HomeMy WebLinkAbout07B- BIOLOGICAL ASSESSMENT
Massmann/Heitter Beach Access,
Mooring Buoy, and Tree Trimming project
Biological Assessment &
NNL Mitigation Plan
March 24th, 2021
For: Joel Massmann and Janet Hietter
1912 33rd Ave S.
Seattle, WA 98144
Site Location:
Jefferson County Parcel # 921-294-008
Table of Contents
1. Project Overview .................................................................................................................... 1
1.1 Purpose ............................................................................................................................. 1
1.2 Applicant Information ...................................................................................................... 1
1.3 Project Location ............................................................................................................... 1
1.4 Project Description ........................................................................................................... 2
1.5 Regulatory Framework ..................................................................................................... 5
1.6 Construction Details.............................................................................................................. 5
1.7 Action Area ........................................................................................................................... 7
2. Species and Habitat ................................................................................................................. 8
2.1 Critical Areas .................................................................................................................... 8
2.2 Vegetation ......................................................................................................................... 8
2.3 Ordinary High Water Mark Delineation ........................................................................... 9
2.4 Wildlife Observed on Site .............................................................................................. 10
2.5 Habitat Surveys .............................................................................................................. 10
2.5.1 September 16th, 2020 SCUBA Habitat Survey ....................................................... 10
2.5.2 January 6th, 2021 OHWM and upland habitat survey ..............................................11
2.6 State Priority Habitat & Species..................................................................................... 12
2.8.1 Forage Fish.............................................................................................................. 14
2.3 Federal ESA Species & Critical Habitat ........................................................................ 15
2.3.1 Puget Sound Chinook ............................................................................................. 16
2.3.2 Hood Canal Summer-run Chum ............................................................................. 17
2.3.3 Bull Trout ................................................................................................................ 17
2.3.4 Puget Sound Steelhead ............................................................................................ 18
2.3.5 Rockfish .................................................................................................................. 18
2.3.6 Marbled Murrelets .................................................................................................. 19
2.3.7 Humpback whale .................................................................................................... 20
2.3.8 Leatherback Sea Turtle ........................................................................................... 20
2.3.9 Southern Resident Killer Whale ............................................................................. 20
2.3.10 Green Sturgeon ....................................................................................................... 22
3. Effects of the Action ............................................................................................................. 22
3.1 Direct Effects .................................................................................................................. 22
3.1.1 Water Quality .......................................................................................................... 22
3.1.2 Above Water Noise Effects ..................................................................................... 24
3.1.3 Federal Emergency Management Agency (FEMA) Related Impacts ..................... 24
3.2 Indirect Effects ............................................................................................................... 25
3.2.1 Salmonid Migratory Pathway Alteration ................................................................ 25
3.2.2 Increased Predation & Shading ............................................................................... 26
3.2.3 Scouring .................................................................................................................. 27
3.2.4 Boating Impacts ...................................................................................................... 28
3.3 Cumulative Effects ......................................................................................................... 28
3.4 Interrelated/Interdependent Effects ................................................................................ 28
4. Conservation Measures to Avoid/Minimize Impacts ............................................................ 29
5. Take Analysis ........................................................................................................................ 30
5.1 Determination of Effect .................................................................................................. 31
6. Mitigation Plan for No Net Loss of Ecological Function ..................................................... 31
6.1 Proposed Mitigation ....................................................................................................... 31
6.2 Mitigation Goals ............................................................................................................. 32
Goal (1) Buffer Enhancement ............................................................................................... 32
Goal (2) Emergent Cover ...................................................................................................... 32
Goal (3) Survival................................................................................................................... 32
Goal (4) Soil .......................................................................................................................... 32
6.3 Mitigation Performance Standards ................................................................................. 32
Performance Standard (1) Buffer Enhancement ................................................................... 33
Performance Standard (2) Emergent Cover .......................................................................... 33
Performance Standard (3) Survival ....................................................................................... 33
Performance Standard (4) Soil .............................................................................................. 33
6.4 Site Preparation .............................................................................................................. 33
6.5 Plant Procurement .......................................................................................................... 33
6.6 On Center Dimensions and Area Coverage.................................................................... 34
6.7 Planting Instructions ....................................................................................................... 34
6.8 Inspection and Maintenance Criteria.............................................................................. 35
6.9 Planting Plan .................................................................................................................. 35
7. Monitoring & Maintenance................................................................................................... 38
7.1 As-Built Report .............................................................................................................. 38
7.2 Monitoring Schedule ...................................................................................................... 38
7.3 Monitoring Methods ....................................................................................................... 38
7.4 Maintenance ................................................................................................................... 39
7.5 Contingency ................................................................................................................... 39
8. Conclusion ............................................................................................................................ 39
9. References ............................................................................................................................. 40
List of Tables
Table 1. NMFS/USFWS Critical Habitat ...................................................................................... 16
Table 2. Plant List ......................................................................................................................... 36
List of Figures
Figure 1. Vicinity Map .................................................................................................................... 2
Figure 2. Site plan ........................................................................................................................... 4
Figure 3. Preliminary Staircase Design .......................................................................................... 6
Figure 4. Trees to be removed*....................................................................................................... 9
Figure 5. Washington State Fish and Wildlife Priority Habitat and Species Map & Table .......... 13
Figure 6. National Wetlands Inventory Map ................................................................................. 14
Figure 7. Forage Fish Spawning Area Map .................................................................................. 15
Figure 8. Dept. of Ecology Water Quality Map Listings .............................................................. 24
Figure 9. FEMA Flood Zone Map ................................................................................................ 25
Figure 3. Planting Instructions ...................................................................................................... 34
Figure 4. Planting Plan Design Map ............................................................................................. 37
Attachments
A. Site Photos
B. September 16th 2020 Habitat Survey Data
C. Native Plant Sources for the Pacific NW
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1. Project Overview
1.1 Purpose
Marine Surveys & Assessments (MS&A) was authorized by Joel Massmann and Janet Hietter,
property owners, to complete a Biological Assessment (BA), including a mitigation plan meeting
Jefferson County No Net Loss (NNL) criteria, for the permitting of a multi-stage project to:
1) construct new beach access stairs,
2) install one recreational mooring buoy, and
3) trim or remove several native trees within the critical area shoreline buffer.
The project site is located on the owners’ residential property in Port Ludlow, WA, along the
shoreline of the Puget Sound, on the south side of Oak Bay. This Biological Assessment report is
in compliance with the Shoreline Management Act of 1971, the Jefferson County Shoreline
Master Program (Chapter 18.25), and the Jefferson County Critical Areas Code (Chapter 18.22).
This report serves to describe MS&A’s findings including evaluating potential direct and indirect
effects of the projects on sensitive habitat and wildlife species that may occur in the project area,
potential impacts to the water quality of nearby waterways, and a mitigation planting plan to
meet the criteria of No Net Loss of ecological function. Because this project occurs within the
100-year floodplain, FEMA flood zone information is also provided.
A dive survey to obtain intertidal habitat information for the mooring buoy component of the
project, along with an Ordinary High Water Mark (OHWM) survey for the stairs to the beach
project, was conducted by MS&A biologists on September 16th, 2020 (Section 2.5.1). A second
habitat survey to gather more upland data for the Mitigation Planting Plan was conducted on
January 6th, 2021, and this survey included a more extensive delineation of the OHWM along the
entire shoreline of the residential parcel. This second survey also assessed the surrounding
vegetation and documented the trees which are proposed for removal and/or trimming (Section
2.5.2).
1.2 Applicant Information
Name: Joel Massmann and Janet Hietter
Mailing Address: 1912 33rd Ave South, Seattle, WA 98144
Phone Number: (206) 919-1363 -Joel, (206) 473-2978 - Janet
Email address: massmann@comcast.net, janet@ketawaters.com
1.3 Project Location
Section 29, Township 29N, Range 1E, (SE ¼)
Physical address: 461 South Bay Way, Port Ludlow, WA 98365
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Jefferson County Parcel #: 921 294 008
Latitude: North 47.972006°, Longitude: West -122.697777°
Waterbody: Oak Bay, Puget Sound
WRIA: 17 - Quilcene - Snow
Legal Description: S29 T29 R1E TAX 80 & TLTX D6 WITH & SUBJ TO EASE
See Figures 1 & 2.
Figure 1. Vicinity Map
1.4 Project Description
The project is located on a 5.04 acre parcel of vacant undeveloped land located in an area zoned
as Rural Residential – One Unit per 5 Acres (RR-5). The parcel is owned by Joel Massmann and
Janet Hietter, who wish to eventually develop a residential home on the property. Before they
build their home, the property owners plan to prepare the land for recreational use by 1)
constructing a new beach access staircase, 2) installing a recreational mooring buoy, and 3)
trimming and removing several native trees within the critical area shoreline buffer to create a
partial view of the water.
The parcel is bordered on the eastern and western sides by similarly wooded shorefront rural
residential properties. To the north is Oak Bay, Puget Sound, and to the south is the
neighborhood street of South Bay Way. The parcel gently slopes from the southern edge on
South Bay Way down towards the shoreline. Closer to the shoreline the slope becomes steeper, in
some places presenting on the shoreline as a nearly vertical bedrock bluff face. The area where
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the stairs are proposed to be located is near the northwest corner of the parcel, where the slope
grade down to the beach is more gradual, at an approximately 35–45-degree angle (70-100%
slope), where a small trail already exists which is possible to scramble down. The Department of
Ecology Coastal Atlas classifies the slope in this area as “stable/bedrock” with “no appreciable
drift,” and it is MS&A’s understanding that no geotechnical analysis is required for this project.
The parcel is forested with a mix of conifer and deciduous trees and overgrown by mostly native
vegetation, but the middle section has been historically and recently cleared for a building site,
and consists primarily of non-native grasses (see vegetation section 2.2). There is a dirt road
grade acting as a driveway, which slopes down from South Bay Way connecting the road to the
clearing.
All components of the proposed beach access will be located well above the Ordinary High
Water Mark (OHWM), with the construction using a retractable “let down” portion of the stairs
to access the beach (Section 1.6 & Figure 3). There will be no structures below the OHWM.
The proposed mooring buoy location can be seen in Figure 4. Eelgrass (Zostera marina) was
documented at the site landward of the proposed buoy location between -3 ft MLLW and -7 ft
MLLW. There is a 25-foot buffer around the proposed mooring buoy location where no eelgrass
is present (Figure 4).
The tree trimming and removal component of the project will include the removal of 1 mature
Douglas Fir (Pseudotsuga menziesii) tree with approximate 14-inch DBH, 22 Douglas Fir
(Pseudotsuga menziesii) saplings (all between 5-25 ft tall), 1 Western Red Cedar (Thuja plicata)
with an approximate 12-inch DBH, and approximately 30 x Red Alder (Alnus rubra) saplings
growing in a densely populated grove, all of which are currently impeding the shoreline view.
There are an additional 10-20 young Douglas Fir trees which are 1-2 feet in height, all of which
are proposed for trimming or removal so that they don’t grow taller and create the same view
obstruction in the future. These trees are described in more detail in Section 2.2. Some minor
trimming of native vegetation to widen the trail down to the beach access staircase may also be
required. All vegetation removal will be mitigated for through a mitigation planting plan,
described in Section 6.
The beach is not regularly used recreationally by the public because it is difficult to access due to
the steep bluff face and consistent private development along the shoreline, though the area
waterward is used recreationally for boating and fishing.
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Figure 2. Site plan
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1.5 Regulatory Framework
This Biological Assessment Report is for the permitting of a combined three-part project
including 1) constructing new beach access stairs within the Shoreline Residential Designation
area, 2) installing one recreational mooring buoy within the Aquatic Shoreline Designation, and
3) removing several native trees and trimming native vegetation located within the critical area
shoreline buffer. Aside from the installation of the mooring buoy, all work will be done above the
OHWM, so no Washington Department of Fish and Wildlife (WDFW) Hydraulic Project
Approval (HPA) will be necessary for the staircase, however an HPA will be needed for the
mooring buoy component of the project. The installation of the recreational mooring buoy will
be within the navigable water jurisdiction of the Army Corps of Engineers, (ACOE), so that
component of the project will require a Specific Project Information Form (SPIF) to be submitted
for federal permitting. A Joint Aquatic Use Permit (JARPA) will be required by all agencies. In
addition, for the mooring buoy component, a JARPA (Attachment E) will need to be submitted to
the Department of Natural Resources (DNR) to obtain an aquatic use authorization for state
owned aquatic lands. The DNR will issue a “fee based” permit for the mooring buoy until the
property owners finish construction of a residential dwelling, at which point the permit will
change to “non-fee based.” The fee-based permit is a yearly fee based on the length of the vessel.
A pre-application conference with Jefferson County was attended by the property owners and
MS&A on August 28th, 2020, and it was agreed that the same Biological Assessment document
could be used for all three components of the project to avoid writing multiple costly reports.
Jefferson County will require a Type II Shoreline Conditional Administrative “C(a)” Use Permit
(CUP) for both the mooring buoy and the beach access components of the project, in compliance
with the CUP criteria outlined in JCC 18.25.590(2) & (3). The CUP involves a public notice
announcement with a 30-day comment period, as well as a decision by the UDC Administrator,
with final approval by the State Department of Ecology (an additional 30 days). The native
vegetation trimming and tree removal must follow the Vegetation Conservation section of JCC
18.25.310, the mooring buy installation must comply with JCC 18.25.350(8) Mooring Buoys,
and the beach access stair construction must follow regulations outlined in JCC 18.25.340 (3) &
(4) Beach Access Structures. Additionally, a mitigation plan is required as part of the project to
achieve No Net Loss of ecological function criteria for the upland components of the project,
under JCC 18.25.270(2) & (3) and to comply with WDFW. The project is SEPA exempt
according to the Washington Administrative Code (WAC) Section 197-11-800(24)(f) mooring of
residential pleasure craft.
1.6 Construction Details
Beach access stairs: The property owners plan to employ Brockman Builders for the staircase
construction. All work will be conducted from the upland side using hand tools. No machinery
will ground on the beach. No earthwork or grading will be necessary. The stairs will be
constructed of galvanized steel. The design will include:
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• One 3’ x 6’ platform at top of stairs
• One 3’ x 4’ platform at bottom of stairs (above OHWM)
• Four 4” x 4” steel posts dug into ground and secured in place with concrete, holding up
the top platform
• Four 4” x 4” steel posts dug into ground and secured in place with concrete, holding up
the bottom platform
• 18’ stringer set of stairs between top and bottom platforms
• Steel let-down stairs attached to bottom platform (above OHWM when not in use)
See Figure 3.
Figure 3. Preliminary Staircase Design
N
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Mooring Buoy: The property owners plan to employ Jim Arnold for the mooring buoy
installation. The anchors are 8 feet in total length with lead and termination. The system includes
a Helix square shaft anchor (matched to vessel size and conditions) installed; the nylon pennant
with a midline float to reach the surface at extreme high water, 6 feet of 1/2-inch long link chain
(at the top of the nylon, running through the 18-inch hard shell buoy) connected to the nylon with
a 3/4-inch Sampson Nylite Assembly, a 3/4-inch swivel and a 3/4-inch shackle. A 5/8-inch
forged retrieval pear ring at the very top attached with a 1/2-inch shackle. All metal parts are
American steel. The system is custom fitted to the conditions of bottom slope, clearance, and
tidal exchange.
Vegetation Trimming/Removal: Tree removal work will be completed by a qualified arborist
outside of nesting season (during the fall or winter months). Additional trimming and pruning of
trees and vegetation will be minimal and focused on improving trail access and the view of the
water, keeping the health of the overall shoreline buffer in mind.
A No Net Loss of ecological function mitigation planting plan is included in this report (Section
6) as compensation for the staircase construction, along with any tree and vegetation removal
within the critical area shoreline buffer.
1.7 Action Area
For the purposes of this report, the “project areas” are defined as the areas within the footprint of
the projects – in the case, the footprint of the beach access staircase, the footprint of the new
recreational mooring buoy, and the total estimated area of canopy coverage of native vegetation
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to be removed (calculated by estimated “on-center” dimensions). The project area also includes
areas that may have been used for staging materials and equipment, as well as accessing the site.
The “action area” is defined as any area that may have been ecologically impacted from short-
term construction activities or long-term habitat modifications, and covers approximately half a
mile from the project area. This half mile area includes a portion of Oak Harbor and Puget Sound
(Figure 1).
2. Species and Habitat
2.1 Critical Areas
The proposed project is within the150 foot Marine Critical Area Buffer as defined by Jefferson
County Shoreline Master Program (18.25.270(4)(e)[i] Critical areas, shoreline buffers, and
ecological protection). This buffer is measured landward (perpendicular) from the Ordinary High
Water Mark (see Figure 3). The proposed beach access stairs are within a Shoreline Residential
Designation area, and the recreational mooring buoy is within the Aquatic Shoreline Designation
area according to the Jefferson County Shoreline Master Program (18.25.500(3) Residential
Shoreline Environmental Regulations). The Department of Ecology Coastal Atlas classifies the
slope in this area as “stable/bedrock” with “no appreciable drift.” The National Wetland’s
Inventory map shows no upland wetlands or streams located within .5 miles of the property,
although the shoreline area is classified as Estuarine and Marine Wetland habitat, and Estuarine
and Marine Deepwater Habitat. The Cowardin designation of the estuarine and marine wetland is
E2AB/USN, which stands for “Estuarine, Intertidal, Aquatic Bed, Unconsolidated Shore,
Regularly Flooded.” The deep-water habitat is designated as E1UBL, which means “Estuarine,
Subtidal, Unconsolidated Bottom.”
2.2 Vegetation
The habitat on site is primarily forested, with a mix of conifer and deciduous trees including
Western Red Cedar (Thuja plicata), Douglas Fir (Pseudotsuga menziesii), Western Hemlock
(Tsuga heterophylla), Big Leaf Maple (Acer macrophyllum), and Red Alder (Alnus rubra). The
understory is a mixture of Salal (Gaultheria shallon), Evergreen Huckleberry (Vaccinium
ovatum), Red Huckleberry (Vaccinium parvifolium), Oceanspray (Holodiscus discolor), Sword
Fern (Polystichum munitum), Trailing Blackberry (Rubus ursinus), Oregon Grape (Mahonia
nervosa), and Salmonberry (Rubus spectabilis). Along the driveway there is some English Ivy
(Hedera helix) growing on several of the Douglas Fir (P. Menziesii) trees. The middle of the
property, where a clearing is located, has filled in with non-native grasses, Thimbleberry (Rubus
parviflorus), Creeping Buttercup (Ranunculus repens) and patches of encroaching invasive
Himalayan Blackberry (Rubus americanus). The area of the staircase has much of the same
upland vegetation, but also includes some Licorice Fern (Polypodium glycyrrhiza) growing on
the hillside.
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The proposed trees to be removed are listed in Section 1.4, and can be seen in Figure 4, as well
as Attachment A. Site Photos. They include 1 mature Douglas Fir (Pseudotsuga menziesii) tree,
22 additional Douglas Fir saplings, 1 Western Red Cedar (Thuja plicata), approximately 30 Red
Alder (Alnus rubra) saplings, and an additional 10-20 young Douglas Fir (P. menziesii) trees
which are 1-2 feet in height. These trees are proposed for trimming or removal because they are
either currently impeding the view of the water, or they will soon grow tall enough to impede the
view. In the case of the single mature Douglas Fir tree, it is proposed for removal because it is
located adjacent to the proposed beach access stairs, and is creating a hazard due to its severe
lean near the pathway. The rest of the trees proposed for removal are young and growing in
dense clusters and/or growing close to larger mature trees. It is the opinion of MS&A that their
removal will not negatively impact the overall habitat, and if anything will aid in ensuring the
longevity of the mature trees by allowing more space for healthy disease-free growth of the
mature trees and understory species. A mitigation planting plan has been prepared for no net loss
of ecological function, and species have been chosen to improve the habitat value for wildlife
(Section 6).
Substrate on the beach consists of sand, cobble, and pebble throughout. Areas of macroalgae and
submerged aquatic vegetation (SAV) are described in Section 2.5.1.
See Attachment A for site photos showing vegetation.
Figure 4. Trees to be removed*
*(Many of the X's are in reference to multiple trees - see attachment A for tree specific pictures.
The Douglas Fir tree adjacent to the proposed staircase is not shown in in this photo).
2.3 Ordinary High Water Mark Delineation
The Shoreline Management Act (SMA) considers the OHWM as a physical and ecological
feature on the landscape, the OHWM is often a transition zone between the aquatic and terrestrial
environments and not a distinct line.
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At the location of the proposed beach access staircase, the OHWM is found approximately one to
two feet up the bluff face (see Figures 2 & 3). The OHWM was identified and delineated in this
location during the habitat survey conducted by MS&A biologists on September 16th, 2020, and
an additional OHWM survey of the entire shoreline was conducted on January 6th 2021 so that a
professional land-surveyor could stake out where the site’s buildable area is located outside of
the Marine Critical Area buffer. During this second OHWM survey, MS&A biologist Jill Cooper
clearly marked the OHWM using pink flagging tape and yellow spray paint dots (as much of the
line is located on the bedrock cliff face – see Attachment A. Site Photos). Field indicators of the
OHWM included a distinct termination of overhanging upland vegetation at the waterline,
exposed roots, a line of orange lichen just above the OHWM, and water staining/color changes
on the bedrock. The soils below the OWHM are exposed, eroding, and depleted, whereas the
soils above the OHWM, in areas where it is not too steep and vegetation is persisting, there is a
thick duff layer and organic soil present.
2.4 Wildlife Observed on Site
During the site visits, MS&A biologist Jill Cooper heard and/or saw the following species of
birds: Red-breasted Nuthatch (Sitta canadensis), Song Sparrow (Melospiza melodia), Belted
Kingfisher (Megaceryle alcyon), Cormorant (Phalacrocorax sp.), Western/Glaucous-winged
Gull (Larus sp.), Northern Flicker (Colaptes auratus), and Pine Siskins (Spinus pinus).
Biologists also saw a North American River Otter (Lontra canadensis) on the shore with a
freshly caught fish in its mouth, and found otter trail, scent stations, and scat on and near the
beach. Additionally, Coyote (Canis latrans) scat was found along the property driveway in more
than one location. No nests were seen in any trees along the shoreline.
2.5 Habitat Surveys
Marine Surveys & Assessments conducted a SCUBA habitat survey, as well as an OHWM
survey of the proposed beach access location on September 16th, 2020, and an additional OHWM
survey of the entire shoreline section of the parcel as well as an upland habitat survey was
conducted on January 6th, 2021.
2.5.1 September 16th, 2020 SCUBA Habitat Survey
A habitat survey was performed using SCUBA on September 16, 2020 from
approximately 4:30 pm to 5:00 pm at the project site. Darby Flanagan and Griffin Hoins
from Marine Surveys & Assessments used SCUBA to run habitat survey transects in the
area of a proposed mooring buoy to identify flora, fauna, substrate types and other
qualitative information (Figures 1 & 2). Weather was calm and smoggy; water visibility
was 23 feet. The shoreline at the site is a steep bluff with some exposed bedrock.
The survey transect baseline for the mooring buoy transects extended 140 feet seaward
(bearing 290 degrees true north) from a point along the shoreline located 85 feet NE of
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the western property line. Four mooring buoy transects, each 100 feet long, were
surveyed from that point (centered on the location of the proposed mooring buoy) – see
Figure 2.
Elevations in the survey area ranged from +9.8 ft MLLW along the transect baseline to -
37 ft MLLW at the seaward end. (The elevations were not collected using survey grade
equipment and are for reference only; they can have an error of +/- 1 foot or more and
should not be used for engineering purposes).
Substrate at the site is sand, cobble, and pebble throughout. Areas of macroalgae
included:
• Ulva 2-80% cover
• Fucus 20% cover
• Saccharina latissima 2 blades (6% cover)
• Mastocarpus 20% cover
• Gracilaria 40-50% cover
• Sarcodiotheca 2-80% cover
Eelgrass (Zostera marina) was documented at the site landward of the proposed buoy
location between -3 ft MLLW and -7 ft MLLW. The eelgrass bed was dense in some
areas; four quadrat samples were collected (with 3 replicates at each sampling location)
with an average density of 3 to 4.7 shoots per 0.25 m2.
Laminariales kelp (Saccharina latissima) was observed at one location at the site at low
density (2 blades; 6% cover).
Areas of total vegetation and locations of Saccharina latissima are mapped in Figure 2.
Ulva is not included in the total vegetation because this area is not documented as herring
spawning habitat; however, the shoreline at the site does have documented sand lance and
surf smelt spawning. A table of the full habitat survey results can be found at the end of
this report.
2.5.2 January 6th, 2021 OHWM and upland habitat survey
The weather during this site visit was partly cloudy and calm with temperatures around
47 degrees Fahrenheit. The low tide in the Port Ludlow area on January 6th, 2021 was
predicted to be 2.90 feet (MLLW) at 5:04pm. MS&A biologist Jill Cooper visited the site
before sunset to survey the OHWM at approximately 3:30pm when the tide was 3.90 feet
(MLLW) when the beach was traversable around the point of land that juts out from the
shore.
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The purpose of this habitat survey was to evaluate the OHWM along the entire shoreline
portion of the parcel so that property owners would work with a certified land surveyor to
determine what buildable area is located outside of the Shoreline Critical Area buffer. The
OHWM determination is further described in Section 2.3. MS&A Biologist Jill Cooper
also surveyed the upland area to document the trees that are proposed to be removed
within the buffer, as well as potential planting areas for the mitigation planting plan. One
mature Douglas Fir (Pseudotsuga menziesii) tree, 22 Douglas Fir saplings (between 5 and
25 feet tall), and 1 Western Red Cedar (Thuja plicata) (approximately 12-inch DBH)
were flagged with pink flagging. The Red Alder (Alnus rubra) sapling grove was left un-
flagged because of the sheer density of small trunks clustered together, and the 10-20
smaller Douglas Fir (P. menziesii) trees (1-2 ft in height) which are planned for removal
or trimming were also left un-flagged. Vegetation seen on site is described in section 2.2,
and wildlife observed on site is described in section 2.4.
A single Vine Maple (Acer circinatum) located within the Marine Critical Area buffer was
accidentally cut down in December of 2020. This occurred during removal of a row of
non-native Leyland Cypress (Cupressus leylandii) trees located on the adjacent property
(491 S Bay Way, Parcel #921294009). The Cypress trees were removed from the
neighboring parcel because of the neighbors’ concern that these trees represented a fire
hazard to their home. During the process of taking down the Cypress trees, the arborist,
without instructions or permission to do so, also removed the Vine Maple (A. circinatum)
that was located on the Massmann/Hietter parcel. A photo showing this Vine Maple is
included in Attachment A. This tree will be included in the total square footage to be
mitigated for in the mitigation planting plan (Section 6).
2.6 State Priority Habitat & Species
The WDFW Priority Habitat and Species mapper indicates Surf Smelt (Hypomesus pretiosus)
and Pacific Sand Lance (Ammodytes hexapterus) spawning, as well as presence of hardshell
clams, Pacific Geoduck (Panopea abrupta), and Dungeness Crab (Cancer magister) within 0.5
miles of the action area (Figure 5). Region 6 Saltwater Wetlands, as well as Estuarine and Marine
Wetland and Freshwater Emergent Wetland Aquatic Habitat are also found within 0.5 miles of
the action area. These wetland areas are listed on the National Wetland Inventory (NWI) mapper
as Cowardin classification E1UBL; Estuarine, Subtidal, Unconsolidated Bottom, E2AB/USN;
Estuarine, Intertidal, Aquatic Bed, Unconsolidated Shore, Regularly Flooded, and PEM1C;
Palustrine, Emergent, Persistent, Seasonally Flooded (Figure 6).
According to queries of the WDFW SalmonScape data, no salmonid bearing streams have been
documented in the action area. However, salmonid species may travel past the project site as
salmonid bearing streams are present 1 to 2 miles away, and NOAA fisheries has designated the
shoreline as ESA Critical Habitat for Puget Sound Chinook and Hood Canal Summer Run Chum.
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Figure 5. Washington State Fish and Wildlife Priority Habitat and Species Map & Table
Biological Assessment & No Net Loss Mitigation Planting Plan MS&A | 14
Figure 6. National Wetlands Inventory Map
2.8.1 Forage Fish
Migrating salmon utilize forage fish such as Pacific Herring (Clupea harengus pallasi), Pacific
Sand Lance (Ammodytes hexapterus), and Surf Smelt (Hypomesus pretiosus) as prey resources.
These fish form a very important trophic link between plankton resources and a wide variety of
predatory marine organisms as well as providing food for marbled murrelets and bald eagles.
According to WDFW, there is documented Surf Smelt and Pacific Sand Lance spawning habitat
along the shoreline (Error! Reference source not found.).
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Figure 7. Forage Fish Spawning Area Map
2.3 Federal ESA Species & Critical Habitat
For each listed species with the potential to be in the project action area, the listing status,
distribution of species, and relevant life history traits are presented in the sections below. Salmon
species that that may migrate past the project site are also included. Critical habitat for listed
species within the project footprint or action area is listed in Table 1.
Biological Assessment & No Net Loss Mitigation Planting Plan MS&A | 16
Table 1. NMFS/USFWS Critical Habitat
NMFS/USFWS Critical Habitat Action
Area
Stair/Tree
removal
Project
Footprint
Buoy
Project
Footprint
Final Nearshore Rockfish Critical Habitat (NMFS, 2014) Y N Y
Final Deepwater Rockfish Critical Habitat (NMFS, 2014) Y N N
Hood Canal Summer-run Chum Salmon Freshwater Critical
Habitat (NMFS, 2005) N N N
Hood Canal Summer-run Chum Salmon Marine Critical
Habitat (NMFS, 2005) Y N Y
Marine Critical Habitat for Puget Sound Chinook Salmon
(NMFS, 2005) Y N Y
Freshwater Puget Sound Chinook Salmon Critical Habitat
(NMFS, 2005) N N N
Freshwater Critical Habitat for Puget Sound Steelhead
(NOAA, 2016) N N N
Marine Critical Habitat Hood Canal Summer-run Chum
Salmon (NMFS, 2005) Y N Y
Southern Resident Killer Whale Critical Habitat (NMFS,
2006) Y N N
Bull Trout Final Critical Habitat (USFWS, 2015) N N N
Marbled Murrelet (USFWS, 2015) Y N N
Leatherback Sea Turtle Critical Habitat (NMFS, 2012) N N N
Green Sturgeon Critical Habitat (NMFS, 2009) N N N
Southern Eulachon (NMFS, 2011) N N N
2.3.1 Puget Sound Chinook
Puget Sound Chinook (Oncorhynchus tshawytscha), also known as King Salmon, are
distinguished from all other Pacific salmon by their large size. Most Chinook in the Puget Sound
are “ocean-type” and migrate to the marine environment during their first year (Myers et al.
1998). They may enter estuaries immediately after emergence as fry from March to May at a
length of ~40 mm, or they may enter the estuaries as fingerling smolts during May and June of
their first year at a length of 60-80 mm (Healey 1982). Chinook fry in Washington estuaries feed
on emergent insects and epibenthic crustaceans (gammarid amphipods, mysids, and cumaceans).
As they grow and move into neritic habitats, they feed on decapod larvae, larval and juvenile
fish, drift insects, and euphausiids (Simenstad et al. 1982). These ocean-type Chinook use
estuaries as rearing areas and are the most dependent of all salmon species on estuaries for
survival.
The Puget Sound Chinook is listed under the Endangered Species Act (ESA) as threatened
according to the National Marine Fisheries Service (NMFS) (70 FR 37160; June 28, 2005). In
Biological Assessment & No Net Loss Mitigation Planting Plan MS&A | 17
addition, NMFS has designated Critical Habitat for 12 Evolutionarily Significant Units (ESUs)
of West Coast salmon, including the Puget Sound Chinook Salmon ESU.
The portion of any project footprint and action area located below the line of extreme high water
is designated as Critical Habitat for the Puget Sound Chinook ESU (70 FR 52685; September 2,
2005). The proposed mooring buoy project site and the entire project action area is within Puget
Sound Chinook marine Critical Habitat. According to queries of the SaSI data, the closest
Chinook riverine presence is approximately 9 miles outside the action area, in Tarboo Creek (Fall
run).
2.3.2 Hood Canal Summer-run Chum
In Puget Sound, chum (Oncorhynchus keta) spawning grounds are situated near coastal rivers
and lowland streams. Puget Sound chum typically spawn from September to March (WSCC
2003). Chum (along with ocean-type Chinook) spend more time in the estuarine environment
than other species of salmon (Healey 1982). Residence time in the Hood Canal ranges from 4 to
32 days with an average residence of 24 days (Simenstad, Fresh, & Salo 1982). Juvenile chum
consume benthic organisms found in and around eelgrass beds (harpacticoid copepods,
gammarid amphipods and isopods), but change their diet to drift insects and plankton such as
calanoid copepods, larvaceans, and hyperiid amphipods as their size increases to 50 - 60 mm
(Simenstad, Fresh, & Salo 1982). Chum move offshore and switch diets when presented with a
lack of food supply (Simenstad et al. 1982).
NMFS has listed the Hood Canal summer-run chum ESU as threatened under the ESA (70 FR
37160; June 28, 2005). NMFS designated Critical Habitat for the Hood Canal summer-run chum
ESU shortly after (70 FR 52739; September 2, 2005) and it includes the entire Hood Canal and
contiguous shoreline north/northwest, ending past Dungeness Bay near Sequim, and streams.
The proposed mooring buoy project site and the entire project action area is within Hood Canal
Summer-run chum marine Critical Habitat. According to queries of the SaSI data and NOAA
Critical Habitat data, the closest Hood Canal summer-run chum stream is Chimacum Creek,
approximately 3.5 miles outside the action area.
2.3.3 Bull Trout
Coastal-Puget Sound Bull Trout (Salvelinus confluentus) have ranged geographically from
northern California (at present they are extinct in California) to the Bering Sea coast of Alaska,
and northwest along the Pacific Rim to northern Japan and Korea. Bull Trout are members of the
char subgroup of the salmon family. Bull Trout live both in fresh and marine waters. Some
migrate to larger rivers (fluvial), lakes (adfluvial), or saltwater (anadromous) before returning to
smaller streams to spawn. Others (resident Bull Trout) complete all of their life in the streams
where they were reared. Habitat degradation, dams and diversions, and predation by non-native
fish threaten the Coastal Puget Sound population (64 FR 58910; November 1, 1999). Spawning
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occurs typically from August to November in streams, and migration to the open sea for
anadromous populations takes place in the spring. Eggs and juveniles require extremely cold
water for survival. Temperatures in excess of approximately 15 degrees Celsius are thought to
limit Bull Trout distribution (Rieman & McIntyre, 1993).
All populations of Bull Trout, including the Coastal-Puget Sound populations, were listed as
threatened by the United States Fish and Wildlife Service (USFWS) in 1999 (64 FR 58910;
November 1, 1999). USFWS designated Critical Habitat for Bull Trout in 2010 (75 FR 63898;
October 18, 2010). Bull Trout Critical Habitat is not within the action area. Also, there are no
streams in the project or action areas with documented Bull Trout presence (SaSI WDFW).
2.3.4 Puget Sound Steelhead
Steelhead is the name given to the anadromous form of Rainbow Trout (Onchorhynchus mykiss).
Other Rainbow Trout remain in freshwater systems for the duration of their lives. Unlike Pacific
salmon, Steelhead can return to the ocean after spawning and migrate to freshwater to spawn
again. Steelhead fry can spend one to two years in freshwater before heading to the open ocean,
where they may stay for two to four years before returning to Washington streams. Steelhead
migrate quickly through Puget Sound and into the open sea as individuals or in small groups
(Crawford 2012). Unlike Chinook, steelhead do not have a long term feeding and growth period
in Puget Sound nearshore areas (Crawford 2012).
NMFS has listed the Puget Sound steelhead (O. mykiss) as a threatened species under the ESA
(72 FR 26722; May 11, 2007). Critical Habitat has been finalized for the Puget Sound steelhead
distinct population segment (81 FR 9252; February 24, 2016). There is no designated Critical
Habitat for Steelhead within the action area.
2.3.5 Rockfish
Bocaccio (Sebastes paucispinis) and Yelloweye (Sebastes ruberrimus) Rockfish remain in the
upper part of the water column as larvae and pelagic juveniles. Around 3 to 6 months old,
Bocaccio Rockfish settle into intertidal, nearshore habitat; they prefer to settle in rocky reefs,
kelp beds, low rock, and cobble areas (Love et al. 2002). Juvenile Yelloweye Rockfish are
usually found in the upper extent of the adult depth range instead of in intertidal habitat
(Studebaker et al. 2009). As both species grow larger, they move into deeper waters. Adults are
found around rocky reefs and coarse habitats. Marine habitats high in complexity are associated
with higher numbers of Rockfish species (Young et al. 2010). Adult Yelloweye and Bocaccio
Rockfish generally inhabit depths from approximately 90 ft to 1,400 ft (Love et al. 2002). Both
species are opportunistic feeders, with their prey dependent on their life stage. Predators of adult
rockfish include marine mammals, salmon, other rockfish, lingcod, and sharks.
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NOAA has listed the distinct population segments (DPSs) of Yelloweye (Sebastes ruberrimus) as
a threatened species under the ESA and listed the Georgia Basin DPS of Bocaccio Rockfish
(Sebastes paucispinis) as endangered (75 FR 22276 April 28, 2010). Critical Habitat has been
finalized for the rockfish distinct population segment (79 FR 219; November 13, 2014). The
Georgia Basin refers to all of Puget Sound, including the area around the San Juan Islands, and
the Strait of Georgia, north to the mouth of the Campbell River in British Columbia. The western
boundary of the Georgia Basin runs from east of Port Angeles to Victoria in the Strait of Juan de
Fuca.
The mooring buoy component of this project is located within Nearshore Rockfish Critical
Habitat area, and of the action area of the project includes both Nearshore and Deepwater
Rockfish Critical Habitat areas. However, although these species have the potential to be present,
the effects of this project on rockfish species are expected to be minimal, if at all. Shallow
intertidal nearshore waters can provide suitable substrate (in rocky, cobble and sand substrates,
with or without kelp) for juvenile Bocaccio Rockfish (3-6 month old), but the highest densities of
juvenile rockfish are found in areas with floating or submerged kelp species. Taking this into
account, the project footprint is within marginally suitable habitat for rockfish due to the
presence of cobbly and submerged aquatic vegetation, but not preferred rockfish habitat because
of the lack of abundance of larger kelp species on-site.
2.3.6 Marbled Murrelets
Marbled Murrelets (Brachyramphus marmoratus) are small marine birds in the Alcidae family.
They spend most of their time at sea and exclusively use old growth areas for nesting. In the
critical nesting areas, fragmentation and loss of old growth forest has a significant impact on the
survival and conservation of the species (WDW 1993). Adult birds are found within or adjacent
to the marine environment where they dive for Sand Lance, Sea Perch, Pacific Herring, Surf
Smelt, other small schooling fish and invertebrates.
Marbled Murrelets have been listed as threatened by the USFWS since 1992 (57 FR 45328;
October 1, 1992). Critical Habitat was designated by USFWS in 1996, revised in 2011, and
reviewed again in 2016 to determine if the ESA definition of Critical Habitat was being met (81
FR 51348, August 4, 2016).
There is no Marbled Murrelet Critical Habitat within close range of the project area, and there
are no nests close to the project site (WDFW, USFWS). Results from the 2018-2019 Puget
Sound Seabird Survey (PSSS) report, created by Seattle Audubon Society, show that 177
individual Marbled Murrelets were sighted across 21 observation study sites during 2018-2019.
None of these sightings by PSSS occurred in the area of the project site. However, based on
eBird citizen science data, the closest recorded Marbled Murrelet sightings are within the action
area, with 4 sightings at Olele Point in 2017, and 4 sightings at the same location in 2007.
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2.3.7 Humpback whale
NMFS has listed the humpback whale (Megaptera novaeangliae) as an endangered species that
may occur in Puget Sound (81 FR 62260; September 8, 2016). Critical Habitat was proposed by
NMFS in 2019, but does not include the project footprint or the action area (84 FR 54354;
October 9, 2019). In the North-Central Puget Sound Sub-basin, there were the following
humpback whale sightings in (Orca Network):
• 2018: June, July
• 2019: February, May, August, September
• 2020*: June, July, August, October
* (no data available yet for December 2020)
2.3.8 Leatherback Sea Turtle
NMFS has listed the Pacific leatherback turtle (Dermochelys coriacea) as an endangered species
that may occur in Puget Sound (35 FR 8491; June 2, 1970). There is no designated Critical
Habitat for Pacific leatherback turtles in Puget Sound at this time; it is designated along the outer
coast of Washington state (77 FR 4170; January 26, 2012).
Breeding habitat for leatherback sea turtles in Washington does not exist, even though they are
occasionally seen along the coast (Bowlby et al. 1994). Leatherback sea turtles are rarely seen in
Puget Sound (McAllister, pers. comm.). It is highly unlikely leatherback turtles would be found
near the project site.
2.3.9 Southern Resident Killer Whale
The Southern Resident Killer Whale (Orcinus orca) population consists of three pods: J, K and
L. According to Wiles (2004), “While in inland waters during warmer months, all of the pods
concentrate their activity in Haro Strait, Boundary Passage, the Southern Gulf Islands, the
eastern end of the Strait of Juan de Fuca and several localities in the southern Georgia Strait.”
During early autumn, these pods, especially J pod, extend their movements into Puget Sound to
take advantage of the Chum and Chinook salmon runs. Resident Killer Whales spend more time
in deeper water and only occasionally enter water less than 5 meters deep (Baird 2001). On
November 15, 2005 NMFS listed the Southern Resident Killer Whale as endangered under the
ESA (70 FR 69903; November 18, 2005). NOAA Fisheries has designated Critical Habitat for
killer whales: "Critical Habitat includes waters deeper than 20 ft relative to a contiguous
shoreline delimited by the line of extreme high water." (71 FR 69054; November 29, 2006).
Southern Resident Killer Whale Critical Habitat is found within the action area. Federally listed
marine mammals also occur in the action area and include the Humpback Whale and Resident
Orca.
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According to the Southern Resident Killer Whale (SRKW) Sighting 1990-2013 map (Olson
2014), Quad #393 (which encompasses the action area) had the following sightings:
Month Number of SRKW Individuals Sighted
January 0
February 1
March 0
April 0
May 0
June 0
July 0
August 0
September 2
October 3
November 1
December 2
And according to the Orca Network, in the North-Central Puget Sound Sub-basin, there were the
following Killer Whale sightings in 2018, 2019, and 2020:
Month Number of sightings
per month in 2018
Number of sightings
per month in 2019
Number of sightings per
month in 2020*
*(no data available yet for
December 2020)
January 3 2 1
February 2 3 0
March 1 4 5
April 3 3 5
May 1 4 4
June 6 3 9
July 1 8 11
August 7 8 4
September 11 2 2
October 2 6 4
November 6 0 7
December 6 3 N/A
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Due to the proposed mooring buoy placement being at a depth less than 20 feet “relative to a
contiguous shoreline delimited by the line of extreme high water,” the Critical Habitat area is
outside of the project footprint (71 FR 69054; November 29, 2006). Therefore, it is highly
unlikely that Southern Resident Killer Whales would be affected by this project.
2.3.10 Green Sturgeon
On April 7, 2006, NMFS determined that the Southern Distinct Population Segment of North
American Green Sturgeon (Acipenser medirostris; hereafter, “Southern DPS”) is at risk of
extinction in the foreseeable future throughout all or a significant portion of its range and listed
the species as threatened under the Endangered Species Act (71 FR 17757; April, 7, 2006).
Critical Habitat for the threatened Southern DPS Green Sturgeon was subsequently designated
by NMFS in 2009 (74 FR 52300; October 9, 2009). Southern DPS Green Sturgeon occupy
coastal bays and estuaries from Monterey Bay, CA to Puget Sound, WA. Observations of Green
Sturgeon in Puget Sound are much less common compared to the other estuaries in Washington
State. Green Sturgeon have a complex anadromous reproductive cycle and do not reach
reproductive age until 15 years old for males and 17 years old for females; female Green
Sturgeon are thought to spawn every 5 years (NMFS, 2002). Activities of concern in Puget
Sound include dredging and capping, which could affect benthic habitats, alter water flow, and
affect water quality (NMFS, 2009).
There is no designated Critical Habitat for Green Sturgeon within the action area.
3. Effects of the Action
When reviewing all of the data, the direct and indirect effects of this project on the listed species
discussed above, as well as their Critical Habitat, have been considered. Impacts to ESA species
and their Critical Habitat areas are based on what we know of the project area, as well as current
baseline conditions. Direct and Indirect effects are discussed below.
3.1 Direct Effects
The likelihood of any listed species and/or Critical Habitat being immediately reduced in size or
population, or destroyed, by direct effects of this project was outlined in Section 2 above. The
types of potential direct impacts caused by the construction process includes increased noise, and
impacts to water quality, which are discussed below.
3.1.1 Water Quality
Beach access component of project: The construction of the stairs will take place in the
dry, above the OHWM. A localized increase in bluff erosion could occur during
construction, however it is expected that effects on water quality will occur on a very
limited basis, if at all.
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Mooring buoy component of project: The installation of the mooring buoy could cause
temporary and localized increases in turbidity and total suspended solids (TSS). This
could impact migrating salmonids and forage fish by reducing feeding rates and causing
physiological stress. Variations in suspended sediment concentration can negatively
impact species composition, biomass, algal growth and can affect secondary production
as well (Newcombe and MacDonald 1991). Filter feeders can have blockages in feeding
structures and effect their feeding efficiency, in turn reducing growth rates, increasing
stress or in some cases can result in death (Newcombe and MacDonald 1991). Suspended
sediments can also impact salmonid fishes by increasing mortality rate, reducing growth
rate and/or reducing resistance to disease, modifying natural movements, interfering with
development, reducing prey abundance and fish catch methods (Newcombe and
MacDonald 1991). Impact level depends on duration of exposure, concentration of
turbidity, the life stage during the increased exposure, and the options available for the
fish to avoid the plumes (Newcombe and MacDonald 1991). The effects can be discussed
in terms of lethal, sublethal or behavioral (Nightingale and Simenstad 2001a and
Simenstad, editor, 1988).
Turbidity effects from this project are expected to be minor, localized, and brief, so no
significant effects on fish or filter feeders is expected. Also, no known water quality
issues are listed by the Department of Ecology for the project area, so any potential
upwelling of sediments caused by the installation of the mooring ball will not pose a risk
of toxicity (Figure 8).
Tree removal component of project: A localized increase in bluff erosion could occur due
to the removal of trees within the Marine Critical Area buffer, however, most of the trees
proposed for removal are located further up the bluff and are crowded by other trees and
vegetation which would help to impede the potential erosion caused by the tree removal.
Therefore, it is expected that effects on water quality will occur on a very limited basis, if
at all. Additionally, new trees and vegetation will be planted for mitigation, introducing
more diverse understory habitat and helping to halt any potential erosion that could affect
water quality.
Biological Assessment & No Net Loss Mitigation Planting Plan MS&A | 24
Figure 8. Dept. of Ecology Water Quality Map Listings
3.1.2 Above Water Noise Effects
Beach access component of project: The construction of the stairs will take place in the
dry, above the OHWM. Some noise effects will likely occur during construction due to
the necessary use of hand tools and material movement. Loud noises could disrupt
wildlife, and/or mask the approach of predators. However, the likelihood of effects on
wildlife due to noise pollution is minimal, since severe noise such as pile driving will not
occur during this project.
Mooring buoy component of project: The installation of the mooring buoy is not
expected to cause any noise effects.
Tree removal component of project: Noise disturbance will likely occur during the
removal of the trees, but will be brief and localized.
3.1.3 Federal Emergency Management Agency (FEMA) Related Impacts
Beach access component of project: Although much of the property is outside of the
FEMA flood zone, the staircase will be located within 13 feet of sea-level, so it is
considered within the FEMA flood zone AE (Figure 9). However, the staircase will be
located above the OHWM, securely attached to the bedrock of the bluff face, and
constructed of weather resistant materials, so its structure should be able to withstand any
potential 100-year floods.
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Mooring buoy component of project: Since mooring buoys designed to remain below
water, the FEMA flood zone information does not apply to this portion of the project.
Tree removal component of project: All trees proposed for removal are above the FEMA
flood zone with the exception of the single Douglas Fir (Pseudotsuga menziesii) located
adjacent to the proposed beach access stairs. This tree will be mitigated for in the No Net
Loss mitigation planting plan, and no significant effects on flooding or erosion are
expected to occur due to its removal.
Figure 9. FEMA Flood Zone Map
3.2 Indirect Effects
Indirect effects are considered negative impacts on listed species and their Critical Habitats
which may occur after the completion of this project. These are discussed below.
3.2.1 Salmonid Migratory Pathway Alteration
All salmonid species are known to use estuarine and nearshore environments at some
time during their life cycle. In addition, critical food fish for salmonids, such as Surf
Smelt (Hypomesus pretiosus), Sand Lance (Ammodytes hexapterus) and Herring
(Clupeaharangus) depend on quiet embayments, sandy, undisturbed, shaded beaches, and
eelgrass beds for spawning (Shaffer 2001). Ecosystem links between upland and
nearshore habitats are extremely important (Shaffer 2001). Properly graded intertidal and
supratidal zones are also crucial habitat elements for biota (Dethier 1990; Heerhartz et al.
2015; Heerhartz & Toft 2015). Furthermore, forage fish spawning occurs high on the
Biological Assessment & No Net Loss Mitigation Planting Plan MS&A | 26
shoreline, which is impeded by structures which cut off part of the intertidal zone (Quinn
et al. 2012).
Beach access component of project: The proposed staircase will be located above the
OHWM, so it is unlikely to have any impacts on salmonoid migratory pathways.
However, because the project will alter the landscape within the footprint of the staircase,
it may have potential impacts on productivity (such as reduced productivity due to
shading in the riparian zone) and natural ecosystem links between the upland and
nearshore habitat systems.
Mooring buoy component of project: The installation of the mooring buoy will alter the
benthic environment within the anchor footprint, but is not expected to have significant
impacts on salmonid migration or movement.
Tree removal component of project: Does not apply.
3.2.2 Increased Predation & Shading
At this time, there is no evidence of structures such as docks or mooring buoys causing
the aggregation of salmonid predators in the Puget Sound (Ratte & Salo 1985; Cardwell
et al. 1980; Nightingale and Simenstad 2001b). Other marine structures, such as
breakwaters, may serve as marine mammal haul out areas, but there is no scientific
literature that states that these mammals are particularly targeting small migrating
juvenile fish. It might be assumed that birds would be interested in small migrating
juveniles, but there is also no evidence that marine structures provide an aggregation site
for predatory birds (Taylor and Willey 1997).
An additional concern about the impacts of overwater structures on migrating salmon is
that they will be forced to move out into deeper water, where they will be consumed by
predatory fish species. However, in the Williams study cited above, the authors noted:
We found no evidence that avian, marine mammal, or fish predators consumed
more juvenile salmon near WSF terminals than along shorelines without
overwater structures. Few species appeared to be targeting abundant fry in
nearshore habitats, and we observed only two occasions in which predators (one
tern sp., one staghorn sculpin) had consumed juvenile salmon.
The authors also state:
Our analysis of fish diets at the Mukilteo ferry terminal provides one piece of
conclusive evidence that juvenile salmon were not a major dietary component of
predatory fish species during our study.
Biological Assessment & No Net Loss Mitigation Planting Plan MS&A | 27
This study would seem to contradict the assertion that overwater structures cause
increased salmonid predation by other fish species.
Beach access component of project: Because this component of the project is located
above the OHWM, no increases in predation are expected.
Mooring buoy component of project: The mooring buoy is not an overwater structure, so
its installation should have no direct effect on predation. However, when a boat is tied to
the mooring buoy, additional shading could cause indirect effects on salmonids and other
sea life. Shading caused by overwater structures can reduce or eliminate eelgrass,
macroalgae, and epibenthic organisms resulting in reduced prey and refugia resources for
salmonids. However, the mooring location was chosen to avoid impacts to submerged
aquatic vegetation that was found without putting the float too far offshore to avoid
navigational issues to passing boat traffic. Limited eelgrass was found in the area, and the
proposed mooring buoy location is at least 25 feet away from any existing eelgrass beds.
The mooring buoy will be placed 140 feet from the shoreline at a depth of approximately
-14 ft MLLW and will not impede nearshore fish migration.
Tree removal component of project: Because this component of the project is located
above the OHWM, no increases in predation are expected.
3.2.3 Scouring
Wave regime and local geology are the primary drivers of modern beach geomorphology.
In the action area, a drift cell is going from left to right (west to east), in an area
considered to have a stable slope (WECY 2015).
Beach access component of project: A structure like the proposed staircase can potentially
act like a groin. Groins change coastal dynamics and sediment transport by blocking
movement of sediment, which leads to sediment accumulation on the updrift side, and
erosion on the downdrift from lack of new sediment addition (Guimanes et al. 2016).
Physical changes in beach structure, specifically beach narrowing and lowering, are also
linked to biological effects. Most directly, forage fish spawning habitat in the upper
intertidal zone may be degraded in both extent and quality (Pentilla 2007). However, due
to the fact that this structure will be located above the OHWM on a stable bedrock slope,
it is not expected to have significant effects on beach sediment transport.
Mooring buoy component of project: Does not apply.
Tree removal component of project: Does not apply.
Biological Assessment & No Net Loss Mitigation Planting Plan MS&A | 28
3.2.4 Boating Impacts
Beach access component of project: Does not apply.
Mooring buoy component of project:
Boating activity can cause damage to the aquatic habitat due to prop scour and increased
turbidity. In several studies, aquatic vegetation and benthic organisms were found to be
absent or greatly reduced in areas where boat traffic was high and the propellers were
within one foot of the bottom (Chmura and Ross 1978). Lagler et al (1950) found that
propellers within approximately 14-inches of the bottom removed all plants and silt
within a swath approximately 5-ft wide. Conversely, boat use over deeper water can
actually stimulate aquatic plant growth by increasing the dissolved carbon dioxide and
increasing water circulation (Warrington 1999).
WA Department of Natural Resources (DNR) recommends -7 ft Extreme Low Tide (ELT)
as the minimum depth to avoid impacts from prop scour; this translates to approximately
-10 ft MLLW. The proposed mooring buoy location is deeper than this recommendation,
and it is assumed that most boating activity adjacent to the float will be at slow speeds.
Tree removal component of project: Does not apply.
3.3 Cumulative Effects
Cumulative effects, which take into account this project as well as future development in the
area, are reasonably certain to occur in the action area. The project area includes many shoreline
properties within 0.5 miles to the north and south. These cumulative habitat alterations could
impact ESA listed species and/or their Critical Habitat areas, as well as human water-dependent
recreational activities such as fishing and swimming. These potential adverse cumulative effects
could be caused by physical obstructions from development, changes in stormwater flow on the
landscape, changes in turbidity and pollution levels, and other such factors. The full scope of
cumulative impacts cannot be quantified in this assessment, but with appropriate regulations in
place, it is unlikely that ESA listed species, Critical Habitat area, or human recreation will be
greatly affected by the addition of the mooring buoy, and beach access staircase. In addition, it is
the opinion of MS&A that the mitigation planting plan will create No Net Loss of ecological
function at the site, and in some cases may improve the understory habitat by introducing more
diverse native plant species.
3.4 Interrelated/Interdependent Effects
Completion of this project is not anticipated to promote future construction or other activities
that would not otherwise occur without its completion. Therefore, no additional interrelated or
interdependent actions that could affect sensitive species are anticipated to occur because of this
project.
Biological Assessment & No Net Loss Mitigation Planting Plan MS&A | 29
4. Conservation Measures to Avoid/Minimize Impacts
Standard Best Management Practices (BMPs) should be followed during the installation of the
mooring buoy and beach access staircase, as well as during any tree trimming/removal.
Suggested BMPs are outlined blow.
BMPs specific to beach access component of project:
• Lowering of staircase materials from upland area to avoid impacts to bluff/slope and
beach.
• No native vegetation removal beyond the actual footprint of the staircase (which will be
mitigated for).
BMPs specific to mooring buoy component of project:
• A helix screw anchor will be used for smallest possible footprint on benthic substrate.
BMPs specific to tree removal component of project:
• Trees should be trimmed or removed during fall/winter months to avoid impacts to
nesting birds.
• Green wood should be removed from the project site and disposed of in an approved
upland facility (such as the County yard waste composting facility) immediately
following removal of trees to prevent the spread of pest species.
General Best Management Practices for Small Construction Sites:
• Whenever possible, use hand-tools during construction.
• Whenever possible, work should be performed from upland area to avoid impacts to
bluff/beach.
• Marking CRZ of trees with paint, flagging, or other and limit soil disturbance and
compaction by avoiding running equipment and stockpiling materials in CRZ.
Additionally, it is recommended that any necessary heavy equipment and/or truck access
should entail a layer of mulch, or sufficiently wide and thick steel plates in the vehicle
wheel path to avoid rutting and damaging the vegetation.
• Construction should not be conducted during heavy precipitation events, regardless of the
protection of vegetation. If vegetation is damaged, or rutting occurs, it is recommended
that those areas be re-planted with native vegetation and a layer of mulch at a minimum
depth of 3 inches.
• Limit the extent of clearing operations and phase construction operations.
• All work should be performed during approved work windows, when applicable, and/or
following any permitting agency seasonal restrictions.
• The duff layer, native topsoil, and natural vegetation should be retained in an undisturbed
state to the maximum extent practicable. The single most effective means of limiting
Biological Assessment & No Net Loss Mitigation Planting Plan MS&A | 30
stormwater impacts during and after construction and minimizing costs of implementing
BMPs is to retain existing soil and vegetation to the maximum practical extent.
• Daily check list of potential safety areas.
• All oil containing equipment will be staged in secondary containment capable of handling
3x the volume of oil contained in said equipment.
• Stacking soils adjacent to areas of excavation to facilitate replacement.
• Utilizing ball valves on all concrete and grout ports to ensure no grout enters the water
column.
• Daily housekeeping to ensure debris does not enter the water/area adjacent to the work
site.
• Prevent pollutant release. Select source control BMPs as a first line of defense. Prevent
erosion rather than treat turbid runoff.
• Divert runoff away from exposed areas wherever possible. Keep clean water clean.
• Reduce runoff velocities to prevent channel erosion.
• Schedule installation of BMPs. Some temporary BMPs should be installed before
earthmoving activities begin.
• Schedule regular inspections of the site and the stormwater BMPs throughout the
construction process. Repair or replace BMPs as needed. Maintain the BMPs as
necessary. Without proper maintenance, all BMPs will fail.
• Before reseeding a disturbed soil area, amend all soils with compost wherever topsoil has
been removed.
• Minimize slope length and steepness.
• Prevent the tracking of sediment off-site.
• Be realistic about the limitations of controls that you specify and the operation and
maintenance of those controls. Anticipate what can go wrong, how you can prevent it
from happening, and what will need to be done to fix it.
• Make sure that bids and estimates include costs of purchase of materials and manpower
for installation, maintenance, and removal of BMPs.
• Be sure that it is understood which party is responsible for BMPs.
• Schedule removal of the temporary BMPs (or retrofit them for permanent use) at the end
of the construction project.
To mitigate for potential impacts on the environment caused by any components of the projects
described in this report, a native planting plan has been created (see Mitigation Plan, Section 6,
below).
5. Take Analysis
The Endangered Species Act defines “take” as to “harass, harm, pursue, hunt, shoot, wound,
trap, capture, collect or attempt to engage in any such conduct.” The USFWS further defines
“harm” as “significant habitat modification or degradation that results in death or injury to
Biological Assessment & No Net Loss Mitigation Planting Plan MS&A | 31
listed species by significantly impairing behavioral patterns such as breeding, feeding, or
sheltering.” It is likely that no “take” will result from this project.
5.1 Determination of Effect
After reviewing the appropriate data, the determination of effect to each listed species and
designated Critical Habitat within the action area is:
• Puget Sound Chinook - "May effect, not likely to adversely affect"
• Rockfish - "May effect, not likely to adversely affect"
• Bull Trout - "No effect "
• Hood Canal Summer-run Chum – "May effect, not likely to adversely affect"
• Steelhead – “No effect”
• Marbled Murrelet – "May effect, not likely to adversely affect"
• Green Sturgeon - "No effect "
• Southern Eulachon – “No effect”
• Humpback whale – “No effect”
• Leatherback sea turtle – “No effect”
• Southern Resident Killer Whale – “May effect, not likely to adversely affect”
6. Mitigation Plan for No Net Loss of Ecological Function
6.1 Proposed Mitigation
This mitigation plan aims to minimize any potential resource impacts for the proposed project by
enhancing ecological value and function of the existing site, particularly along the Marine
Critical Area buffer. This will be done by planting 1,686 square foot area of newly installed
native plants in the clearing located just upland from the shoreline, along where the treeline ends
and the clearing begins. These newly installed native plants will help to reduce runoff and
erosion, improve nutrient input, and create additional wildlife habitat along the Marine Critical
Area buffer.
It is recommended that this 1,686 square foot area be planted to comply with the 1:1 mitigation
required for new disturbance area within a Critical Area buffer, as per Jefferson County Critical
Areas Ordinance Section 18.22.660(3)[a] Mitigation. The square footage was calculated to
mitigate for the following aspects of the project:
1. New stairs to beach: the total square footage of new project footprint for the proposed
beach access staircase is 84 square feet (Figure 3). Thus, to achieve the necessary 1:1
mitigation ratio, 84 square feet of new planting area must be installed.
2. Mooring buoy installation: It is the opinion of MS&A that no major loss of ecological
function will result with the installation of the mooring buoy, and that no mitigation is
needed for the at this time.
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3. Native tree removal and vegetation trimming: For the proposed removal of 1 mature
Douglas Fir (P. menziesii) tree, 22 Douglas Fir saplings, 1 Western Red Cedar (T.
plicata), approximately 30 Red Alder (A. rubra) saplings, 10-20 shrub-sized Douglas Fir
trees (1-2 ft in height), and 1 Vine Maple (A. circinatum) previously removed by
accident, a total of 1,602 square feet of new planting area must be installed. This was
calculated by using standard “on-center” (O.C.) dimensions for native plants (described
further in Section 6.6 and below).
• 10-foot O.C. was used for the 23 mature and sapling Douglas Fir trees proposed
for removal, which is equal to 31.42 sf per tree. 23 trees X 31.42 sf = 723 sf of
new plants needed for mitigation.
• 10-foot O.C. was also used for the single Western Red Cedar tree proposed for
removal, as well as the single Vine Maple previously removed. 2 trees x 31.42 sf
= 63 sf of new plants needed for mitigation.
• 6-foot O.C. was used for the approximately 30 Red Alder saplings proposed for
removal, which is equal to 18.8 sf per tree. 30 trees X 18.8 = 564 sf of new plants
needed for mitigation.
• 4-foot O.C. was used for the 10-20 shrub sized Douglas Fir trees proposed for
trimming and/or removal, which is equal to 12.6 sf per tree. 20 X 12.6 = 252 sf of
new plants needed for mitigation.
o Total = 1,602 square feet of new plants needed to mitigate for all potential
vegetation removal.
6.2 Mitigation Goals
Goal (1) Buffer Enhancement: Create a newly vegetated area of approximately 1,686 square
feet O.C. mature plant coverage of diverse native plant species. This will enhance the ecological
value and function of the habitat within the critical area buffer by reducing erosion, improved
nutrient input, and creating wildlife habitat.
Goal (2) Emergent Cover: 60% by year one, 80% by year three, 90% by year five.
Goal (3) Survival: 100% by year one, 85% survival by year three.
Goal (4) Soil: For newly planted plants, deconsolidate and amend soil where holes are dug
before plants are installed and add a minimum of 3” mulch.
6.3 Mitigation Performance Standards
Performance standards are measurable criteria for determining if the goals and objectives of the
mitigation project are being achieved. If the proposed benchmarks are not achieved by
comparing the surveys to the mitigation goals, then contingency plans will need to be
implemented, which are outlined in section 7.5 below.
Biological Assessment & No Net Loss Mitigation Planting Plan MS&A | 33
Performance Standard (1) Buffer Enhancement: Native plants will be installed in year one.
Photographs will be taken during monitoring years. A comparison of photographs from previous
years along with the percent cover and survivorship standards outlined below will help in
assessing the quality of the buffer. The planting area is clearly outlined in this report, and
described in Goal (1) and Table 2.
Photo stations for the planting site will be determined, and a photograph of the restoration
location will be taken on an annual basis. To meet survival performance standards, individual
plants that die must be replaced with the same species unless a different species is suggested by
the project biologist due to site conditions.
Performance Standard (2) Emergent Cover:
The percent cover standard will be monitored by using the Point Intercept Method of surveying
the planting plots. One or more transect lines will be established by stretching a measuring tape
between two points. The location of the transect will be staked and flagged at each end so that the
same transect can be surveyed each monitoring year. A data form will be used to collect
information at a minimum of five-foot intervals, stopping along the tape to record what is located
directly beneath it at each interval point. If no plants are present, bare ground will be noted. Once
data is recorded, the following formula will be used to calculate the percent of bare ground:
(Number of points with bare ground divided by total number of points evaluated) X 100 =
percent of bare ground
Performance Standard (3) Survival:
Immediately after planting, all plants will be counted and documented. At the end of each
growing season (late Aug- early Sept) plots will be visited and a count of surviving plants will be
documented. The percent survival for the plots will be calculated by dividing the total number of
plants after planting by the total number of surviving plants at the end of the season.
Performance Standard (4) Soil: A minimum of 20% organic matter by bulk density in the soil
will be verified by invoices.
6.4 Site Preparation
Topsoil around and beneath newly installed native plants will be comprised of a minimum of
20% organic matter. MS&A recommends that the amended soil consist of 6" of coarse sand and
6" of vegetative compost which should be worked into the soil before planting. After plant
installation, a layer of mulch at least 3” thick will be placed as a groundcover around the plants.
6.5 Plant Procurement
Plants will be selected from a regional native plant nursery. Invoices will be provided after
purchase. See Attachment 1 for a list of local native plant nurseries and resources. Substitutions
may be necessary for species or individuals outlined in this planting plan which cannot be found
at local nurseries. All plant substitutions will be approved by the project biologist prior to
installation to ensure their suitability for the site.
Biological Assessment & No Net Loss Mitigation Planting Plan MS&A | 34
6.6 On Center Dimensions and Area Coverage
The total square footage of native plant coverage was calculated using “on center” dimensions
(i.e. the distance between the center of one plant to the center of the next plant, when mature).
The average on center (O.C.) dimensions of each plant species was sourced from Sound Native
Plant’s “Calculating Plant Quantities” guidelines, and a conservative estimate of coverage was
calculated using a typical plant quantity/coverage calculator.
6.7 Planting Instructions
Whenever possible, planting should be done between mid-October and mid-December as plants
grow roots during the cool weather, even when the tops of the plants are dormant. Planting
between mid-December and mid-April is also acceptable but more attention to supplemental
watering may be required due to drier seasonal weather conditions. Any nursery instructions that
come with the plants should be read and followed.
Plants should be laid out by hand generally following the spacing specified on the planting plan
map (Figure 11). Before planting, set the potted plants out on the landscape according to the
planting plan design and make sure the arrangement works before digging any holes. Next, dig a
bowl-shaped hole for each plant at least twice the width, and slightly deeper, than the potted
plant’s container. Roughen the sides and the bottom of the hole with a pick or shovel. If the soil
is especially dry, fill the hole with water and let it soak in before continuing.
Remove the plant from its container gently without pulling on the stem of the plant. Loosen
bound roots on the outer inch of soil and cut any roots that encircle the root ball to ensure that the
plant will not continue to grow within its “memory” of the pot wall confines. Set the plant in the
hole so that the top of the soil remains level with the surrounding soil. Fill the surrounding space
with loose topsoil comprised of at least 20% organic matter. Native top-soils are preferred,
whenever possible. Cover any exposed roots but do not pile dirt onto the stem or root collar, as
this can kill some plants. To discourage root rot, gently tamp down the filled soil to remove any
air pockets that may exist below ground, while allowing the soil to remain somewhat loose.
Form a temporary basin or trench around each plant to encourage water collection, and then
water thoroughly.
Immediately after watering, mulch such as wood chips, leaves, or brown carbon rich compost
should be added to a 3-inch thickness over the entire planting area without covering the stems of
the plants. The mulch will aid in slope stability, moisture and nutrient retention, and weed
control. Heavy duty woodchips are preferable in areas where noxious or invasive species may
become a problem. Staking of trees or shrubs should not be necessary unless high winds exist or
the tree is tall and has little roots. If staking is deemed necessary, use a thick rope or padding
around the trunk of the tree to prevent damage to the bark, and use the minimum amount of
tension necessary to achieve balance.
Figure 10. Planting Instructions
(sourced from City of Seattle Department of Planning and Development Environmentally Critical
Areas Standard Mitigation Plan)
Biological Assessment & No Net Loss Mitigation Planting Plan MS&A | 35
6.8 Inspection and Maintenance Criteria
Maintenance must be done twice yearly. No herbicides or pesticides are to be used, and all work
should be performed by hand whenever possible, with the lightest possible equipment where
such use is necessary.
During year one, every failed plant must be replaced within the plot. During year one, and during
the first year after any replacement planting, plantings must receive 1 inch of water at least once
weekly between June 15 and September 15. Trees and shrubs must be weeded to the dripline, and
mulch must be maintained at a depth of 3 inches. Weed herbaceous plantings as necessary
(flowers, ferns, etc.). All litter and non-native vegetation must be removed, such as Himalayan
blackberry (Rubus armeniacus), reed canary grass (Phalaris arundinacea), evergreen blackberry
(Rubus laciniatus), Scots broom (Cytisus scoparius), English ivy (Hedera helix), morning glory
(Convolvulus arvensis), Japanese knotweed (Reynoutria japonica), etc., and properly disposed of
off-site. Any receipts obtained from work done on the site should be filed with the Department of
Permitting through the project biologist monitoring report.
6.9 Planting Plan
To cover a minimum of 1,686 square feet, it has been determined that 20 small trees (6 ft O.C.)
and 61 shrubs (4 ft. O.C.) will be required for this planting plan. Instead of replacing the trees
proposed for removal “tree for tree,” the equivalent square footage of small trees and shrubs
were chosen to increase understory habitat diversity, help the overall health of the remaining
Biological Assessment & No Net Loss Mitigation Planting Plan MS&A | 36
trees by not planting competing trees nearby, and to keep the waterfront view visible. Following
is a table showing the plant species, numbers, and O.C. dimensions for the planting areas. Plants
will be selected from a regional native plant nursery. The species in the table below were chosen
to create bird and insect habitat, while taking into account hardiness, ecology, and aesthetics. Site
photos of the planting areas can be seen in Attachment A.
Table 2. Plant List
Quantity Scientific Name Common Name Spacing
3 Sambucus racemosa Red Elderberry Spacing: 6’ O.C.
1 Crataegus douglasii Black Hawthorne Spacing: 6’ O.C.
4 Oemleria cerasiformis Indian Plum Spacing: 6’ O.C.
1 Acer circinatum Vine Maple Spacing: 6’ O.C.
2 Corylus cornuta Beaked Hazelnut Spacing: 6’ O.C.
2 Prunus emarginata Bitter Cherry Spacing: 6’ O.C.
7 Cornus stolonifera Red Osier Dogwood Spacing: 6’ O.C.
8 Ribes sanguineum Red Flowering Currant Spacing: 4’ O.C.
7 Holodiscus discolor Oceanspray Spacing: 4’ O.C.
6 Vaccinium ovatum Evergreen Huckleberry Spacing: 4’ O.C.
5 Vaccinium parvifolium Red Huckleberry Spacing: 4’ O.C.
8 Rosa nutkana Nootka Rose Spacing: 4’ O.C.
2 Rhododendron macrophyllum Pacific Rhododendron Spacing: 4’ O.C.
7 Symphoricarpos albus Snowberry Spacing: 4’ O.C.
4 Mahonia aquifolium Tall Oregon Grape Spacing: 4’ O.C.
14 Blechnum spicant Deer Fern Spacing: 4’ O.C.
Biological Assessment & No Net Loss Mitigation Planting Plan MS&A | 37
Figure 11 . Planting Plan Design Map
Biological Assessment & No Net Loss Mitigation Planting Plan MS&A | 38
7. Monitoring & Maintenance
7.1 As-Built Report
An as-built drawing and report will be submitted as documentation of the implementation of the
approved planting plan within one month of installation. The plan will include a
quantitative final list of species, vegetation descriptions, and photo documentation from
established photo stations. A panoramic photo of the entire mitigation site will also be provided.
Photos should be taken between June and August, during the growing season.
7.2 Monitoring Schedule
Monitoring will take place over a period of five years at the end of the growing season (late
August or early September) of each monitoring year. The performance standards will be
monitored by measuring plots within the planting area, which will be established and mapped
after the planting occurs. Collected data and photos will be compiled into an annual Riparian
Planting Report, which will be submitted by October 31 each monitoring year for five years.
7.3 Monitoring Methods
Each annual monitoring report shall include written and photographic documentation on plant
mortality and any replanting efforts. There will be specific locations where photos will be taken
from for each plot, and these photo points will be referenced on the as-built plan. The site will
have at least four photo points per project, or ¼ acre (whichever is greater). Each year, photos
will be taken at the established photo points for each site, and these successive photos will be
used for comparison over the 5 years. Photos will be taken at all established photo points for all
monitoring years to provide visual documentation of the performance standards progress, or lack
thereof. In addition to photos at designated locations, photo documentation must include a
panoramic view of the entire planting area. Submitted photos must be formatted on standard 8
1/2" by 11" paper, and must include the date the photo was taken, as well as the direction from
which the photo was taken. The established photo location points must be identified on a site
drawing.
Percent cover will be measured using the point intercept method as described above in the
Performance Standards, section 6.3. There will be at least one transect per plant community, and
transect locations will be shown on the site plan. Up to 20% of any stratum can be composed of
desirable native volunteers when measuring cover. No more than 10% cover of non-native or
other invasives, e.g., Himalayan Blackberry, Japanese Knotweed, Evergreen Blackberry, Reed
Canary Grass, Scots Broom, English Ivy, Morning Glory, etc. is permissible in any monitoring
year. Bond holders are encouraged to maintain mitigation sites within these standards throughout
the monitoring period, to avoid corrective measures. Measurement criteria will follow the goals
outlined in section 6.2.
A qualitative review of the condition of the site’s hydrology (e.g. erosion, slope stability, etc.),
soil health, buffer condition, and wildlife use will be included in the monitoring report. The
Monitoring Report will also document whether the performance standards are being met.
The results of the Monitoring Report will determine whether or not contingency measures will be
needed. If deficiencies are found, they will be corrected within 60 days. Monitoring may be
extended if mitigation goals have not been met. Receipts for any maintenance activities such as
Biological Assessment & No Net Loss Mitigation Planting Plan MS&A | 39
re-planting, dump runs for weed removal, structural replacement, etc. will be provided to the
project biologist to include in the monitoring report. The applicants will be responsible for the
maintenance of their site, and will hire a biologist of their choosing to conduct the as-built and
monitoring surveys and to prepare the required reports to document the progress. Contact
information MS&A can be found in the title page of this report, and the applicant information is
located in section 1.2.
7.4 Maintenance
Maintenance shall occur at least twice during the growing season to ensure the survival of all
native species within the mitigation area, including volunteer natives. Watering by hand or
sprinkler may be necessary during year number one until the plants are established (see section
7.5). Water requirements will depend on the timing of planting with the seasons and weather
conditions. Once plants are established, extra watering may not be necessary. Hand weeding may
be necessary around all plants that are being monitored for survival and coverage.
If the required survival rate is not met by the end of any monitoring year, plants lost to mortality
will be replaced to achieve the percentage cover performance standard described above. Prior to
replacement, observations will be made on plants that did not survive in order to attempt to
determine whether their survival was affected by species/site selection, damage caused by
wildlife, or other factors. Subsequent contingency actions must be designed to respond directly
to any stressor(s) that are determined to have increased the mortality of planted native species
(Section 7.5).
Monitoring on an annual basis for five years will occur with photographs to determine the
survival rate of the transplanted area. If 100% success is achieved before reaching the five-year
mark, monitoring will continue without extra replanting efforts.
7.5 Contingency
Contingency actions must be designed to respond directly to any stressor(s) that are determined
to have increased the mortality of planted native species. If it is found that a particular plant
species is not surviving well at the site, a more appropriate species will be selected for its
replacement. If excessive damage by wildlife, exposure, or other elements is observed, protective
measures may need to be introduced. Monitoring years may be added if significant re-planting
becomes necessary. Monitoring on an annual basis for five years will occur with photographs
and measurements outlined in section 7.3 to determine the survival rate of the transplanted area.
8. Conclusion
While the proposed project may result in some short-term negative impacts to the habitat, it is
the opinion of MS&A that the overall outcome is unlikely to cause long-term adverse impacts to
ecological function of the nearshore marine environment. Short-term impacts are likely
temporary and minor. We believe that the native planting plan (Section 6) should be sufficient to
mitigate any potential adverse effects from the project.
Biological Assessment & No Net Loss Mitigation Planting Plan MS&A | 40
Final jurisdictional authority and permitting on this project will be the responsibility of the
appropriate local, state, and/or federal government agencies involved. All information contained
in this report should be reviewed by the appropriate regulatory agencies prior to approval or
issuance of permits.
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www.nalms.org/bclss/impactsrecreationboat.htm
Washington Department of Fish and Wildlife (WDFW). 1993. Status of the Marbled Murrelet
Brachyramphus marmoratus in Washington. Unpubl. Rep. Wash. Dept. Wildl., Olympia, WA.
Washington Department of Fish and Wildlife (WDFW). 1994. 1992 Washington State Salmon
and Steelhead Stock Inventory, Appendix One, Puget Sound Stocks, Hood Canal and Strait of
Juan de Fuca Volume, Olympia
Washington Department of Fish and Wildlife (WDFW). 2018. Priority Habitats and Species
report. Available at: http://wdfw.wa.gov/mapping/phs/. Olympia, Washington. Accessed:
August 15, 2020.
Washington Department of Fish and Wildlife (WDFW). 2018. Salmonid Stock Inventory (SaSI).
Available at: https://wdfw.wa.gov/conservation/fisheries/sasi/ Accessed: August 15, 2020.
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(PNPTC). February 10, 2005. Memorandum report: 2004 Progress report on Hood Canal
summer Chum salmon. 15 p.
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Washington State Salmon and Steelhead Stock Inventory, Appendix One Puget Sound Stocks,
South Puget Sound Volume. Washington Department of Fish and Wildlife. Olympia, WA.
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I. Cullinan, R. Moursund, and M. Stamey. Assessing Overwater Structure - Related Predation
Risk on Juvenile Salmon: Field Observations and Recommended Protocols. September 2003.
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Attachment A. Site Photos MS&A | 1
Attachment A. Site Photos
The following photos begin at top of property and work their way towards the
water, ending with photos of the mooring buoy area.
Attachment A. Site Photos MS&A | 2
Upland habitat – driveway coming into property (outside of shoreline Critical Area buffer)
End of driveway, beginning of clearing on other side of tree island (photo facing water)
Attachment A. Site Photos MS&A | 3
Vine Maple tree on the Massmann/Hietter parcel which was accidently cut down when Cypress
trees were removed on the neighboring parcel.
Attachment A. Site Photos MS&A | 4
Proposed mitigation planting plan area (plot # 1) at bottom of clearing, near tree-line and within
Shoreline Critical Area buffer
Attachment A. Site Photos MS&A | 5
1 x Western Red Cedar tree (~12 inch DBH) to be removed (pen pointing at tree)
9 x Douglas Fir saplings (~10-15 ft tall) to be removed (pen pointing at group of trees)
Attachment A. Site Photos MS&A | 6
2 x Douglas Fir trees (one ~20’ tall with another smaller sapling interwoven). To be removed
(pen pointing at trees)
2 x Douglas Fir tree saplings (one ~8 ft tall and one ~15’ tall) to be removed (pen pointing at
trees)
Attachment A. Site Photos MS&A | 7
6 x Douglas Fir tree saplings (~5 to 25’ tall) clumped together, to be removed (pen pointing at
grove of trees, with some flagging visible)
3 x Douglas Fir saplings (~15 to 25 ft tall) to be removed (pen pointing at trees)
Attachment A. Site Photos MS&A | 8
Alder grove (approximately 30 trunks in tight formation) to be removed (pen pointing at group).
This area proposed as planting plan plot # 2.
Top of trail which leads from clearing through woods down slope to proposed beach access stairs
Attachment A. Site Photos MS&A | 9
View of pathway down slope to proposed staircase location, where some minor trimming of
vegetation may occur
Proposed beach access staircase location
Attachment A. Site Photos MS&A | 10
Ordinary High Water Mark below proposed staircase location (marked with bright yellow paint)
Attachment A. Site Photos MS&A | 11
OHWM survey along entire shoreline, marked bright yellow paint
Attachment A. Site Photos MS&A | 12
Attachment A. Site Photos MS&A | 13
Typical Substrate at site (photo taken during September 16th SCUBA habitat survey)
Attachment A. Site Photos MS&A | 14
Eelgrass (Zostera marina) bed (photo taken during September 16th SCUBA habitat survey)
Macroalgae observed in habitat survey area of September 16th 2020 SCUBA survey
Attachment B.
September 16th 2020 Habitat Survey Data
Massmann Habitat Report Page | 5
Table 1. Habitat Survey Results
Transect BL (Bearing 290 d True North)
Distance (Ft)
along
transect
from
OHWM
Elevation
(Corrected to
Ft MLLW)
Substrate Macroalgae % Cover &
SAV presence/density
0 9.8 Bedrock Barren.
24 2.8 Pebble, cobble, sand
Ulva 20%; Fucus 20%;
Mastocarpus 20%.
56 -1.2 Pebble, cobble, sand Ulva 60%; Gracilaria 40%.
78 -3.2 Pebble, cobble, sand Barren.
116 -7.2 Pebble, cobble, sand Sarcodiotheca 60%.
130 -11.2 Pebble, cobble, sand Ulva 20%; Sarcodiotheca 80%.
140 -14.2 Pebble, cobble, sand Ulva 40%; Sarcodiotheca 40%.
Transect MB-9 (Bearing 200 d True North)
Distance (Ft)
along
transect
from
buoy center
Elevation
(Corrected to
Ft MLLW)
Substrate Macroalgae % Cover &
SAV presence/density
0 -14.2 Sand, cobble, pebble Ulva 40%; Sarcodiotheca 40%.
11 -12.2 Sand, cobble, pebble Ulva 40%; Sarcodiotheca 40%.
18 -10.2 Sand, cobble, pebble Ulva 40%; Sarcodiotheca 40%.
27 -10.2 Sand, cobble, pebble Ulva 40%; Sarcodiotheca 40%.
47 -9.2 Sand, cobble, pebble
Ulva 10%.
Z. marina bed boundary.
67 -8.2 Sand, cobble, pebble
Ulva 10%. Z. marina bed (avg 4.7
shoots per 0.25 m2).
87 -7.2 Sand, cobble, pebble
Ulva 10%. Z. marina bed (avg 3.0
shoots per 0.25 m2).
100 -7.2 Sand, cobble, pebble
Ulva 10%. Z. marina bed
continues beyond transect.
Transect MB-12 (Bearing 290 d True North)
Distance (Ft)
along
transect
from
buoy center
Elevation
(Corrected to
Ft MLLW)
Substrate Macroalgae % Cover &
SAV presence/density
0 -14.2 Sand, cobble, pebble Ulva 40%; Sarcodiotheca 40%.
10 -16.2 Sand, cobble, pebble Ulva 20%; Sarcodiotheca 20%.
Massmann Habitat Report Page | 6
16 -18.2 Sand, cobble, pebble Ulva 5%; Sarcodiotheca 20%.
23 -20.2 Sand, cobble, pebble Ulva 5%; Sarcodiotheca 5%.
30 -22.2 Sand, cobble, pebble Ulva 2%; Sarcodiotheca 2%.
43 -24.2 Sand, cobble, pebble Sarcodiotheca 2%.
67 -30.1 Sand, cobble, pebble Sarcodiotheca 2%.
78 -31.1 Sand, cobble, pebble Barren.
90 -34.1 Sand, cobble, pebble Barren.
100 -35.1 Sand, cobble, pebble Barren.
140 -37.1 Sand, cobble, pebble Barren.
Transect MB-3 (Bearing 20 d True North)
Distance (Ft)
along
transect
from
buoy center
Elevation
(Corrected to
Ft MLLW)
Substrate Macroalgae % Cover &
SAV presence/density
0 -14.1 Sand, cobble, pebble Ulva 40%; Sarcodiotheca 40%.
8 -14.1 Sand, cobble, pebble Ulva 40%; Sarcodiotheca 40%.
20 -14.1 Sand, cobble, pebble Ulva 40%; Sarcodiotheca 40%.
30 -15.1 Sand, cobble, pebble Ulva 40%; Sarcodiotheca 40%.
40 -15.1 Sand, cobble, pebble
Ulva 40%; Sarcodiotheca 40%.
Saccharina 2 blades (6% cover);
50 -16.1 Sand, cobble, pebble Ulva 40%; Sarcodiotheca 40%.
60 -16.1 Sand, cobble, pebble Ulva 40%; Sarcodiotheca 40%.
70 -16.1 Sand, cobble, pebble Ulva 40%; Sarcodiotheca 40%.
80 -17.1 Sand, cobble, pebble Ulva 40%; Sarcodiotheca 40%.
100 -17.1 Sand, cobble, pebble Ulva 40%; Sarcodiotheca 40%.
Transect MB-6 (Bearing 110 d True North)
Distance (Ft)
along
transect
from
buoy center
Elevation
(Corrected to
Ft MLLW)
Substrate Macroalgae % Cover &
SAV presence/density
0 -14.1 Sand, cobble, pebble Ulva 40%; Sarcodiotheca 40%.
10 -11.1 Sand, cobble, pebble Ulva 20%; Sarcodiotheca 80%.
20 -9.1 Sand, cobble, pebble Sarcodiotheca 60%.
30 -6.1 Sand, cobble, pebble
Ulva 20%; Sarcodiotheca 10%.
Z. marina bed boundary.
39 -5 Sand, cobble, pebble
Ulva 20%. Z. marina bed (avg 3.3
shoots per 0.25 m2).
40 -5 Sand, cobble, pebble Z. marina bed.
50 -4 Sand, cobble, pebble Ulva 20%. Z. marina bed.
Massmann Habitat Report Page | 7
59 -3 Sand, cobble, pebble
Ulva 20%. Z. marina bed (avg 4.7
shoots per 0.25 m2).
63 -3 Sand, cobble, pebble
Ulva 50%; Gracilaria 50%. Z.
marina bed boundary.
74 -2 Sand, cobble, pebble Ulva 40%; Gracilaria 40%.
86 -1 Cobble Ulva 40%; Gracilaria 40%.
90 0 Cobble Ulva 80%.
105 1 Cobble Ulva 10%.
Attachment C.
Native Plant Sources for the Pacific NW
Native Plant Sources for the Pacific Northwest
This list contains those nurseries known to Permitting staff that grow plants native to the Puget lowlands of
Western Washington in quantities suitable for most mitigation sites. It was extracted from a longer list
compiled by the Water and Land Resources Division (WLRD) of King County for your convenience, drawing
in part on the Hortus West native plant directory and journal: Hortus West, P.O. Box 2870, Wilsonville, OR
97070. 800-704-7927. Fax: 503-570-0855. E-mail: editor@hortuswest.com. It is not an endorsement of these
businesses. The full list is available from WLRD at 206-296-6519.
Nurseries that specialize in seeds are marked (SEEDS).
Abundant Life Seed Foundation (SEEDS) Davenport Seed Corporation (SEEDS)
P.O. Box 772 P.O. Box 187
Port Townsend, WA 98368 Davenport, WA 99122-0187
360-385-5660 800-828-8873
Barford's Hardy Ferns Emmery's Gardens
23622 Bothell Way 2829 - 164th Avenue SW
Bothell, WA 98248 Lynnwood, WA 98037
Phone: 425-438-0205 Phone: 425-743-4555
Fax: 206-483-0205 Fax: 425-743-0609
Botanica Firetrail Nursery
P.O. Box 19544 3107 - 140th Street NW
Seattle, WA 98109 Marysville, WA 98271
206-634-1370 360-652-9021
Clark's Native Trees and Shrubs Frosty Hollow Ecological Restoration (SEED)
1215 - 126th Avenue SE P.O. Box 53
Everett, WA 98208 Langley, WA 98260
206-337-3976 360-579-2332
Cold Creek Nursery Heathwood Cottage Nursery
18602 NE 165th Street 18540 - 26th Avenue NE
Woodinville, WA 98072 Lake Forest Park, WA 98072
425-788-0201 206-363-3189
Colvos Creek Farm IFA Nurseries, Inc.
P.O. Box 1512 463 Eadon Road
Vashon, WA 98070 Toledo, WA 98591
206-441-1509 425-864-2803
Inside Passage (SEEDS) Sound Native Plants
P.O. Box 639 P.O. Box 10155
Port Townsend, WA 98368 Olympia, WA 98502
206-781-3575 Phone: 360-352-4122
Fax: 360-943-7026
Sourced from the King County Critical Areas Restoration and Enhancement document, Appendix A 2020
J & J Landscape Co. Storm Lake Growers
19538 - 75th NE 21809 - 89th SE
Bothell, WA 98011 Snohomish, WA 98290
360-794-4842
Judd Creek Wetland and Native Plant Nursery Sweet Briar
20929 - 111th Avenue SE P.O. Box 25
Vashon, WA 98070 Woodinville, WA 98072
206-463-2812 425-821-2222
MSK Nursery Thorsett Landscaping Nursery
20066 - 15th Avenue NW 13503 Southeast 226th Place
Seattle, WA 98177 Kent, WA 98042
206-546-1281 253-361-5838
Northfork Nursery Wabash Farms Native Plants
15751 Polson Road Ornamental and Reclamation
Mt. Vernon, WA 98273-7142 19390 SE 400th
360-445-4741 Enumclaw, WA 98022
Phone: 360-825-7051
Fax: 360-825-1949
Pacific Natives & Ornamentals Weyerhauser-Western Revegetation Greenhouse
P.O. Box 23 33405 - 8th Avenue South
Bothell, WA 98041 Federal Way, WA 98003
Phone: 425-483-8108 800-732-4769
Fax: 425-487-6198
Revegetate & Resource Plants Woodbrook Native Plant Nursery
17836 Cedar Grove Road 5919 78th Ave NW
Maple Valley, WA 98038 Gig Harbor, WA 98335
425-432-9018 253-857-6808, woodbrk@harbornet.com
Sourced from the King County Critical Areas Restoration and Enhancement document, Appendix A 2020