HomeMy WebLinkAboutSEPA Att M-2 - Parcel 821344064
BDN, LLC – SEPA Checklist Addendum M-2
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SEPA Checklist - BDN, LLC Geoduck Farm – Rev. 3/31/20
Addendum M-2 – Upland Parcel 821344064
Description of Property and Potential Usage.
This parcel is owned by BDN, LLC (“BDN”.) It consists of 1.26 acres of unimproved land,
zoned Rural Residential RR-5, Assessor’s Land Use Code 9100-Vacant Land. It is accessed at
its southwest corner via a 30’ wide recorded easement 821344064 (Vol 2 Short Plats, Page 166,
records of Jefferson County) across the adjacent parcel 821344029 to the south, owned by Alona
Parcel 821344064
May 07 2021
BDN, LLC – SEPA Checklist Addendum M-2
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J. Cowing, and the along parcel 821344032 to the south of 821344029, owned by Mary
Cameron, ending at Shine Road. That easement is roughly co-extensive with the dirt roadway
visible to the lower left of the parcel in the above photo.
The Google Earth Imagery Date for this photo is 5/13/2018, and shows it as vacant land covered
with grasses, small bushes, and three medium sized conifer trees at its northern end.
The usage proposed by BDN of this parcel will be:
1) Storage during BDN geoduck aquaculture planting, growing and harvest activities of
4” in diameter by 10" long PVC geoduck planting tubes. These tubes will be stored in
open piles or stacks in areas in the northern half of the parcel currently covered by grass
or small shrubs. Total coverage of these piles at any one time will be not more than
4,000 square feet, and the piles will not exceed 7 feet in height. These piles will allow
free draining of precipitation to the unimproved land beneath them, and will not
significantly compact the surface of the parcel.
The lack of release of microplastics from aquaculture gear is supported by available data
for the Salish Sea, showing lower levels of microplastics in water and sediment in areas
of active shellfish aquaculture compared with urban embayments. Similar claims about
phthalate plasticizers are unsupportable because such plasticizers are used in flexible
PVC, not rigid PVC. Does Plastic Shellfish Gear Increase Microplastic And Chemical
Exposures? Schoof, Rosalind Ramboll, Environ US Corporation, Abstracts, 71st Annual
Shellfish Growers Conference and Tradeshow Pacific Coast Shellfish Growers
Association National Shellfisheries Association Pacific Coast Section Welches, OR,
September 19-21, 2017. There are no known studies indicating that the amount of PVC
components that might be introduced into the environment through the storage of PVC
Tubes on the property has any adverse environmental effect, immediate or cumulative.
2) Parking on the parcel of one to two light trucks and/or light trailers used for
delivering or removing materials to or from parcel.
3) 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.
3) 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.
4) Parking of a maximum of 6-8 passenger vehicles or light trucks on the parcel for no
more than 5 hours per day during planting or harvesting activities.
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
BDN, LLC – SEPA Checklist Addendum M-2
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Intrusion Protection Zone, but no activities proposed on the property will in any way impact the
parcels aquifer or saltwater intrusion functions or characteristics.
Cumulative Impacts of the Use of This Parcel by BDN
Materials stored on the parcel will be visible only to the three neighbors immediately adjacent to
the parcel. The small piles of black mesh tubes will be unobtrusive and the small amount of
associated vehicle traffic will be much, much less from a noise and pollution standpoint than the
high volume of 24-hour-per-day, seven-days-per-week vehicle traffic on the heavily used SR 104
highway immediately adjacent to the parcel.
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 on-site storage of PVC tubing, and the small amount of related vehicle traffic generated by
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.)