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HomeMy WebLinkAboutSEPA Att M-1 - Parcel 970200001 BDN, LLC – SEPA Checklist Addendum M-1 Page - 1 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 Page - 2 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 Page - 3 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.)