng the fionitorinE Se epplbant will work wth Jeffe6on ftunty and the WashinElton Dep6ftment of E6lo6/to inshll @rreeive m6sures to pevent additional impacE !nd appt appropriate mitiGFtion as nded to compen$b for identfid impacb- 2 (Contnued)a TdMl memh€ hal6t *Msn 13.m and 2r..Om pounds of manih cl6m and betuen 13,OOO rnd 4A.OOO punds of P.cific oFterfrombeDrckabushabne. $ffiarehrEhly6nsndabutpotentialimpacbtoSErmFtuntresoue_ fteDSE|Ssb6 hatfrb implemenbtion of idendd mitigton measurs. no significant unarcdable adEE imFcB tosheilfsh wouk b anticapatd. Hilever, the anatsis d€ nol@nsder the inc@*d risk of spills and accid€nb that rculd @ur wau Se ircrease in v6sel traffc hS on land and in the water. Although the SDES descrik plans tor sbrmwater to be managd appropriately, the lhcre6sed risk ofdischar6es frcm conbminen6. turbid wateB or sedimentas a resultofconstruction and operations must be AStormwaEr Polldon Pl*nlon Pbn (swPPP)will b dewbpd 3nd impbmentd as rqukd under he NatonalPollu&n Oisch.rEe Eamanatd SFEm (NPDS)stormwater rogulations tor Enstudon siB- Constrrctbn Ehnhu6 will utilize Bst Mana8pment Practic (BMk) to minimize potental amFcE to specbs. ln addtoon. Se bntrador will prepare a mnstwton Spill Prerention. Contol and ftuntermeasures (SPCC) Plan br the proFt.eordrng b Washin6on Sute D6pament of Transpotuton guidane. ky poGntial spills will hMndldanddispsedof anamannerthatdcnot@nbminateth6surroundingarea. &equatematerialsandproeduresbrBpondto unanticipatedweatherondhionsoraccidenblreleasesofmaterialswillbavailableonsile, Thiswillincludematerialsneessarybisolate plluEnb frcm the €nvironment and @nhin and aborb spills. TE SPCC Plan will also ensure th6 proper mana6ement of oil, gasoline and solvenb used in the oFration and marntena@ of constudon quipmeot aM Sat quipment remain fre ofenernal pevoleum+ad prducE prior to enteringffe rc* arca aM during Se rcrk, as rellas lor makingany ne6ary Epai6 prior to reurnand$e {uipmcnt b oFra0dintuwo*.re. TheSPCCPLnwillh@nsblentwffi40CFRll2.3asrellasseSbGofWashingboOilSpillContnEencyPlan (wrc 1731e). Work will b in 6hplhnce with oSer l@1. sEE a.d tederal reguhtions and r6triclons. local critEalar6s odinane and lad use regulatons. Shorelire MasGr Plan. SbE EnvironmenEl Policy Act, and 4OlWaterQuality CenifEton. AuaffE and v6el anatsb should addre$ the conern for increased rEkofspills and aeadens, 4 1 Plaementdfillan wetlands may rqurG an indNiduald Eeneral(Bbnwide) prmitfrom the USArmy Corps d Engrnerc (CoF). Weadvise fte applient to6nbcth hrF to determire ila Frhit is ndd. Sh@ld an individualCorN pmi h rquid, a walerqualityenjfi@tionwillahobrquirdfromE@log/. lfSeretlandisdeermadbhasoletdendnolsubj*tbS€&rps iurisdidion, it remains a JUnsdbtonal wetand for E6log/. and will require permming by Sis a8ency. For moe information. pl6a$ conbct Rick Mraz, Wetland and Shoreline Sp*iahstal&e phonc numEr given abve. File No. 126774O1-1O November 24, 2015 Pagc 1 ol3 (WetJands B, C and D)are tsolad. 5 Pleasant Halbor Draft Supplemental Environmental lmpact Statement GeoEngineers Response to Comments O0nattLrtd l{utS-OoorHt l{unt .Oqiffit R..Fr.. E oofrn{t 7 35 (we ned to rcrk with Pek to address ktryingwetlands will destq lhe natural sFlems now inbct and $e welland will no longer E able b help in natural fihralon of sbrmwter. Wetlands mitiEation plan has not kn don€. kveloper to €vise plan b lave wedan& as wellands. The k6tde wfth th€ wetland neds to h lefras it is kause SB wlll help the prcldto clean som6 of th€ sbrmwater runotrthatwill & caused by thE prcjecl Developer to do wet6nds mitigation plan bfore approval of DSEIS. Sbrmwater will be conuolld aeordingro approprBte E@log/ Stormwater runofi manual (Ecolotl,2005). A rctland and builer milEaton plan has ben developd for tk sire (GsEngin*6 2012)- $e k mfiEatioa plan for more infomaton. 9 13 N/A-CommenlisregardingwaErsupply. CommentisdtrddtoBenderwithinthe6mmentle(erFcke! 14 Not a$jgnd b us an EA€ssiSnmens d@ument but it is listd as us in the Ener packet fhere ae Sre'ket66'.nd.s*bH retlands on Bhck Point -A. B and C. Th6 proFsalwill@nven ketde B. whrch has 6 hiEh €Ingofa &te8ory lll due to & habbtvalue and fidereb b high v.lue forwabr quelity fundons (p9.3-7-2. Volume 1)to a :ontol rcnd fol holdingtreatd wastflater from lhe waswater trBhenl system b proMde r6ydd waier tor reuse and for gdf rouce iritlaton and fire pro@ton- To offet tie @nversion. the osEls sbts that Ketde C may b 'erhand.' Since the w€tland mitiEatonplanhasnotbeendone,hisimpcibletoknowhowthelossofSekettleBwetlandwill*compensaled. Wefel itronEy that in order b met the sbE's nHetloss of wetlands plicy, Kefle B and ass@iated watlehds should * kept in $eir narural sbte. The DSES should also sbte Sat tM prorcsd MPR prcjet should not be allowd b encrech on retland bufferc. A retland 6d buffer mftgaton plan has h preFrd for fie prorcd projed {GeoEnAn*6. 2012)- A redand will h crsH within Kede C b comFnsab for imFG to Wedand B. Please s* the mitEaton plan for mo€ intormation. I {Contnued) 15 Nol lsignd b us an EAassignmenE d@umehl but it is list€d 5s us in the leter packet We faiH b find a listngof chemi€ls (Erbbd6, rticides. or fetulizeE) satwill h usd tor 6olf @u6e Eras marncn.ne or any ,6c6,onothmSede€loperplansbprot*tCroundwaGrorstormwaErrunofffromSeuseoftsechemi€ls. TheAMPS(kt Managem€ntPlans)lorgolfcoursemainbnanedstobeexplaindindeEil. also,S€r@mmendat,oosrela!ngbgolfcouE6 Dnbind in the WRIA 16 WateBhed Management Plan should h notd and a plan for hw the dmlrFr willadhere to the 'e6mmendations dEcussed in tE WRIA Plan hBnh and sfety. The plan adher6 ro S€ @mmendatbns wi$in $e wab6hd menaEement phn as w.Er @nsetoaton strateg6 have kn emdryd (i.e-. water colledbn owr Se entre 6olf couEe properq and using the kettle and Wetland B b conbin wabr runoff Satwill FusedlorsuchthingsasirigatjonforSe6olf@urs).TheBMPSforthepropodSolfcou6eareexplaindwitiinthedrafr Goltbu6e Developmen! and Operation Best Mana8ement Practies Plan (6@Engn€6, 2012). 25 1 During my prevrous reviry of the submi&ls, it apErd that the appli€nt was intendingb ue the creatd wetland as pan of Se raGrueahentsFem. EadonaquickrevEwofthedeuments,ldidnotindadrawlngUatslffiSeconnetonsforSeoc sbmE&r sbrage and trehent). Tk applicant sbuld clarit Sat Se miIEaton arca h separaG frcm ober water anfrashcture lo oPrab Se r6ot. WedandBwillbusdaspafrofthewatert€tmentsFGm. lmpa6towedandBwill&mrtigatdforbycreatngwetlandhabibtata2:1 rab wfth,n Kecle C, This wetand milEaton siE wall not E usd as Fn of Se waEr ueahent sFtem. 2 Ihe JCC allow for mitiEation Fdoman€ bndinEand. gven the numhrof mitiEalion planb propGd. lrculd suEgestthatSe appli€nb b required to p6ta bnd to ensure fundingfor mitiEation, including@nlingency measures, and to ensure tharannual monitoring repoG are submind. Ihe comment is acknwledged and Se appli@ntwill follow rCC regulatbns and poste bnd to ensure fundinglorthe prop6d milgatid plan. 3 C and D (and is sometimes relered to in lfu fuument as 'enhancd" hydrologc paterns). ln he JCC, afteratron of wetland hydroloB/ as a regubtd actv(y. The ES prepard br Se r+bn€ was clear Sat U66 M wodands rcub not h impacbd. one ot {hachenendsotftileandisind6epErimitybas@psbF. TheexistngEgebUonandwedandtundonsatSeemre&nds are bd on Se current hydrologic regme. tuy mdili@lon b the hydrolodc ondilions will affd se Egebtion and should E ENaderd a retland impad. bturepndseastofKcSeB. Therevasdplanforreclaimdwater,a@rdingtoSep@j4tenginer,*llanvolvewaterEingpumPdiom Kefre I b the bp o, the ridge so it @n tu as a *ries of weGr falb end sueem ac6s the faiMays and lhrcugh the M pnds to Se ast of thkede. Walertromthem6teasGrlypndispumpedbackbthebpofhrUlPtor*iculatesrouEhSewabrfertursdntnuousr. Water frll not b d6chargd from Keft B @ Wedands C or O. Overflore from Se KettJe B pnd will infilra@ al ttu Frimeer of Kettl€ B or in k effeme e*, iow by piE inbSe mit€laton c@d retlend. 4 (this commentwill ned to b addressed by EA Ihe ar€ of impact tor each lmpact Class lD in FiguE 3.+1 should & quantfied to suppod the sbtement in Section 3.y. Removing approximatet 89 perent ofthe vegebtion ts in6nsistent wfth the dnclusion that there will b no signiticant unavoidable mpacb to planb. The epplient should provide more informaton b suppft that sbtement G6EnE9n@6 did not prepare Flgure 3.31 (divided the area into impactciass arss) end w€ did not discuss reElebtion removal percenbge amounb. TheDSE|Sd6$ythatberewjllEnosignificantimpacbewnthough89percentof vegebtionrsgoingbbremoved. A(So appears to have prepard the fiEure and discussed veEegtion removal amounb) will ned to address sis comment. 29 1 n the past I haw rcrkd ddj.cent to a Bof cou6e and am flmiliar ffi Se ftdlizinglnd p€stcide us $at is usd to m.inbin Se grens. Rd $rsd is a tungus $at is @mmon and is @nvdld by regular nfuab and fungcide applbtons. The 8r*ns ab hd s€enal nitab tenilizer and other fticde reahenb. The phn hat ms pre*nted by the Sbt6man Group was that sq rculd E usingorganr6 b U€t $e golt @ue. The maintenan€ of fu 6olf @uce rculd E naat impsgble wi$ just organr6 {manure spreadeG on a 6olt6uM? not likely). Ihe @mmeni is acknwledged. Hrewr. tE applicrnt fels il is fssible b u* org.ni6 to mainbrn Se er*ns- File No. 12677{01-10 NovemEr 24. 2015 Page 2 ol3 GaExetxtcslQ t@rdrngto the projfrt encineer, plahs will E revrsed: reclarmed water fl[ Pleasant Hartor Draft Supplemental Eruircnmental lmpact Statement to Comments OoltmtL.tE ilurn hlffiLurti cqnffi RaDc.D Codrfrt 2 It is abo possible that the nivaB and EUciG @dd run off onto Se cbm ffi or run dwn anb Se aqutrer. fu informal masurcment ot Se r.anfrllin $ts rE was ffir 10'd rain in 3 daF. Ntuat6 contibuE b lil dis$lEd oryEpn lnd ft 'ded .ohes'Sa!5rclwinHd&nal. ln&eaquiler.nhracareveryhamtultohumanhehiffouhdind.inkih6waGr. The sne will b regraded and dsignd $ balallwateron tu sjc will b @ll*H. Ucad aM reud and willnot Edi$harggd to Hd Qnal. ln .#aton Sere will b strral ar6s monibd for waEr qual(y arcund the sile to ensure thst il 6n a6iden6l rebse @c!8, @rredw m4su16 6n h ihplementd quickt. 29 (continud) 3 (re ned b mrk frS EA b addr6 $is cmment) Ib Hood CanalaE has ben ud and enjryd by buras$ tor orer 1m F6. Suret a differenl lo€tbn Sat 6 not abw some of bcPacifcNonhrest!Ht&mmmg&acBoulCbfouM. Hd&nalisaEohdodoEfortheslilwaterllushinsland replaGmeat back b th. PueBt Sound. This is jusl Se wrong place tor a r6ot 1 N/A-6mmentisreEardingSupponingnoaction. CommentisdirectdtoEAwr$inthecommentbfterpacket hmment is dfdd t Pek withrn Se emmenl bner peckA; howewr, I dcs inrclve water qualfry. Assumd this s Ge's @mments b addr6s. k hl@ for omment and r6ponse. 2 No marer hN'envionmenEllysafe'a golf cource E, there is buhd b b run off into Hd Gnalthat rculd impad rerestional The comment is acknwldEid. k Ue r6rcnse for @mment lefter 29, 6mment 2. 30 3 Moving from 1 b 2.2 million cubic yard of eanh trom the hillsid6 around Pleasant Harbor would make the area highly susceptible to ercionireoftangetS5inchBotreihin24houE- Also,thereisnowayheywouldbeablebyanktheundergrffihfromUe Etround on the buildingsrG. put it in a holding 5rea, and Eiet lpod sutoival so they @uld later replant it. Wearenotsureofthemntextof removingundergromhvege6tionandpuftnEitinaholdihgare. lf undergroMhvegebtionisremovdinan area th6y will later want to replant. it is likely they will need to replanrwith @nbinerized veEpbtion to get adequate cowraEp. and suruival 59 1 liE 3 mil6 south of the prosd rsn 6nd $ihk il's way t6 much for Se hiEhway adjaent and Se Duckabush river and etuary. dhich is alrddysuffernEselmon degradaton isu6. The ste will E regraded and designed so that all water on Se site will b @ll6td and will not E di$harEed to Hod &nal. ln €ddition there will k se€ralateas monftored forwater quality around the siteto ensure Sat if an asidenblrelease @urs, corrective m€sura 6n F impl€mend quickly. File No. 12677401-10 Novembr 24.2015 Page 3 of3 GaEtetxzeulQ ind commercial shell fishing and water quality. Comment Letter Number Comment Number Comment Response to Comment 2 2 TheproposedprojectislocatedwithintheUsual andAccustomedareaofthePortGambleS'KallamTribe. Tribal membersdepend on the fish, shellfish and wildlife resources within the project area for thelr cultural and economic well being. We are concerned that habitat loss and degradation from the proposed project would impact salmon, shellfish and other important species in the area. The Dosewallips and Duckabush rivers and their deltas serve as critical habitat for threatened salmon and other fish, shellfish and wildlife populations valued by the Tribe. Therefore, we are concerned that the proposed project would jeopardize the Tribe's treaty rights to fish and hunt in the project area. Theprojectisproposingseveral minimizationmeasurestolimitpotential impactstofishandwildlifeinthePointBlackarea. Althoughonlya 150-foot buffer from the Ordinary High Water (OHW) is required according to JCC, the project is proposing a 2oGfoot buffer within the golf course area and is replanting existing degraded riparian areas within the shoreline buffer and will limit access to the shoreline in the area of thegolfcourse. lnaddition,theprojectisleavingwildlifecorridors(areasofundisturbedvegetation)throughoutthegolfcoursearea.These corridors will lead to more than 20O acres of relatively undisturbed vegetation on and off site in addition to the existing and created wetland features. For more information on fish and wildlife minimization measures, see the Habitat Management Plan Report (GeoEngineers, 2012). The site is also being designed so there will be no discharges of runoff into Hood Canal; all water will be collected, treated and reused. 5 ln a December 21, 2001jolnt SEPA comment letter from Point No Point Treaty Council, Jamestown S'Kallam, Port Gamble S'Klallam and Skokomish Trabes, we highlighted the presence of numerous sensitive environmental features that would be degraded by resort development including unique kettle ponds and streams. ln addition, the Washington Department of Natural Resources landslide hazardzone mapsdepictsteep,unstableslopesfringingtheBlackPointkettleponds. Theproposedprojectwouldresultintheloss of approximately 20,700 square feet of wetland area and a portion of the wetland buffers associated with Wetlands C and D. The proposal to create wetland area as a mitigation measure does not guarantee the successful replacement and maintenance of this important habitat. Annual monitoring of wetland creation areas is not sufficient for detecting any adaptive management that may be required. As part of the permit requirements of the project, twice as much wetland will be created as will be impacted; approximately 41,4OO square feet of wetland will be created to mitigate for impacts to approximately 20,693 square feet of wetland. The created wetland will be monitored for 5 ormoreyearstoensurethatwetlandconditionshavebeenestablished. ]fthesiteisnotsuccessful correctivemeasureswill betakento ensure that approximately 41,400 square feet of wetland is established. The project will not result in the loss of buffers associated with Wetlands C and D; buffer averaging will be utilized as allowed for in the JCC. Wetland C and D buffers will be reduced in some areas and WetlandCandDbufferswill beincreasedinsomeareassothereisnonetlossofwetlandbufferhabitat. SeetheWetlandandWetlandBuffer Mitigation Plan Report for more information (GeoEngineers,2OT2). Annual monitoring is typical of mitigation sites; however, if the site is not deemed successful after 5 years of monitoring, the Washington State Department of Ecolory will likely not release the site from monitoring requirements until the site is successful. 6 The forested uplands to the northwest of Black Point represent an important elk migration corridor between the Dosewallips and Duckabush river valleys. The proposed development would result in the loss of existing upland wildlife habitat and although the areas of on-slte habitat would be retained, we are concerned about the impacts to the elk migration corridor. The SDEIS did not address this issue. The project is proposing several minimization measures to limit potential impacts to fish and wildlife in the Point Black area. The project is leaving wildlife corridors (areas of undisturbed vegetation) throughout the golf course area. These corridors will lead to more than 200 acres of relatively undisturbed vegetation on and off site in addition to the existing and created wetland features. ln addition, a fence will go up along theprojectboundarytolimitelkaccesstothesite. Also,accordingtotheprojectengineer,cattleguardsorsimilardevicewill beinstalledat the entries to further limit the potential of elk coming onto the property. For more information on fish and wildlife minimization measures, see the Habitat Management Plan Report (GeoEngineers, 2012). 7 (We are supposed to work on this with Peck and Esvelt) The plan includes the monitoring of water quality from the state water quality sampling station at Pleasant Harbor to identiry any impacts on fish species. However, additional monitoring stations both on and off site and more preventatave measures are needed to adequately protect water quality and existing fish species. We are concerned that once degradation occurs from the project, impacts to spawning and refugia habitat will be irreversible. The plan does not provide any assurance that water quality issues would be adequately resolved. There should be no impacts to water quality as a result of the proposed project because all stormwater runoff will be collected, treated and reused and not allowed to be discharged to Hood Canal. The water quality monitoring will ensure that stormwater and other runoff is being collectedandwill notcausepollutionoftheHoodCanal waters. lfdegradationisidentifiedduringthemonitoring,theapplicantwill workwith Jefferson County and the Washington Department of Ecolo$/ to install correcrive measures to prevent additional impacts and apply appropriate mitigation as needed to compensate for identified impacts. 2 (Continued)8 Tribal members harvest between 13,000 and 21,000 pounds of manila clam and between 13,000 and 48,000 pounds of Pacific oyster from the Duckabush alone. So we are highly concerned about potential impacts to this important resource. The DSEIS states that with implementation of identified mitigation measures, no significant unavoidable adverse impacts to shellflsh would be anticipated. However, the analysis does not consider the increased risk of spills and accidents that would occur with the increase in vessel traffic both on land and in the water. Although the SDEIS describes plans for stormwater to be managed appropriately, the increased risk of discharges from contaminants, turbid waters or sediment as a result of construction and operations rnust be considered. AStormwater Pollution Prevention Plan (SWPPP)will be developed and implemented as required underthe National Pollution Discharge Elimination System (NPDES) stormwater regulations for construction sites. Construction techniques will utilize Best Management Practices (BMPs)tominimizepotential impactstospecies. lnaddition,thecontractorwill prepareaconstructionSpill Prevention,Control and Countermeasures (SPCC) Plan for the project according to Washington State Department of Transportation guidance. Any potential spills will be handled and disposed of in a manner that does not contaminate the surrounding area. Adequate materials and procedures to respond to unantlcipated weather conditions or accidental releases of materials will be available on site. This will include materials necessary to isolate pollutants from the environment and contain and absorb spills. The SPCC Plan will also ensure the proper management of oil, gasoline and solvents used in the operation and maintenance of construction equipment, and that equipment remain free of external petroleum-based products prior to entering the work area and during the work, as well as for making any necessary repairs prior to returning the equipmentto operation in the work area. The SPCC Plan will be consistent with 40 CFR 112.3 as well as the State of Washington Oil Spill Contingency Plan (WAC 173-182). Work will be in compliance with other local, state and federal regulations and restrictions, local critical areas ordinance and land use regulations, Shoreline Master Plan, State Environmental Policy Act, and 401 Water Quality Certification. A traffic and vessel analysis should address the concern for increased risk of spills and accidents. 4 7 Placement of fill in wetlands may require an individual or general (nationwide) permit from the US Army Corps of Engineers (Corps). We advise the applicant to contact the Corps to determine if a permit is needed. Should an individual Corps permit be required, a waterqualitycertificationwill alsoberequiredfromEcology. lfthewetlandisdeterminedtobeisolatedandnotsubjecttotheCorps jurisdiction,itremainsajurisdictional wetlandforEcology,andwill requirepermittingbythisagency. Formoreinformation,please contact Rick Mraz, Wetland and Shoreline Specialist at the phone number given above. Pleasant Harbor Draft Supplemental Environmental lmpact Statement GeoEn$neers Response to Comments Weacknowledgethecomment. TheCorpshasbeencontactedandtheyhaveissuedajurisdictional determinationthatthethreeidentified wetlands (Wetlands B, C and D) are isolated. File No. 12677-001-10 November 24,2075 Page 1 of3 Ercrrre Rsa Pleasant Harbor Draft Supplemental Environmental lmpact Statement GeoEn$neers Response to Comments Comment Letter Number Comment Number Comment Response to Comment 7 35 (we need to work with Peck to address this comment) Destroying wetlands will destroy the natural systems now intact and the wetland will no longer be able to help in natural filtration of stormwater. Wetlands mitigation plan has not been done. Developer to revise plan to leave wetlands as wetlands. The kettle with the wetland needs to be left as it is because this will help the project to clean some of the stormwater runoff that will be caused by this project. Developerto do wetlands mitigation plan before approval of DSEIS. Stormwater will be controlled according to appropriate Ecolog)/ Stormwater runoff manual (Ecolory 2005). A wetland and buffer mitigation plan has been developed for the site (GeoEngineers 2012). See the mitigation plan for more information. I 13 N/A - Comment is regarding water supply. Comment is directed to Bender within the comment letter packet. 14 Not assigned to us in EA assignments document but it is listed as us in the letter packet. Therearethree"kettles'andassociatedwetlandsonBlackPoint -A,BandC.Theproposal will convertkettleB,whichhasahigh rating of a Category lll due to its habitat value and moderate to high value for water quality functions (pg.3.7-2, Volume 1) to a control pond for holding treated wastewater from the wastewater treatment system to provide recycled water for reuse and for golf course irrigation and fire protection. To offset the conversion, the DSEIS states that Kettle C may be 'enhanced." Since the wetland mitlgation plan has not been done, it is impossible to know how the loss of the kettle B wetland will be compensated. We feel strongly that in order to meet the state's no-net-loss of wetlands policy, Kettle B and associated wetlands should be kept in their natural state. TheDSE|SshouldalsostatethattheproposedMPRprojectshouldnotbeallowedtoencroachonwetlandbuffers. Awetlandandbuffermitigationplanhasbeenpreparedfortheproposedproject(GeoEngineers,2012). Awetlandwill becreatedwithin Kettle C to compensate for impacts to Wetland B. Please see the mitigation plan for more information. 9 (Continued) 15 Not assigned to us in EA assignments document but it is listed as us in the letter packet. We failed to find a listing of chemicals (herbicides, pesticides, or fertilizers) that will be used for golf course grass maintenance or any discussionof howthedeveloperplanstoprotectgroundwaterorstormwaterrunofffromtheuseofthesechemicals- TheBMPs(Best Management Plans) for golf course maintenance needs to be explained in detail. Also, the recommendations relating to golf courses contained in the WRIA 16 Watershed Management Plan should be noted and a plan for how the developer will adhere to the recommendations discussed in the WRIA Plan. The chemicals used on the site will be determined bythe maintenance group and will be chosen based on performance of the chemicals and health and safety. The plan adheres to the recommendations within the watershed management plan as water conservation strategies have been employed (i.e., water collection over the entire golf course property and using the kettle and Wetland B to contain water runoJf that will beusedforsuchthingsasirrigationforthegolfcourse).TheBMPsfortheproposedgolfcourseareexplainedwithinthedraft GolfCourse Development and Operation Best Management Practices Plan (GeoEnginee's.,2Ot21. 25 7 During my previous review of the submittals, it appeared that the applicant was intending to use the created wetland as part of the water treatment system. Based on a quick review of the documents, I did not find a drawing that shows the connections for the on- site water system. Wetlands created as mitigation for critical areas cannot be used to meet other code sections (such as the stormwater storage and treatment)- The applicant should clarify that the mitigation area is separate from other water infrastructure to operate the resort. WetlandBwill beusedaspartofthewatertreatmentsystem. lmpactstoWetlandBwill bemitigatedforbycreatingwetlandhabitatata2:1 ratio within Kettle C. This wetland mitigation site will not be used as part of the water treatment system. 2 The JCC allows for mitigation performance bonding and, given the number of mitigation plants proposed, I would suggest that the applicants be required to post a bond to ensure funding for mitigation, including contingency measures, and to ensure that annual monitoring reports are submitted. The comment is acknowledged and the applicant will follow JCC regulations and post a bond to ensure funding for the proposed mitigation plan. 5 The wetland mitigation plan states that reclaimed water will be directed to the existing wetlands, which presumably means Wetlands CandD(andissometimesreferredtointhedocumentas"enhanced"hydrologicpatterns). lntheJCC,alterationofwetland hydrology is a regulated activity. The EIS prepared for the re-zone was clear that these two wetlands would not be impacted, one of whlch extends of fsite and is in close proximity to a steep slope. The exasting vegetation and wetland functions at these two wetlands are based on the current hydrologic regime. Any modification to the hydrologic conditions will affect the vegetation and should be considered a wetland impact. Accordingtotheprojectengineer,planswill berevised; reclaimedwaterwill notbedirectedintoexistingwetlands. Therearetwowater featurepondseastof KettleB. Therevisedplanforreclaimedwater,accordingtotheprojectengineer,will involvewaterbeingpumpedfrom Kettle B to the top of the ridge so it can flow as a series of water falls and stream across the fairways and through the two ponds to the east of the kettle. Water from the most easterly pond is pumped back to the top of the ridge to recirculate through the water features continuously. Waterwill notbedlschargedfromKettleBtoWetlandsCorD. OverflowsfromtheKettleBpondwill infiltrateattheperimeterof KettleBorin the extreme case, flow by pipe into the mitigation created wetland. 4 (this comment will need to be addressed by EA The area of impact for each lmpact Class lD in Figure 3.3-1 should be quantified to support the statement in Section 3.34. Removing approximately 89 percent of the vegetation is inconsistent with the conclusion that there will be no significant unavoidable impacts to plants. The applicant should provide more information to support that statement. GeoEngineers did not prepare Figure 3.3-1 (divided the area into impact class areas) and we did not discuss vegetation removal percentage amounts. The DSEIS does say that there will be no significant impacts even though 89 percent of vegetation is going to be removed. EA (who appears to have prepared the figure and discussed vegetation removal amounts) will need to address this comment. 29 7 ln the past, I have worked adjacent to a golf course and am familiar with the fertilizing and pesticide use that is used to maintain the greens. Red thread is a fungus that is common and is controlled by regular nitrate and fungicide applications. The greens also need seasonalnitratefertilizerandotherpesticidetreatments. TheplanthatwaspresentedbytheStatesmanGroupwasthattheywould be using organics to treat the golf course. The maintenance of the golf course would be nearly impossible with just organics (manure spreaders on a golf course? not likely). The comment is acknowledged. However, the applicant feels it is feasible to use organics to maintain the greens. File No. 12677-001-10 November 24,2075 Page 2 of3 GroEre rnrengl Pleasant llarbor Draft Supplemental Environmental lmpact Statement GeoEn$neers Response to Gomments Comment Leter Number Comment Number Comment Response to Comment 29 (continued) 2 hisalsopossiblethatthenitratesandpesticidescouldrunoff ontotheclambedsorrundownintotheaquifer. Aninformal measurement of the rainfall in this area was over 10' of rain in 3 days. Nitrates contribute to low dissolved oxygen and the 'dead zones' that are now in Hood Canal. ln the aquifer, nitrates are very harmful to human health if found In drinking water. The site will be regraded and designed so that all water on the site will be collected, treated and reused and will not be discharged to Hood Canal. ln addition there will be several areas monitored for water quality around the site to ensure that if an accidental release occurs, corrective measures can be implemented quickly. 3 (we need to work with EA to address this comment) The Hood Canal area has been used and enjoyed by tourists for over 100 years. Surely a different location that is not above some of the Pacific Northwest's best clamming beaches could be found. Hood Canal is also notorious for the slow water flushing and replacement back to the Puget Sound. This is just the wrong place for a resort. The comment is acknowledged. 30 L N/A - Comment is regarding Supporting no action. Comment is directed to EA within the comment letter packet. 2 No mater how "environmentally safe" a golf course is, there is bound to be run off into Hood Canal that would impact recreational and commercial shell fishing and water quality. The comment is acknowledged. See the response for comment letter 29, comment 2. 3 Moving from Lto 2.2 million cubic yard of earth from the hillsides around Pleasant Harbor would make the area highly susceptible to erosion; weoftenget3-5inchesof rainin24hours. Also,thereisnowaytheywouldbeabletoyanktheundergrowthfromthe ground on the building site, put it in a holding area, and get good survival so they could later replant it. We are not sure of the context of removing undergrowth vegetation and putting it in a holding area. lf undergrowth vegetation is removed in an area they will later want to replant, it is likely they will need to replant with containerized vegetation to get adequate coverage. and survival 59 7 I live 3 miles south of the proposed resort and think it's way too much for the highway adjacent, and the Duckabush river and estuary, which is already suffering salmon degradation issues. The site will be regraded and designed so that all water on the site will be collected and will not be discharged to Hood Canal. ln addition there will be several areas monitored for water quality around the site to ensure that if an accidental release occurs, corrective measures can be implemented quickly. File No. 12677-001-10 November 24,2075 Page 3 of3 GroEneweenslfi