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Home My WebLink AboutBLD2020-00572 - 09 NNL Report NO-NET-LOSS REPORT Discovery Bay NNL Jefferson County, WA Prepared for Jane Uhlir 1138 Broadway Ave E Seattle, WA 98102 (360) 257-0881 December 26, 2019 Prepared by Ecological Land Services 1157 3rd Avenue South, Suite 220A • Longview, WA 98632 (360) 578-1371 • Project Number 3087.01 Jane Uhlir – Discovery Bay NNL Ecological Land Services, Inc. No-Net-Loss Report i December 26, 2019 TABLE OF CONTENTS INTRODUCTION ................................................................................................................................1 JEFFERSON COUNTY SHORELINE MASTER PROGRAM ..................................................................1 STUDY AREA DESCRIPTION .............................................................................................................1 SITE DEVELOPMENT PROPOSAL .....................................................................................................2 MITIGATION SEQUENCING ..............................................................................................................2 ENVIRONMENTAL AND HABITAT CONDITIONS ...............................................................................3 WILDLIFE INVENTORY ................................................................................................................... 3 SHORELINE ENVIRONMENT ........................................................................................................... 6 BUFFER FUNCTIONS ....................................................................................................................... 6 IMPACT ANALYSIS ...........................................................................................................................7 Shoreline Impacts ..................................................................................................................... 7 Shoreline Buffer Impacts .......................................................................................................... 7 Shoreline Ecological Functions and Cumulative Impacts ....................................................... 8 No-Net-Loss Assessment .......................................................................................................... 8 LIMITATIONS ...................................................................................................................................9 REFERENCES ..................................................................................................................................10 FIGURES & PHOTOPLATES Figure 1 Vicinity Map Figure 2 Existing Conditions Figure 3 Site Plan Figure 4 Shoreline Designation and Zoning Map Figure 5 Coastal Shoreline Photo-2006 Figure 6 Coastal Atlas Map Figure 7 Shoreline Mitigation Plan Photoplates Site Photos Jane Uhlir – Discovery Bay NNL Ecological Land Services, Inc. Shoreline No-Net-Loss Assessment i December 26, 2019 SIGNATURE PAGE The information and data in this report were compiled and prepared under the supervision and direction of the undersigned. Keelin Lacey Biologist ___________________________ Joanne Bartlett, PWS Senior Biologist Jane Uhlir – Discovery Bay NNL Ecological Land Services, Inc Shoreline No Net Loss Assessment 1 December 26, 2019 INTRODUCTION Ecological Land Services, Inc. (ELS) has been contracted by Jane Uhlir to conduct a no-net-loss assessment (NNL) that addresses potential impacts associated with a new single-family residence on the property at 183 Aldrich Road, Port Townsend, Washington. The residential shoreline property consists of Jefferson County Tax Parcel Number 999200601, that lies in a portion of Section 31, Township 30 North, Range 1 West of the Willamette Meridian (Figure 1). The project is located within the 200-foot shoreline jurisdiction and requires completion of the shoreline buffer plan to satisfy the requirements of Jefferson County Code, Title 18, Shoreline Master Program (JCCSMP). Mitigation sequencing is required to address the potential impacts associated with building a home within the 150-foot shoreline buffer. JEFFERSON COUNTY SHORELINE MASTER PROGRAM This project is being reviewed under the updated JCSMP adopted in 2015 because it is within 200 feet of the shoreline of Discovery Bay. The entire property lies within 200 feet of the shoreline, so it is under shoreline jurisdiction and requires a shoreline no-net-loss assessment under Jefferson County Shoreline Master Program (JCSMP). The required buffer width is 150 feet, which extends across approximately half of the property. Under the current administrative process, projects proposing construction within the designated shoreline buffer must complete a shoreline report to document existing conditions and show that there will be no-net-loss of buffer function per Section 18.25.200 of the JCSMP. STUDY AREA DESCRIPTION The study area consists of four parcels adjacent to Discovery Bay, Tax Parcel Numbers 999201101, 999200601, 999200602, and 999200605 (Figure 1 and 2). The project location is across three parcels, parcel numbers 999200601, 999200602, and 99200605, where a boundary line adjustment (BLA) is proposed to convert the three properties into two. The home will be placed on parcel number 999200601 and the septic on parcel number 999200605 to avoid impacts to the shoreline buffer (Figure 3). The report focuses on observations in the proposed building area on parcel 999200602, within the buffer, and along the shoreline. This square parcel is 0.58 acres in size and slopes down from east to west. The property is developed with a gravel driveway and small cabin on the south side (Photoplates 1 and 2). The rest of the property is forested by coniferous forest consisting of Western red cedar, Douglas fir, Pacific madrone, big leaf maple, ocean spray, Nootka rose, snowberry, Oregon grape, and serviceberry (Photoplates 3 and 4). A gravel road, Aldrich Road, runs along the north property boundary which provides access to this property and two other cabins on the properties to the west (Photoplates 1 and 4). A foot path extends from the northwest property corner across Parcel 999201101 and provides access to the shoreline. The path descends the slope to the west to a grassy terrace above the beach (Photoplates 4 and 5). The slope leading down to the terrace is vegetated by dense unmowed grasses with scattered trees and shrubs consisting of Douglas fir, bitter cherry, snowberry, beach grass, orchard grass, yarrow, prickly- pear cactus, bracken fern, and gumweed. Loose soil is laying on the bulkhead in areas where the bank appears to be sloughing. A wooden bulkhead with creosote treated pilings is built at the base of the slope below the two offsite cabins and the building area (Photoplate 6). Jane Uhlir – Discovery Bay NNL Ecological Land Services, Inc Shoreline No Net Loss Assessment 2 December 26, 2019 The beach adjacent to the study area is armored by the wooden bulkhead, but the rest of the shoreline is relatively undeveloped. Adjacent to the bulkhead is about 25 feet of sandy beach with pea-sized gravel mixed throughout. The beach substrate coarsens from the nearshore to marine waters changing from sand to cobble-sized rocks (Photoplate 6). Eelgrass blades and kelp were identified in the wrack and some driftwood and large rocks were present adjacent to the bulkhead (Photoplate 7). To the north of the bulkhead is a stretch of undeveloped beach. Abundant driftwood and vegetation were present east of the ordinary high water mark (OHWM). Salt tolerant vegetation including European searocket, saltbush (Atriplex patula), and gumweed were identified growing adjacent to the beach in a saltmarsh (Photoplate 7). SITE DEVELOPMENT PROPOSAL The proposal involves a BLA to convert Parcel Numbers 999200601, 999200602, and 999200605 into two properties to allow for development of a single-family residence and septic system (Figure 3). The single-family residence will be placed on the northern portion of the existing Parcel Number 999200601 and the septic system will be placed on the eastern portion of the existing Parcel Number 999200605. The BLA will allow for the septic system to be placed entirely outside of shoreline jurisdiction to avoid impacts to the shoreline. The placement of the single-family residence has been chosen to avoid impacting the largest trees onsite. Because a portion of the residence will intrude into the 150-foot shoreline buffer and require removal of some native vegetation, the project is required to demonstrate no-net-loss of shoreline ecological functions per JCCSMP 18.25.270. MITIGATION SEQUENCING The single-family residence is proposed within 200 feet of Discovery Bay, which represents the only critical area within the study area. The project proposes to place a portion of the single- family residence within the required 150-foot shoreline buffer. The portion of shoreline buffer that extends across the proposed building area consists of upland forest and is well vegetated. Placement of the residence will require removal of six trees in the buffer and some native vegetation. As part of the mitigation process, projects are required to address mitigation sequencing to assess whether the project can avoid, minimize, rectify, or reduce impacts before identifying compensation or mitigation measures. Avoiding Impacts: Most of the study area lies within shoreline jurisdiction; the 150-foot shoreline and 10-foot setback cover approximately half of the building area. The location of the proposed single-family residence and septic system was chosen to cause the least impact to native vegetation onsite and to Discovery Bay. The building area is heavily wooded and was surveyed to mark the locations of trees to determine the best location for a home. Most of the home will be outside of the buffer, but a portion (1,006 square feet) will extend into the 10-foot setback and 150- foot buffer, requiring removal of only nine trees in the building area out of 47 total trees in the vicinity (Figure 7). Six of the nine trees will be removed from within the buffer. The residence has also been designed to be built around five trees, which will be in the middle of the structure, so they can be preserved. Impacts are also avoided by placing the septic drainfield entirely outside of shoreline jurisdiction (Figure 3). Jane Uhlir – Discovery Bay NNL Ecological Land Services, Inc Shoreline No Net Loss Assessment 3 December 26, 2019 Minimizing Impacts: The project is minimizing impacts to the shoreline buffer by proposing removal of only the smallest trees (5 to 16 inches diameter at breast height (DBH)) and by building the residence in areas with less significant vegetation. Minimal area will be cleared to keep as much native vegetation onsite as possible when constructing the home. Rectifying, Reducing, or Eliminating the Impacts: The project represents a permanent impact to the shoreline buffer, so cannot eliminate or rectify the impacts but has worked to reduce impacts to the native vegetation onsite by designing the house in areas where there is less vegetation and where the largest trees can be saved. Compensating for the Impacts: The project cannot entirely avoid, rectify, or eliminate impacts to a small portion of the shoreline buffer. However, the project works to avoid impacts where possible in the building area by designing the single-family residence to avoid the largest trees and areas of native vegetation on the property. Only nine trees will be removed in the building area, six of which will be in the buffer. To compensate for vegetation removal in the buffer, the rest of the 47 trees and all other vegetation will be retained onsite. The rest of the property is heavily vegetated and several fir trees ranging from 36 to 42 inches DBH will be retained in this area. No further compensation should be required on this property because the avoidance, minimization, and compensation measures have been taken and as much vegetation as possible will be retained onsite. There is also no available area to plant native species onsite due to the dense forest. ENVIRONMENTAL AND HABITAT CONDITIONS Wildlife Inventory State and Federally Listed Species and Critical Habitat Federally listed fish, bird, and mammals for Discovery Bay and Jefferson County (WDFW 2017) identified using the NOAA Fisheries and USFWS websites are presented in Table 1. State and federal status and presence of critical habitat is also included in the table. Table 1: State and Federally Listed Endangered and Threatened Species and Critical Habitat Species, ESU1 or DPS2 State Status4 Federal Status3 Critical Habitat5/6 in Project Vicinity Fish Puget Sound ESU Chinook Salmon (Oncorhynchus tshawytscha) Candidate Threatened Yes Hood Canal Summer-run Chum Salmon ESU (Oncorhynchus keta) Threatened Threatened Yes Puget Sound DPS Steelhead (Oncorhynchus mykiss) None Threatened No Bull Trout (Salvelinus confluentus) Candidate Threatened Yes Puget Sound/Georgia Strait DPS Yellow-eye rockfish (Sebastes ruberrimus) Candidate Threatened Yes Puget Sound/Georgia Strait DPS Bocaccio (Sebastes paucispinis) Candidate Endangered Yes Jane Uhlir – Discovery Bay NNL Ecological Land Services, Inc Shoreline No Net Loss Assessment 4 December 26, 2019 Species, ESU1 or DPS2 State Status4 Federal Status3 Critical Habitat5/6 in Project Vicinity Birds Marbled Murrelet (Brachyramphus marmoratus) Endangered Threatened No Yellow-billed Cuckoo (Coccyzus americanus) Candidate Threatened No Streaked Horned Lark (Eremophila alpestris strigata) Endangered Threatened No Mammals Fisher (Pekania pennanti) Endangered Threatened No Southern Resident DPS Killer Whale (Orcinus orca) Endangered Endangered No Humpback whale (Megaptera novaeangliae) Endangered Endangered Yes Plants Golden paintbrush (Castilleja levisecta Threatened Threatened No 1) ESU - Evolutionarily Significant Unit. A distinct group of Pacific salmon. 2) DPS – Distinct Population Unit. 3) Endangered - In danger of becoming extinct or extirpated; Threatened - Likely to become endangered within the foreseeable future throughout all or a significant portion of its range and that has been formally listed as such in the Federal Register under the Federal Endangered Species Act; Sensitive - Vulnerable or declining and could become Endangered or Threatened in the state; Species of Concern - An unofficial status, the species appears to be in jeopardy, but insufficient information to support listing. State candidate species include fish and wildlife species that the Department will review for possible listing as State Endangered, Threatened, or Sensitive. A species will be considered for designation as a State Candidate if sufficient evidence suggests that its status may meet the listing criteria defined for State Endangered, Threatened, or Sensitive. 4) Washington Department of Fish and Wildlife, PHS website. 5) NOAA 2019 6) USFWS 2019 Washington Department of Fish and Wildlife Priority Habitats and Species The Washington Department of Fish and Wildlife Priority Habitat and Species (PHS) website (WDFW 2019b) identifies presence of priority habitat and species areas within this area of Discovery Bay. The WDFW Forage Fish mapping website (WDFW 2019a) indicates herring spawning and sand lance spawning areas on the beach adjacent to the building area. Because the project takes place at the outer edge of the 150-foot shoreline buffer, the project will have no effect on the listed habitats and species. There are no terrestrial habitat features mapped by PHS within the project vicinity. Table 2: WDFW Priority Habitats and Species Priority Habitat or Species Priority Area Location Pacific geoduck (Panopea abrupta) Presence Adjacent Hardshell clam Presence Adjacent Pacific sand lance (Ammodytes hexapterus) Breeding Area >750 ft to NW of site Estuarine/Marine wetlands Aquatic habitat Adjacent Jane Uhlir – Discovery Bay NNL Ecological Land Services, Inc Shoreline No Net Loss Assessment 5 December 26, 2019 Washington Department of Natural Resources, Natural Heritage Program The Washington Department of Natural Resources, Natural Heritage Program (WDNR 2019) identifies 27 species of rare plants in Jefferson County. The building area is well forested with little herbaceous cover due to the thick canopy and shrub layer. The building area does not contain suitable habitat for these rare plants, and none of these plants were observed during the site visit. Washington Department of Ecology, Coastal Atlas The Washington Department of Ecology (Ecology 2010), Coastal Atlas Mapping tool indicates presence of patchy eelgrass fringe, continuous dunegrass fringe, patch fringe salt marsh, and patch low marsh along this section of Discovery Bay (Figure 5). No other significant features were noted on the Coastal Atlas map. Eelgrass blades, kelp, and beach grasses were identified onsite during the November 5, 2019 site visit along this section of beach. A saltmarsh within a coastal lagoon was also identified to the north but is over 300 feet from the proposed project location (Photoplates 5 and 8). The project will not have an impact on eelgrass beds, kelp beds, beach vegetation, or the saltmarsh because it does not propose any impacts along the shoreline itself. Jefferson County Critical Areas Mapping The Jefferson County Critical Area Maps (JCCA) viewed through the on-line mapping website was used to identify the presence of critical areas found within and along the shores of Discovery Bay (Jefferson County 2019). Wetlands are mapped across this section of shoreline; however no wetlands were found directly adjacent to the building area. The JCCA maps also indicate FEMA flood zones, however, these flood zones do not extend to the building area. Research and Site Investigation Fish and Whales Discovery Bay provides habitat for the listed fish and aquatic mammal species appearing on Table 1. The beach adjacent to the building area is composed of mostly unvegetated sandy beach that coarsens to cobble and gravel sized rocks toward the water (Photoplate 7). Driftwood has accumulated along the OHWM and most of the shoreline along this side of Discovery Bay is unarmored and natural (Figure 6). There is little overhanging vegetation due to the steepness of the bluffs in this area. Because this section of the bay is in a relatively natural condition it provides good habitat for fish and whales using this section of shoreline. The project will not have a direct impact on this habitat because it will be located within the outer 25 percent of the 150-foot shoreline buffer. Birds and Mammals Research conducted for this project shows that the property is not within habitat or management areas for fisher, marbled murrelet, streaked horned lark, and yellow-billed cuckoo (WDFW-PHS 2019; USFWS 2019). The upland along this section of Discovery Bay is developed with small single-family residences, some as close as 30 feet from the shoreline. The trees present in the project vicinity may provide perching areas and habitat for bald eagles and other predatory birds. However, no bald eagle nests or birds of prey were observed during the site visit. Jane Uhlir – Discovery Bay NNL Ecological Land Services, Inc Shoreline No Net Loss Assessment 6 December 26, 2019 Shoreline Environment The shoreline adjacent to this property is located along the northeast side of Discovery Bay (Figure 1). This section of shoreline is composed of sandy beach with pea-sized gravel that coarsens waterward to cobble-sized rocks. The beach adjacent to the building area is mostly unvegetated due to armoring by a wooden bulkhead (Photoplates 6 and 7). Driftwood has accumulated along the edge of the bulkhead and boulders are also scattered throughout the shoreline. To the north, a more a natural stretch of undeveloped beach is present with abundant driftwood accumulation and beach vegetation (Photoplate 8). Maps obtained for this project indicate the presence of patchy eelgrass fringe, continuous dunegrass fringe, patch fringe salt marsh, and patch low marsh along this section of shoreline (Figure 5) (DOE 2019). The WDFW Priority Habitats and Species (PHS) mapping also indicates estuarine and marine wetlands (WDFW 2019). Kelp and eelgrass blades were found in the wrack on the beach and beach grass was also observed growing along this section of shoreline. A saltmarsh is also present northwest of the building area adjacent to the beach. Despite being developed with residences, the adjacent properties are well forested. There is little overhanging vegetation along this section of shoreline due to the steepness of the bluffs. This section of Discovery Bay provides habitat features for water-dependent species because it is mostly unaltered. It also has the potential to provide habitat for birds because most of the shoreline to the north of the building area is wooded. Buffer Functions The designated buffer for all marine shorelines in Jefferson County is 150 feet from the OHWM. The existing mapped buffer consists of a beach pathway that leads up the steep bluff from the armored shoreline to provide access to four residences along Aldrich Road; two of the residences occur within the relatively undisturbed forested buffer. The slope along the beach pathway is vegetated by grasses and scattered trees with more dense vegetation occurring at the top of the bank. Two cabins are present approximately 20 to 30 feet from the OHWM along the bank above the bulkhead (Photoplate 7). A gravel road provides access to these cabins, running from northwest to southeast roughly parallel to the shoreline and the western property boundary of Parcel Number 999200601. From the proposed building area there is no line of sight to Discovery Bay due to the steepness of the slope and forest cover as well as one of the two western cabins (Photoplate ). The cabins, gravel road, and slope provide a functional break in the buffer per JCC 18.22.095 which states, “functional isolation can occur due to existing public roads, structures, vertical separating, or any other relevant physical characteristic”. The outer portion of the mapped buffer where the residence is proposed is disconnected from the shoreline due to slope, existing development, and distance from the shoreline. The width of buffers necessary to protect a critical area from degradation is related to the functions of the critical area and the buffer itself (Castelle, et al. 1992). Buffers function to protect water quality of critical areas including shorelines by removing sediment and nutrients from runoff and the function depends on the type of soils, vegetation, and characteristics of the runoff. The function of buffers is also based on width and slope. In some cases, buffers as low as 50 feet are effective in filtering pollutants when there is dense groundcover, no slope or a gradual slope, and the runoff sheet flows across the buffer. The buffer currently functions well to filter runoff where forest vegetation is present. Jane Uhlir – Discovery Bay NNL Ecological Land Services, Inc Shoreline No Net Loss Assessment 7 December 26, 2019 IMPACT ANALYSIS Shoreline Impacts The shoreline of Discovery Bay will not be directly impacted by onsite construction activities because the project will take place in the upland approximately 123 feet from the shoreline, at the closest point (Figure 3). There will be no direct impact to species that utilize the shoreline or habitat. There will be some noise generated by workers and machinery during construction of the home, however, the trees in the existing buffer and the slope will provide significant blocking of noise. Following construction there will be a decrease in noise. Light and noise from the new residence is not expected to impact the shoreline because the residence will be approximately 65 feet above the shoreline and the slope will provide screening. The trees within the existing buffer and dense shrub vegetation will also provide screening. Currently, there is noise and light generated by the cabins which are built between the building area and the shoreline. This new residence is unlikely to impact the shoreline due to its proximity, current screening, and current development within the immediate shoreline buffer. Shoreline Buffer Impacts The project proposes to build a single-family residence at the northern end of Parcel Number 999200601. The western side of the proposed residence will intrude, at maximum, 27 feet into the 150-foot buffer (Figure 3). This location was chosen for the residence because it avoids impacts to the most significant vegetation on the property. There are large trees present in and out of the designated buffer that will be preserved. Approximately 1,006 square feet of vegetation in the shoreline buffer and nine trees onsite, ranging from 5 to 16 inches DBH, will be impacted. All other vegetation inside and outside of the buffer will be retained. The project will not represent a significant impact on the shoreline buffer because it will take place within the outer 25 percent of the buffer. Per JCC 18.22.270(6) the buffer may be reduced if it will not adversely affect habitat functions, and the buffer is not reduced to less than 75 percent. There is existing development adjacent to the building area that includes a cabin and a driveway. The driveway provides access to multiple residences and the cabin represents a permanent structure that interrupts the shoreline buffer. There is a significant change in slope within the buffer; the shoreline is approximately 65 feet lower than the area where the new residence is proposed. The combination of the slope and native vegetation will provide noise and light blocking from the new residence, as will the existing cabin that lies adjacent to the proposed residence. The buffer will be minimally impacted because vegetation will only be cleared for the footprint of the home in the buffer; all other vegetation will be retained. The largest trees have been surveyed and the home has been designed to remove only the smallest trees. There will be an increase in impervious surface of 1,006 square feet in the buffer, however, the native vegetation to be preserved will still serve to filter and slow runoff from these impervious surfaces. No mitigation plantings are proposed because the project has worked to keep the rest of the native vegetation onsite; the vegetation is dense on the rest of the site and there was no invasive cover noted so there is no ability to plant additional species. Jane Uhlir – Discovery Bay NNL Ecological Land Services, Inc Shoreline No Net Loss Assessment 8 December 26, 2019 Shoreline Ecological Functions and Cumulative Impacts The WAC 173-26-201(3)(d)(i) lists essential functions of different type of shoreline environments. The main functions provided by marine waters are listed below: • Hydrologic: Transporting and stabilizing sediment, attenuating wave and tidal energy, removing excessive nutrients and toxic compounds; recruitment, redistribution and reduction of woody debris and other organic material. The shoreline adjacent to the building area is fairly natural, despite the presence of a wooden bulkhead. There is large woody debris accumulation along the OHWM and most of the shoreline is in a natural state along this stretch of Discovery Bay. The project will not take place directly on the shoreline, so will not have an effect on hydrologic functions. • Vegetation: Maintaining temperature; removing excess nutrients and toxic compounds, attenuating wave energy, sediment removal and stabilization; and providing woody debris and other organic matter. Retaining vegetation along the shoreline is most vital within proximity to the shoreline itself so it can perform the functions listed above. The project will not impact any vegetation immediately adjacent to the shoreline. Vegetation removal will take place within the outer edge of the 150-foot buffer which will not significantly impact the shoreline itself due to the distance. Furthermore, the design of the residence has been built around the most significant vegetation to ensure that the largest trees are retained on the property. • Habitat for aquatic and shoreline-dependent birds, invertebrates, mammals; amphibians; and anadromous and resident native fish: Habitat functions may include, but are not limited to, space or conditions for reproduction, resting, hiding and migration; and food production and delivery. The project will not have a significant impact on habitat because the residence has been designed to avoid the largest trees and most significant vegetation. The largest trees, which are more likely to be used by birds and mammals, will be retained on the property; only the smallest trees will be removed and are less likely to be used for nesting sites. The project will not have an impact on habitat along the shoreline that could affect water-dependent species because it will take place over 123 feet, at the closest, from the shoreline. Considerable thought has been put into the design of the house to preserve as much forest and habitat as possible. No-Net-Loss Assessment The buffer as it currently exists is interrupted by the cabin and driveway offsite to the west, which physically separates the shoreline from the proposed project. The building area is also approximately 70 feet above sea level and the OHWM at about 10 feet above sea level, so the proposed building site is approximately 60 feet higher in elevation than the shoreline. The slope provides vertical separation from the critical area and contributes to the function of the buffer to to shield any light or noise generated in this area from reaching the shoreline. Due to the difference in elevation of the building area and interruptions from development in the buffer, it is unlikely that this portion of the buffer provides significant protection for the shoreline. The project has worked to avoid, minimize, and reduce impacts to the shoreline by designing the residence to avoid the largest trees and most significant vegetation onsite. Of the 47 trees in the building area, only nine of the smallest trees will be removed. Some of these trees are just outside of the buffer; Jane Uhlir – Discovery Bay NNL Ecological Land Services, Inc Shoreline No Net Loss Assessment 9 December 26, 2019 it was determined to be a better choice to impact the very small trees in the outer portion of the buffer than to remove large old-growth trees just outside of the buffer, which include Douglas fir and western red cedar trees ranging from 30 to 42 inches DBH (Figure 7). By removing only the smallest trees, despite their location in the outer buffer, there should be less impact to the overall ecological function onsite because vegetation will be preserved on the rest of the site. Essential functions listed in the section above will not be impacted by the project due to its distance from the shoreline. The project has also worked to avoid impacts to the shoreline by proposing the septic system for this residence completely outside of the shoreline buffer and shoreline jurisdiction. During construction, best management practices will be utilized and minimal clearing will take place to ensure that native vegetation onsite is preserved. Because the project has been designed to avoid, minimize, and reduce impacts, preserve native vegetation, and will take place on the outer edge of the interrupted buffer the project will result in in no-net-loss of shoreline ecological functions as required by the JCCSMP. LIMITATIONS ELS bases this report’s determinations on standard scientific methodology and best professional judgment. In our opinion, local, state, and federal regulatory agencies should agree with our determinations. However, the information contained in this report should be considered preliminary and used at your own risk until it has been approved in writing by the appropriate regulatory agencies. ELS is not responsible for the impacts of any changes in environmental standards, practices, or regulations after the date of this report. Jane Uhlir – Discovery Bay NNL Ecological Land Services, Inc Shoreline No Net Loss Assessment 10 December 26, 2019 REFERENCES Castelle, A.J., C. Conolly, M. Emers, E.D. Metz, S. Meyer, M. Witter, S. Maurermann, T. Erickson, S.S. Cooke. 1992. Wetland Buffers: Use and Effectiveness. Adolfson Associates, Inc., Shorelands and Coastal Zone Management Program, Washington Department of Ecology. Olympia. Pub. No. 92-10. Jefferson County Code. 2017. Title 18 Shoreline Management Program. Jefferson County Parcel Search, 2019. https://jeffcowa.maps.arcgis.com/home/index.html Accessed December 2019. NOAA Fisheries (NOAA). 2019. West Coast Salmon & Steelhead Listings. https://www.fisheries.noaa.gov/region/west-coast#management. Website accessed December 2019 Sheldon, D. T. Hruby, P. Johnson, K. Harper, A. McMillan, T. Granger, S. Stanley, and E. Stockdale. March 2005. Wetlands in Washington State – Volume 1: A Synthesis of the Science. Washington State Department of Ecology. Publication #05-06-006. Olympia, WA. United States Fish and Wildlife Service (USFWS). 2019 Endangered Species Website. http://www.fws.gov/endangered/. Website accessed December 2019. Washington Department of Ecology (Ecology). 2019. Washington State Coastal Atlas https://fortress.wa.gov/ecy/coastalatlas/. Website accessed December 2019. Washington Department of Ecology (Ecology). 2017. Shoreline Master Programs Handbook: Chapter 4 – No-net-loss of Shoreline Ecological Functions. Washington State Department of Ecology. Publication #11-06-010. Olympia, WA Washington Department of Fish and Wildlife (WDFW). 2019a. Forage Fish Spawning Map – Washington State. https://wdfw.wa.gov/fishing/management/marine-beach-spawning. Website accessed December 2019. Washington Department of Fish and Wildlife (WDFW). 2019b. Priority Habitats and Species PHS on the Web. http://apps.wdfw.wa.gov/phsontheweb/. Website accessed December 2019. FIGURES AND PHOTOPLATES Latitude Longitude SITE SCALE IN MILES 30150 SITE 12 / 2 6 / 2 0 1 9 1 0 : 2 4 A M c: \ U s e r s \ r i g h t \ B o x \ E L S \ W A \ j e f f e r s o n \ C o u n t y \ 3 0 8 7 - u h l i r \ 3 0 8 7 . 0 1 - d i s c o v e r y b a y s m p \ 3 0 8 7 . 0 1 - f i g u r e s \ 3 0 8 7 . 0 1 _ S M P . d w g ri g h t N 6 :( DA T E : DW N : RE Q . B Y : PR J . M G R : CH K : PR O J E C T N O : Fi g u r e 1 VI C I N I T Y M A P 12 / 2 6 / 1 9 30 8 7 . 0 1 Di s c o v e r y B a y N N L Ja n e U h l i r Se c t i o n 31 , T o w n s h i p 30 N , R a n g e 1W , W . M . Je f f e r s o n C o u n t y , WA JL L KL SC A L E I N F E E T 0 20 0 0 40 0 0 11 5 7 3 r d A v e . , S u i t e 2 2 0 A Lo n g v i e w , W A 9 8 6 3 2 Ph o n e : ( 3 6 0 ) 5 7 8 - 1 3 7 1 Fa x : ( 3 6 0 ) 4 1 4 - 9 3 0 5 ww w . e c o - l a n d . c o m PROJECT VICINITY MAP CAMAS QUILCENE QUEETS NEAH BAY CLALLAM BAY 5 542 542 209 LOPEZ FRIDAY HARBOR ORCAS ANACORTES LAKE ROSS ROCKPORT BELLINGHAM FERNDALE LYNDENBLAINE SEDRO WOOLLEY MOUNT VERNON OAK HARBOR STANWOOD DARRINGTON ARLINGTON EVERETT MUKILTEO 9 MONROE PORT TOWNSEND 113 112 SEQUIM ANGELES PORT 101 FORKS MORTON KELSOLONGVIEW HOQUIAM ABERDEEN MONTESANOOCEAN SHORES WESTPORT RAYMOND CENTRALIA CHEHALIS WINLOCK CASTLE ROCK CATHLAMET WOODLAND 5 12 12 6 5044 12 101 PACIFIC BEACH GRAYS HARBOR PACIFIC LEWIS COWLITZ WAHKIAKUM KALAMA ELMA 5 BATTLE GROUND VANCOUVER NORTH BONNEVILLE STEVENSON CARSON MT. ST. HELENS MOSSYROCK RANDLE PACKWOOD EATONVILLE MT. RAINIER ROY ORTING BUCKLEY ENUMCLAWPUYALLUP DUPONT TENINO YELM OLYMPIA SHELTON HOODSPORT GIG TACOMA AUBURN KENT NORTH BEND SEATTLE DUVALL BOTHELL SKYKOMISH 14 LA CENTER 503 5 SKAMANIA CLARK MASON KING THURSTON PIERCE KITSAP 505 127 123 410161 101 3 3 18 90 2 WAY 101 101 ILWACO OCEAN PARK LONG BEACH COPALIS BEACH JEFFERSON CLALLAM SNOHOMISH SKAGIT WHATCOM ISLAND SAN JUAN AMANDA PARK SOUTH BEND KIRKLAND REDMOND BELLEVUE HARBOR FEDERAL PORT ORCHARD BREMERTON POULSBO STEILACOOM RIDGEFIELD WASHOUGAL LOCATION MAP WASHINGTON SITE Gr a v e l R o a d Fo o t P a t h Ex i s t i n g Ho u s e Fo o t P a t h Wo o d e n Bu l k h e a d To p o f B a n k Ed g e o f V e g e t a t i o n 15 0 ' S h o r e l i n e Bu f f e r Ex i s t i n g Ca b i n 20 0 ' S h o r e l i n e J u r i s d i c t i o n Ex i s t i n g Ca b i n 12 / 2 6 / 2 0 1 9 1 0 : 2 4 A M c: \ U s e r s \ r i g h t \ B o x \ E L S \ W A \ j e f f e r s o n \ C o u n t y \ 3 0 8 7 - u h l i r \ 3 0 8 7 . 0 1 - d i s c o v e r y b a y s m p \ 3 0 8 7 . 0 1 - f i g u r e s \ 3 0 8 7 . 0 1 _ S M P . d w g ri g h t N 6 : ( DA T E : DW N : RE Q . B Y : PR J . M G R : CH K : PR O J E C T N O : 11 5 7 3 r d A v e . , S u i t e 2 2 0 A Lo n g v i e w , W A 9 8 6 3 2 Ph o n e : ( 3 6 0 ) 5 7 8 - 1 3 7 1 Fa x : ( 3 6 0 ) 4 1 4 - 9 3 0 5 ww w . e c o - l a n d . c o m DA T E : DW N : RE Q . B Y : PR J . M G R : CH K : PR O J E C T N O : Figure 2 SITE MAP 12 / 2 6 / 1 9 30 8 7 . 0 1 Di s c o v e r y B a y N N L Jane Uhlir Se c t i o n 31 , T o w n s h i p 30N , Range 1W , W.M. Je f f e r s o n County, WA JL L KL SC A L E I N F E E T 0 50 10 0 NO T E ( S ) : 1. Ae r i a l f r o m G o o g l e E a r t h ™ 2. Fe a t u r e s l o c a t e d u s i n g h a n d h e l d G P S w i t h s u b m e t e r a c c u r a c y . ST U D Y A R E A LEGEND:Study Area Parcel Boundary 150' Shoreline Buffer 200' Shoreline Jurisdiction Edge of Existing Vegetation Pa r c e l N o . 99 9 2 0 0 1 0 3 Pa r c e l N o . 99 9 2 0 0 6 0 1 Pa r c e l N o . 99 9 2 0 0 6 0 2 Parcel No.999200605 Gr a v e l R o a d Fo o t P a t h Ex i s t i n g Ho u s e Fo o t P a t h Wo o d e n Bu l k h e a d To p o f B a n k Ed g e o f V e g e t a t i o n Proposed Septic Pr o p o s e d Si n g l e - F a m i l y Re s i d e n c e 15 0 ' S h o r e l i n e Bu f f e r 10 ' B u i l d i n g S e t b a c k Ex i s t i n g Ca b i n 20 0 ' S h o r e l i n e J u r i s d i c t i o n 3 7 ' Ex i s t i n g Ca b i n 12 / 2 6 / 2 0 1 9 1 0 : 2 4 A M c: \ U s e r s \ r i g h t \ B o x \ E L S \ W A \ j e f f e r s o n \ C o u n t y \ 3 0 8 7 - u h l i r \ 3 0 8 7 . 0 1 - d i s c o v e r y b a y s m p \ 3 0 8 7 . 0 1 - f i g u r e s \ 3 0 8 7 . 0 1 _ S M P . d w g ri g h t N 6 : ( DA T E : DW N : RE Q . B Y : PR J . M G R : CH K : PR O J E C T N O : 11 5 7 3 r d A v e . , S u i t e 2 2 0 A Lo n g v i e w , W A 9 8 6 3 2 Ph o n e : ( 3 6 0 ) 5 7 8 - 1 3 7 1 Fa x : ( 3 6 0 ) 4 1 4 - 9 3 0 5 ww w . e c o - l a n d . c o m DA T E : DW N : RE Q . B Y : PR J . M G R : CH K : PR O J E C T N O : Figure 3 SITE PLAN 12 / 2 6 / 1 9 30 8 7 . 0 1 Di s c o v e r y B a y N N L Jane Uhlir Se c t i o n 31 , T o w n s h i p 30N , Range 1W , W.M. Je f f e r s o n County, WA JL L KL SC A L E I N F E E T 0 50 10 0 ST U D Y A R E A LEGEND:Study Area 150' Shoreline Buffer 10' Building Setback 200' Shoreline Jurisdiction Existing Parcel Boundary Proposed Parcel Boundary Edge of Existing Vegetation Impact Area (1,006 sq.ft.) NOTE(S): 1.Map provided on-line by Jefferson County at web address: https://jeffcowa.maps.arcgis.com/ 12 / 2 6 / 2 0 1 9 1 0 : 2 4 A M c: \ U s e r s \ r i g h t \ B o x \ E L S \ W A \ j e f f e r s o n \ C o u n t y \ 3 0 8 7 - u h l i r \ 3 0 8 7 . 0 1 - d i s c o v e r y b a y s m p \ 3 0 8 7 . 0 1 - f i g u r e s \ 3 0 8 7 . 0 1 _ S M P . d w g ri g h t SITE N 6 :( DA T E : DW N : RE Q . B Y : PR J . M G R : CH K : PR O J E C T N O : Fi g u r e 4 JE F F E R S O N C O U N T Y C R I T I C A L A R E A S M A P 12 / 2 6 / 1 9 30 8 7 . 0 1 Di s c o v e r y B a y N N L Ja n e U h l i r Se c t i o n 31 , T o w n s h i p 30 N , R a n g e 1W , W . M . Je f f e r s o n C o u n t y , WA JL L KL SC A L E I N F E E T 0 80 16 0 11 5 7 3 r d A v e . , S u i t e 2 2 0 A Lo n g v i e w , W A 9 8 6 3 2 Ph o n e : ( 3 6 0 ) 5 7 8 - 1 3 7 1 Fa x : ( 3 6 0 ) 4 1 4 - 9 3 0 5 ww w . e c o - l a n d . c o m NOTE(S): 1.Map provided on-line by WA State Department of Ecology at web address: https://fortress.wa.gov/ecy/coastalatlas/tools/map.aspx 12 / 2 6 / 2 0 1 9 1 0 : 2 4 A M c: \ U s e r s \ r i g h t \ B o x \ E L S \ W A \ j e f f e r s o n \ C o u n t y \ 3 0 8 7 - u h l i r \ 3 0 8 7 . 0 1 - d i s c o v e r y b a y s m p \ 3 0 8 7 . 0 1 - f i g u r e s \ 3 0 8 7 . 0 1 _ S M P . d w g ri g h t SITE N 6 :( DA T E : DW N : RE Q . B Y : PR J . M G R : CH K : PR O J E C T N O : Fi g u r e 5 CO A S T A L A T L A S M A P 12 / 2 6 / 1 9 30 8 7 . 0 1 Di s c o v e r y B a y N N L Ja n e U h l i r Se c t i o n 31 , T o w n s h i p 30 N , R a n g e 1W , W . M . Je f f e r s o n C o u n t y , WA JL L KL SC A L E I N F E E T 0 10 0 20 0 11 5 7 3 r d A v e . , S u i t e 2 2 0 A Lo n g v i e w , W A 9 8 6 3 2 Ph o n e : ( 3 6 0 ) 5 7 8 - 1 3 7 1 Fa x : ( 3 6 0 ) 4 1 4 - 9 3 0 5 ww w . e c o - l a n d . c o m Eelgrass Fringe (patchy) Dunegrass Fringe (continuous) Salt Marsh Fringe (patchy) Low Marsh Fringe (patchy) 12 / 2 6 / 2 0 1 9 1 0 : 2 4 A M c: \ U s e r s \ r i g h t \ B o x \ E L S \ W A \ j e f f e r s o n \ C o u n t y \ 3 0 8 7 - u h l i r \ 3 0 8 7 . 0 1 - d i s c o v e r y b a y s m p \ 3 0 8 7 . 0 1 - f i g u r e s \ 3 0 8 7 . 0 1 _ S M P . d w g ri g h t N 6 : ( 11 5 7 3 r d A v e . , S u i t e 2 2 0 A Lo n g v i e w , W A 9 8 6 3 2 Ph o n e : ( 3 6 0 ) 5 7 8 - 1 3 7 1 Fa x : ( 3 6 0 ) 4 1 4 - 9 3 0 5 ww w . e c o - l a n d . c o m DA T E : DW N : RE Q . B Y : PR J . M G R : CH K : PR O J E C T N O : DA T E : DW N : RE Q . B Y : PR J . M G R : CH K : PR O J E C T N O : Figure 6 CO A S T A L S H O R E L I N E P H O T O 12 / 2 6 / 1 9 30 8 7 . 0 1 Di s c o v e r y B a y N N L Jane Uhlir Se c t i o n 31 , T o w n s h i p 30N , Range 1W , W.M. Je f f e r s o n County, WA JL L KL NO T T O S C A L E NO T E ( S ) : 1. Ma p p r o v i d e d o n - l i n e b y W A S t a t e D e p a r t m e n t o f E c o l o g y a t w e b a d d r e s s : ht t p s : / / f o r t r e s s . w a . g o v / e c y / c o a s t a l a t l a s / t o o l s / M a p . a s p x SI T E Fo o t P a t h Pr o p o s e d Si n g l e - F a m i l y Re s i d e n c e 15 0 ' S h o r e l i n e Bu f f e r 10 ' B u i l d i n g S e t b a c k 20 0 ' S h o r e l i n e Ju r i s d i c t i o n Ex i s t i n g Ho u s e 3 7 ' Grave l R o a d 12 / 2 6 / 2 0 1 9 1 0 : 2 4 A M c: \ U s e r s \ r i g h t \ B o x \ E L S \ W A \ j e f f e r s o n \ C o u n t y \ 3 0 8 7 - u h l i r \ 3 0 8 7 . 0 1 - d i s c o v e r y b a y s m p \ 3 0 8 7 . 0 1 - f i g u r e s \ 3 0 8 7 . 0 1 _ S M P . d w g ri g h t N 6 : ( DA T E : DW N : RE Q . B Y : PR J . M G R : CH K : PR O J E C T N O : 11 5 7 3 r d A v e . , S u i t e 2 2 0 A Lo n g v i e w , W A 9 8 6 3 2 Ph o n e : ( 3 6 0 ) 5 7 8 - 1 3 7 1 Fa x : ( 3 6 0 ) 4 1 4 - 9 3 0 5 ww w . e c o - l a n d . c o m DA T E : DW N : RE Q . B Y : PR J . M G R : CH K : PR O J E C T N O : Figure 7 NO - N E T - L O S S A S S E S S M E N T 12 / 2 6 / 1 9 30 8 7 . 0 1 Di s c o v e r y B a y N N L Jane Uhlir Se c t i o n 31 , T o w n s h i p 30N , Range 1W , W.M. Je f f e r s o n County, WA JL L KL SC A L E I N F E E T 0 25 50 LE G E N D : St u d y A r e a 15 0 ' S h o r e l i n e B u f f e r 10 ' B u i l d i n g S e t b a c k 20 0 ' S h o r e l i n e J u r i s d i c t i o n Ex i s t i n g P a r c e l B o u n d a r y Pr o p o s e d P a r c e l B o u n d a r y Im p a c t A r e a ( 1 , 0 0 6 s q . f t . ) Ed g e o f E x i s t i n g V e g e t a t i o n Tr e e L o c a t i o n s ( 4 7 ) Re m o v e d T r e e s I n B u f f e r ( 6 ) Re m o v e d T r e e s O u t s i d e B u f f e r ( 3 ) 14 " F i r 16 " F i r 12 " F i r 12 " Ma d r o n a NO T E ( S ) : 1. Al l v e g e t a t i o n o u t s i d e o f i m p a c t a r e a t o b e re t a i n e d . Photo 1 was taken from the driveway look- ing southeast and shows the upland forest vegetation on the property. 1157 3rd Ave., Suite 220A Longview, WA 98632 Phone: (360) 578-1371 Fax: (360) 414-9305 DATE: 11/8/19 DWN: KL PRJ. MGR: KL PROJ.#: 3087.01 Photoplate 1 2019 Site Photos Project Name: Discovery Bay SMP Client: Jane Uhlir Jefferson County, Washington Photo 3 was taken from the driveway look- ing southwest toward the shoreline. This driveway leads down to access the two cabins along the shoreline. Photo 2 was taken from the driveway look- ing south near the northeast corner toward an existing cabin. Photo 4 was taken from the footpath leading down to the beach. This photo looks northwest toward an existing struc- ture and upland forest. 1157 3rd Ave., Suite 220A Longview, WA 98632 Phone: (360) 578-1371 Fax: (360) 414-9305 DATE: 11/8/19 DWN: KL PRJ. MGR: KL PROJ.#: 3087.01 Photoplate 2 2019 Site Photos Project Name: Discovery Bay SMP Client: Jane Uhlir Jefferson County, Washington Photo 6 was taken from the footpath looking west toward the shoreline and shows the forest vegetation. The footpath descends down to the west to the shoreline. Photo 5 was taken from the footpath looking east toward an existing cabin. Photo 7 was taken from the footpath leading to the beach and shows the vegeta- tion between the shoreline and the proposed building area. The cabin built at the top of the bank repre- sents a functional break in the buff- er. 1157 3rd Ave., Suite 220A Longview, WA 98632 Phone: (360) 578-1371 Fax: (360) 414-9305 DATE: 11/8/19 DWN: KL PRJ. MGR: KL PROJ.#: 3087.01 Photoplate 3 2019 Site Photos Project Name: Discovery Bay SMP Client: Jane Uhlir Jefferson County, Washington Photo 9 shows another view of the upland forest between the shoreline and this property. This area was vegetated by snowberry, hazelnut, and bigleaf maple. Photo 8 shows more of the forest vegetation between the shoreline and this prop- erty which is vegetated by a dense shrub layer. Photo 10 was taken from the beginning of the beach pathway which leads to Discovery Bay. This portion of the driveway provides access to the two cabins west of the building area. 1157 3rd Ave., Suite 220A Longview, WA 98632 Phone: (360) 578-1371 Fax: (360) 414-9305 DATE: 11/8/19 DWN: KL PRJ. MGR: KL PROJ.#: 3087.01 Photoplate 4 2019 Site Photos Project Name: Discovery Bay SMP Client: Jane Uhlir Jefferson County, Washington Photo 12 was taken from the bottom of the beach stairs where they let out on a grassy terrace at the top of the bluff above the beach. Photo 11 was taken from the beach pathway and looks west toward the shoreline showing the forest vegetation in this area. Photo 13 was taken from the grassy terrace near the south line looking east at the vegetation on the slope an exist- ing cabin on a property to the west of the proposed project. This cabin is built at the top of the shoreline bank. 1157 3rd Ave., Suite 220A Longview, WA 98632 Phone: (360) 578-1371 Fax: (360) 414-9305 DATE: 11/8/19 DWN: KL PRJ. MGR: KL PROJ.#: 3087.01 Photoplate 5 2019 Site Photos Project Name: Discovery Bay SMP Client: Jane Uhlir Jefferson County, Washington Photo 15 shows more of the grassy terrace above the beach. Photo 14 was taken from the grassy terrace near the south line looking northeast at the bluff above the beach and the shoreline in the background of the photo. A sandy beach, driftwood, and saltmarsh are present in the background of this photo. Photo 16 was taken from the water’s edge and looks to the north. The beach was sandier toward the bluff; the beach substrate coarsened toward the water. 1157 3rd Ave., Suite 220A Longview, WA 98632 Phone: (360) 578-1371 Fax: (360) 414-9305 DATE: 11/8/19 DWN: KL PRJ. MGR: KL PROJ.#: 3087.01 Photoplate 6 2019 Site Photos Project Name: Discovery Bay SMP Client: Jane Uhlir Jefferson County, Washington Photo 18 shows the bluff and beach path- way. The beach pathway is used by multiple residences to access the bay. A section of the shoreline adja- cent to this property is armored by the wooden bulkhead seen in this photo. Photo 17 was taken from the same location as Photo 16 and looks to the north- east. The sand and cobble beach can be seen in the foreground of the pho- to and the bluff and beach pathway in the background. Photo 19 was taken from the water looking southeast, showing the bulkhead and beach access from properties to the west of the building area. 1157 3rd Ave., Suite 220A Longview, WA 98632 Phone: (360) 578-1371 Fax: (360) 414-9305 DATE: 11/8/19 DWN: KL PRJ. MGR: KL PROJ.#: 3087.01 Photoplate 7 2019 Site Photos Project Name: Discovery Bay SMP Client: Jane Uhlir Jefferson County, Washington Photo 21 was taken from the bottom of the stairs seen in Photos 17 and 18. Photo 20 was taken from the same location as the last photo looking south. The bluff steepens along this section of shoreline. Photo 22 shows a berm adjacent to the offsite portion of beach to the north. Most of the shoreline along Discov- ery Bay is natural and unarmored with large woody debris present. 1157 3rd Ave., Suite 220A Longview, WA 98632 Phone: (360) 578-1371 Fax: (360) 414-9305 DATE: 11/8/19 DWN: KL PRJ. MGR: KL PROJ.#: 3087.01 Photoplate 8 2019 Site Photos Project Name: Discovery Bay SMP Client: Jane Uhlir Jefferson County, Washington Photo 24 was taken from the bottom of the bluff and looks west toward the bay. Photo 23 looks further to the northeast and shows the offsite saltmarsh, which was dominated by salt tolerant vege- tation. Photo 25 was taken from the top of the bluff adjacent to the property, which is nearly vertical and is vegetated by grasses and some scattered shrubs. 1157 3rd Ave., Suite 220A Longview, WA 98632 Phone: (360) 578-1371 Fax: (360) 414-9305 DATE: 11/8/19 DWN: KL PRJ. MGR: KL PROJ.#: 3087.01 Photoplate 9 2019 Site Photos Project Name: Discovery Bay SMP Client: Jane Uhlir Jefferson County, Washington Photo 27 looks across the bluff toward the south and the beach pathway. Photo 26 shows the bluff and sandy beach below. Photo 28 shows the beach adjacent to the wooden bulkhead. 1157 3rd Ave., Suite 220A Longview, WA 98632 Phone: (360) 578-1371 Fax: (360) 414-9305 DATE: 11/8/19 DWN: KL PRJ. MGR: KL PROJ.#: 3087.01 Photoplate 10 2019 Site Photos Project Name: Discovery Bay SMP Client: Jane Uhlir Jefferson County, Washington Photo 30 was taken from the same location as Photo 29 and looks up the bluff. Photo 29 shows the wooden bulkhead at the toe of the slope adjacent to this property.