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HomeMy WebLinkAboutLog046 e e State of Washington DEPARTMENT OF FISH AND WilDLIFE Region 6 Office: 48 Devonshire Road - Montesano. Washington 98563-9618 - (360) 249-4628 January 12,2000 Pope Resources ATTENTION: Jon Rose P.O, Box 1780 Poulsbo, Wa. 98370 Dear Mr. Rose: SUBJECT: Hydraulic Project Application OOE2251.01 The Washington Department ofFish and Wildlife (WDFW) received a request by Pentec Environmental to modify the above referenced permit. The request was received on 28 December 2000, The agency response follows. WDFW first had conversations about this project with Ron Parker, Associated Earth Sciences, in approximately November of 1999, Final project design was permitted by the WDFW in January 2000, and included review by Jim Johannesen, Coastal Geologic Services, and myself. Additional discussions on project design have apparently also taken place between Pentec Environmental Services and Dan Pentilla ofWDFW. The permitted project is to repair erosion and aesthetics of a commercial recreational shoreline property using more aesthetic soft bank techniques, including wood placement on the beach. The project beach is located west of the large hotel/resort and just east of the Port Ludlow Marina, The property, including project site, is made up entirely of fill from the original Pope Resources mill. Non-native rock and other fill material is still visible on the project beach. The following points reiterate my perspective on discussions during the 28 September 1999 site visit with your contractor, Ron Parker of Associated Earth Resources, Randy Cline, and myself. 1) Minimal marine based erosion appears to be occurring at this site. The change in the beach is due in part to surface runoff from impervious surfaces of the adjacent filled and developed area, Marine based erosion that may be occurring may in be in part due to prop wash from boats using the gas dock at the adjacent marina. This is a concern I have raised in subsequent site visits on the Olympic Property Management Marina Expansion, 2)The existing beach is compromised by a number of features at the site including, but not limited to, the adjacent fill (including riprap), surface runoff, and stray non-native material on the beach. The sub standard quality of this beach can be easily be illustrated by comparing the LOG ITEM # Lf~ PAge---L- of.-1:- e e Mr. Rose January 12,2000 Page 2 project beach to the restored beach that begins immediately east ofthe old smoke stack and continues approximately one half kilometer to the north. The restored beach includes forage fish spawning beds, and is illustrative of what the project beach site would look like if unaltered. 3)As you know, this area is critical habitat for at least two ESA listed species, and three of their forage fish. In their last letter Pentec, as your agent, requested that the issued HP A be modified to delete the provisions detailing beach graveling, and removal oflarge non-native materials. Justification for this request is that the Corps of Engineers (CoE) determination states that the existing beach is high quality, and that the mix of beach gravel possibly inappropriate. The HP A I have issued is the best alternative for replacing degraded fish habitat while allowing for bank protection. As documented in other areas, if done properly the placed material may slow any marine based erosion (if it is in fact occurring). Without placing material on the beach, armoring the shore with wood is an incomplete attempt to address the stated problem. Therefore the proposed work may not be done without gravel placement for the reasons stated above. Location, size, and volume of the material may be negotiable depending on CoE jurisdiction, and direction from project designers, including qualified coastal process geologists and engineers including Coastal Geologic Services. I would also once again urge you to identify and remedy drainage problems associated with uplands adjacent to the project site, As you may know, the CoE has just issued a Programmatic Biological Evaluation (BE) for Streamline Endangered Species Consultation (public notice dated 8 December 2000). The CoE is currently evaluating the BE to see if it applies to this project. Both the CoE and the WDFW will get back to you once the CoE has determined if this project is exempt under this BE, or ifin fact the material placement needs to be changed to alleviate CoE jurisdictional concerns, In the meantime I would encourage you to contact Johannessen again and discuss project details, including revisions to material volumes and composition. If you have any questions, please contact me at (360) 457-2634, Sincerely, I~~ J. Anne Shaffer Area Marine Habitat Biologist JAS:jas:00e2251 # PAge lOG ITEM 4~ _,"_ ~ of~ / . . "",1 . i i f,:'.' -"~'T STATE OF WASHINGTON DEPARTMENT OF FISHERIES Post Office Box 43135, Olympia, Washington 98504-3135 · (206) 902-2200 SCAN 902-2200 TOO 902-2207' May 18, 1993 Craig Ward Jefferson County Planning and Building Department Post Office Box l220 Port Townsend, Washington 98368 SUBJECT: Final Environmental Impact statement - Pope Resources Proponent - Port Ludlow Inn Development - Port Ludlow, Hood Canal, Tributary to puget Sound, section 16, Township 28 North, Range 01 East, Jefferson county, SEPA Log No. 22494, WRIA 17. KARI Dear Mr. Ward: The Washington Department of Fisheries (WDF) has reviewed the above- referenced Final Environmental Impact statement for the Port Ludlow Inn Development and offers the following comments at this time. Other comments may be offered as the project progresses. WDF habitat policy (POL-410), adopted September 1990, states ". it is the goal of WDF to achieve no net loss of the productive capacity of the habitat of food fish and shellfish resources of the state." This policy requires applicants of projects potentially impacting fish resources and habitat to mitigate all adverse effects. Applicants must first take all reasonable steps to avoid habitat damage, and second, take all reasonable steps to minimize any unavoidable habitat damage. Any habitat which is unavoidably damaged or lost must be replaced to its full productive capacity using proven methods. First, WDF would like to commend Pope Resources on their proposed usage of sewage pump stations, both portable and stationary, dye tablets to detect illegal sewage discharge, and education programs providing help to boaters in need of pumpout services. This type of program serves as a model for the entire state. The plans for the pond however, remain a concern to WDF. The opera- tion and maintenance of this facility requires the use of Hood Canal marine waters to manage the temperature, thereby controlling the growth of algae and associated nuisances. There is also some specu- lation that aeration of the water that spills from the reflecting LOG ITEM 4-Co If oel # Page o ~.e-'H' . . Jefferson County Page 2 May 18, 1993 pond into the main pond and transplanting eelgrass that would compete with the ulva will improve water quality in the pond. ~he water being returned to Port Ludlow over the weir structure would have to be the quality of the water being removed from the marine system through the proposed filtered hydraulic pumps. Improving water quality through aerating the water in the manner described and transplanting eelgrass is speculative and would require proven success before approval could be granted. Of concern also is where the donor stock for eelgrass would come from. Under no circumstances will WOF allow salt water pond construction if any of the current measures of algae control have to be continued. It remains unclear as to the permeability of the dike to saltwater once the proposed project is built. Is it not possible to reduce the seepage of saltwater into the system so that it could be a closed stable system for freshwater only? WOF would like to reiterate that a closed system would improve the water quality of Port Ludlow Bay, could be more efficiently integrated into the stormwater design, and eliminate any potential problems with unwanted algal formations. The only salt water option that would be acceptable to WOF at this time would be a system that is completely open such as the pocket beach cove as suggested in a prior response. One final concern WOF continues to have is the proposal for dredging for the marina expansion. Mitigation for such projects is extremely difficult to accomplish. Every effort to expand the marina should be made without the condition for dredging. For instance, the proponent may want to consider designating certain areas of the boat basin for "SHALLOW ORAFT VESSELS ONLY". We appreciate your cooperation in our efforts to protect, perpetuate and manage the fish resources of the state of Washington. Thank you for the opportunity to provide these comments. If you have any questions please call me at (206) 895-4757. Sincerely, P.~~'3~ ~'- John Boettner Regional Habitat Manager Habitat Management oivision JB:jb:20:May:lh cc: R. Timothy Flint - WOF Barbara Ritchie - OOE Tom Luster - OOE ., Mr. Rose January 12,2000 Page 3 e e cc: WRIA File, Olympia Jefferson County (Peters) DNR (Shreck) CoE (Gosset) DoE (Stewart) LOG ITEhil if ~0 Page '3 01. ~