HomeMy WebLinkAboutHMP - HMP Habitat Managment Plan - 8/30/2009 THE WETLAND CORPS W"077
Wetland Delineation - Habitat Management Plans - Riparian Restoration • Mitigation • Biological Evaluation
PARCEL 123203400010 HABITAT MANAGEMENT PLAN
210 NE Timberline Drive
Belfair,Washington
Mason County
Prepared for:
Peninsula Topsoil LLC.
c/o Steve Johnson
PO Box 640
Belfair,WA 98528
Prepared by:
Heather Lane and Lee Boad
August,2009
PO Box 2854, Belfair,WA 98528 cell:360-620-0618, Office: 360-372-2421 e-mail: wetlandcorps@hotmail.com
THE WETLAND CORPS
Wetland Delineation - Habitat Management Plans • Riparian Restoration - Mitigation - Biological Evaluation
PARCEL 123203400010 HABITAT MANAGEMENT PLAN
TABLE OF CONTENTS
1.0 PROJECT DESCRIPTION...................................................................................................1
2.0 PROPERTY DESCRIPTION ...............................................................................................2
3.0 APPLICABLE SETBACKS..................................................................................................3
4.0 DESCRIPTION OF HABITAT AND SPECIES.................................................................4
5.0 ANALYSIS OF EFFECTS....................................................................................................6
6.0 MITIGATION MEASURES.................................................................................................7
7.0 MONITORING ....................................................................................................................11
8.0 SUMMARY...........................................................................................................................11
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Figure 1. Site Vicinity Map
Figure 2. Site Plan
Figure 3. National Wetland Inventory Map
Figure 4. Mason County Soil Survey Map
Figure 5. Department of Natural Resources Water Resource Map
PO Box 2854, Belfair,WA 98528 cell:360-620-0618, Office: 360-372-2421 e-mail: wetlandcorps@hotmail.com
THE WETLAND CORPS
Wetland Delineation - Habitat Management Plans - Riparian Restoration - Mitigation - Biological Evaluation
August,2009 Page 1
PARCEL 123203400010 HABITAT MANAGEMENT PLAN
210 NE Timberline Drive
Belfair,Washington
1.0 PROJECT DESCRIPTION
The details of a Habitat Management Plan for the above referenced property are discussed in full in
this report. The site is found in the SW I/4 of Section 20 Township 23 North, Range 1 West along
the Union River(See Figure 1. Site Vicinity Map).
The purpose of this Habitat Management Plan (HMP) is to address impacts resulting from the
completed bank armoring within the type S stream buffer of Union River. All type S streams in
Mason County require 150 feet of undisturbed buffer with an additional 15-foot building setback.
The rock wall was originally constructed to quickly and efficiently repair the damage from the
December 2007 flood event, for the purpose of protecting upland portions of the property. The
completed bank armor extends a lineal distance of approximately 30-feet adjacent to the stream.
This report also addresses and provides mitigation for proposed additional bank armoring which
will extend the completed wall an additional 10-feet downstream. The additional bank armoring is
necessary to prevent the stream from eroding further to east and falling several red alders near the
river.
Both the completed and proposed bank armoring are necessary to protect adjacent upland property.
The project is intended to prevent future flood events from substantially eroding and displacing
useable upland area.
The objectives of this HMP are as follows:
■ To evaluate the potential adverse effects to critical area functions as well as fish and wildlife
habitat resulting from the completed and proposed bank armoring along the stream bank.
Emphasis is placed on the possible loss of habitat for any listed species found to be residing
in the vicinity of the parcel.
■ To identify possible mitigation measures that could be implemented to offset the adverse
effects resulting from the completed and proposed bank armoring within the Type S stream
buffer.
PO Box 2854, Belfair,WA 98528 ceil:360-620-0618, Office: 360-372-2421 e-mail: wetlandcorps@hotmail.com
Parcel 123203400010 MiP
August,2009
Page 2
2.0 PROPERTY DESCRIPTION
The subject parcel is 23 acres in size, and bordered to the south by Timberline Drive,to the west by
Union River and to the north and east by residential parcels of similar size. The Union River
drains westerly into Hood Canal, located approximately one mile west of the property. The portion
of the stream buffer adjacent to the project site is comprised of grasses and shrubs such as Japanese
knotweed and salmonberry with a patch of mature red alder in the western area. The portion of the
stream buffer that has been bank armored is located within the southernmost portion of the
property. Prior to the flood event, the area that is currently occupied by the bank armoring was
likely comprised of an exposed cut bank.
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Photo 1. Completed portion of rock wall. A lineal distance of approximately 30 feet.
PO Box 2854, Belfair,WA 98528 cell:360-620-0618, Office: 360-372-2421 e-mail: wetlandcorps@hotmail.com
Parcel 123203400010 HMP
August,2009
Page 3
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Photo 2. Additional Portion of bank proposed for armoring circled in red.
3.0 APPLICABLE SETBACKS
The project site is within the jurisdiction of Mason County. Ordinance 17.01.110 identifies Fish
and Wildlife Habitat Conservation Areas adopted by Mason County.
The applicable setback for this project is as follows:
Habitat Type Buffer Building Setback from Buffer
Type S Stream (Union River) 150' 15'
PO Box 2854, Belfair,WA 98528 cell:360-620-0618, Office: 360-372-2421 e-mail: wetlandcorps@hotmail.com
Parcel 123203400010 HMP
August,2009
Page 4
4.0 DESCRIPTION OF HABITAT AND SPECIES
4.1 Puget Sound Chinook(Oncorhynchus tshawytsha)-Threatened
Listed as threatened since March 24,1999 adult Puget Sound Chinook spawn in several rivers and
streams flowing into Puget Sound. The lower Union River is known to support small runs of Puget
Sound Chinook. These fish are assumed to be of hatchery origin but have maintained some level of
natural production over the last decade.
The mainstem of the Union River is listed as a final designation in the NOAA Fisheries Northwest
Region Critical Habitat Designations for West Coast Salmon and Steelhead in Washington- August
2005.
The project proposal includes mitigation and tactical design intended to protect and maintain water
quality of the stream as well as prevent sedimentation. Given that no displacement of important
spawning habitat will be necessary, this project is not likely to impact Puget Sound Chinook.
Mitigation includes the establishment of a native riparian community along an area occupied by an
open grass area adjacent to the river.
4.2 Puget Sound Steelhead (Oncorhynchus mykiss)-Threatened
Listed as Threatened since May 2007, Puget Sound Steelhead spawn in several streams throughout
Puget Sound. Spawning usually occurs in moderate to steep gradient sections of streams, usually
in heads of riffles or the tails of pools where hydraulic conditions are conducive to intragravel
flow. Side channels and the anterior portions of islands are also used. Spawn timing for summer
steelhead runs typically ranges from mid May through October while winter run steelhead are
present from December through May. Adequate cover from predation, water temperature, and
spawning gravel are important factors for instream habitat, while little is currently known about
specific marine habitat requirements.
The Union River is accessible to Puget Sound Steelhead. However, no part of this project will
displace important spawning or rearing habitat, therefore, no impacts are likely. The overall
project described in this report is not expected to impact water quality or aquatic habitat important
fish. The pool habitat which will likely result at the base of the rock wall will provide important
rearing habitat for juveniles.
4.3 Hood Canal Summer Chum(Oncorhynchus keta)-Threatened
Hood Canal Summer Chum spawning areas in proximity to the site include the Union River and,
historically, the Tahuya River. Recovery efforts are in place to restore naturally spawning summer
chum populations to the Tahuya system while the Union stock remains healthy. Summer chum
adults are present from August to mid October in the lower Union River. The project area falls
within the Summer Chum ESU. Chum salmon generally prefer medium size gravels that are
PO Box 2854, Belfair,WA 98528 cell:360-620-0618, Office: 360-372-2421 e-mail: wetiandcorps@hotmail.com
Parcel 123203400010 HMP
August,2009
Page 5
relatively sand and silt free. No damage to stream habitat or associated buffers has or will result
from the project addressed in this plan. The proposed rip rap installation is not likely to impact
Hood Canal Summer Chum as impacts will be mitigated through the restoration of riparian
vegetation and continued stabilization of the stream bank. Measures are provided in this report to
protect water quality and other habitat features potentially important to all fish species potentially
inhabiting the stream.
Measures are provided in this plan to protect water quality and aquatic habitat. Given that no
modification to spawning habitat or forested riparian area are proposed, no impacts to summer
chum or their habitats are likely to occur.
4.4 Bull Trout(Salvelinus malma)-Threatened
Bull trout typically inhabit very cold, clear headwater streams at high elevations that are supported
by snowmelt. For spawning and early rearing, bull trout require loose, clear gravel, relatively free
of fine sediments.
Bull trout are not documented within this stream. Given the scale of the project and mitigation
proposed,the project is not likely to have any adverse impacts on bull trout.
4.5 Bald Eagle(Haliaeetus leucocephalus)-Threatened
Habitat areas associated with Bald Eagle include uneven aged coniferous stands with some old-
growth components. Nests are typically constructed in larger trees with dead or broken tops
providing an unobstructed view of nearby water. Snags and trees with exposed lateral limbs, or
dead tops are used as perches and defense stations.
There are no documented Bald Eagle nesting sites in the vicinity of the project area. The
completed project did not require the removal of any trees. Recommended overstory plantings
recommended in Section 6.3 should improve the potential for use of the site by Bald Eagle in the
future. As no important habitat features are to be removed, this project will have no adverse
impacts on bald eagles. The proposed mitigation is expected to provide a net benefit.
4.6 Marbled Murrelet(Brachyramphus marmoratus)-Threatened
Marbled Murrelets are typically associated with coastal habitats and nest in old-growth forests.
Murrelets may fly as far as 50 miles inland to nest,however the average distance is roughly 5-miles
from nest to sea. It is only during the summer breeding months that they are commonly found
inland. During non-nesting seasons they live at sea. Murrelets require tall mossy trees in
coniferous old growth forests with cavities on thick branches where they can construct a cup nest
20-40 meters above the forest floor.
Murreletts have been documented laying eggs on rocky ground habitats only when a sufficient
forest is unavailable. There are no documented nesting sites surrounding the project site. No
potential nesting trees containing platform features are within the project area. This project will
likely have no adverse impact on Marbled Murrelet given there are no documented nesting sites or
potential nesting trees within the project area.
PO Box 2854, Belfair,WA 98528 cell-360-620-0618, Office: 360-372-2421 e-mail: wetlandcorps@hotmail.com
Parcel 123203400010 IIW
August,2009
Page 6
4.7 Northern Spotted Owl(Strix occidentalis caurina)-Threatened
Spotted owls require a large amount of land for their nesting and hunting grounds; pairs may occupy
up to 58 sq. km. They are territorial and do not migrate, but they may shift their ranges slightly in
response to seasonal changes
Suitable spotted owl habitat includes trees relatively large in diameter, multi-layered forest canopy
with a moderate to high canopy closure in overstory, midstory, and understory, large, tall, live trees
with cavities, broken tops, mistletoe, or platforms of branches capable of holding accumulated
organic matter suitable for use as a nest. Dead standing trees and fallen decayed trees supporting
abundant populations of prey species are critical to spotted owl populations. Currently there are no
spotted owl nesting sites documented in proximity to the project site.
As spotted owls are currently not present, and the project is of a scale that has no impact on forested
areas, no impacts to spotted owl or their habitat are expected result from the completed or proposed
project.
5.0 ANALYSIS OF EFFECTS
The project lies within the regulated buffer of a Type S stream. Project scale in the protected area
is as follows:
Development Type Habitat Type Approximate Project scale
Bank Armoring(completed) Type S Stream Buffer 30 lineal feet
Bank Armoring(proposed) Type S Stream Buffer 10 lineal feet
Total Type S Stream Buffer 40 lineal
5.1 Vegetation Disturbance
The portion of the stream buffer displaced by the bank armoring is located in an area that was
previously an exposed cut bank prior to the December 3`d 2007 flood event. The site was eroded
toward the northwest during the flood. The area where the bank armoring is proposed is occupied
by grasses and exposed soil along the existing slope, with little native shrub or overstory
vegetation. No native trees or shrubs were removed or are proposed to be removed for the project.
With recommended planting of native vegetation described in Section 6.3, the project will likely
have a net benefit of vegetation abundance and diversity within the parcel.
5.2 Designated Critical Habitat for Salmonids
Designated Critical Habitat for Salmonids is within the the project area. However, none of the
completed or proposed work will displace or substantially modify Designated Critical Habitat. The
stream channel will be maintained in its current location. With proposed mitigation, actions
described in this plan are not expected to jeopardize the continued existence of any listed species.
PO Box 2854, Belfair,WA 98528 cell:360-620-0618, Office: 360-372-2421 e-mail: wetlandcorps@hotmail.com
Parcel 123203400010 HIVW
August,2009
Page 7
5.3 Temporary Increase in Sediment and Turbidity During Construction
The proposed work has the potential to temporarily increase turbidity and suspended sediment
within the project area. Best Management Practices have been recommended in Section 6.4 to
avoid siltation of waters during project implementation.
5.4 Light and Glare
The proposed project has not resulted in an increase in light and glare. No impacts to the use of the
site by wildlife species is likely to result from light and glare associated with this project.
6.0 MITIGATION MEASURES
6.1 Preservation of Critically Important Plants
No removal of critically important plants or vegetative communities has occurred or is proposed.
6.2 Minimization Mitigation
The project minimizes impacts to the stream buffer by armoring only the areas damaged during the
December 3rd 2007 flood event, and the areas that have high potential to be eroded during future
flood events. The areas to be potentially eroded are important to the continued protection of the
property.
6.3 Enhancement Recommendations
The portion of the stream buffer that is proposed for bank armoring is occupied by exposed soil,
with little native vegetation. To compensate for the completed and proposed bank armoring within
the stream buffer, it is recommended that a ten-foot wide strip of the buffer, adjacent to the stream
bank be enhanced with native vegetation. The ten-foot wide strip extends the entire length of the
stream buffer adjacent to the bank armoring addressed in this plan (approximately 40 feet), and
will be identified as the Enhancement Zone. The Enhancement Zone is currently occupied by flat,
open grass area. A moderately dense forested and shrub community within this specified area is
likely to improve water quality maintenance, upland stabilization, and wildlife utilization of the
site. The area selected as the Enhancement Zone occupies approximately 400 square feet of the
stream buffer.
PO Box 2854, Belfair,WA 98528 cell:360-620-0618, Office: 360-372-2421 e-mail: wetlandcorps@hotmail.com
Parcel 123203400010 HMP
August,2009
Page 8
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Photo 3. Representative portion of proposed enhancement zone,circled in red.
Native Plantings
It is recommended that the mitigation zone be enhanced with native plants. It is recommended that
potted plants be used as opposed to bare root seedlings. The following plant species and potted
sizes are recommended:
Trees: western red cedar(Thuja plicata)-2 gallon
Douglas fir(Pseudotsuga menziesii)- 2 gallon
Shrubs: Oregon grape (Mahonia nervosa)- 1 gallon
salal (Gaultheria shallon)— 1 gallon
evergreen huckleberry(Vaccinium ovatum) - gallon
nootka rose(Rosa nutkana)— 1 gallon
salmonberry (Rubus spectabilis)— 1 gallon
Pacific Willow(Salix lusida)— 1 gallon
PO Box 2854, Belfair,WA 98528 cell:360-620-0618, Office: 360-372-2421 e-mail: wetlandcorps@hotmail.com
Parcel 123203400010 MV
August,2009
Page 9
Hooker willow(Salix hookeriana)— 1 gallon
Scouler willow(Salix scouleriana)— 1 gallon
Sitka willow(Salix sitchensis)— 1 gallon
beaked hazelnut(Corylus cornuta)— 1 gallon
Indian plum(Oemleria cerasiformis)— 1 gallon
oceanspray(Holodiscus discolor)— 1 gallon
Pacific ninebark(Physocarpus capitatus)— 1 gallon
California black currant(Ribes bracteosum)— 1 gallon
western thimbleberry(Rubus parviflorus)— I gallon
red elderberry (Sambucus racemosa)— 1 gallon
Ferns: sword fern(Polystichum munitum)— 1 gallon
Native Planting Guidelines
It is recommended that plantings be installed within the identified mitigation zone to achieve the
following densities. A minimum of 1 tree species and five shrub or fern species from the above list
are recommended.
trees- 10' on center
shrubs- 5' on center
ferns- 4'on center
These densities will provide a moderately dense, structurally diverse plant community within the
mitigation zone. To fulfill the above mentioned planting density recommendation, the mitigation
zone will be planted with a total of 4 trees, 12 shrubs, and 9 sword fern. It is recommended that
installation be done as single trees and or clusters of three shrubs, on approximate 10-foot centers.
Finally, sword fem will be randomly installed throughout the planting row on average four-foot
centers. Any volunteer native vegetative species may be counted toward target densities.
Typically,planting should occur during winter dormancy. The optimum time for planting is during
February and March, however, the need to complete the project in a timely manner may call for
planting to occur outside optimum time periods. No machinery earthwork will be necessary to
implement this enhancement plan; planting holes for specified vegetation will be hand dug. No
additional clearing or grading should be necessary for site enhancement. All installed vegetation
shall be marked with colored flagging to facilitate monitoring inspections. The monitoring
program is recommended to insure project effectiveness.
Invasive species such as Himalayan blackberry, reed canary grass, Japanese knotweed, and English
Ivy may invade the enhancement zone. These species are stubborn competitors for light and
nutrients and limit success of native plants. Invasive species should be removed from the stream
buffer, and/or enhancement zone should they invade. Herbicides should not be used to achieve
this due to the proximity to the stream. Persistent cutting during the growing season is sufficient to
offset the rhizomes of invasive species if they become a problem.
PO Box 2854, Belfair,WA 98528 cell:360-620-0618, Office: 360-372-2421 e-mail: wetlandcorps@hotmail.com
Parcel 123203400010 MIP
August,2009
Page 10
6.4 Best Management Practices
Recommended Best Management Practices for this project are as follows:
• Perform excavation and site preparation work during dry weather.
• Install silt fencing between exposed erodible soils and the stream when feasible and practical to
prevent erosion and siltation of waters(See diagram below).
• Minimize amount of erodible soils at any given time to the maximum extent feasible.
• Check all equipment daily for leaks. Refueling and lubrication of equipment should occur off
site. Do not store any fuel, lubricants, chemicals, or hazardous substances outside overnight
within the project area.
• Do not apply any chemicals when there is a possibility of rain.
• Comply with all permits and requirements of governing authority.
HIGH
CONSTRUCTION
STEEL POST FENCE
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10 Fr MAX SPACING WITH
WIRE SUPPORT FENCE
6 FT MAX SPACING Y/RF1OUr
WIRE SUPPORT FENCE
FILTER FABRIC
PONDING HT.
FILTER FABRIC
ATTACH SECURELY
STEEL POST TO UPSTREAM
SIDE OF POST.
R!-UNOFF
12- MIN.
••�4"x6"TRENCH
WITH COMPACTED
BACKFILL
Silt Fence Diagram
Silt fence maintenance
The presence of exposed soil in proximity to regulated waters poses a risk of erosion and siltation
during storm events. It is recommended that silt fencing be installed between the work areas and
the stream to avoid siltation of waters. The silt fence should be inspected and repaired if necessary
after each storm event. Sediment should be removed from the fence and deposited to an area that
will not contribute to regulated waters.
PO Box 2854, Belfair,WA 98528 cell:360-620-0618,Office: 360-372-2421 e-mail:wetlandcorps@hotmail.com
Parcel 123203400010 HMI'
August,2009
Page 11
7.0 MONITORING
Monitoring of the site will begin the first fall following project completion and maintained on a
seasonal basis. The information gathered will provide the following: 1) condition of reintroduced
plant species; 2) the use of the site by wildlife species; 3) any disturbance caused by the bank
armoring and its effect on the protected zone and associated aquatic habitat; 4) any occurrence of
exotic species within the mitigation zone; 5) any corrective measures that may be deemed
necessary to provide desired conditions. This monitoring will be in effect for the duration of three
years. The information gathered will be provided in an annual report and submitted to the Director
of Mason County Department of Community Development.
8.0 SUMMARY
This report addresses the effects of armoring a portion of a Type S stream bank (Union River).
Bank armoring has been completed along a lineal distance of 30 feet adjacent to the stream, to
protect the ownership from further damage during the December 2007 flood event. This report also
addressed the proposed installation of additional bank armoring along the western portion of the
stream buffer, along a lineal distance of 10 feet adjacent to the stream. The purpose of the
proposed bank armoring is to protect the subject property from further damage from erosion caused
by future flood events. Mitigation recommendations include native plant enhancement of the area
adjacent to the bank armor, which is currently maintained as open grass area. The enhancement
zone occupies approximately 400 square feet. No impacts to water quality or stream habitat are
expected. Best Management Practices are recommended to insure no negative impacts to the
stream.
Mitigation Measures, and Best Management Practices, have been identified to avoid, minimize,
and mitigate for potential impacts associated with completed and proposed construction.
We trust this information is sufficient for your needs at this time. Thank you for choosing The
Wetland Corps as your environmental consultant. If you have any questions feel free to call.
Respectfully submitted,
Lee Boad
Senior Ecologist
Heather Lane
Staff Wetland&Natural Resource Specialist
PO Box 2854, Belfair,WA 98528 cell:360-620-0618, Office: 360-372-2421 e-mail: wetlandcorps@hotmail.com
REFERENCES
Audobon WatchList. http;//audobon2.org/webapp/watchlist/viewSpecies.
Knutson, K.L., and V.L. Naef. 1997. Management recommendations for
Washington's priority habitats: riparian. Washington Department of Fish and Wildlife, Olympia. 181
PP•
Native Plants for Kitsap County. ftp://kcwppub3.co.kitsap.wa.us/pw/sw/Native
Policy of Washington Department of Fish and Wildlife and Western Washington
Treaty Tribes Concerning Wild Salmonids. Adopted by Washington Fish and Wildlife
Commission,1997.
Washington State Department of Ecology; William Symington Lake Habitat Analysis. 1998.
PO Box 2854, Belfair,WA 98528 cell:360-620-0618, Office: 360-372-2421 e-mail: wetlandcorps@hotmail.com
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FIGURE 1 VICINITY MAP
Project Name: Parcel 123203400010 UMP
Location: Belfair,Washington
Project: TWC09-353
Client: Steve Johnson
THE LAND CORDS Date: 08/09
This site map was created by TWC by
coordinating measurements and information
from several sources, including the Mason Parcel 123203400010
County Assessor Aerial Photo 2005 and
GoogleEarth aerial images and measurements.
All locations are approximate. 11 N
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Union River
Type S Stream
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building setback
150'
Proposed
Restoration Zone
(400 sq. ft)
Proposed portion//
of rock wall (10')
0 500'
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FIGURE 2. SITE MAP
Project Name: Parcel 123204390130 HMP
Location: Belfair,Washington
Project: TWC09-341
T WETLAND
C0RIPS Client: Steve Johnson
�/�/ Date: 08/09
-s Approximate
Project Location
Map Legend
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Mapper website Figure 3 National Wetland Inventory Map
Section 20 Township 23N Range 01W
FIGURE 3 NWI MAP
Project Name: Parcel 123203400010 IEVIP
Location: Belfair,Washington
Project: TWC09-353
�� Client: Steve Johnson
'roLDate: 08/09
THE WETLAND CORPS
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Onsite Soil Conditions based on Mason County Soil Survey
Subject Site Soil:
Belfast sandy loam, 0 to 3 percent slopes (Ba).-The Belfast series consists of moderately well drained, slightly to medium
acid, brown alluvial soils that lie along smaller streams. Their parent material is washed mainly from surrounding areas of
Vashon glacial drift. The native vegetation is a mixture of Douglas-fir, cedar, maple, willow, alder, vine maple, swordfem,
shrubs, and grasses. During winter the water table is close to the surface, and some areas are flooded during high water. Soil
texture and depth to underlying gravel change within short distances. Coarse sand,with or without gravel,is at depths ranging
from 2 1/2 to 4 feet.Large areas of any one texture are few.The soils are in small areas,mainly in the northeastern part of the
county along the many small streams. In some areas these Belfast soils differ from the Juno soils only in depth to underlying
gravel. The Belfast soils differ front other alluvial soils of the county mainly in having parent material that was deposited
during the Vashon glaciation. Belfast sandy loam, 0 to 3 percent slopes (Ba):This soil is mainly along the. Tahuya and
Union Rivers.It is closely associated with Belfast silt loam and with Juno soils.
FIGURE 4 SOIL SURVEY
Project Name: Parcel 123203400010
AAr IEMP
Location: Belfair,Washington
Project: TWC09-353
TA E VV 1ETL_--t_N D COR. _'� Client: Steve Johnson
Date: 08/09
i
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FIGURE 5 DNR STREAM MAP
Project Name: Parcel 123203400010 HMP
Location: Belfair,Washington
Project: TWC09-353
T H F A`fir FTL A N D COR —'� Client: Steve Johnson
Date: 08/09