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David W. Johnson
From: Paul Anderson [panderson@parametrix.com]
Sent: Friday, November 04,2005 1 :19 PM
To: David W. Johnson
Cc: jparker@jeffpud.org
Subject: Fwd: HDD and Corps permitting for Marrowstone Isl water
RECEIVED
HOV 0 4 2005
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Paul S. Anderson
Wildlife Biologist
Parametrix, Inc.
Email: panderson@parametrix.com
Phone: (425) 458-6279
Fax: (425) 458-6363
>>> "Paul Anderson" <panderson@parametrix.com> 11/4/2005 1 :14:33 PM >>>
David:
Thank you for calling me this morning to discuss the Marrowstone Island Water System project. I think this is a
very interesting project and I am always glad to be of help.
In reference to horizontal directional drilling (HDD) and permitting for the Marrowstone Island Water System
installation, I called the U.S. Army Corps of Engineers (Corps) Seattle District Office for clarification on whether
a Section 404 nationwide permit would be required for boring beneath wetlands and tidal waters. Beth Coffee,
Acting Section Chief, South Section, from the Corps Seattle District Regulatory Branch, left a voicemail saying
that a Section 10 permit (Rivers and Harbors Act of 1899) will be required for boring beneath the SR 116
causeway between Marrowstone and Indian Islands. The waters beneath the causeway are tidal, marine
waters. Tidal waters are considered navigable waters of the U.S. and under the Corps jurisdiction and
permitting authority.
Issuing a Corps permit is a federal action that will trigger the requirement for preparation of a biological
evaluation (BE). The completed BE should be submitted to the Corps with the JARPA. One of the Corps
project managers that I spoke to earlier this week, thought that submitting a brief project description,
including drawings, would assist the Corps in making a determination on required permits. In the 3 areas where
HDD is anticipated for water line installation (Wetland 2 at Schwartz Road, wetlands on the east side of SR 116
in Nordland, and along the SR 116 causeway between Marrowstone and Indian Islands), I believe Corps permits
will only be required for work at the causeway and possibly Nordland. I think, given the location and topography
of the Schwartz Road wetlands, the Corps would rule Wetland 2 as an isolated and non-jurisdictional wetland.
In environmentally sensitive areas, HDD is an accepted alternative to conventional open trenching for utility
installation, with significantly less disturbance to vegetation, water quality, and surface topography. The process
of HDD includes establishing entry and exit pits for the drill bit; drilling the pilot hole; attaching a larger diameter
reamer to the drill bit and pulling it, along with the utility pipe back through the pilot hole. For installation of large-
diameter pipe, geotechnical studies are recommended to help determine the bore depth and identify occlusive
layers or bedrock. Ideally, an impermeable layer of soil overlays the bore to reduce the risk of frac-out (where
drilling muds are released to the surface).
For the Marrowstone project, I would anticipate that entry and exit pits will be established in upland areas along
the road shoulder and other than the risk of unintentional frac-out, there will be no direct impacts (clearing,
discharge of fill) to wetlands or shoreline areas as a result of HDD.
I attended an ESA workshop in 2003, at which Mike Grady, NOAA Fisheries Northwest Regional Office, stated
that from an ESA standpoint, NOAA Fisheries prefers HDD for utility installation. There is much less risk to fish
and fish habitat than in-water work.
11/612005
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, I will be contacting HDD contractors in the near future for more specific information on anticipated boring depth
and potential noise levels associated with boring. If you have any other question about boring or the wetlands
delineation report, please let me know.
Paul
Paul S. Anderson
Wildlife Biologist
Parametrix, Inc.
Email: panderson@parametrix.com
Phone: (425) 458-6279
Fax: (425) 458-6363
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