HomeMy WebLinkAboutSEPA Att M-1 - Parcel 970200001
BDN, LLC – SEPA Checklist Addendum M-1
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SEPA Checklist - BDN, LLC Geoduck Farm – Rev. 3/31/20
Addendum M-1 – Use of Upland Parcel 970200001
Description of Property and Potential Usage.
This parcel is owned by applicant James Smersh. It consists of .29 acres of unimproved land,
zoned Rural Residential RR-5, Assessor’s Land Use Code 9100-Vacant Land. It is accessed at
its northwest corner via a recorded easement across the adjacent parcel 970200002 immediately
Parcel 970200001
May 07 2021
BDN, LLC – SEPA Checklist Addendum M-1
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to the west, owned by Bruce A. Olsen. That easement is roughly co-extensive with the roadway
visible to the left of the parcel in the above photo.
The Google Earth Imagery Date for this photo is 5/13/2018, and shows it being used by the
applicant for storage of three small personal watercraft in the upper northeast area, and storage
by BDN, LLC of white PVC geoduck planting tubes connected with existing nearby BDN
aquaculture operation. There are two BDN trailers parked temporarily on the property as shown
to the left of the PVC tubes. Since the date of the photo, all BDN items have been removed from
the property, and it is once again being used only for storage of the personal watercraft.
Because BDN has now acquired a nearby parcel (821344064) for storage and staging as
described elsewhere in this SEPA Checklist, there will be no future storage of BDN tubes or
other materials on parcel 970200001. It will be used solely as a secondary parking area for
activities related to the operation of the proposed aquaculture project.
There will be no clearing, grading or construction of any kind on this parcel by BDN, LLC, and
no impervious surfaces will be created. This property is not within 150 feet of any waterbody, is
not within 150 feet of any known Type F, N or S streams, is not a wetland, and is not in a
Shoreline Jurisdiction. It is not within a FEMA Flood Zone, Landslide Hazard Area, Soil Erosion
Area or Soil Seismic Area. It is within a Critical Aquifer Recharge Area and a Saltwater
Intrusion Protection Zone, but no activities proposed on the property will in any way impact the
parcels aquifer or saltwater intrusion functions or characteristics.
The only BDN use anticipated for this parcel will be as follows:
1) Parking of one or two passenger vehicles or light trucks on the parcel for 1-2 hours once
weekly for regular beach inspections of geoduck gear.
2) Parking of one or two passenger vehicles or light trucks on the parcel in connection with
emergency responses per the applicable Gear Management Plan. From prior BDN
experience in the area, such emergency responses occur on less than five days per year,
typically in the winter and sometimes at night.
3) Parking of a maximum of 6 passenger vehicles or light trucks on the parcel for no more
than 5 hours per day during planting or harvesting activities. However, it is anticipated
that BDN parcel 821344064 will be the primary parking and staging area for these
operations, such that related parking on this parcel will take place an average of less than
ten days per year.
Cumulative Impacts of the Use of This Parcel by BDN
By far the dominant vehicle traffic impact on the area is from the 24-hour-per-day, seven-days-
per-week vehicle traffic on Shine Road, which passes a few hundred feet from both the existing
and proposed BDN projects. The addition of the very few additional vehicle trips and parking
activities as described in the annotated site plan (BDN004R) will have at most a tiny cumulative
effect on the project area when compared to the constant visual and noise impact from Shine
Road and the surrounding feeder roads, especially since regular parking will be provided for all
beach workers on parcel 821344064 as necessary.
BDN, LLC – SEPA Checklist Addendum M-1
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The SMP defines “Cumulative impacts” or “cumulative effects” as “the combined impacts of a
proposed development action along with past impacts and impacts of reasonably foreseeable
future development actions. (JCC 18.25.100(3)(aa)). “Reasonably foreseeable” is defined as
“predictable by an average person based on existing conditions, anticipated build-out, and
approved/pending permits.” (JCC 18.25.100(18)(d))
Similarly, the National Environmental Policy Act (“NEPA”) requires the consideration of the
cumulative impacts of the Project, which include both direct effects, defined as those impacts
"caused by the action and occur[ing] at the same time and place" and indirect effects, which are
impacts "caused by the action and are later in time or farther removed in distance, but are still
reasonably foreseeable." 40 C.F.R. § 1508.8. Note that although indirect effects may be removed
in distance from the proposed action, they nonetheless must be caused by that action; i.e., there
must be a "reasonably close relationship" between the environmental effect and alleged cause.
Department of Transportation v. Public Citizen, 541 U.S. 752, 767 (2004).
The miniscule additional vehicle traffic generated by infrequent parking of vehicles on the parcel
as described above will have no significant cumulative impact on the areas surrounding the
parcel, either nearby or distant, while facilitating an aquaculture usage that is preferred under
Washington law (RCW 90.58.020.)