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Home My WebLink About2961-454 Gt1\.Pr <- A-i-, ~fa eM. , M.M I 'Ji\Utut.t ~ W Washington State Department of Transportation Paula J. Hammond, P.E. Secretary of Transportation l~ ~) Olympic Region Environmental and Hydraulic Services Office 150 Israel Road SW, FI 4, Tumwater PO Box 47417 Olympia, WA 98504-7417 360-570-6700 / Fax 360-570-6697 TTY: 1-800-833-6388 www.wsdot.wa.gov April I, 2009 Jefferson County, Department of Community Development Attn: Michelle McConnell, Associate Planner Shoreline Master Program (SMP) Update Project Manager 621 Sheridan Street Port Townsend, W A 98368 ? --I 1'----\'- it} ;,( ...) RE: 2009 Jefferson County Shoreline Master Program (Proposed) Comments from WSDOT JHHRSllN CUlJrHY OeD Dear: Ms. McConnell: The Washington State Department of Transportation (WSDOT) Olympic Region Environmental & Hydraulic Services Office has reviewed the December 3,2008 Preliminary Draft Jefferson County Shoreline Master Program (SMP) as proposed. Our comments are attached. Our comments pertain to WSDOT's activities and actions associated with the preservation, maintenance, and construction of our existing and proposed highways, bridges, and other facilities located within Jefferson County. WSDOT realizes that the standards contained within the SMP are to protect the environment and the public's health, safety and general welfare. Our comments are intended to point out WSDOT's interests, while supporting Jefferson County's objectives in implementation of the Shoreline Master Program. If you need clarification regarding our comments or if you have any questions, please contact Randy Neff, of my staff at (360) 570-6705. Thank you for the opportunity to comment on the proposed SMP. Sincerely, ?fI~ Jeff Sawyer Environmental & Hydraulic Manager Olympic Region JBS:ren:lfm Enclosures: WSDOT's Comments on the 2009 Jefferson County Shoreline Master Program (Proposed) cc: Steve Yach, WSDOT HQ ESO, w/enclosure Project File, w/enclosure SF0401009(5225) WSDOT's Comments: 2009 Jefferson County Shoreline Master Program (Proposed) Article 6 - General Policies and Regulations 6.1. B. Regulations - No Net Loss and Mitigation. Sections 1, 2, and 3 seem to be in conflict with Section 5 and 6, in that 1, 2 and 3 do not allow deviation, whereas 5 and 6 were written "without teeth" and the ability to deviate. Is this intended? 6.1. B.6.ii. - There is no mention of monitoring or duration of monitoring in general. 6.1. B.6.vi. - WSDOT should be exempt from this provision. There is no need to post a bond for work conducted by State of Washington. 6.1. D. Regulations - Critical Areas and Shoreline Buffers. In Section 5, last sentence states "all buffers shall be maintained in predominantly natural. . ." condition, whereas Section 8 says buffer needs to be 1 00% or 80% "well- vegetated and predominantly natural condition." This is inconsistent. In Section 6.ii. why is the buffer on Lake shores 100 ft. (vs. 150 ft. as for Marine and Stream/Rivers Shores)? The buffers should be consistent. In Section 10. Increased Buffers, how is the increase in required buffer area to be determined, by best available science? In Section 10.Hi. "including risks associated with sea level rise" is a good idea, but will the applicant need to evaluate this potential? In Section 10.iv. slopes of25% are not always indicative of slope failure. Some slopes that have a higher angle of repose are not at risk of failure (i.e., slopes that are made of consolidated soils left from the terminal moraines and facing the south). How was 25% slope determined? Article 7 - Shoreline Modification Policies and Regulations 7.6. In-stream Structures In 7.6.C., Section 9, WSDOT should be exempt from these standards since all projects that are located within a stream corridor are analyzed for the particular site, vegetation replacement, bridge vs. bottomless culvert, hydraulic study, biologic assessment, SEPA , review, etc. WSDOT projects "are adequately addressed via another regulatory review process:" (numerous federal or state laws and requirements). 7.7. Structural Shoreline Armoring and Shoreline Stabilization In 7.7.C., Section l.i., how is "no net loss of ecological function" determined, and whom at the County would have the expertise to review these designs? In Section l.ii. many of the structures that have been placed in WSDOT road corridors were built many years ago and need to be replaced. In most cases these structures (culverts, bridges, etc) were not built to the same standards as is now required. WSDOT should be exempted from these standards. Article 8 - Use Specific Policies and Regulations 8.10. Transportation In 8.l0.D. Section 8. last sentence, add "or synthetics." WSDOT uses many different materials for construction of our facilities. WSDOT avoids using treated wood or other toxic materials in our projects. Article 9 - Permit Criteria and Exemptions 9.3. Exemptions Listed In 9.3.A. Section 14. Noxious Weeds, WSDOT considers this a maintenance issue and notes it is extremely important our agency be able to keep areas (wetland mitigation) sites free of noxious weeds. 9.4. Statement of Exemption In 9.4.B., regarding dredging, WSDOT removes material at the intake of their culverts to maintain flows, so that the road is not washed out. Most of the material that migrates down stream is caused by forest practices (logging operations). The forest practices should be restricted, or required to use selective logging practices to reduce the amount of material reaching the streams and rivers. Maintenance of the roadway prism is extremely important to the longevity of WSDOT 'transportation systems. Maintenance activities for state highways should be exempt from the Jefferson County Shoreline Master Program.