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T ECHNICAL M EMORANDUM
Date: April 12, 2017
To: Clark H. Close
From: Kenny Booth, Andy Noone
Permit Number LUA16-000614, ECF, SM,
TWC Project Number: 150809
Project Name: Southport Shoreline Modifications
Subject: Response to October 11th, 2016 comments and questions
This letter is intended to respond to the October 11, 2016 “On Hold” Notice, which includes
requests for additional information regarding the Southport Shoreline Modification Project
(LUA16-000614). Since receipt of the notice we have initiated revisions to the proposed project.
A detailed description of project revisions, as well as a specific response to each of the
comments received is provided below.
Project Revisions:
• To increase the amount of mitigation offered, in the easternmost extent of the project
area, approximately 53 linear feet of bulkhead is proposed for removal to facilitate the
enhancement of the shoreline through construction of a more natural soft-shore cove.
This shoreline enhancement will also include removal of additional pilings (51),
placement of woody debris, placement of salmon-friendly gravels, and installation of
575 square feet of native emergent and upland plantings.
• A superior alternative bulkhead repair method is proposed. This method allows for
removal of additional in-water components including pilings immediately adjacent to
the existing bulkhead. Removal of the in-water components adjacent to the bulkhead
allows for the proposed apron to be excluded from the plans, thereby reducing
overwater coverage.
• Access ways to the float have been modified. Two new pilings will be required for two
small piers that provide access to each float. Due to the changes in access, overwater
coverage of the western float has increased slightly and overwater coverage of the
eastern float has decreased. The changes to the floats and access, along with removal of
the apron represents a significant reduction in over water coverage (1,636 square feet).
• The access ways to the floats have been modified to ensure that 18-inches of clearance is
maintained throughout the nearshore environment.
Southport Shoreline Modifications Technical Memorandum – Response to Comments April 2017 Page 2
Response to comments in October 11, 2016 “On Hold” Notice:
1. The Lake Study notes that the proposed new floats are "intended to provide public access
opportunities for primarily non-motorized watercraft." How do you intend to regulate these floats so
they do not become moorage facilities for motorized watercrafts?
Response: The floats will not specifically prohibit motorized watercraft. As such,
incidental use of motorized watercraft will likely occur. However, the proposed floats
will be designed to accommodate non-motorized watercraft. Additionally, the proposed
floats are designed to accommodate temporary moorage – no permanent moorage or
boat storage is proposed.
2. Why is the easternward float as large as proposed? If it is to be used for non-motorized watercraft, it
should be sized similarly to the westernward new float as shown on the plan sheets.
Response: The proposed float is sized to accommodate current and anticipated
demand. The Southport development complex, when completed, will include a 347-
room hotel, 383 apartment units, 24,138 square feet of retail space and over 728,000
square feet of office space. The proposed floats are also in the vicinity of the popular
Gene Coulon Memorial Beach Park. If the eastern float were reduced in scale similar to
the western float, the available temporary watercraft moorage would be inadequate and
require future expansion. With that said, the total amount of proposed overwater
coverage has been reduced by nearly 40% from 4,227 square feet to 2,591 square feet.
3. More information is needed about the pump out facility. We did not see where this new facility is
proposed. The details of this facility and its location should be included in revised materials.
Response: The peristaltic pump out facility will be sited along the western property
boundary on the existing wharf. The location of the facility has been added to the plans.
4. Have you tested the surrounding sediments to see if creosote has spread beyond the proposed piling to
be removed?
Response: No testing of sediments has occurred or is proposed. Proposed pile removal
will be consistent with Washington Department of Natural Resources Derelict Creosote
Piling Removal Best Management Practices, which are adapted from EPA guidance and
WSDOT methods. The BMPs described in this document do not include testing of
surrounding sediments.
The Watershed Company Technical Memorandum – Response to Comments April 2017 Page 3
5. Is there a rough estimate available for the number of new pilings that will be needed to support the
bulkhead? See Table 1 from the lake Study.
Response: The proposed bulkhead repair plan has been modified and as a result no
new pilings will be needed to support the bulkhead. The repair will involve the
installation of sheetpile along the bulkhead instead. Two pilings will be necessary for
each float system in order to connect the float systems to the existing bulkhead.
6. Why are you proposing to keep the existing timber pile stubs shown east to the new easternward
float? These pilings should be removed to reduce salmon predator habitat and provide improved
conditions for juvenile Chinook and other salmon.
Response: The proposed plans have been modified to remove all derelict piles,
including those east of the eastern float.
7. The lake Study notes that no lighting is proposed as part of the shoreline improvements; however, the
Biological Evaluation notes that there may be lighting. Please clarify if the new floats will have
artificial lighting.
Response: No artificial lighting is proposed.
8. Also, the lake Study and Biological Evaluation notes the four, 5-story mixed-use apartment
buildings, a new hotel comprised of two-12 story buildings, and 3 office buildings that are now or will
be under constructed all of which should be expected to have outdoor artificial lighting. How are these
adjacent buildings ensuring that their artificial lighting will avoid shining on Lake Washington in
the project area thus reducing the salmon mitigation benefits from this project?
Response: The other projects in the Southport development complex (including the
apartment buildings, hotel, and office space) were permitted separately. Concerns about
lighting impacts and mitigation with those developments have been addressed as part of
the Shoreline Permit LUA99-189. This project seeks approval for bulkhead repairs, float
installation, removal of derelict in-water piles and cove construction only.
9. Can you work with WA DNR to see if the drifted logs resting against the bulkhead that are proposed
for removal can be used at the two WA DNR mitigation/enhancement sites (i.e. South Lake
Washington and Bird Island) adjacent to this project.
Response: The project team will attempt to reach out to DNR to see if the logs resting on
the bulkhead that are proposed for removal are suitable for the nearby
mitigation/enhancement sites mentioned.
10. On page 1, of the submitted, project narrative, it reads: "The central shoreline area ten feet upland of
the bulkhead includes a pedestrian easement (Recording Nos. 2005102100894, 20051021000895, and
Southport Shoreline Modifications Technical Memorandum – Response to Comments April 2017 Page 4
20051021000896)." Please note that there are four (4) recorded public pedestrian easements to the
City related to this property (Rec. Nos. 2005102100894, 20051021000895, and 20051021000896,
and 20160208000458).
Response: The project narrative has been revised to correctly reflect all four pedestrian
easements on the property.
11. On page 9, of the submitted project narrative, it reads: "an additional 3,853 square feet of publically
accessible shoreline use area is being added. Accordingly, at least three additional public parking
spaces will be provided. The nearest parking that is provided (see Figure 2) is located approximately
150 feet from the shoreline and outside of vegetated buffers. Since boat launching will not occur on
site, the demand for public parking is expected to be minimal. There is additional parking nearby
associated with the apartments, the forthcoming hotel, the commercial developments, and the nearby
Gene Coulon Memorial Beach Park. Much of these additional parking facilities will be available for
use by the public." Parking is for day-use only at Gene Coulon Memorial Beach Park, and for park
patrons. The parking spaces provided at the Park do not support additional activities from
neighboring amenities. Please remove all references to off-site parking availability at Gene Coulon
Memorial Beach Park within the project narrative and any other submitted document that makes the
same claim.
Response: The project narrative has been revised to remove all references of parking at
Gene Coulon Memorial Beach Park. No other documents discuss public parking.
12. Clarify and describe in more detail why the project will not be replacing the abandoned 164-foot-long
floating walkway referred to as the "log boom." This log boom protected the wood bulkhead on the
eastern edge of Southport’s property line and provided shoreline protection by minimizing wave
action to Gene Coulon Memorial Beach Park. The structural integrity to all surrounding bulkheads
should be adequately addressed to ensure Park stability. The structural observation report should also
address impacts to the natural shoreline of Bird Island as a result of abandoning the log boom.
Response: Mott MacDonald has prepared a memorandum summarizing the results of a
study assessing proposed vessel wakes and wave impacts. The study concludes that
wave action from wind and vessels in the moorage area of the project site is
insignificant. Thus, replacing the log-boom that was removed over 15 years ago is
unlikely to provide any necessary benefits to the shore or bulkhead. Additional
information and detail about expected waves in the moorage area can be found in the
Recreational Dock Facility Passing Vessel Wave Review memorandum (Mott
MacDonald, December 2016).
The log boom slated for permanent abandonment was removed over 15 years ago and
its location was over 100 feet away from Bird Island. Removal of the log-boom likely did
not have any negative impacts to Bird Island. Removal may have actually provided
some benefits by reducing nearby over-water coverage. If removal resulted in any
The Watershed Company Technical Memorandum – Response to Comments April 2017 Page 5
significant negative impacts to Bird Island they would have likely been identified at
some point in the last 15 years, or through the active restoration project that is underway
at the site. The log boom slated for abandonment is shown below in Figure 1.
Figure 1. Removed log-boom location. Note distance from Bird Island.
13. With increased boat traffic, staff recommends completing a Wave Analysis. The report should
incorporate all potential impacts to Gene Coulon Memorial Beach Park around Bird Island and the
west side of Coulon Park (the area near the vicinity of the abandoned log boom). Please specify vessel
sizes and trip numbers as part of the analysis. Recommended mitigation and protection measures
should also be included in the report to regulate boat traffic.
Response: Additional correspondence with the City has indicated that “at this time, you
do not need to complete a wave analysis but rather a lesser report that provides expert
defensible analysis demonstrating the insignificance of the wave study.” Accordingly,
Mott McDonald has prepared a report that demonstrates the insignificance of a formal
wave study. Additional information and detail can be found in the report.
Bird Island
Log boom