ExemptionRequest.pdfMay 20, 2016
Kernen Lien, Sr. Planner
City of Edmonds Department of Development Services
1215th Ave N
Edmonds, WA 98020
Contact: Kernen Lien, k r lienITl ie!i
Re: 23.40.230Exemption Request and Review Process
Dear Kernen,
Point Edwards HOA believes that we meet the Exemption Request and Review Process regarding the
select vegetation removal activity on a critical slope. This letter will allow us to implement the work
necessary on the West and North Slope to remove volunteer saplings that are four inches (4") or less in
diameter (dbh). We believe that we meet the new Exemption Request and Review Process because this
type of maintenance on our critical slopes will become part of our existing annual routine maintenance.
The removal of ongoing vegetation will be performed in accordance with best management practices.
The work will be performed with hand-held equipment and hand tools. Some debris will be diced and
scattered to maintain natural occurring decay and larger items will be chipped. We will communicate to
The City of Edmonds when we plan to perform this work.
Point Edwards' understanding is that this letter will be placed on file with the City of Edmonds and will
act in perpetuity as an ongoing acceptance per the Ordinance.
The West and North Slope Ongoing Operations Management Plan is attached per your request. Please
let us know if you have any questions or clarification.
Thank you,
Bel' Johnson
Landscape Manager
Cc:
Brian Anderson, L.S. Chairperson, Deb Carter, Associate Manager
Tom Graff, PEOA L.S. Board Liaison,
Point Edwards Owner Association ("PEOA")
West and North Slope Operations Management Plan
Maintenance of Trees and Other Vegetation on PEOA West and North Slopes, and
Formal Grounds designated by the City of Edmonds (" COE') as Critical Areas
The PEOA shall manage its property for slope benefit, slope preservation, view
protection (including consideration for COE Code 23.10.140 Public Access), wildlife
habitat, safety and environmental benefit. The Operations Plan shall be followed and
used perpetually for the West Slope, North Slope, and Formal Grounds. A four -fold
objective shall guide the regular care for best management practices of trees and
smaller vegetation located on COE designated critical slopes:
1. Stability of overburden (the depth of topsoil and mineral soil) soil held in place by
networks of healthy, cohesive root -systems. PEOA's number one goal is to maintain
slope stability by using best management practices to avoid future landslide
hazards.
2. Health of all desirable vegetation—a multi -culture plantation shall be maintained to
avoid devastating future insect or disease problems.
3. Eradication of all noxious non-native vegetation—chiefly Himalayan blackberry,
(Rubus discolor or Armeniacus), to maintain the slopes so that they are free of
aggressive competition that will, if unchecked, eventually smother desirable stock
including trees.
4. Protection of Puget Sound, Edmonds Marsh, City, and mountain from the zero tide
beach -edge westward, southwestward and northwestward from all units of the Pt.
Edwards community that enjoy those views as committed by the Developer to
prospective owners in the Condominium Declaration' for Point Edwards.
SITE DESCRIPTION:
The elevation of the slope range west of PEOA buildings 31 and 41 has an elevation of
110 feet that drops to the property toe at approximately 30 feet above sea level. The
slope starts at the same level as the lawn west of buildings 31 and 41, and extends
across roughly 572 feet west to north. The slope is gradual at the upper sixty foot
elevation, then is typically terraced between the 60 and 40 foot elevations and then
drops to the toe.
1 The Declaration commits the PEOA to remove any trees and/or shrubs that materially obstruct views from Units in a manner that
is consistent with regulations of the City of Edmonds.
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WEST SLOPE ONGOING OPERATIONS MANAGEMENT PLAN:
Because view and slope stability are the dual goals, plant height and slope elevation
need to be coordinated. Position on the slope shall determine the intensity of
management. In all cases the plant trimmings and pruning debris will be diced up and
left on the slope near the location of origin unless if doing so would in any way risk soil
exposure or erosion.
• Please recognize that this elevation zone will require the most management with
more frequent height reduction pruning performed more often. It is better for the
plants to have smaller pruning cuts, so height reduction pruning should begin
while the plants are relatively young then maintained and repeated.
• Prune shore Pine (Pinus Contorta) and Vine Maple (Acer Circinatum) located
between a 110 feet and 60 feet to a height that does not exceed the 110' top
edge. Most Maples and Pines will be maintained at an approximate 6' benchmark
height. Shore Pines and Scots Pines develop as multi -leader trees (decurrent
form). That habit provides the skilled Landscape Manager with an opportunity to
execute height reduction pruning without drastic alteration to the trees' form or
negative impacts to their health. This document serves as notice that pruning for
shrubs, trees, and removal of noxious vegetation will be performed annually or as
necessary. These species are conducive to controlled shaping, as evidenced by
centuries of Japanese Gardens and Japanese style pruning (Local examples
Kubota gardens, South Seattle and Seattle Japanese Garden at the Washington
Park Arboretum.) Pruning needs to be done by an Arborists and/or guided by the
principles of proper pruning as outlined in the American National Standards
Institute (ANSI) A-300 pruning standardsfight./lt is, usia nes /a si-a3 -
stand�rt-1) while also under the direct guidance of the PEOA Landscape
Manager.
• Volunteer deciduous trees and shrubs will be pruned lateral clearance to reduce
competition for sunlight and space with more desirable planted species but
performed without exposing large gaps that could lead to soil exposure or
erosion.
• Any remnant, stumps of Big Leaf Maples (Acer Macrophylla), and Red Alders
(Alnus rubra) will be treated as "sugar bushes" in New England. The oldest and
largest sprouts removed leaving the smaller and younger new sprouts each
pruning session. Pruning will be done to try to gain a minimum of 6 -inches of
growing space between the bases of remaining shoots. Allowed plant height
should be determined by position on slope. The remnant stumps across the
North and West Slope equate to approximately 1 to 2% of the overall vegetation
canopy.
• Volunteer new species or any native deciduous species such as Big Leaf Maple,
Red Alder, and Black Cottonwood-Populus trichocarpa, Bitter Cherry -Prunus
Emarginata, and Native Willows -Salix Sitchensis will be removed if they have
reached a 4" diameter (dbh).
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• If a plant or a group of plants decline or die they will be replaced with the same
species or like -kind which will allow for a minimum amount of disturbance. If
plants are crowding others causing undo stress to other plants then they will be
removed or transplanted to appropriate locations.
From 60 -ft Surve ed FJevation Down to the Toe and Property,Line.
• The plants on the slope, lower in elevation will receive less intensive
management. Maintain deciduous trees to be 50 -ft tall, "benchmark height", or
taller depending on tree's slope position. Using a combination of sprout thinning,
height reduction, and/or drop crotch canopy pruning on a three -five year
schedule. Pruning back to "the benchmark" height and then pruning back to that
height on an expected perpetual schedule.
• Maintain Big Leaf Maple and Red Alder stump sprouts by allowing the strongest
to become 50 -110 -ft trees. Prune sprouts, tree canopies, and branches occurring
laterally as needed to reduce competition between species and introduce
sunlight to the forest floor to improve understory regeneration. Prune height back
to "the benchmark" while managing the structure and composition of the plants to
increase wildlife habitat, species individualism, and sunlight to the forest floor
which is beneficial for understory plants.
• Trees shouldn't be allowed to smother each other and/or desirable understory
species. Management shall include pruning as few lateral branches as
necessary to provide enough clearance for species individualism without
exposing bare soil or opening large patches.
• Some trees at this elevation should be converted into wildlife snags. Becoming
habitat trees and retained to decay through time. Few remnant habitat features
like standing dead trees or large course woody debris nurse logs currently exist.
• Single -trunk conifer trees such as Western Red Cedars (Thuja plicata), Western
Hemlocks (Tsuga heterophylla) and Douglas fir (Pseudotsuga menziesii) should
not be pruned using the same height reduction pruning methods used on
deciduous trees. View pruning on single trunk conifers is best done through
canopy thinning and end weight tipping to decrease the overall profile for the tree
rather than back to laterals. It is never recommended to top conifers back using
heading cuts. This will need to be regardless of "the benchmark".
• Volunteer trees and shrubs shall be maintained through regular pruning or
selective removal when four inches (4") or less to avoid competing with desirable
understory and overstory species. Pruning will be part of routine maintenance.
An overstory conflict example is many Red Alders growing in the dripline,
competing for space with a desirable long-lived Western Red Cedar.
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SITE DESCRIPTION:
The elevation of the slope range north of PEOA building five and below the retention
pond is fourteen feet, starting at an elevation of forty feet that drops to twenty-six feet.
The slope starts at the same level as the gravel path and sedimentation pond at building
five, and extends across roughly 285 feet west to east. The slope is gradual at the
upper elevation of forty feet and then is terraced and in many areas drops to a twenty to
thirty foot flat area that includes the WSDOT/Unocal/Chevron property. Where there is
a measureable drop there is typically a concrete wall.
The North Slope of PEOA was revegetated by the Developer with Pine (Pinus Contorta)
Vine Maples, and various shrubs such as Ribes (Current), Ceonothus, Red Twig
Dogwood (Cornus) and ferns. The understory is also covered with field grass. There is
a thicket of young dense native deciduous trees, primarily Red Alder; 77% of which are
less than 6" at 4.5 -ft above the ground a standardized height; diameter at breast height.
The PEOA intends to manage the slope stability and ecological community similar to the
above described West Slope.
Maintenance of the North Slope differs from the West Slope since the property is owned
by two distinct parties, the PEOA and Unocal/Chevron/WS DOT. In addition, Point
Edwards, LLC (the developer) included a pedestrian path and viewpoint open to the
public, north of PEOA buildings 61 and 71 at the request of the COE. View maintenance
is enforced by COE Ordinance 23.10.140. This path overlooks the North Slope, the
Edmonds Marsh, the Ferry terminals, the north-western Puget Sound waterfront, Mount
Baker, and the City of Edmonds. Note: PEOA does not have jurisdiction over view
corridors past our property line and therefore cannot be held responsible for complying
with COE Ordinance 23.10.140.
The slope north of building one has a slope range of twenty-six feet, starting at an
elevation of seventy feet that drops to forty-four feet north of building one. This slope is
fairly gradual and also extends to the Unocal/ChevronM/SDOT property line. It also has
a thirty foot flat area that includes the WSDOT property.
The slope north of building 61 has a slope range of thirty-seven feet, starting at an
elevation of seventy feet that drops to thirty-eight feet north of building two. This slope
is fairly gradual; has one area that drops and it also extends to the WSDOT property
line. It also has a twenty foot flat area that includes the Unocal/Chevron/WSDOT
property.
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NORTH SLOPE ONGOING OPERATIONS MANAGEMENT PLAN:
The primary goal is always to maintain slope stability and health but reasonable use and
enjoyment of the unique Edmonds viewshed is also an objective. The PEOA desires to
manage the North Slope to improve the number of native plant species present, to
increase the ecological composition and structural diversity in order to better retain,
move, and manage storm water by introducing ferns, large shrubs and managing long-
lived, tall, deciduous species to be an appropriate height to meet "the benchmark
views".
There are currently 145+ Alder trees and saplings, 3 Big Leaf Maples over 6' (dbh) and
7 Cedars located on PEOA property.
• The developer planted area (between the walking path and the property
line), shall be kept clear of nuisance invasive species (such as but not
limited to) Blackberry, Alders, Willows, Cedar, Fir, Hemlock starts, Scotch
broom, and Ivy.
• Use best management practices starting at the elevation of approximately
70' to the toe and regularly prune all new and existing Alder shoots, Cedar,
Fir, Hemlock, or any other deciduous or evergreen saplings and invasive
species at a dbh 4" or less to avoid competing with desirable understory
and overstory species on an annual or as needed basis.
o Cuttings/brush which results from maintenance pruning across the slope shall be
diced and scattered to achieve maximum contact of cuttings with slope -surface
soil and duff (partly decayed organic matter on the floor of a forest).
• Reduce the height of three Big -Leaf Maples and maintain leaders at
approximately 6 feet. Such pruning will stimulate new shoot growth.
Proper thinning can result in crown reduction and open canopies for framed
views and increased sunlight to desirable understory vegetation. No
stump's shoots shall be pruned until the largest shoot on any stump has
developed a stem diameter of 2" measured 18" above the stump's surface.
The PEOA Landscape Manager will then selectively eliminate as many
shoots as needed to create (or open up), at the existing stump -surface, a
minimum 6" growing space between the bases of remaining shoots. When
Maple shoots reach higher than 6 feet, they shall be pruned as needed—
usually on an annual basis. Hand held power tools, hand -pruners or small
hand -saws shall be used for such pruning which will be determined by the
Landscape Manager.
• The majority of Pine trees that stand near the top (approximately 70' as
opposed to the 110' on the West Slope) and throughout the North Slope
shall be maintained as large bushes. They will still absorb and transpire
water out of the ground during the growing season—they are not in
dormancy. This will preserve the slope by not allowing the trees to get so
tall that they become top heavy, susceptible to blow -down, and cause soil
erosion or ultimately become a landslide hazard.
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• No Maple or any other species shall be allowed to over -shade conifers
(Pines primarily). All conifers shall be maintained to give a full foliage
crown (pruned properly for height control), including Shore Pines and Scot
Pines.
• Volunteer saplings/trees, and shrubs shall be maintained through regular pruning
or selective removal when they reach four inches (4") dbh or less to avoid
competing with desirable understory and overstory species. Pruning will be part
of routine maintenance.
• Due to the volume of vegetation on the formal portion of the developer planted
area a mix of shearing and hand pruning shall occur. Pruning will be done with
hand -pruners, hand saws, hand-held equipment, and lopping shears for pruning
of wood (saplings) less than four inches (4") in diameter. Small chain -saws may
be necessary for wood three inches (3") and greater in diameter or thickness.
Cuttings/brush which results from maintenance pruning across the slope shall be
diced and scattered to achieve maximum contact of cuttings with slope -surface
soil and duff (partly decayed organic matter on the floor of a forest).
• All conifers throughout the North Slope shall be maintained at a height that is
conducive to prevent slope instability and view obstruction (6' to 10' benchmark)
depending on location of trees. Pines located by the sediment pond shall
generally be pruned annually but may be maintained to a different height than
those located along the public pathway. Those conifers along the public pathway
will need to be pruned to promote lateral growth for view preservation. Shore
Pines and Scots Pines develop as multi -leader trees (decurrent form). That habit
provides the skilled Landscape Manager with an opportunity to execute height
reduction pruning without drastic alteration to the trees' form or negative impacts
to their health.
PEOA Formal Grounds:
The formal grounds originally designed by the Point Edwards, LLC (the developer) also
require maintenance specific to slope benefit, safety and view protection. The PEOA
shall use best management practices to maintain the formal grounds as follows:
• Shrubs and trees may be replaced, removed or divided and relocated as long as
the overall appearance is consistent with the "lush" look of the original landscape.
Such areas will be maintained for overall health of the landscape.
• Trees shall be regularly thinned to prevent view obstruction. Proper thinning may
result in crown reduction and open canopies for framed views and increased
sunlight to desirable understory vegetation.
• Damaged and diseased trees shall be removed promptly to minimize harm to
residents, the public, and surrounding vegetation and trees. Proper tree
replacement will occur — for every one tree being removed one tree will be
replaced.
• All noxious non-native vegetation — chiefly Himalayan blackberry (Rubus discolor
or Armeniacus) and English Ivy shall be eradicated to maintain the formal
.-.-.-.__-..... _..................................
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grounds and keep them free of aggressive competition that will, if gone
unchecked smother desirable stock including trees.
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