HomeMy WebLinkAbout935700024 - 175 N Beach Dr - FLOOD (0003)
Peninsula Environmental Group, Inc.
824 E. 8th St. Suite D | Port Angeles WA 98362
(360) 504-3825 | www.peninsulaeg.com
WA Contractor ID: PENINEG813MC
May 7, 2021
Client
Guillermo Mendoza Gonzales & Angelina Mendoza
PO Box 79 | Tenino, WA
360.451.7979 | angelinamcm@yahoo.com
Project Addresses
175 N Beach Dr | Port Ludlow, WA 98365
Jefferson County Parcel: 935700024
Consultants
Liz Donadio, Wetland Scientist & Botanist
Kia Sutter, GIS Analyst & Biologist
Report Compliance
FEMA Floodplain Habitat Assessment
Wetland Review Area Assessment
No-Net-Loss Assessment
Habitat Management Plan
Contents
1 Executive Summary ............................................................................................................................... 4
2 Proposed Activity and Construction Methods ...................................................................................... 6
2.1 Description of Work ...................................................................................................................... 7
3 Background ........................................................................................................................................... 8
3.1 Methods ........................................................................................................................................ 9
4 Existing Conditions .............................................................................................................................. 10
4.1 Site History and Properties ......................................................................................................... 10
4.2 Soils ............................................................................................................................................. 11
4.3 Vegetation ................................................................................................................................... 12
4.4 Hydrology .................................................................................................................................... 14
5 Critical Areas Assessments .................................................................................................................. 15
5.1 Wetland Assessment ................................................................................................................... 15
5.2 Shoreline ..................................................................................................................................... 16
5.3 Habitat Conservation Areas and Habitat Assessment ................................................................ 17
5.3.1 Listed Species, Critical and Priority Habitats ....................................................................... 17
5.3.2 Fish and Wildlife Conservation Areas ................................................................................. 24
6 Effects of Proposed Action .................................................................................................................. 25
6.1 Effects on Listed Species and Critical Habitats............................................................................ 25
6.1.1 Potential direct effects include the following: .................................................................... 25
6.1.2 Potential indirect effects include: ....................................................................................... 25
6.2 Potential Effects to the AE FEMA Flood Zone ............................................................................. 26
6.3 Potential Effects to the Residential Shoreline Designation ........................................................ 27
7 Regulatory Setting ............................................................................................................................... 28
7.1 Federal Regulation ...................................................................................................................... 28
7.2 County Regulation ....................................................................................................................... 28
7.2.1 Shoreline ............................................................................................................................. 28
7.2.2 FEMA Flood Zone ................................................................................................................ 29
7.2.3 FWHCA – Squamish Harbor ................................................................................................ 29
7.2.4 Additional Setbacks ............................................................................................................. 29
8 Conclusions ......................................................................................................................................... 30
9 Closing Remarks .................................................................................................................................. 31
9.1 About the consultants: ................................................................................................................ 31
10 General Assumptions and Limitations ................................................................................................ 32
11 References and Resources .................................................................................................................. 33
Appendix A – Site Photos ............................................................................................................................ 35
Appendix B – Habitat and ESA Documentation .......................................................................................... 37
Appendix C – Wetland Determination Forms ............................................................................................. 49
Appendix D – Mitigation Strategies ............................................................................................................ 51
A.D.1 Mitigation Actions and Timeline ................................................................................................... 51
A.D.2 Impact Avoidance and Minimization ............................................................................................ 52
A.D.3 Reducing and Compensating ......................................................................................................... 52
A.D.3.1 Mitigation Zones .................................................................................................................... 52
A.D.4 Monitoring & Contingency Plan .................................................................................................... 53
A.D.4.1 Performance Standards .......................................................................................................... 53
Appendix E - Noxious Weed Control ........................................................................................................... 55
A.E.1 Noxious Weed Control Board ........................................................................................................ 55
A.E.3 Onsite Noxious Weed Control ....................................................................................................... 55
Noxious Weeds Onsite ........................................................................................................................ 55
Appendix F – Soil Rehabilitation and Native Plant Restoration .................................................................. 57
A.F.1 Soil Rehabilitation Guidelines ........................................................................................................ 57
A.F.2 Plant Installation Guidelines .......................................................................................................... 57
A.F.3 Plant Schedule ............................................................................................................................... 58
Appendix G - Critical Areas and Mitigation Maps ...................................................................................... 59
Tables
Table 1. Summary of Critical Areas within Project Vicinity ........................................................................... 4
Table 2. Land use change across site ............................................................................................................ 6
Table 3. Summary of estimated permanent impact and mitigation within critical areas ............................ 6
Table 4. Site properties as of assessment date........................................................................................... 10
Table 5. Summary of wetland indicator status ratings ............................................................................... 12
Table 6. Onsite Upland Plant Species Observed ......................................................................................... 13
Table 7. Wetland Assessment Summary ..................................................................................................... 15
Table 8. Shoreline information table .......................................................................................................... 16
Table 9. Occurrence of listed species and critical habitats in or near project area .................................... 18
Table 10. Summary of estimated permanent impact and mitigation within critical areas ........................ 28
Table 11. Mitigation timeline ...................................................................................................................... 51
Table 12. Mitigation plant list ..................................................................................................................... 58
Photos
Photo 1. Jefferson County mapped wetland area. ..................................................................................... 15
Photo 2. Upland, DP-1. ................................................................................................................................ 15
Photo 3. Existing wooden bulkhead, view from south looking north. ........................................................ 16
Photo 4. Patchy fringe salt marsh mapped by DOE Coastal Atlas. ............................................................. 16
Photo 5. Project Site. View from west looking east towards North Beach Drive. ...................................... 35
Photo 6. Native Douglas-fir near N Beach Drive, to be retained. ............................................................... 36
Figures
Figure 1. National Wetland Inventory map (Above) and Jefferson County mapped wetlands (below). ... 37
Figure 2. Water Quality Atlas listed 303(d) within vicinity of Project Area. ............................................... 38
Figure 3. Water Quality Atlas Puget Sound Nutrient Source Reduction Project (in development). .......... 39
Figure 4. IPaC USFWS listed T&E species near Project Area. ...................................................................... 40
Figure 5. NOAA mapped T&E species within Project Area: Boccaccio, Steelhead, Chinook and Chum. .... 43
Figure 6. WDFW PHS Map and species overview ....................................................................................... 45
Figure 7. WDFW SalmonScape mapped T&E species near Project Area. ................................................... 46
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 4 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
1 Executive Summary
Angelina and Guillermo Mendoza (the “Client”) requested Peninsula Environmental Group, Inc. (the
“Consultant”) to conduct a Habitat Assessment at 175 N Beach Dr, Port Ludlow, WA 98365, Jefferson
County parcel number 935700024 (the “Project Area/Site”). The Client intends to develop the site with a
single-family residence and garage.
This report and assessment comply with Jefferson County Code (JCC) Chapter 18.22 and 18.25 Shoreline
Master Program (SMP) and is prepared to ensure that development does not result in unintentional
impacts to critical areas and that all known impacts are assessed. The 0.13-acre (5,662-sqft) parcel
contains, or is near, the following critical areas:
A portion of the Site lies within the FEMA Flood zone AE. AE designation is considered a high-risk area
with occasional flooding. According to Chapter 15.15 JCC and Articles IV and IX, Chapter 18.22 JCC, the
Client is required to submit a Habitat Assessment prepared by a professional biologist. The Habitat
Assessment included in this report has been prepared in accordance with FEMA Guidelines from the
publication, Floodplain Habitat Assessment and Mitigation: Regional Guidance for the Puget Sound Basin
(FEMA 2013).
This Habitat Assessment also complies with the Jefferson County Critical Areas Code with regard to
preparation of a Habitat Management and Mitigation Plan (JCC 18.22). The requirements for projects
within the buffer zones of sensitive areas under the JCC are to demonstrate that mitigation of Project
effects constitutes "No Net Ecological Loss" of habitat. This is also the criteria for compliance with FEMA
Floodplain Habitat Assessment and Mitigation (FEMA 2013).
During the site investigation on April 4th, 2021, no threatened, endangered, candidate or priority species
and associated habits were observed with the review area during the site visit. The onsite wetland
Table 1. Summary of Critical Areas within Project Vicinity
Critical Area (CA) Designation
Jefferson
County Buffer
Size
Size of CA
(sqft) Onsite
Estimated Size
of Permanent
Impact (sqft) in
CA
Shoreline Designation Shoreline Residential 150-ft + 10-ft
setback 5,662 1,920
FEMA Flood Zone AE
Base flood 13-feet N/A 1,412 225
Squamish Harbor Fish and Wildlife
Habitat Conservation
Area (FWHCA) 150-ft 5,662 1,920
Geohazard Area Seismic Hazard To be determined by a geotechnical engineer
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 5 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
determination plot rendered upland results; no wetlands are located onsite. The proposed Project Area
currently provides low levels of ecosystem functions and values as it is cleared and disturbed and is
dominated by non-natives in the lower strata and does not have critical habitat.
However, some federally listed species could potentially occur near the Project Area within adjacent
Squamish Harbor FWHCA and Hood Canal.
If the guidelines and mitigating measures in this report are followed, we find the proposed project will
result in a No-Net-Loss of shoreline function, and there will be No Effect to listed species or their habitats
on the parcel. Mitigation and shoreline enhancement activities will include noxious plant control and
native plant installation. These mitigation activities will occur within the outlined Mitigation Zone totaling
1,510-sqft within the FEMA Flood Zone, residential shoreline, and 150-feet (ft) FWHCA buffer.
The Project Area/Site lacks a community of native vegetation, and mostly lacks shrub and tree strata. By
installing groundcover, shrubs, and trees where possible, a healthy, multistoried, plant community can be
established. This community will be maintainable while still providing a variety of services including,
interception of rainwater preventing some from reaching the ground, aiding in infiltration, helping bind
soil and increasing soil cohesion, and providing habitat.
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 6 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
2 Proposed Activity and Construction Methods
Impervious Surfaces:
1. The Site currently is undeveloped. Existing driveway and parking impervious surface are 340-
square feet (sqft).
2. The total permanent land disturbance, impervious surface proposed for the project is 1,920-sqft.
3. Temporary land disturbance, the development envelop, is 1,220-sqft.
4. Primary dwelling proposed 1,220-sqft is proposed partially within the AE FEMA flood zone, entirely
within the FWHCA 150-ft buffer and residential shoreline.
5. Gravel driveway of 700-sqft leading to the proposed single-family dwelling is proposed entirely
within the FWHCA 150-ft buffer and residential shoreline.
6. Permanent and temporary land disturbance will be mitigated for with noxious weed control and
native plant installation of 330 plants: 39 small trees and shrubs and 291 subshrubs, forbs, and
grasses.
Table 2. Land use change across site
Surface Total Existing
Surfaces (sqft)
Total Future Surfaces
(sqft)
Difference in Existing
and Future (sqft)3
Impervious Surfaces1 340 2,260 1,920
Lawn/Non-native Vegetation 5,022 3,112 (1,890)
Native Vegetation4 300 270 (30)
1 Impervious surfaces include dwellings, garage, deck, hardscape, and packed-gravel driveways.
2 Mitigation to include: 1. Soil rehabilitation 2. Removal of noxious weeds 3. Installation of native plants
3 Size of new construction 4 Pre-mitigation
Table 3. Summary of estimated permanent impact and mitigation within critical areas
Critical Area Total Size of Critical
Area on Site (sqft)
Size of Permanent
Impact (sqft) in
Critical Area
Mitigation within
Critical Area (sqft)
Residential Shoreline 5,662 1,920 1,510
FEMA Flood Zone 1,414 225 1,150
FWHCA – Squamish Harbor Inlet 5,662 1,920 1,510
Total Mitigation Area 1,510-sqft
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 7 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
2.1 Description of Work
Construction: Construct a single-family residence, garage and driveway designed by LexarHomes.
Access: A private road, North Beach drive abuts the site and will be used for all staging and construction
activities. Squamish Harbor will not be used as an access to the site.
Staging Areas: All work and staging will be accomplished without disturbing any native woody vegetation.
All equipment and materials will be staged in the lawn dominated by non-native grass and forb species.
All work is being performed outside of the Ordinary High-Water Mark (OHWM).
Site Preparation: Establishment of temporary erosion and sediment controls (TESC). No tree or woody
vegetation removal necessary.
Stormwater controls/Management: Stormwater management will be designed to follow Jefferson County
stormwater requirements. The Client will work with their builder to incorporate the necessary stormwater
management protocols into the construction plan.
Filling and Grading: The project site is relatively flat, and the project site will require minimal site grading.
Fill will be placed as necessary for structural integrity.
Equipment: Equipment will likely include excavators, dump trucks, grading equipment, concrete mixers,
and powered hand tools.
Running of equipment during construction: Mechanical equipment will be operated only during daylight
hours.
Construction materials to be used: Drain rock, gravel, concrete, and standard house-building materials.
Location of disposal: All construction debris will be removed and disposed of offsite at an approved
disposal location and no burning of any materials will occur onsite.
Vegetation and Mitigation: Approximately 1,920-sqft of non-native herbaceous cover will be removed
and replaced with impervious surface. Plantings of native herbaceous and woody plants will compensate
for habitat alteration for residence and other improvements. A total of 330 native plants will be installed:
39 small trees and shrubs and 291 herbaceous cover and subshrubs will be installed. These plantings will
be located mostly within 23-ft of the shoreline to restore and enhance ecological functions on the Site.
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 8 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
3 Background
Purpose of Project
• Evaluate baseline environmental conditions at property.
• Delineate ordinary-high-water-mark (OHWM) of Puget Sound.
• Conduct a habitat assessment.
• Determine specific impacts of site development.
• Apply proper mitigation sequence consideration to potential impacts of development.
• Provide a site-specific impact analysis report, including mitigation plan for proposed impacts.
Professional Assumptions & Limitations
This report summarizes the data collected during the Consultant’s site assessment, conversations
regarding the project, and the Consultant’s professional opinions and recommendations. The results and
recommendations contained in this report represent the Consultant’s professional opinion derived from
biological forensics, information provided to the Consultant, referenced material and the Consultant’s
experience. The Consultant’s recommendations are compiled using industry standards, best available-
science and currently accepted best management practices.
• Consultants visited the Site on April 4th, 2021. This report summarizes site characteristics as they
were observed this day only.
• This report is intended for the exclusive use of the Client and their agents and only for specific
application to the referenced property. This report should not be applied to any other property
for any purpose.
• Field GPS points were gathered using the Juniper Geode GNS2, with sub-meter accuracy.
• Geospatial analyses were made using ESRI ArcGIS using projected coordinate system NAD83 2011
US Feet for Washington State (North).
• Parcel, contour, and critical area layers were sourced from Jefferson County GeoData Center.
• Climate data was gathered from the USDA Natural Resources Conservation Service (NRCS)
National Water Climate Center (2021).
• Further General Assumptions & Limitations can be found in Closing.
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 9 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
3.1 Methods
FEMA Floodplain Habitat Assessment
The FEMA Flood zone is assessed through the National Marine Fisheries Services Biological Opinion (NMFS
BiOp) and Floodplain Habitat Assessment and Mitigation manual (FEMA 2013). This report was prepared
using JCC 18.22.950 Habitat management reports and JCC Chapter 18.25 SMP. Lists of federally and state
listed Threatened and Endangered Species (T&E Species) were reviewed using websites of the U.S. Fish
and Wildlife Service (USFWS 2021), the National Marine Fisheries Service (NMFS 2021), the National
Oceanic and Atmospheric Administration website (NOAA 2021), and the Washington Department of Fish
and Wildlife (WDFW 2021).
The National Floodplain Insurance Program (NFIP) requires no specific format for reports, however there
is a recommended outline discussed in the FEMA guidance document (FEMA 2103).
Wetland Assessment
Wetlands shall be delineated in accordance with the requirements of RCW 36.70A.175 (JCC 18.22.710).
Wetland determinations are conducted in accordance with the Regional Supplement to the Corps of
Engineers Wetland Delineation Manual: Western Mountains, Valleys, and Coast Region (Corps, 2010) and
the Corps of Engineers Wetland Delineation Manual (Environmental Laboratory, 1987).
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 10 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
4 Existing Conditions
4.1 Site History and Properties
• The parcel is privately owned by Guillermo Mendoza Gonzales & Angelina Mendoza, purchased
September 18 2018.
Table 4. Site properties as of assessment date.
County Jefferson
Parcel 935700024
Legal Description BRIDGEHAVEN DIV 7 25
Lat/Long 47.837, -122.686
Total Site Acreage 0.13
Township/Range/Section T27N/R1E/S16
Zoning RR-5 Rural Residential
Land Use Code 9800 - Garages, Outbuildings, Other Imps (dock)
Elevation 11.4 to 13.2 feet, flat
Existing Structures None
Jefferson County Mapped
Critical Areas
Onsite and Offsite Wetlands
Shoreline Jurisdiction
FEMA flood Zone – AE
Site Visit Conditions The weather was primarily clear during the site assessment. There was 5-
7mph winds with temperatures around 55°F.
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 11 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
4.2 Soils
A generalized view of the soils present on the property can be found through the Natural Resource
Conservation Service (NRCS) Web Soil Survey. The NRCS shows one soil onsite Lu—Lumni silt loam.
Setting
• Landform: Flood plains
• Parent material: Alluvium and/or marine deposits
Typical profile
• H1 - 0 to 10 inches: silt loam,
• H2 - 10 to 29 inches: silt loam
• H3 - 29 to 60 inches: silt loam
Properties and qualities
• Slope: 0 to 2 percent
• Depth to restrictive feature: More than 80 inches
• Drainage class: Poorly drained
• Capacity of the most limiting layer to transmit water
• Depth to water table: About 12 to 24 inches
• Frequency of flooding/ponding: None
• Available water capacity: High (about 9.7 inches)
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 12 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
4.3 Vegetation
A landscape’s specific plant community is an indicator of common environmental conditions. Hydrophytic
plant communities are those plants adapted to areas of saturation and inundation. The amount of
hydrophytic plants as contrasted to upland plants is a factor in determining wetlands and their
boundaries. Hydrophytic vegetation is determined based on estimates of percent areal cover by plant
species and indicator status ratings of those plant species.
Table 5. Summary of wetland indicator status ratings
Rating (Abbreviation) Designation Definition—Short Version Estimated
Probability
Obligate Wetland (OBL) Hydrophyte Almost always occurs in wetlands > 99%
Facultative Wetland (FACW) Hydrophyte Usually occurs in wetlands, but may
occur in nonwetlands 1% – 33%
Facultative (FAC) Hydrophyte Equally likely to occur in wetlands
and non-wetlands 34% – 66%
Facultative Upland (FACU) Nonhydrophyte Usually occurs in nonwetlands, but
may occur in wetlands 67 – 99%
Upland (UPL) Nonhydrophyte Almost never occurs in wetlands > 99%
Onsite Plant Community
• The Site lacks native vegetation, and lacks shrub and tree strata, with only a single native Douglas
fir tree near Beach Drive.
• The Site is an upland, maintained lawn, and is dominated by facultative, facultative upland and
upland grasses and forbs.
• The Site lacks obligate and facultative wet species indicative of wetland sites.
• Approximately 90+% of vegetation onsite is introduced.
• Several ornamental and garden species including California poppy, sea thrift and grape hyacinth
are scattered throughout.
• See Table 6. Onsite Upland Plant Species Observed.
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 13 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
Table 6. Onsite Upland Plant Species Observed
Common Name Scientific Name Relative
Abundance
Nativity/Weed
Class
Indicator
Status
Upper Strata: Trees
Douglas fir Pseudotsuga menziesii Low Native FACU
Middle Strata: Shrubs
Scotch broom Cytisus scoparius Low Class B FACU
Lower Stata: Subshrubs, Forbs and Grass
Annual bluegrass Poa annua Moderate Introduced FAC
Black medic Medicago lupulina Low Introduced FACU
California poppy Eschscholzia californica Low Introduced FACU
Common daisy Bellis perennis Moderate Introduced FACU
Common dandelion Taraxacum officianale Moderate Introduced FACU
Common sowthisitle Sonchus oleraceus Moderate Introduced UPL
Common velvetgrass Holcus lanatus Moderate Introduced FAC
Common yarrow Achillea millefolium Low Native FACU
Daffodil Narcissus pseudonarcissus Low Introduced NA
Douglas aster Symphyotrichum subspicatum Low Native FACW
Garden vetch Vicia sativa Low Introduced UPL
Goldmoss stonecrop Sedum acre Moderate Introduced NA
Grape Hyacinth Muscari neglectum Low Introduced NA
Kentucky bluegrass Poa pratensis Moderate Introduced FAC
Narrowleaf plantain Plantago lanceolata Moderate Introduced FACU
Miniature lupine Lupinus bicolor Low Native UPL
Purple deadnettle Lamium purpureum Low Introduced UPL
Red clover Trifolium pratense Low Introduced FACU
Redstem stork’s bill Erodium cicutarium Moderate Introduced UPL
Sea thrift Armeria maritima Low Introduced NA
Tall fescue Schedonorus arundinaceus Moderate Introduced FAC
Smooth cat’s ear Hypochaeris glabra Moderate Introduced UPL
White clover Trifolium repens Moderate Introduced FAC
Wild arugula Diplotaxis tenuifolia Low Introduced NA
Wild oat Avena fatua Low Introduced UPL
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 14 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
4.4 Hydrology
Local Conditions
Based on the past 30 years of precipitation data for the CHIMACUM 4 S, WA, WA WETS Station, the
average March precipitation for the site ranges from 2.03 to 3.72 (mean 3.10) inches of rainfall. Hydrologic
indicators represent slightly below normal conditions onsite for this time of year due to the 2.00 inches
of precipitation for the month of March 2021, prior to this assessment.
Water Resource Inventory Area (WRIA): 17 - Quilcene – Snow
Hydrologic Unit Code (HUC): Subwatershed 12-Digit: 171100180704 - Thorndyke Creek-Frontal Hood
Canal
Water bodies bordering or adjacent to project location
• Squamish Harbor and Hood Canal
• No in water work will occur within Squamish Harbor to the west of the Site.
• Hood Canal is located to the north, west and south of the Site and is separated by North Beach
Drive.
Water Quality Atlas
Within the subwatershed of the project area:
1. Hood Canal north is listed as a Category 5 303(d) impaired water body (Figure 2).
2. Puget Sound Nutrient Source Reduction Project (In Development) for Dissolved oxygen,
dissolved inorganic nitrogen, and total organic carbon (Figure 3).
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 15 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
5 Critical Areas Assessments
5.1 Wetland Assessment
The US Fish and Wildlife Service National Wetland Inventory (NWI) mapper shows Wetland System:
Estuarine and Marine Wetland, Code: E2USN offsite. Additionally, Jefferson County has mapped wetland
onsite (Figure 1).
Determination plot 1 (DP-1) was collected within the proposed footprint of development. The
determination plot location is representative of the entire Site and was collected to access the vegetation,
soils, and hydrology. The pit was dug onsite to a depth of ~ 16inches to aid in delineating wetland and
upland. No wetland indicators were observed; there is no wetland onsite.
Table 7. Wetland Assessment Summary
WETLAND DETERMINATION
Photo 1. Jefferson County mapped wetland area.
Photo 2. Upland, DP-1.
Vegetation
Determination Negative dominance test
Species
The site is dominated by FAC,
FACU and UPL grasses and
forbs. The plot was
representative of the plants
onsite.
Soils
Determination Non-hydric
Depth of pit 0-16
Matrix 100% 10YR 3/2
Texture Sand
Hydrology
Determination No indicators present
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 16 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
5.2 Shoreline
The property is located along the shoreline of the Puget Sound (Hood Canal-Squamish Harbor) and is
designated Shoreline Residential (SR) by the Jefferson County SMP.
The shoreline environment is located on the western edge of the Site is a lowbank waterfront and includes
surficial beach face substrate composed of sand, fine to course, granules, and pebbles. The backshore
consists of a 55-foot-long by 12-ft tall wooden vertical seawall, that functions as shoreline armoring and
delineates the OHWM.
Table 8. Shoreline information table
Shoreline Inlet of Squamish
Harbor of Hood Canal
Photo 3. Existing wooden bulkhead, view from south looking
north.
Photo 4. Patchy fringe salt marsh mapped by DOE Coastal
Atlas.
Shoreline
Designation Shoreline Residential
Regulated
Under JCCC SMP 18.25
Size on site 55 linear feet
OHWM
elevation 12 feet
Armoring Armored Wooden
Seawall
Landform No appreciable
landform/drift: Low
energy Driftcell
Stability Stable
Biology Patchy fringe salt
marsh
Sediment N/A
Infrastructure
Dock connected to
parcel but located
offsite to west of
parcel towards
Squamish Harbor.
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 17 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
5.3 Habitat Conservation Areas and Habitat Assessment
5.3.1 Listed Species, Critical and Priority Habitats
The Endangered Species Act (ESA) legally defines Critical Habitat as ‘specific geographic areas that contain
features that are essential to the conservation of an endangered or threatened species and that may
require special management and protection’ (ESA 1973). JCC 18.22 dictates regulation of important
habitats and species in accordance with both ESA listings and Washington State listed species and
associated habitats.
Affecting any threatened or endangered species is considered a "take" under the ESA. A "take occurs if a
listed species is harassed, harmed, pursued, hunted, shot, wounded, killed, trapped, captured, or
collected, or from an attempt to engage in any such conduct.
"Take" comes in two forms: 1) incidental take that is approved through consultation with responsible
federal agency in the form of a Biological Opinion (Section 7), or 2) a Habitat Conservation Plan (Section
10) and unauthorized "take” (Section 9) of the ESA. Habitats used by listed species are also protected by
the ESA, classified as Critical Habitat. Adverse modification of Critical Habitat is also an unauthorized
"take" of the listed species.
Protective regulations prohibiting unauthorized "take" of listed species are known as the 4(d) rules. When
endangered species are listed, the prohibition of unauthorized "take" is also made effective at the same
time. In addition, protective regulations for threatened species may be published later after listing.
A species and habitat list for the project site was compiled from USFWS, WDFW, NOAA and NMFS and
WDNR. Data for this project was accessed on the appropriate websites in April 2021. This list is compiled
below in Table 9. According to:
1. USFWS IpaC database, there is no critical habitat within the Project Area.
2. NOAA fisheries Protected Resources database, there are four federally listed Critical Habitats
found near the Project Area within Squamish Harbor and Hood Canal.
o Bocaccio, Chinook, Chum, and Steelhead (Figure 5).
3. WDFW PHS maps the areas adjacent to the subject parcel as priority habitat for
o Oyster beds and Estuarine and Marine Wetland (Figure 6).
4. WDFW SalmonScape database, there are four salmonid species mapped within the Project Area.
o Chum, Coho, Pink(odd year), Steelhead (Figure 7)
5. WDNR Natural Heritage Program – WA Wetlands of High Conservation Value
o No locations of unique and high value wetlands and plant species at risk were mapped
within project vicinity.
During the Site visit no threatened, endangered, candidate or priority species and associated habits were
observed with the review area. However, some federally listed species could potentially occur near the
Project Area.
It is expected that the proposed action with mitigation strategies will have No Effect on listed species
and will not destroy or adversely modify critical habitat for listed species.
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 18 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
Table 9. Occurrence of listed species and critical habitats in or near project area
Species, ESU 1or DPS2 Status Data
Source
Designated
Critical
Habitat
Designated
Priority
Habitat
Effects
Determination
INVERTEBRATES
Oyster beds State: Candidate WDFW NO NO No Effect
FISH
Bocaccio2 State: Candidate
Federal: Endangered
NOAA
Fisheries YES NO No Effect
Bull Trout State: Candidate
Federal: Threatened
NOAA
Fisheries NO NO No Effect
Dolly Varden Not listed NOAA
Fisheries NO NO No Effect
Salmon, Chinook,
Puget Sound1
State: Threatened
Federal: Threatened
NOAA
Fisheries YES NO No Effect
Salmon, Chum, Hood
Canal1
State: Threatened
Federal: Threatened
NOAA
Fisheries YES NO No Effect
Salmon, Coho1 Not listed NOAA
Fisheries NO NO No Effect
Salmon, Pink (Odd Year)1 Not listed WDFW NO NO No Effect
Steelhead, Puget
Sound2
State: Candidate
Federal: Threatened
NOAA
Fisheries YES NO No Effect
BIRDS
Marbled murrelet State: Endangered
Federal: Threatened
WDFW,
USFWS NO NO No Effect
Streak horned lark State: Endangered
Federal: Threatened
WDFW,
USFWS NO NO No Effect
Yellow-billed cuckoo State: Endangered
Federal: Threatened
WDFW,
USFWS NO NO No Effect
PLANTS
Golden Paintbrush State: Threatened
Federal: Endangered
WDFW,
USFWS NO NO No Effect
HABITAT
Estuarine and Marine
Wetland Not listed WDFW N/A No No Effect
1 ESU: Evolutionarily Significant Unit which include Pacific salmon.
2 DPU: Distinct Population Unit
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 19 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
5.3.1.1 Invertebrates
Oyster beds – Potentially Olympia Oyster (Ostrea lurida)
The Olympia oyster is the only oyster species native to the Pacific Northwest. It is reported to occur from
Panama to Sitka, Alaska. Although some populations thrive in pure seawater, this oyster’s preferred
habitat is usually restricted to bays and estuaries with brackish water, with salinities no lower than 23 to
24 parts per thousand. In Washington state, prolific natural beds have historically existed in Willapa Bay,
Samish Bay and throughout the maze of inlets in southern Puget Sound. Priority Species Criteria:
Vulnerable Aggregations and Species of Recreational, Commercial, and/or Tribal Importance.
• Oyster beds are mapped by PHS sourced from WDFW within Squamish Harbor to east of Site and
within Hood Canal to the west.
• It is expected that the proposed action will have No Effect on oyster beds and will not destroy or
adversely modify habitat for oyster beds.
5.3.1.2 Fish
There are 8 listed fish species, 4 with listed critical habitat, and 3 with priority habitat.
Bocaccio (Sebastes paucispinis)
Bocaccios are a type of large Pacific coast rockfish. Their historical range is from Baja California to Alaska.
They are slow growing and late to mature, and as such are very sensitive to overfishing and habitat
degradation. The Puget Sound/Georgia Basin DPS is the only bocaccio DPS that is listed as endangered
under the ESA. It was listed as "endangered" in the Puget Sound/Georgia Basin Distinct Population
Segment (DPS) in 2010. Although juvenile rockfish tend to be more than adults in shallower water,
rockfish make their home on the ocean floor, generally between 80 to 820 feet deep. They remain in the
saltwater their entire lives, and do not wander into freshwater streams or rivers. Washington State has
closed many commercial fisheries that caught rockfish incidentally, and there is no direct commercial
harvest of them in Puget Sound. Recreationally, targeting or retaining any species of rockfish in Puget
Sound waters east of the Port Angeles area is not allowed.
• Marine/nearshore Boccaccio (Puget Sound/Georgia Basin DPS) is mapped by NOAA protected
resources within Squamish Harbor to east of Site and within Hood Canal to the west.
• It is expected that the proposed action with mitigation strategies will have No Effect on Bocaccio
and will not destroy or adversely modify critical habitat for Bocaccio.
Bull Trout (Salvelinus confluentus)
Bull Trout are also a salmonid and was listed as "threatened" in 1999. The historical range of bull trout
included Alaska, California, Idaho, Montana, Nevada, Oregon, and Washington. Two forms of bull trout
exist: migratory and resident. Migratory bull trout move to larger bodies of water to overwinter, then
migrate back to smaller water bodies to reproduce, whereas resident bull trout spend their entire lives in
the same stream or creek. There also exists an anadromous form in the Coastal-Puget Sound population,
which spawn in rivers and streams but rear their young in the ocean. Adult migratory bull trout feed
primarily on fish, while resident and juvenile bull trout feed on invertebrates and small fish.
The most common threats to bull trout are loss of historical habitat and fragmentation of remaining
habitat, predation by invasive species, fish passage issues, and rising water temperatures due to climate
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 20 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
change and other natural or manmade factors. Current recovery plans aim to protect the remaining good
habitat and restore what has been degraded to ensure enough connectivity among populations. Bull trout
require cold water to survive, and thus seldom venture into waters above 59-64 degrees Fahrenheit.
Additional Primary Constituent Elements (PCEs) of the species include stable stream channels, clean
spawning and rearing gravel, complex and diverse cover, and unblocked migratory corridors.
• It is expected that the proposed action with mitigation strategies will have No Effect on Bull Trout
and will not destroy or adversely modify critical habitat for Bull Trout.
Dolly Varden (Salvelinus malma)
Dolly Varden were previously considered a subspecies of S. alpinus by some authors but recently has been
treated as a distinct species. Recent genetic work indicates that Salvelinus malma may not warrant species
status. Though similar to, and often confused with, trout, Dolly Varden are actually a char (Salvelinus sp).
Char have light spots (white or yellow to red) on a dark body, while trout have dark spots (brown to black)
on a light body.
Juvenile Dolly Varden (and freshwater-resident adults) vary in color depending on the waters they inhabit.
In clear streams and lakes, young Dolly Varden are usually olive-brown, but in glacial streams they are
pale silver-gray. While living in freshwater before going to sea, young Dolly Varden have 8–12 dark,
irregularly-shaped vertical bars (parr marks) on their sides straddling the lateral line. Pale white or orange
to red spots, brightening at the onset of maturity, begin to develop when juveniles reach 3–4 inches in
length.
• It is expected that the proposed action with mitigation strategies will have No Effect on Dolly
Varden and will not destroy or adversely modify critical habitat for Dolly Varden.
Salmon, Chinook - Puget Sound ESU (Oncorhynchus tshawytscha)
Puget Sound Chinook are an evolutionarily significant unit that includes all naturally spawned chinook
salmon originating from rivers flowing into the Puget Sound from the Elwha River eastward, to rivers in
the Hood Canal, South Sound, North Sound, and the Strait of Georgia. It also includes chinook salmon
spawned in hatcheries and other artificial propagation programs located throughout the same region.
Puget Sound Chinook have complex habitat needs. During spawning events in freshwater, gravels must
be a certain size and be free and clear of sediment to allow successful incubation of the eggs. The eggs
also require cool, clean, and well-oxygenated waters. Once eggs hatch, juveniles require abundant food
sources including invertebrates and other small fish, and need places to hide from predators, such as
under logs, root wads, and overhanging vegetation along the stream. Low-flow side channels and deep
pools are also needed to seek refuge from periodic high flows and warm summer waters.
Their time spent in the nearshore environment as adults requires an adequate food supply and cool, clean
water that is free of contaminants and passage barriers.
• Marine, nearshore critical habitat mapped by NOAA Protected Resources within Squamish Harbor
to east of Site and within Hood Canal to the west. Offshore to a depth of 30 meters.
• It is expected that the proposed action with mitigation strategies will have No Effect on Chinook
and will not destroy or adversely modify critical habitat for Chinook.
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 21 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
Salmon, Chum - Hood Canal ESU (Oncorhynchus keta)
The Hood Canal summer chum evolutionarily significant unit includes all naturally spawned populations
of summer-run chum salmon in the Hood Canal and its tributaries, as well as populations in Olympic
Peninsula rivers between Hood Canal and Dungeness Bay. Their habitat requirements and PCES are like
those mentioned above for Puget Sound Chinook.
• Hood Canal summer-run ESU chum are mapped by NOAA Protected Resources and SalmonsScape
within Squamish Harbor to east of Site and within Hood Canal to the west.
• SalmonScape also maps fall-and winter-run Puget Sound\Strait of Georgia Chum Salmon. Offshore
to a depth of 30 meters. Marine/nearshore Strait of Juan de Fuca Population within the
watershed.
• It is expected that the proposed action with mitigation strategies will have No Effect on Chum
and will not destroy or adversely modify critical habitat for Chum.
Salmon, Coho - ESU (Oncorhynchus kisutch)
Coho spawn in small coastal streams and the tributaries of larger rivers. They prefer areas of mid-velocity
water with small to medium sized gravel. Because they use small streams with limited space, they must
use many streams to successfully reproduce. As a result, coho can be found in virtually every small coastal
stream with a year-round flow.
• Puget Sound\Strait of Georgia Coho Salmon mapped by WDFW SalmonScape.
• It is expected that the proposed action with mitigation strategies will have No Effect on Coho
and will not destroy or adversely modify critical habitat for Coho.
Salmon, Pink - Odd year ESU (Oncorhynchus gorbuscha)
Pinks use the mainstems of large rivers and some tributaries, often very close to saltwater. Because their
fry move directly to sea after emerging, the closer they spawn to saltwater the better. The shorter journey
reduces predation and increases survival. In Washington, pink salmon runs only occur in odd-numbered
years.
• Mapped by SalmonScape.
• It is expected that the proposed action with mitigation strategies will have No Effect on Pink and
will not destroy or adversely modify critical habitat for Pink.
Steelhead - Puget Sound DPS (Oncorhynchus mykiss)
Puget Sound Steelhead are a distinct population segment of salmonids that includes naturally spawned
anadromous steelhead originating below natural and manmade fish passage barriers from rivers flowing
into the Puget Sound from the Elwha River eastward, to the Hood Canal, South Sound, North Sound, and
the Strait of Georgia. This also includes steelhead produced in six artificial propagation programs
throughout the same region. Their habitat requirements are like those mentioned above for Puget Sound
Chinook, however no critical habitat has been identified yet.
• Presence/Migration mapped to west and south of site by NOAA Protected Resources and
SalmonsScape. SalmonScape maps winter and summer steelhead populations.
• It is expected that the proposed action with mitigation strategies will have No Effect on Steelhead
and will not destroy or adversely modify critical habitat for Steelhead.
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 22 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
5.3.1.3 Birds
There are three species of birds listed on USFWS ESA species list.
Marbled murrelet (Brachyramphus marmoratus)
The marbled murrelet was federally listed as "threatened" in 1992, with its Critical Habitat designated in
1996. In Washington State, the species occurs in the greatest numbers in the Puget Sound and Strait of
Juan de Fuca. Marbled murrelets are small Pacific seabirds that spend most of their life in the marine
environment, only venturing to old-growth forests for nesting. They feed primarily on fish and
invertebrates found mostly in near-shore marine waters. During the nesting season, the birds find inland
old-growth forests of primarily Douglas-fir. The trees that have large branches to support their nests.
Murrelets nest in tree stands varying in size between several acres to several thousand acres, with large
enough branches to support their nests. They lay one egg per nest and incubate for approximately 30
days. Primary Constituent Elements (PCEs) for this species include old-growth stands of primarily Douglas-
Fir located within 50 miles of the marine environment, and nearshore marine waters that are free of
contaminants and pollutants, with adequate food supplies.
Threats to the species include loss of suitable nesting habitat due to commercial timber harvest,
predation, oil spills and other marine pollutants, disease, and gill-net fishing operations. Monitoring
programs began in 2000 as part of the Northwest Forest Plan and has continued annually. All efforts to
date show a long-term downward trend on the population of this species.
• Marbled Murrelets are not mapped by Jefferson County within the project area or within 2 miles
of the site.
• Since the Project Site is located near the shoreline of Puget Sound, it is possible that there are
nests of the marbled murrelet in the vicinity. However, there were no observed nests within 200
feet of the Project Site during field survey, and since the proposed Project is the construction a
single garage on an already developed parcel, our determination is that the Project "may affect,
not likely to affect" this species.
• No habitat associated with marbled murrelet would be disturbed, and it is expected that the
proposed action will have No Effect on marbled murrelet and will not destroy or adversely modify
critical habitat for marbled murrelet.
Streaked horned lark (Eremophila alpestris strigata)
The streaked horned lark was federally listed as a "candidate" for listing under the ESA in 2001. As of 2012,
it is still under review to be listed as "threatened" in the future. This species is endemic to the Pacific
Northwest. They are small, ground-dwelling birds that feed on a variety of seeds and insects and tend to
select habitats based on the structure of the vegetation. The current range of the species is divided into
three regions: 1) the Puget lowlands in Washington, 2) the Washington coast and lower Columbia River
islands, and 3) the Willamette Valley in Oregon. The largest known populations breed in the southern
Willamette Valley. Historically, the species’ range extended from southern British Columbia, south
through the Puget lowlands and outer coast of Washington, along the lower Columbia River through the
Willamette Valley, down the Oregon coast and into the Umpqua and Rogue River valleys of southwestern
Oregon.
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 23 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
Ongoing threats to this species include a loss of habitat from conversion to agriculture and industry, a loss
of natural disturbance processes like fires and floods, encroachment of woody vegetation, and invasion
of coastal areas by non-native beach grasses. Other threats include inbreeding depression and low
reproductive success, which are leading to declining population sizes.
Associated critical habitat and PCEs of the species includes wide open spaces with no trees and little to no
shrubs. They nest on the ground in areas dominated by grasses and forbs, typical of native prairies,
grasslands, estuaries, coastal dunes, fallow and active agricultural fields, and airports. Most of the
landscapes used by streaked horned larks are in sizes of 300 acres or more.
• Topography and vegetation in the immediate area surrounding the Site is not conducive to the
lark's preferred nesting requirements.
• We determine there will be No Effect to streaked horned lark.
Yellow-billed cuckoo (Coccyzus americanus)
The yellow-billed cuckoo is a medium sized bird that feeds primarily on large insects including cicadas and
tent caterpillars. Historically, the species bred throughout much of North America, however data suggests
that within the last 50 years, the distribution of the species west of the Rockies has declined substantially.
This decline can be attributed to a loss of streamside/riparian habitat due to agriculture, dams, river flow
management, overgrazing, and competition from non-native plants. Washington is listed as possibly
extirpated (SH).
• Associated habitat for the species includes dense willow and cottonwood stands in river
floodplains. No critical habitat currently exists for this species; however, it has been proposed.
• We determine there will be No Effect to yellow-billed cuckoo.
5.3.1.4 Plants
Golden paintbrush (Castilleja levisecta)
Golden paintbrush is a short-lived perennial herb in the figwort family, typically living 5-6 years. It
reproduces exclusively by seed, which matures in August and is dispersed in the fall. Historically, it has
been reported from more than 30 sites across the Puget Trough of Washington, British Columbia, and the
Willamette Valley of Oregon. Many populations have since been extirpated due to agricultural, residential,
and commercial development. Only two populations of the species remain on small islands near Victoria,
BC, and nine populations remain in Washington.
The species occurs primarily in upland prairies within relatively flat grasslands. In Washington, all the
known populations are found on soils that have been derived from glacial origins. Historically, this habitat
was maintained in part through periodic burns to suppress encroaching woody vegetation. Competition
from native and non-native woody plants because of fire suppression is now a serious threat to the golden
paintbrush. Trampling, collection of the plant at public sites, and herbivory also threaten the recovery
efforts of the species.
• No golden paintbrush was observed onsite. The Project area is highly disturbed, and harbors very
few natives plant species.
• We determine there will be No Effect to golden paintbrush.
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 24 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
5.3.1.5 Habitat
Estuarine and Marine Wetlands
There are no known estuarine and marine wetlands within the project area, and as such, the
proposed action will have No Effect on wetlands. Refer to the Wetland Assessment in Section
5.1 for wetland determination.
5.3.2 Fish and Wildlife Conservation Areas
Fish and wildlife habitat conservation areas (FWHCAs) are areas that serve a critical role in sustaining
needed habitats and species for the functional integrity of the ecosystem, and which, if altered, may
reduce the likelihood that the species will persist over the long term. FWHCAs include those areas
identified as being of critical importance to the maintenance of endangered, threatened, or sensitive
species of fish, wildlife or plants, or designated habitats and species of local importance (JCC 18.22.610).
5.3.2.1 Squamish Harbor Inlet
Squamish Harbor Inlet abuts the Project Area along the OHWM of the wooden bulkhead.
• Squamish Harbor has been mapped as critical habitat by NOAA and WDFW for federally listed
species (endangered and threatened) and state-listed species (endangered, threatened, and
sensitive species) which qualifies as a FWHCA under JCC 18.22.610.a.
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 25 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
6 Effects of Proposed Action
6.1 Effects on Listed Species and Critical Habitats
The project area was surveyed for the potential direct and indirect effects of the proposed project, as
described in Section 4.1 of the FEMA Regional Guidance Manual for the Puget Sound Basin (2013).
A complete review and anticipated impacts are discussed in Section 5.3 Habitat Conservation Areas and
Habitat Assessment.
6.1.1 Potential direct effects include the following:
Permanent clearing and grading of any habitat area, temporary clearing and grading of any habitat area
during construction, permanent structures, pavements, etc., constructed within or placed within a habitat
area, and diversion of water that will change the hydrologic or sediment regime in the project action area.
6.1.2 Potential indirect effects include:
Disrupting high or low stream flows, including impacts from stormwater runoff, contributing to
sedimentation that fills in substrate, blocking a corridor that connects habitat areas, increases in water
temperature, or degradation of chemical or biologic water quality parameters through removal of riparian
vegetation or other actions, disturbance of riparian vegetation (for example, clearing vegetation to the
edge of a forested riparian area), moving or removing large woody debris, destabilizing banks, or altering
natural lateral or vertical channel migration or channel forming processes, and degrading wetland areas
through disturbance of adjacent vegetation or modification of hydrology.
• Proposed development resides within Residential Shoreline designation of the Puget Sound, and
potential impacts are discussed below.
• The increase in impervious surface will be managed through onsite stormwater management and
native plant restoration.
Potential Direct Effects to ESA listed species
No permanent direct effects to the habitat area of the ESA listed species will occur as a result of this
project. The development of the SFD will result in 1,920-sqft of impervious surface but there are no critical
habitats within the location of the proposed site development. 330 native plants will be installed as
mitigation to ensure no loss of habitat function will occur as a result of the increase in impervious surfaces.
Furthermore, the proposed Project Area currently provides low levels of ecosystem functions and values
as it is cleared and disturbed and is dominated by non-natives in the lower strata and does not have critical
habitat. There will be no modifications to any waterbodies in the project area.
1. As a result, there will be No Effect on the listed species and their associated habitats.
Potential Indirect Effects to ESA listed species
No permanent indirect effects to the habitat area of the ESA listed species will occur as a result of this
project. Through the implementation of onsite stormwater management, no changes, or disruptions to
existing high or low flows will occur. The project will utilize BMP erosion control methods which will
prevent sediment and pollutants from the project site from entering surface waters. Therefore, we do not
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 26 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
anticipate any water quality changes to surface waters or waterbodies within or adjacent to the project
area.
2. As a result, there will be No Effect on the listed species and their associated habitats.
6.2 Potential Effects to the AE FEMA Flood Zone
Water Quality and Quantity: The proposed development will have No Effect on water quality or quantity
to the nearshore marine environment of Squamish Harbor – Hood Canal. Stormwater from impervious
surfaces will be managed onsite and will not lead to increased stormwater discharge or runoff offsite.
There will be no change to water temperatures from this development, as there is no removal of
vegetation that results in decreased shading of any bodies of water.
Flood Volumes and Velocities: The proposed development will have No Effect on low-flow hydrologic
regimes, due to the separation of the Site from the nearest body of water. Because it is located within a
100-yr floodplain, there is the possibility of some modification to the high-flow hydrologic regime during
flood events due to an increase in impervious surfaces. These impacts, however, given their sizes and
construction methods, will have No Effect on flood volumes and velocities during high-flow events.
Spawning Substrate/Gravel Recruitment: The proposed development will not be impacting the
nearshore substrate, and thus will have No Effect on spawning substrates or gravel recruitments along
the shoreline.
Floodplain Connectivity: The proposed development will have No Effect on the floodplain connectivity.
The area surrounding the proposed project is already developed with single family residences. The
floodplain extends partially onto the parcel on the , and the proposed development will not impede the
movement of water across the floodplain.
Stormwater Discharge: The proposed development will result in 1,920-sqft of impervious surface where
non-native grass and forb species currently dominate. The increase in impervious surface will lead to an
increase in stormwater discharge, however, this will be offset due to onsite stormwater management.
The development will have No Effect on stormwater discharge offsite. No stormwater will enter Squamish
Harbor – Hood Canal, or flow offsite.
Riparian Vegetation/Bank Stability: The proposed development is not within a riparian corridor, and thus
will have No Effect on riparian vegetation or bank stability.
Channel Migration: The proposed development does not involve any stream channel activities, and as
such will have No Effect on channel migration.
Large Woody Input: There proposed development is not within the area of the shoreline where large
woody debris accumulates and will have No Effect on large woody input to the shoreline.
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 27 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
6.3 Potential Effects to the Residential Shoreline Designation
Washington’s Shoreline Management act require a review of potentially affected shoreline functions.
These include water quality/quantity affects, coastal shoreform and sediment drift modifications, bank
protection, nutrient cycling, and animal and plant habitat. JCC’s SMP has designated this parcel as
Shoreline Residential (Appendix G - Critical Areas Map with Proposed Development).
Washington State’s standard for protection of marine and freshwater shoreline resources is “no net loss”
(WAC 173-26-201.2.c). Net loss is measured by identifying shoreline ecological functions “as they
currently exist” against shoreline functions after a specific action modifies a specific shoreline. “As they
currently exist”, refers to current shoreline conditions immediately prior to the action. These current
conditions may be a natural setting or a degraded setting. Shoreline resources will incur a net loss if their
functions, values, and processes are not sustained after the action. Net loss does not compare historical
ecosystems.
Specific shoreline functions of this property include:
1. Bank stability/Sediment recruitment
a) Site is wooden armored lowbank waterfront.
b) No appreciable landform/drift due to low energy; sediment recruitment will not be negatively
affected by the proposed development.
c) Standard TESC measures will be implemented during construction to prevent sediment from
entering surface waters.
d) Onsite stormwater management will be incorporated into the project design to avoid conditions
that could result in bank erosion or sediment runoff.
2. Nutrient cycling
a) No effect to detritus accumulation within shoreline.
b) Installation of native shrubs within the shoreline will increase detrital fall, beachface organic
deposits and insect abundance.
c) Native small trees, shrubs, subshrubs, and herbaceous cover will be planted, increasing the input
of valuable nutrients to the ecosystem.
3. Fish & wildlife habitat
a) The removal of non-native plants will positively contribute to native/regional vegetative habitat,
as opposed to exotic vegetative habitat.
b) Fish & wildlife habitat will be improved under this plan, given invasive plants are removed and
replaced with native species.
4. Woody debris recruitment
a) Project will have no impact on woody debris recruitment.
5. Stormwater pollution control
a) Current stormwater from lawn on site flows into Squamish Harbor of the Hood Canal.
b) Stormwater management BMPs will be incorporated into project design.
c) Downspout controls, collection, and dispersion to support native plantings will be implemented.
d) Where applicable, evergreen plants will be chosen for revegetation/replacement to contribute
to rainwater attenuation.
With appropriate mitigation strategies, the project will demonstrate a No-Net-Loss in shoreline function.
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 28 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
7 Regulatory Setting
7.1 Federal Regulation
The Federal Emergency Management Agency (FEMA) compliance within 100-yr floodplains require
Habitat Assessments. Such assessments shall meet FEMA Region 10 Regional Guidance for Floodplain
Habitat Assessment and Mitigation in the Puget Sound Basin (2013). This document is formatted to meet
Army Corps ESA Section 7 consultation requirements should that be required.
7.2 County Regulation
7.2.1 Shoreline
The shoreline residential designation accommodates residential development and accessory structures
that are properly located and designed, in areas where high density residential developments and services
exist or are planned. 18.25.210 JCC.
As per JCC 18.25.220 the following is permittable for the Site: Single-family (and normal appurtenances);
Accessory structures associated with single-family development (other than beach access structures,
boating facilities, and boathouses); Use may be permitted subject to policies and regulations of program.
May require shoreline substantial development permit or statement of exemption approval
1. The entire Site is mapped as Residential Shoreline.
1. Proposed Development of single-family home and appurtenances lies the Residential Shoreline
within the with ~1,920-sqft of added impervious surface in an area that lacks native habitat. As
permitted by JCC 18.25.220.
2. Proposed mitigation is ~1,510-sqft within the shoreline in an area that lacks native vegetation and
that has high potential for native plant restoration and enhancement (critical area layers overlap).
Table 10. Summary of estimated permanent impact and mitigation within critical areas
Critical Area Total Size of Critical
Area on Site (sqft)
Size of Permanent
Impact (sqft) in
Critical Area
Mitigation within
Critical Area (sqft)
Residential Shoreline 5,662 1,920 1,510
FEMA Flood Zone 1,414 225 1,150
FWHCA – Squamish Harbor Inlet 5,662 1,920 1,510
Total Mitigation Area 1,510-sqft
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 29 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
7.2.2 FEMA Flood Zone
According to Chapter 15.15 JCC and Articles IV and IX, Chapter 18.22 JCC, the Client is required to submit
a Habitat Assessment prepared by a professional biologist. The Habitat Assessment included in this report
has been prepared in accordance with FEMA Guidelines from the publication, Floodplain Habitat
Assessment and Mitigation: Regional Guidance for the Puget Sound Basin (FEMA 2013).
2. The Site contains a mapped AE FEMA floodplain of 1,414-sqft near the OHWM of Squamish Harbor
inlet. AE designation is considered a high-risk area with occasional flooding.
3. Proposed Development of single-family home lies partially with the FEMA floodplain with ~225-
sqft of added impervious surface in an area that lacks native habitat.
4. Proposed mitigation is ~1,150-sqft within the FEMA floodplain in an area that lacks native
vegetation and that has high potential for native plant restoration and enhancement (critical area
layers overlap).
7.2.3 FWHCA – Squamish Harbor
1. Squamish Harbor has been mapped as critical habitat by NOAA and WDFW for federally listed and
state-listed T&E species, which qualifies as a FWHCA under JCC 18.22.610.a.
2. Squamish Harbor Inlet is subject to a 150-ft buffer (JCC Table 18.22.630.2).This buffer extends
over the entirety of the Site.
5. Proposed development lies within the FWHCA buffer, with approximately 1,920-sqft of added
impervious surface in an area that lacks native habitat.
3. Proposed mitigation is ~1,510-sqft within the FWHCA in an area that lacks native vegetation and
that has high potential for native plant restoration and enhancement (critical area layers overlap).
7.2.4 Additional Setbacks
As per JCC 18.25.300 a building setback of 10 feet shall be established on the landward edge of the
shoreline buffers.
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 30 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
8 Conclusions
1) Critical Areas Assessment:
a. A portion of the Site is mapped as AE FEMA flood zone.
b. The entire Project Area is within the Residential Shoreline designation and 150-ft buffer
of the FWHCA.
c. The previously mapped NWI freshwater, emergent wetland was determined as upland,
non-wetland habitat.
d. A portion of the Site is mapped seismic hazard and is not addressed within this report.
2) Proposed actions:
a. The Client intends to develop a single-family residence and driveway partially within the
FEMA flood zone, entirely with the shoreline and FWHCA buffer.
i. Approximately 1,920-sqft of non-native herbaceous cover will be removed and
replaced with impervious surface.
b. Compensation of habitat alteration for development of residence and appurtenances will
be achieved through mitigation of approximately 1,510-sqft of residential shoreline,
1,150-sqft of FEMA floodplain and 1,510-sqft of the FWHCA (critical areas layers overlap).
i. A total of 330 native plants will be installed: 39 small trees and shrubs and 291
herbaceous cover and subshrubs will be installed. These plantings will be located
mostly within 23-ft of the shoreline to restore and enhance ecological functions
on the Site.
c. We recommend an assessment of bulkhead to include wood decay drill testing. Repair of
shoreline armoring should be facilitated through necessary permits. Repair of bulkhead
should occur prior to bulkhead failure, which will require substantially more planning and
permitting than repairs.
Following the habitat assessment and biological evaluation, we find the project will result in No Effect to
listed species or their habitats within the Project Area, and No-Net-Loss of shoreline or FWHCA function,
if the prescribed Mitigating Strategies in Appendix D of this report are followed.
The Project Area/Site lacks a community of native vegetation, and mostly lacks shrub and tree strata. In
addition to managing stormwater, installing native plants in the areas of grass will aid in increasing
infiltration, and habitat within the shoreline. Currently the only habitat within the FEMA floodplain is non-
native grass and forb lawn.
By installing groundcover, shrubs, and trees where possible, a healthy, multistoried, plant community can
be established. This community will be maintainable while still providing a variety of services including,
interception of rainwater preventing some from reaching the ground, aiding in infiltration, helping bind
soil and increasing soil cohesion, and providing habitat.
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 31 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
9 Closing Remarks
Work for this project was performed and this report prepared in accordance with generally accepted
professional practices for the nature and conditions of work completed in the same or similar localities,
at the time the work was performed. No warranty, expressed or implied, is made. Neither the Consultants,
nor Peninsula Environmental Group, Inc., has any current or prospective interest in the plants or
properties discussed. Acceptance of this report acknowledges receipt and agreement with Peninsula
Environmental Groups, Inc. attached Assumptions & Limiting Conditions.
Peninsula Environmental Group, Inc.
824 E. 8th Street, Suite D
Port Angeles, WA 98362
Contractor License: PENINEG813MC
Port Angeles | Olympia | Petoskey
Community Specific, Resource Specific Planning
9.1 About the consultants:
Liz Donadio | Wetland Scientist & Botanist | liz@peninsulaeg.com
Liz Donadio is a wetland and wildife biologist with Peninsula Environmental. Liz has consulted on aquatic
resources throughout western Washington since 2015. Liz has graduate level education in wetland and
soil sciences and is trained through the Washington Department of Ecology
to assess hydrogeomorphic classifications and provide wetland ratings. Liz
is trained to on the USACOE 1987 Delination Manual and Western WA 2014
Wetland Rating System. In 2005, Liz obtained a Bachelor of Science in
Wildlife Management and Conservation from Humboldt State University.
For 20 years Liz has worked on numerous resource projects throughout the
United States, including wetland delineating and rating, mitigation planning
and monitoring, critical area assessment, bird, mammal, fish, amphibian
and reptile surveying and monitoring, marine and riverine restoration.
Kia Sutter | GIS Specialist & Biologist | kia@peninsualeg.com
Kia Sutter is an associate biologist and GIS specialist with Peninsula Environmental. Kia obtained her
Bachelor of Science from the University of Washington in Biology and Conservation. She also has a
certificate in GIS from the UW. Her experience includes wetland delineations and ratings, critical areas
assessments, timber management plans and geospatial analysis and mapping.
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 32 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
10 General Assumptions and Limitations
1. Any legal description provided to Consultant is assumed to be correct. Any titles and ownerships to any property are
assumed to be good and marketable. Consultant assumes no responsibly for verification of ownership or locations of
property lines, or for results of any actions or recommendations based on inaccurate information. It is assumed that any
property is not in violation of any applicable codes, ordinances, statutes, or other governmental regulations, unless explicitly
stated otherwise.
2. Consultant assumes no responsibilities for legal matters in character. Consultant assumes all property appraised or evaluated
is free and clear and is under responsible ownership and competent management.
3. Any evaluation or assessment carried out was restricted to the property and the plants or landscapes within the Scope of
Assignment. No assessment of any other plants or landscapes has been undertaken by Consultant. The conclusions of this
report do not apply to any zones, landscapes, trees, plants, or any other property not explicitly covered in the Scope of
Assignment.
4. The total monetary amount of all claims or causes of action the Client may have as against Consultant, including but not
limited to claims for negligence, negligent misrepresentation, and breach of contract, shall be strictly limited to solely the
total amount of fees paid by the Client to Consultant pursuant to the Agreement for Services as dated for which this
Assignment was carried out. Further, under no circumstance may any claims be initiated or commenced by the Client against
Consultant. or any of its directors, officers, employees, contractors, agents, or Assessors, in contract or in tort, more than 12
months after the date of this Assignment.
5. Although Consultant has taken care to obtain all information from reliable sources and to verify the data insofar as possible,
Consultant does not guarantee and is not responsible for the accuracy of information provided by others
6. Consultant shall not be required to testify or attend court due to any report unless mutually satisfactory contractual
arrangements are made, including payment of an additional fee for such Services as described in a Consulting Arborist
Agreement.
7. Unless otherwise required by law, possession of this report or a copy thereof does not imply right of publication or use for
any purpose by any other than the parties to whom it is addressed, without the prior expressed written or verbal consent of the Consultant.
8. Neither all or any part of the contents of this report, nor copy thereof, shall be conveyed to anyone, including the client, to the public through advertising, public relations, news, sales, or other media, without prior expressed written consent of Consultant. Particularly as to value conclusions, identify of Consultant., or any reference to any professional society or to
any initialed designation conferred upon Consultant as stated in its qualifications. 9. This report and any values expressed herein represent the opinion of the Consultant, and the Consultant’s fee is in no way contingent upon the reporting of a specific value, a stipulated result, the occurrence of a subsequent event or upon any finding to be reported. 10. All photographs included in this report were taken by Consultant during the documented site visit, unless otherwise noted. 11. Sketches, drawings, and photographs in this report, being intended as visual aids, are not necessarily to scale and should not be construed as engineering or architectural reports or surveys. The reproduction of any information generated by architects, engineers or other Consultants and any sketches, drawings or photographs is for the express purpose of coordination and ease of reference only. Inclusion of such information on any drawings or other documents does not constitute a representation by Consultant as to the sufficiency or accuracy of the information. 12. Unless otherwise agreed, (1) information contained in this report covers only the items examined and reflects the condition of those items at the time of inspection; and (2) the inspection is limited to visual examination of accessible items without dissection, excavation, probing, climbing, or coring. Consultant makes no warranty or guarantee, express or implied, that the problems or deficiencies of the plans or property in question may not arise in the future. 13. This report is based on the condition of the trees, landscape, or plants at the time of inspection.
14. Loss or alteration of any part of this report invalidates the entire report. This report is only valid if reproduced from a digital file.
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 33 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
11 References and Resources
WETLAND ASSESSMENT
USACE 1987
Wetland
Delineation
Manual
U.S. Army Engineer Research and Development Center - Environmental Laboratory (2010)
Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Western
Mountains, Valleys, and Coast Region - Final -2- Attachment 4 REVISED June 1, 2011
report. ERDC/EL TR-08-13, April 2008, 3909 Halls Ferry Road, Vicksburg, MS 39180-6199.
https://www.nrcs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb1046494.pdf
Western
Mountains,
Valleys, and Coast
Region Regional
Supplement
U.S. Army Corps of Engineers. 2010. Regional Supplement to the Corps of Engineers
Wetland Delineation Manual: Western Mountains, Valleys, and Coast Region (Version
2.0), ed. J. S. Wakeley, R. W. Lichvar, and C. V. Noble. ERDC/EL TR-10-3. Vicksburg, MS:
U.S. Army Engineer Research and Development Center.
http://www.usace.army.mil/CECW/Documents/cecwo/reg/west_mt_finalsupp.pdf
Washington
Department of
Fish and Wildlife
National Wetland Inventory (NWI). 2021. Wetland Mapper. U.S. Fish and Wildlife Service.
https://www.fws.gov/wetlands/data/Mapper.html
FEMA ASSESSMENT
Federal Emergency
Management
Agency (FEMA)
FEMA. 2021. Flood Zones. U.S. Dept. of Homeland Security. https://www.fema.gov/flood-
zones
FEMA's National Flood Hazard Layer. (2021). https://hazards-
fema.maps.arcgis.com/apps/webappviewer/index.html?id=8b0adb51996444d4879338b5
529aa9cd&extent=-124.11702740493826,46.840574168606835,-
124.07887566390944,46.85524987052379
FEMA. 2013 Floodplain Habitat Assessment and Mitigation; Regional Guidance for the
Puget Sound. https://dupont.civicweb.net/document/31796
Compliance Options for the 2008 NMFS Biological Opinion for the NFIP in Puget Sound -
National Flood Insurance Program and the Endangered Species Act, FEMA Region 10.
http://www.fema.gov/nfip-and-endangered-species-act
SOILS DATA
NRCS Soil Survey U.S.D.A. Natural Resource Conservation Service (NRCS). 2017. WA635 Kitsap County Area.
https://websoilsurvey.sc.egov.usda.gov/App/HomePage.htm
U.S.D.A. Natural Resource Conservation Service (NRCS). 2014. Washington Hydric Soils
List. http://www.nrcs.usda.gov/wps/portal/nrcs/main/soils/use/hydric
VEGETATION
Wetland Plant List WSDOT Wetland Monitoring Plant List
https://wsdot.wa.gov/sites/default/files/2017/07/24/Env-Wet-PlantList.pdf
Noxious Weeds Washington State Noxious Weed Control Board. https://www.nwcb.wa.gov/identify-a-
noxious-weed
HYDROLOGY and CLIMATE
Coastal Flood
Exposure Mapper
NOAA. Coastal Flood Exposure Mapper. (2021). https://coast.noaa.gov/floodexposure/#-
13653417,5953459,12z
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 34 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
Department of
Ecology (DOE)
Washington State Coastal Atlas. DOE Washington. (2021a).
https://apps.ecology.wa.gov/coastalatlas/tools/Flood.aspx
Washington State Water Quality Atlas. DOE Washington. (2021b).
https://apps.ecology.wa.gov/waterqualityatlas/wqa/map
DNR Department of Natural Resources Forest Practices Application Mapping Tool. DNR
Washington. (2021). https://fpamt.dnr.wa.gov/default.aspx
Natural Resources
Conservation
Science (NRCS)
Natural Resources Conservation Service. (2021). National Water and Climate Center.
United States Department of Agriculture, USA http://agacis.rcc-acis.org/
THREATENED AND ENDANGERED SPECIES
NOAA NOAA Fisheries Protected Resources (2021).
https://www.webapps.nwfsc.noaa.gov/portal/apps/webappviewer/index.html?id=7514c7
15b8594944a6e468dd25aaacc9
USFWS US Fish and Wildlife Service. (2021). IPaC-Information for Planning and Consultation.
https://ecos.fws.gov/ipac/location/index
Washington
Priority Habitats
and Species
Washington Department of Fish and Wildlife. (2021). Priority Habitats and Species.
WDFW, Washington State. https://wdfw.wa.gov/species-habitats/at-risk/phs
Priority Habitats and Species List. (August 2008).
https://wdfw.wa.gov/sites/default/files/publications/00165/wdfw00165.pdf
Washington Department of Fish and Wildlife. (2021). SalmonsScape. WDFW, Washington
State. https://apps.wdfw.wa.gov/salmonscape/map.html
Johnson, David H., and Thomas A. O'Neil. Wildlife-Habitat Relationships in Oregon and
Washington. Oregon State University Press, 2001.
JURISDICTION INFORMATION
Jefferson County Jefferson County. (2021a). Jefferson County Code. Municode.
https://co.jefferson.wa.us/502/Jefferson-County-Code
Jefferson County. (2021b). Jefferson County Shoreline Master Program.
https://co.jefferson.wa.us/502/Jefferson-County-Code
Jefferson County. (2021c). Jefferson County Maps. Jefferson County, Washington.
https://jeffcowa.maps.arcgis.com/home/index.html
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 35 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
Appendix A – Site Photos
Photo 5. Project Site. View from west looking east towards North Beach Drive.
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 36 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
Photo 6. Native Douglas-fir near N Beach Drive, to be retained.
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 37 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
Appendix B – Habitat and ESA Documentation
Figure 1. National Wetland Inventory map (Above) and Jefferson County mapped wetlands (below).
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 38 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
Figure 2. Water Quality Atlas listed 303(d) within vicinity of Project Area.
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 39 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
Figure 3. Water Quality Atlas Puget Sound Nutrient Source Reduction Project (in development).
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 40 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
Figure 4. IPaC USFWS listed T&E species near Project Area.
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 41 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 42 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 43 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
Figure 5. NOAA mapped T&E species within Project Area: Boccaccio, Steelhead, Chinook, and Chum.
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 44 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 45 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
Figure 6. WDFW PHS Map and species overview
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 46 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
Figure 7. WDFW SalmonScape mapped T&E species near Project Area.
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 47 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 48 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 49 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
Appendix C – Wetland Determination Forms
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 50 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 51 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
Appendix D – Mitigation Strategies
All Mitigating Strategies should be followed by contractors, subcontractors, and agents during all
phases of project construction.
As per JCC 18.22.660.2 and 18.25.270 mitigation shall include avoiding, minimizing, rectifying, reducing,
compensating, and monitoring. Washington State sets forth the following mitigation sequence to be
followed when development proposals impact critical areas. This mitigation sequence was subscribed to
while developing the plan and construction methods.
A. Avoiding the impact altogether by not taking a certain action or parts of an action;
B. Minimizing adverse impacts by limiting the degree or magnitude of the action and its
implementation;
C. Rectifying the adverse impact by repairing, rehabilitating, or restoring the affected environment
to the historical condition or the condition existing at the time of the initiation of a project;
D. Reducing or eliminating the adverse impact over time by preservation and maintenance
operation during the life of the action;
E. Compensating for the adverse impact by replacing, enhancing, or providing substitute resources
or environments;
F. Monitoring the required compensation and taking appropriate corrective measures when
necessary.
A.D.1 Mitigation Actions and Timeline
Implement the following standards and best management practices within the timeframe allotted.
Table 11. Mitigation timeline
Timeframe Mitigation Measure Summary
Before Project & During
Project Avoidance, Minimization
1) Erosion & Sediment Control
2) Site Plan inclusion and
contractor debriefing
After Project Completion Reduction, Compensating
1) Noxious Weed Control
2) Soil Rehabilitation
3) Native plant revegetation and
enhancement
4) Monitoring Report
Annually for 5 Years
Monitoring and
Contingency
1) 5 Year Monitoring and
Contingency Plan
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 52 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
A.D.2 Impact Avoidance and Minimization
1) All stormwater from the new development impervious and partially impervious surface, shall be
conveyed through infiltration trenches and allowed to permeate through soils. Storm water from
impervious surfaces should not be allowed into the Puget Sound.
2) Standard TESC (temporary erosion and sediment control) measures will be installed in a manner
consistent with Jefferson County standards. Stormwater management implementation will meet
Jefferson County stormwater requirements.
3) Existing native trees on property shall be protected and preserved.
4) Vehicles will not be parked over dripline of retained trees.
5) Cement and other construction materials and equipment will not be cleaned over dripline of retained
trees.
6) Debris will not be piled over dripline of retained trees.
7) Add temporary signage on wooden stakes along the beach environment edge to ensure work is not
8) Demolish/construction clean-up, tool washing, and other contaminants shall be contained upland.
Petroleum based chemicals, or other hazardous chemicals should not be cleaned on site.
9) Emergency spill response and clean-up equipment shall be available on site during all work activities.
At minimum, kit will include material for containment and clean-up of petroleum product.
A.D.3 Reducing and Compensating
Mitigation will be achieved through noxious weed control, soil rehabilitation and native plant restoration
and enhancement.
A.D.3.1 Mitigation Zones
1. Shoreline Enhancement Zone (1,510-sqft)
Mitigation Zone A includes, Residential Shoreline, FEMA floodplain and FWHCA buffer.
a) 23-ft of lawn closest to the shoreline will be infilled with native small trees, shrubs, subshrubs,
and herbaceous plants to recover portions of this area.
b) Install a minimum of 280 native plants as outlined in Table 12. Mitigation plant list.
a. For all native planting, follow Appendix F – Soil Rehabilitation and Native Plant
Restoration.
c) Remove all noxious weeds.
a. Use Appendix E - Noxious Weed Control for information on how to remove plants.
2. Lawn and Landscape Enhancement Zone (remainder of site)
a) Install remainder of plants that were not installed in Zone A, if densities are too high within
Mitigation Zone A.
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 53 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
A.D.4 Monitoring & Contingency Plan
If part of the mitigation plan is not meeting a performance standard, as measured during monitoring,
enact the contingency plan to help the mitigation get back on track. Failure to do so may result in
incomplete mitigation and additional mitigation requirements beyond the original plan.
A. Control and monitor Class B noxious weeds annually for 5 years either by hand or a Washington
Department of Agricultural Licensed Pesticide Applicator.
B. Monitoring of plant health and survival:
i. Dead or dying plants shall be replaced the following fall as needed to meet or exceed
mitigation standards.
ii. Different species of plants taken from our recommended plant list should be used when
other species fail.
iii. Plant species substitutions may be made if recommended by an arborist or ecologist
experienced in restoration.
iv. Monitor native plant success for 5 years.
A.D.4.1 Performance Standards
Year 1 Performance Standards
1) Class B noxious weed cover shall be below 10% within Site.
a. Retreat area as needed to reduce invasive plant cover below performance standards.
2) Plants installed in restoration area shall meet a 90% survivability rate.
a. Reinstall plants according to this Mitigation Plan as necessary to meet required cover.
Year 2 Performance Standards
1) Native ground cover within restoration area shall be over 50%.
a. Install ground cover according to this Mitigation Plan as necessary to meet required cover.
2) Native shrub cover in restoration area shall be over 20%.
a. Install shrubs according to this Mitigation Plan as necessary to meet required cover.
3) Native tree cover in restoration area shall be over 20%.
a. Install trees according to this Mitigation Plan as necessary to meet required cover.
4) Class B noxious weed cover shall be below 10% within the disturbed area.
a. Retreat area as needed to reduce invasive plant cover below performance standards.
Year 3 Performance Standards
1) Native ground cover within restoration area shall be over 75%.
a. Install ground cover according to this Mitigation Plan as necessary to meet required cover.
2) Native shrub cover in restoration area shall be over 40%.
a. Install shrubs according to this Mitigation Plan as necessary to meet required cover.
3) Native tree cover in restoration area shall be over 40%.
a. Install trees according to this Mitigation Plan as necessary to meet required cover.
4) Class B noxious weed cover shall be below 10% within the disturbed area.
a. Retreat area as needed to reduce invasive plant cover below performance standards.
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 54 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
Year 4 Performance Standards
1) Native ground cover within restoration area shall be over 75%.
a. Install ground cover according to this Mitigation Plan as necessary to meet required cover.
2) Native shrub cover in restoration area shall be over 50%.
a. Install shrubs according to this Mitigation Plan as necessary to meet required cover.
3) Native tree cover in restoration area shall be over 50%.
a. Install trees according to this Mitigation Plan as necessary to meet required cover.
4) Class B noxious weed cover shall be below 10% within the disturbed area.
b. Retreat area as needed to reduce invasive plant cover below performance standard
Year 5 Performance Standards
1) Native ground cover within restoration area shall be over 75%.
a. Install ground cover according to this Mitigation Plan as necessary to meet required cover.
2) Native shrub cover in restoration area shall be over 50%.
a. Install shrubs according to this Mitigation Plan as necessary to meet required cover.
3) Native tree cover in restoration area shall be over 50%.
a. Install trees according to this Mitigation Plan as necessary to meet required cover.
4) Class B noxious weed cover shall be below 10% within the disturbed area.
c. Retreat area as needed to reduce invasive plant cover below performance standards.
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 55 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
Appendix E - Noxious Weed Control
A.E.1 Noxious Weed Control Board
The Washington State Noxious Weed Control Board establishes county Noxious Weed Control Boards
throughout the state to provide resources and education to help control invasive plant species. A State
Noxious Weed List is developed to designate non-native plant species that are harmful to agriculture, the
environment, and people. Listed plants are divided into three classes:
• Class A: these species are generally not well-established; the possibility of eradicating them still
exists. Eradication of Class A Noxious Weeds is required by State law.
• Class B: these species are generally sporadically found. Control is required where they are not yet
established; OR when local county weed boards determine control is necessary.
• Class C: these species are generally widespread throughout Washington and well-established.
Example: Himalayan blackberry (Rubus armeniacus). Control of these species is not required by
the state, although individual counties may require control at their discretion.
All landowners, including, city, county, and state governments, are required to eradicate all Class A
species, control, and prevent the spread of any Class B species, and selected Class B or C species on their
property. A full list of Washington State listed weeds for 2021 may be found online at
https://www.nwcb.wa.gov/printable-noxious-weed-list.
A.E.3 Onsite Noxious Weed Control
1. Noxious weeds on the Jefferson County Noxious Weed List shall be controlled in an ongoing plan.
2. Any application near water, or with the potential to enter water ways, must be done by an
applicator with Aquatic certification, and using only herbicides/surfactants that have been
approved for aquatic use. Herbicides should not be sprayed within 60 feet of water bodies and
creeks, without further consultation with the Noxious Weed Board. Remember, it is the herbicide
applicators responsibility to apply the product in accordance with the instructions on the label.
3. After any removal of invasive species, as described below, or any chemical treatments that result
in bare ground exposure, reinstall native plants from Appendix F – Soil Rehabilitation and Native
Plant Restoration.
4. Monitoring noxious Weeds is key to long-term control. Retreatment will likely be necessary to
get any missed plants, and to treat newly emerging plants.
5. Control all Class B noxious weeds for 5 years.
Noxious Weeds Onsite
1. Identify and Control Class B Noxious Weeds
a. Scotch broom near bulkhead
b. For control onsite, use the following noxious weed control methods.
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 56 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
Scotch broom (Cytisus scoparius) Listed: 1988 Class B & Quarantine list
Identification: perennial, many-branched, shrub
ranging in height from 3 to 10 feet tall. Flowers are
typical of those in the pea family. They are bright
yellow, about 3/4 inches long and have 5 petals.
There are few leaves. The upper are simple and the
lower are 3 parted. They are deciduous and pointed
at both ends. Leaves may fall early in the year,
leaving bare green stems.
Impact: It displaces native and beneficial plants,
causing loss of grassland and open forest. It
aggressively spreads to form monocultures,
replacing desirable forage grasses and young trees.
Seeds are toxic to livestock and horses.
Control: Manual Hand pulling and digging up plants
are an option for small infestations. Use a tool like a
Weed Wrench, Extractigator, or Uprooter to
leverage plants out of the ground, along with their
roots. Must ensure root removal or it will resprout.
Creates disturbance that may encourage infestation.
Mechanical Not as effective as other methods.
Requires frequent mowing to exhaust root reserves
and follow up control for reinfestation from seed
bank. Cutting repeatedly can be effective on older
individuals but may spread seeds.
Chemical Foliar spray, basal bark treatment, and
cutting stems and painting the fresh cut with
herbicide can provide effective control. Foliar
application with triclopyr (0.75%-1.5%) or
glyphosate (2%). Cut stump application with
triclopyr (~16%) or glyphosate (~14%).
Biological Scotch broom bruhid, and Scotch broom
seed weevils are two bio control insects.
Effectiveness is still being assessed.
Distribution: A few specimens scattered near
bulkhead.
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 57 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
Appendix F – Soil Rehabilitation and Native Plant Restoration
A.F.1 Soil Rehabilitation Guidelines
1. If soil is recovered through the process of demolition, that soil should be rehabilitated.
2. Till newly exposed soil beneath old shed to a depth of 2 feet.
3. Incorporate 25 pounds high nitrogen compost per 1000 square feet into the soil and regrade.
4. Replant using species in Table 10. Mitigation plant list.
A.F.2 Plant Installation Guidelines
1. Plant in areas where specified in A.D.3.1 Mitigation Zones.
2. Do not plant trees close to structures that they may impact with roots or branches to such a
degree that they would require removal in the future.
3. Follow species selection, size, and quantities in Native Plant Schedule.
a. The estimated quantities are based on the available area and average on center distances.
b. Plants should be installed at the numbers and spacing suggested, and shrubs and
groundcover should be in small groups of 3-5, of the same species where possible.
4. All plant installation and irrigation work shall be done by hand and with hand operated
equipment. No machinery shall be used.
5. Plant installation shall follow 2012 ANSI A300 Part 6: Tree, Shrub, and Other Woody Plant
Management – Standard Practices (Planting) and 2012 International Society of Arboriculture Best
Management Practices: Tree Planting.
6. Planting shall ideally be performed in the late fall through winter, and at least in the window of
October to March.
7. Apply 3” depth of arborist wood chip from Site (uncomposted, non-cedar) in planting areas,
except where chips would harm existing native vegetation or in areas where wood chips are not
appropriate for the habitat type, i.e., rocky riverbed.
a. Chips are to be free of weed seed, sawdust, and shall not contain anything detrimental to
plant growth.
b. Pull chips 2” away from base of plant.
8. Consider using plant protective barrier if grazers, such as deer, are impacting survival.
9. Local nursery stock should be used, when available, to ensure that the material has acclimated to
local conditions and is genetically comparable with plants in the local area.
10. If specified plant species are not available due to limited inventories at local nurseries, or prove
during monitoring to perform poorly onsite, substitutions may be allowed provided the plants are
native or native hybrids within the same general plant stratum (upper, middle, or lower strata).
The project will not result in the removal of any woody vegetation, but approximately 1,920-sqft of non-
native herbaceous cover will be removed and replaced with impervious surface. Plantings of native
herbaceous and woody plants will compensate for habitat alteration for residence and other
improvements. A total of 330 native plants will be installed: 39 small trees and shrubs and 291 herbaceous
cover and subshrubs will be installed. These plantings will be located mostly within 23-ft of the shoreline
to restore and enhance ecological functions on the Site.
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 58 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
A.F.3 Plant Schedule
Table 12. Mitigation plant list
Common Name Scientific Name Size Quantity Spacing
(on center)
Middle Strata: Small Trees and Shrubs = 39
Black twinberry Lonicera involucrata 1-gallon+ 9 5ft
Evergreen huckleberry Vaccinium ovatum 1-gallon+ 3 5-8ft
Osoberry Oemleria cerasiformis Bareroot up to 1-
gallon+ 6 4ft
Red elderberry Sambucus racemosa 1-gallon+ 2 10-12ft
Salal Gaultheria shallon 4” to 1-gallon 15 3-5 t
Sweet gale Myrica gale 1-gallon+ 3 5-8ft
Vine maple Acer circinatum 1-gallon+ 1 4-6ft
Lower Stata: Herbaceous cover and subshrubs = 291
Blue wildrye Elymus glaucus 4”+ 15 1-2ft
Coastal strawberry Fragaria chiloensis 4”+ 30 4-6ft
Common yarrow Achillea millefolium 4”+ 30 2-3ft
Douglas aster Aster subspicatus 4”+ 30 2-3ft
Hendersons checker
mallow Sidalcea hendersonii 4”+ 15 2-3ft
Large-leaf lupine Lupinus polyphyllus 4”+ 6 4-6ft
Kinnikinnick Arctostaphylos uva-ursi 4”+ 45 2-3ft
Oregon sunshine Eriophyllum lanatum 4”+ 30 2-3ft
Western sword fern Polystichum munitum 1-gallon+ 15 4-6ft
Red fescue Festuca rubra 4”+ 15 1-2ft
Tufted hairgrass Deschampsia cespitosa 4”+ 30 1-2ft
Youth-on-age Tolmiea menziesii 4”+ 30 2-3ft
Total Number of Plants for Mitigation= 330
May 7, 2021
175 N Beach Dr | Port Ludlow, WA 98365
FEMA Habitat Assessment and Mitigation Plan
Page| 59 of 59 Peninsula Environmental Group, Inc. | www.peninsulaeg.com | (360) 504-3825
Appendix G - Critical Areas and Mitigation Maps
Page left blank intentionally.
Site Maps on following pages.
Prepared for: Mendoza Date: April 2021 Project #: 20427
Map Title: Critical Areas Site Map
Description: Client parcel showing the proposed building
location, Ordinary High Water Mark, wetland determination
plot and critical areas.
Address: 175 N Beach Dr | Port Ludlow, WA 98365
DP-1
Maxar, Microsoft, Jefferson County, WA., Pro-West & Associates, Inc.
Legend
Determination Plot
Upland
Ordinary High Water Mark
OHWM Buffer
FEMA Flood Zone AE
Shoreline Environmental Designations
Aquatic (OHWM)
Shoreline Residential
Proposed Development
Client Parcel
Jefferson County Parcels
0 20 4010 Feet
Prepared for: Mendoza Date: April 2021 Project #: 20427
Map Title: Mitigation Zone Site Map
Address: 175 N Beach Dr | Port Ludlow, WA 98365
Shoreline
Enhancement
Zone
Maxar, Microsoft
Legend
Mitigation Zone A
Proposed Development
Client Parcel
Jefferson County Parcels
0 20 4010 Feet