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Attachment 9 - Public Comment with PE ResponsesMarch 23, 2021 The Point Edwards Homeowners Association (PEHOA) submits this reply to those public comments filed with the City of Edmonds (COE) regarding Point Edwards (PE) proposed permit (Type III -A) PLN2020-0054 and Land Use Management Plan (LMP). Questions of Mike Shaw dated February 16, 2021: 1. With a previous history of unauthorized (and very environmentally detrimental) tree removal in their past, have the Point Edwards people shown the awareness and willingness to do better this time. PE: In reference to Mr. Shaw addressing the applicant is not as "the Point Edwards' people," we are proud to be citizens of Edmonds who own condominium units at Point Edwards (PE) organized as the PEHOA. PE does not have a history of unauthorized and environmentally harmful tree removal in their past. Mr. Shaw is likely referring to the wrongful clearing of what is called the West Slope by the developer in 2003. That action was not known or approved by the PEHOA prior to its occurrence. In fact, the developer's wrongful actions took place long before the first two condominium buildings (Bldgs. 61 and 71) were built and ready for occupancy in January 2005. See, 20050112563, Snohomish County Records. Neither the residents nor the PEHOA had the power to stop the unforeseeable actions of the developer as the West Slope was under the sole control and ownership of the developer. The PEHOA hired Bel Johnson as its Landscape Manager. She is a well -respected landscape designer and manager. Bel works closely with the COE in managing the slopes. Since her full- time employment with PE there has been no complaints regarding slope management, wildlife habitat nor vegetation issues. She has worked diligently within the codes and guidelines that the City of Edmonds sets forth. We share Mr. Shaw's interest in the health of the slopes, their flora and fauna. Slope preservation, wildlife habitat, and healthy vegetation are always at the forefront of all decisions. 2. If active bird nests (one's birds are currently using and that may have eggs in them) are discovered in any of the trees to be cut down, is there a plan? PE: The residents are mindful of the environment and ecology surrounding PE. The trees, shrubs, and foliage on the slopes are a part of the residents' back yard. 1. The birds and wildlife live in the residents' back yard. Very few birds' nests have been sighted within the areas proposed for actions under the permit. So far 1 nest has been sighted and appears it is inactive. PE' s plan is not to take action except -1- Attachment 9 for possible pruning, on any trees harboring nests, active or inactive. If pruning is planned on a specific tree, that pruning will occur when no birds are present. 3. If active bird nests are discovered in any of the trees to be pruned, will they be treated with all due caution and respect? PE: Point Edwards has a regular and well -established practice of not pruning trees, shrubs, and bushes when birds are nesting within them. This is nothing special. It is just how PE and its Landscape Manager Bel Johnson conducts landscape management. See also, reply to question number 2 above. 4. If animal dens or burrows are discovered in the areas necessary to achieve tree removal or pruning, will they be left undisturbed as much as possible? PE: If dens and burrows were to be found during the proposed management of the slope, they would be treated as they are on the West Slope. Dens and burrows are left alone and not disturbed. This is a part of a well -established landscape management plan. It is how Bel Johnson conducts her landscape practice. S. Will care be taken not to let potential pollutants (petrochemicals, pesticides, high nitrogen and/or high -phosphorous fertilizers) leach into the ground/groundwater? PE: Trees that are marked for removal will be continually recut to avoid use of chemical applications. Organic composted material will be used as soil amendments where required. Chips made by work performed will be used as top dress once revegetation has occurred. At least 50% of the material from the trees felled will remain in place to break down organically. No petrochemical or other toxic chemicals are planned for use in PE's proposed permit actions. There is no plan to use high nitrogen and high phosphorous fertilizers. See Permit Application, p. 26. 6. Will the access footprint for this activity be as small and minimally invasive as possible? PE: Yes, the actions proposed in the permit have been developed by PE in collaboration with Arborists, Biologists and Save Our Marsh citizen/scientists so that the final result will be beneficial to wildlife and -slope stabilization into the future. Yes, the footprint will be small and minimally invasive. Each proposed action is limited to a specific tree which is identified by number and species. There are no generalized actions involving the trees on the slopes. The area proposed is quite specific and small -scaled in comparison with the size of the north slope. Once again, each action is limited to a specific tree. 7. If any of the above is NOT achieved, is there a plan for mitigation/restoration? -2- Attachment 9 Raedeke and Associates has submitted a Technical Report as part of PE's supplemental package which covers Mr. Shaw's questions regarding mitigation measures. PE also will be monitoring, inspecting, and reporting to the COE the progress of the revegetation for 5 years. There are plans for the possibility that some revegetation may fail. PE also proposes sharing annual pruning schedules with the COE. See, Permit Application, pp.27-28. 8. Will the company chosen for this work be vetted and held accountable for a high environmental and ecological awareness, sensitivity, and track record? PE: Champion Tree Service under the supervision of Champion Tree Care, Justina Kraus, and the PE Landscape staff under the supervision of Bel Johnson will be conducting the proposed permitted actions. Justina Kraus is ISA (International Society of Arboriculture) certified arborist. Every three to five years, Ms. Kraus meets TRAQ (Tree Risk Assessment Qualified) standards. Ms. Kraus has a B.S. and M.S. in Urban Forest Ecology and Management from the University of Washington. Bel Johnson is a well -recognized landscape designer who has received several awards from the Edmonds horticultural community. Bel's qualifications are evident in the condition of PE' s formal grounds. Comments from the SOM dated February 13, 2021: 1. Is the proposed site for tree removal in the vicinity of the 'illegal' tree removal that occurred when Point Edwards condos were developed, and will the land management actions affect the mitigation that should have occurred for the illegal cutting? Answered by Kernen Lien: Following the cutting in 2003, the City entered into a settlement agreement with the developer that included replanting of the western slope to mitigate the cutting. The settlement agreement with the developing provided little language on the maintenance of the planting. The current application does not propose any tree removal on the western slope (the area of the illegal tree cutting referred to) but does provide information on vegetation maintenance on the western slope. The tree cutting action are in the different portions of the property than the 2003 cutting. 2. Has a wildlife professional assessed the potential effects of the proposed landscape changes on wildlife in the area including 1) the resident bald eagles on Pont Edwards; 2) the wildlife using the Demo Garden, the Willow Creek wildlife corridor, and the Edmonds Marsh -Estuary and Wildlife Sanctuary; and 3) wildlife that currently or in the future (after restoration) will utilize lower yard of the old Unocal property that has a large pond used by migrating waterfowl and is the potential sit of an expanded Wildlife Sanctuary in Edmonds? Answered by Kernen Lien: The application has not been evaluated by a wildlife professional. Staff has requested a survey for a potential blue heron colony on the site that was identified on the State's Priority Habitat Species layer, but not an overall evaluation of the proposal. The -3- Attachment 9 proposal will create 24 wildlife snags, each tree that is cut will be replaced at a ratio of one to one and the proposal also calls for planting of shrubs and groundcover which will improve the diversity of habitat of the primarily alder stand that currently exists. PE's response to comments from SOM dated February 13, 2021: PE: Point Edwards at the request of the SOM and Raedeke Associates, Inc. has amended the Permit to address the wildlife. Raedeke Associates, Inc. has been retained to provide Great Blue Heron information as well as the review of PE's Permit Application and LMP with respect to bird and wildlife habitat and impact. Raedeke Associates' qualifications can be reviewed at https:Hraedeke.com. In short, the firm was founded over 40 years ago by Dr. Kenneth J. Raedeke, Ph.D., a former professor at the University of Washington, College of Forest Resources. Raedeke Associates has expertise in environmental impact statements, land stewardship planning, habitat conservation plans, habitat management plans and wildlife inventories among other ecological and environmental subjects. Raedeke Associates' report will be filed with PE's amended permit application and LMP. Bebobopbill dated February 24, 2021: 1. I would encourage you to space out your timetable, and not cut so many at once. And it being on a steep slope above a wetland, I would think that this is a critical area, and all tree cutting should be limited and curtailed. Mr. Phipps believes that the slope is steep and critical. He is correct. The slope is classified as a critical slope by the COE with resulting management requirements for the vegetation on the slope. The vegetation on the slope must be managed to minimize slides and soil erosion. Fostering the health of the urban forest on the slope requires selected tree cutting and pruning. Mr. Phipps believes that any cutting should be done in phases. PE did consider whether performing the removal work in phases would benefit the wildlife, but it does not. If PE did not do the work consecutively but phased it over a longer period of time this would have a much larger consequence on the wildlife, due to continued disturbance. SOM dated February 23, 2021: We urge you to revisit your Landscape Management Plan with an eye towards the adverse as well as beneficial aspects of vegetation management on wildlife in the area. We appreciate the desire to maintain views of the beautiful environs around Pt. Edwards, and only ask that your landscape planning take into account and "balance" the value of trees for life history needs of wildlife (as well as human health) with property owner desires open views. M Attachment 9 The application and its accompanying LMP is required because the vegetation on the slope need to be managed to minimize the risk of slide and erosion. No LMP will prevent slides or erosion. However, slides and erosion can be managed, and they present a direct, not speculative, risk of harm to wildlife. The North Slope presents " ... a significant concern for slope erosion and loss. If this occurred, the impact on habitat would be substantial." See, Blair Bernson, Public Comment submitted on February 24, 2021. PE accepted SOMs suggestions for consultation with wildlife professionals. See, Raedeke Associates' Technical Memo discussed above. Their professional opinion is that phasing in the removal of trees is more likely to adversely impact wildlife than acting at one time. They have years of experience and considerable expertise in the application of both the state and federal Environmental Protection Acts and SEPA. We trust in their judgement. PE shares the same vision you espouse regarding the Unocal property. We do not want to see commercial development or waste land. What we see now, however, is a wildlife corridor that could be far better than it is. A monoculture of alder is developing and, in some places, has taken hold. In this area, there is limited production of berry, fruit or seeds for animals, birds, or beneficial insects. There is dense canopy, spreading ivy, and bramble. In that part of the monoculture encroaching on PE's property, the proposed permit and LMP will take this habitat which lacks diversity and turn it into a place where a variety of birds and animals can nest and live. Marthlynn Jones dated February 24, 2021: 1. As a citizen and member of Save Our Marsh who appreciates all aspects of nature, I carefully read the proposal and studied the maps for the petition by the Point Edwards Homeowners Association to remove or prune 175 trees that are close to the Edmonds Marsh, Willow Creek, and the Salmon Hatchery, and I have several concerns. According to the application, 175 trees will be altered (removed, turned into stumps, pruned) across the area in front of the entire Point Edwards complex yet only 45 trees will be replanted, and all of those are in section 102 on the east side. PE: Ms. Jones mis-characterizes how the proposed permit activity will occur. The proposed permit will affect only the North slope, not the entire PE complex. Nor will the entire border of the Unocal property be without trees. PE's property intersects with the Unocal Road only at two small points. There is a considerable barrier of trees between PE's property line and the Unocal Road that is on Unocal property and will not be touched. Where the Unocal Road ends, the trees on PE's property merge into the Alder on Unocal property which unfortunately will remain. For example, on map L102, which is close to the Unocal Road, and off Pine Street and the Demo Garden and hatchery, no trees are scheduled for removal. There are two trees that will remain -5- Attachment 9 untouched and be monitored in the future. Yet even though no trees will be removed, 25 trees will be replanted. On map L103, a bit farther from the Unocal Road and with a substantial barrier of trees between that road and PE' s property line, no trees are being removed. No trees will be replanted. On map L104 and L105 showing PE's property merging into the Unocal monocultured forest, 35 trees will be removed, and 20 trees will be replanted. However, in these two areas 437 new plants, including the noted trees, will be planted bringing seeds, berries, fruit, and foliage to this area which lacks any nourishment for wildlife. See, Permit Application, pp. 24-25 and Permit Application, Maps, Exhibit 2. 2. On the State Environmental Policy Act (SEPA) checklist form under "animals that could be affected," only rabbit and coyote are noted. There are no listings under the headings for birds or fish. The truth is, the Point Edwards Community Trail is listed as a birding hotspot on the popular bird website eBird. Fifty-seven bird species have been sighted from the trail in recent years. You can see the list at #bit.ly//3glwBj#. Shouldn't this information be included on the SEPA checklist? PE: The SEPA checklist form has no such phrase "animals that could be affected". Section b.5.a.(page 10) asks for "birds and other animals that have been observed ... the site. Save our Marsh have addressed the SEPA Study as well. Our SEPA Study has been amended by Raedeke Associates, an environmental and wildlife consulting firm who has reviewed PE's SEPA Checklist. PE recently received an amended bird list from Save Our Marsh which is referred to in the SEPA Checklist as exhibit 11 in the Permit. Raedeke has had years of experience and expertise in the application of both the state and federal Environmental Protection Acts and the SEPA Checklist. PE will follow Raedeke' recommendations. In their Technical Report it notes observations of 17 bird species during their field investigations and references the bird list provided by Save Our Marsh, which is referred to in the SEPA Checklist as exhibit 11 in the Permit. They recognize that a wide variety of birds and mammals may be found on the site or in the vicinity at different times of the year. Point Edwards and Raedeke Associates are confident that all the SEPA questions have been addressed. We are pleased that we are listed as a birding hotspot. We take great care and passion regarding our slope wildlife. 3. The petition states that they will plant shrubs and groundcover to "increase species diversity." There is already a lot of species diversity documented in the area. We need to understand how all the species that are present now use the current vegetation before we make drastic changes to it. Attachment 9 PE: The revegetated areas will enhance the wildlife habitat. Presently, there are only alder, ivy, and other invasive plant material in the area proposed for revegetation at this time. The area is barren of any beneficial wildlife habitat. The backside of the Pines and their structure have been completely compromised by the alder and there is few wildlife that can forage in this planned revegetated area. While rabbits abound unfortunately on the upper edge of the North and West slopes where the slopes abut PE's formal grounds, they are not sighted in the dense alder where there is limited food or shelter for them, only ivy and bramble. While many birds are sighted in the permit area, there is little signs of nesting activity. We believe that with the introduction of low structural diversity and the presence of the invasive species being improved by that structural component and the elimination of those invasive species, (replaced by native species) it will provide a higher quality habitat. By planting a diverse variety of food and foliage for bird and wildlife, it is hoped there will be an increase in the number and type of bird and wildlife residing in the permit area. 4. The petition states that there will be no tree work within 200 feet of any of the waterways that are nearby including the marsh, Deer Creek Hatchery, Willow Creek, and the Unocal property. None of the properties were shown on the tree maps, so how do we know that this claim is accurate? PE: Ms. Jones is referred to Google Earth and Google Maps where she can review the location of PE's property line and waterways and other locations. Lastly, the commentator needs to review why the COE requires critical slopes to be managed. The slope is harmed by erosion and slides. Animals and birds are harmed when their habitat is destroyed by slides and erosion. Wildlife habitat is enhanced when dense, dark, monoculture urban forests are changed into areas where berry and seeds can feed the birds and wildlife. 5. And how will the pond on the Point Edwards property be affected? PE: The pond will not be impacted by the work. The tree work will be done in fall to winter to not disturb nesting periods. In the spring when the revegetation occurs, PE believes that it will invite more wildlife into this section due to the native plant life that will be installed of which there is none at this time. 6. The trees that are to be removed are all listed as being 36 feet tall. Replacing the 36- foot tree with a 2-foot tree does nothing to improve wildlife habitat. Shouldn't there be requirements for the maturity as well as a type of tree that is replacing a fully grown tree? PE: We believe most trees will be in the 6' to 12' range depending on availability. It would take heavy equipment to install for instance a 20' tree or larger caliper trees which we will not be using. All plant material will be brought in, holes dug, and planted by manual labor. There is -7- Attachment 9 documented evidence that planting a tree that has a smaller root structure is more likely to survive. Statement made by Marthlyn Jones — "I believe that we need an independent evaluation by a wildlife ecologist to answer questions about how wildlife is currently utilizing the areas that would be affected; ... and the streams and wetlands." PE: Ms. Jones wants to understand what the risk to wildlife would be with the removal, coppicing, and pruning 175 trees. She would like to understand how the removal of the trees might impact the waters. Whether there is indeed a 200-foot buffer between the project area and streams and wetlands. Raedeke Associates has been hired and has done a thorough study of the revegetation area which will be available for review (Technical Report by Raedeke Associates). The Technical Report is part of the supplemental information being sent to the COE to update the original Permit. 9. Many Edmonds citizens were appalled and sickened when the tall trees in this area were butchered illegally one weekend during the building of Point Edwards many years ago — trees where bald eagles roosted, and herons nested. PE: There are over 400 Edmonds citizens that reside at Point Edwards currently. The slopes are an integral part of our 21-acre site. With passion and attention, we manage our slopes. The Landscape Management Plan will allow us further attention to detail, and we continue to join with the City of Edmonds to make our critical slopes healthy and inviting for all types of wildlife and people to enjoy. Below are two selected comments published in MY EDMONDS NEWS which cover different issues than those sent to the COE are included here for a response. Comments by Joe Scordino dated February 25, 2021: PE: We appreciated Mr. Scordinos' input and on sight meeting at Point Edwards. Point Edwards has addressed the questions that Save Our Marsh and Joe Scordino posed and have amended all Permit documents so the wildlife on Point Edwards north slope is more thoroughly addressed. The vast majority of the trees being scheduled for removal are alder. The vast majority of the trees remaining are alder. The trees are being replaced on a one-to-one basis and the replacement trees are either 100% native or native cultivars hybridized with other species to increase their chance of survival. The replacement trees will bring diversity to the forest and food for wildlife that is not now present. PE would like to plant Pacific Northwest Dogwood, Cornus 'nuttallii'. That species is beautiful, provides fruit and seeds -for wildlife and is native. However, it suffers from Dogwood anthracnose and would not be a good choice. Cornus 'Eddies White Wonder' provides the same beauty and adds the additional fruit and seed as the native species because it is part of the native species that has been hybridized to resist In Attachment 9 anthracnose. This is but one example. However, PE has reviewed with its wildlife biologist the ratio of non-native species in its replanting plans and have altered its selection of plants and trees so that they are all native or native cultivars. And finally, this is not about views. Those trees being removed or pruned are being acted on to improve the slope and forest. If view were a paramount or even high priority, an entirely different selection of trees in entirely different locations would be identified for removal. Comments by Alan Mearns dated February 27, 2021: We need an assessment, right now, of the birds and wildlife uses of the forest below the Residential buildings. At least 3 large nests are easily visible in the currently leafless native deciduous tree canopies. The nests are even visible from the boardwalk on the north side of the Marsh (from Harbor Square lookouts), using binoculars and cameras with telephoto lenses. Two nests look very much like Bald eagle nests. "Right now" means before the deciduous trees leaf out in mid -March, when it will be much difficult to view existing and new nests. Ironically, we are into the second year of an ongoing, decade -long, professional biweekly "Edmonds Marsh Avian Habitat Us Monitoring Study -at -Edmonds -marsh -project)). sponsored by the Pilchuck Audubon Society and the Puget Sound Bird Observatory (see Avian Habitat Use Monitoring at Edmonds Marsh — Pilchuck Audubon Society). This study includes the buffer zone and tree habitats below the condominiums. I would appreciate knowing if the PE HOA or the City is looking at that data as part of the permit evaluation. What a shame if that science is being ignored. PE: has hired Raedeke and Associates to review the herons and other wildlife. Wildlife including nesting birds is paramount to their consideration. PE does not know if Raedeke is using the website you mentioned but as experienced experts in bird and wildlife habitat, PE is sure that they are aware of the resource. Supplemental filing for the Point Edwards Permit has updated information that is being submitted to the City of Edmonds. In Attachment 9 From: Save Our Marsh <save.the.edmonds.marsh@gmail.com> Sent: Saturday, February 13, 2021 11:07 AM To: Lien, Kernen <Kernen.Lien @edmondswa.gov> Cc: Council <Council@edmondswa.gov>; Nelson, Michael <Michael.Nelson @edmondswa.gov>; mtmian1946@gmail.com; bel@pointedwardshoa.com Subject: Point Edwards Tree Removal Application #PLN2020-0054 In response to the public notice (copy attached) placed on Pine Street near the Demo Garden and potential 'soon -to -be' Wildlife Sanctuary adjacent to Point Edwards, we request you provide us advance notice of all hearings, actions and subsequent documents posted at http://edmondswa.gov/public- notices-text/development-notices.html for Application Number PLN2020-0054. Save Our Marsh will be added as a party of record and receive future notices for this application. However, parties of record are not contacted every time new material is submitted on a application. To see if other documents have been submitted, Save Our Marsh can reach out to me periodically to see if additional information has been submitted. The applicants have until April 28t" to respond to the City's first round of comments. From: Save Our Marsh <save.the.edmonds.marsh@gmail.com> Sent: Tuesday, February 23, 2021 9:37 PM To: Lien, Kernen <Kernen. Lien @edmondswa.gov> Subject: Re: Point Edwards Tree Removal Application #PLN2020-0054 Mr. Lien - we note that the PLN2020-0054 website does not currently include several exhibits referenced in the application (Exhibit 413, 4C and Critical Area Checklist) - will those be posted soon? Will future postings include the additional information request(s) you made of the applicant? Exhibit 413, 4C, Critical Area Checklist and the subsequent critical area determination are attached. Additional information will be posted with the Notice of the Public Hearing and will be included in the staff report to the ADB. Also, would it be possible for the City to post the Settlement Agreement(s?) referenced in the application for the Point Edwards illegal cuttings on the PLN2020-0054 website? If posting is not appropriate, could you E-Mail us the documents? Settlement agreement is attached. Lastly, could you clarify the approval process? Is the City's Architectural Board the only entity involved in recommending approval/denial to a Hearing Examiner or are there City of Edmonds recommendations/approvals (such as critical areas) involved? The application is a Type III -A process with the Architectural Design Board issuing the decision which is appealable to Superior Court. The application is design review because it is a modification to the landscape plan for the Point Edwards development. The City has issued the critical area determination for the property which is attached. The project also requires SEPA review and the City will issue a SEPA threshold determination prior to the public hearing before the Architectural Design Board. The SEPA determination is appealable to the Hearing Examiner. If the SEPA determination is appealed, the ADB's -10- Attachment 9 meeting will only be a public meeting (no public comment due to state law restrictions against two open record public hearings) and the ADB will make a recommendation to the Hearing Examiner. The Hearing Examiner would issue the decision on the SEPA appeal and design review application. A staff report analyzing the proposal consistency with City code will be available a week before the ADB meeting. Thank you for your assistance. We're sure you understand the proximity of the proposed tree removals to a wildlife corridor and future Wildlife Sanctuary is of great concern to Edmonds citizens. Yes I was aware this application would be of interest to Edmonds' citizens. Letter to the editor: Wildlife concerns with tree removal at Point Edwards Posted: February24,2021 @ 1126 Save Our Marsh sent the following letter to the Point Edwards Homeowners Association and requested that it also be published as a letter to the editor To: Point Edwards Homeowners Association We urge you to revisit your Landscape Management Plan with an eye towards the adverse as well as beneficial aspects of vegetation management on wildlife in the area. We appreciate the desire to maintain views of the beautiful environs around Point Edwards, and only ask that your landscape planning take into account and "balance" the value of trees for life history needs of wildlife (as well as human health) with property owner desires for open views. The vegetated strip on the hillside below the condos is part of the Willow Creek wildlife corridor, and the timing, numbers, and species of trees removed and replanted should take this into account. Removing patches of mature trees all at one time is likely to adversely affect the wildlife that utilize those trees and affiliated habitat. Great blue herons used to nest in areas of dense alder trees between the marsh and the Point Edwards property, and herons have been observed in recent years carrying nesting material over the marsh (though no active nests have yet been documented). Bushtits and other birds commonly use alder trees for their nests, Deer fawns and coyote pups have also been observed in the wildlife corridor. As you know, with WSDOT terminating their plan to relocate the ferry terminal below Point Edwards, the Save Our Marsh group has urged the city and State to designate the old Unocal property as a wildlife reserve (or sanctuary) with a tidal channel across it to bring back salmon and restore the estuary. Thus, vegetation management on the hillside above the old Unocal property will be important for and affect wildlife restoration. We ask that the Point Edwards Homeowners Association consider incorporating the "Certified Wildlife Habitat" criteria established by the National Wildlife Federation (see: www.nwf.org/certify (https://www.nwf.org/certify) ) into your Landscape Management Plan, and obtain wildlife habitat certification and post signs of such on your property. We'd also suggest the association consult a wildlife ecologist in making necessary revisions to the Landscape Management Plan. We did note that the SEPA checklist that you sent to the City of Edmonds does not adequately address wildlife in the area, nor the potential adverse effects of tree removal on wildlife. Further, the SEPA checklist does not acknowledge the wildlife value and usage of the stormwater detention pond on your property. Even though it is a manmade pond, it has aevaluable asset to wildlife and any tree removal near the pond can adversely affect that wildlife. Bill Anderson, a local wildlife enthusiast and photographer who recently passed away, documented 28 different bird species from 2013 to 2016 in the 'I Point Edwards Walkway, Condos, Unocal" area. The following bird species that Bill has documented at Point Edwards should be addressed in the SEPA document: Canada goose, Gadwall, Mallard, Northern shoveler, Redhead, Ring-necked duck, California quail, Great blue heron, Green heron, Bald eagle, Cooper's hawk, Sharp -shinned hawk, Rufous hummingbird, Anna's hummingbird, Northern flicker, Steller's -11- Attachment 9 jay, American crow, Violet -green swallow, Barn swallow, Bushtit, Bewick's wren, Ruby -crowned kinglet, American robin, Cedar waxwing, Song Sparrow, Dark -eyed junco, Red -winged blackbird, and American goldfinch. Deer (adults and fawn), coyotes (adults and pups) and racoons have also been observed at Pt Edwards and should be addressed in the SEPA document. Thank you for your consideration of our request to modify your Landscape Management Plan to "balance" wildlife needs and the value of mature trees to human health and well being with your goal to maintain views. Marjorie Fields Edmonds on behalf of Save Our Marsh Letter to the editor: Point Edwards responds to Save Our Marsh concerns Posted: March 5, 2021 903 Editor: We want to thank Save our Marsh for sharing their thoughts with Point Edwards (see the Feb. 24 letter here) and to thank the Edmonds community as well for their questions and comments. Point Edwards Homeowners Association and Landscape Team, in conjunction with Certified Arboricultural and Biological Experts, have submitted an application for a Type III -A Landscape Modification Permit to be able to work on a small portion of the PE complex. The project does not propose any new development, will not change the slope or stormwater movement, and will not create any impervious surfaces. Instead, the entire goal is to positively influence the landscape by responsible tree work, and then careful replanting This project balances current zoning, the City of Edmonds Comprehensive Plan, the COE Urban Forest Management Plan, as well as the wildlife goals of adjoining properties with the goals of the owners making up the HOA. Our application has been uploaded and can be found on the City of Edmonds website. Though the public comment period has closed, comments will still be considered if sent to Landscape Manager Bel Johnson, if received by March 20, 2021. The following statement was already shared with COE City Council and Development Department Staff, with Point Edwards residents, and was sent to Marjorie Fields, as lead contact for Save Our Marsh. Because we cannot be sure if everyone interested has seen our response, and to reach a broader audience, we want to share the following: To: Marjorie Fields on behalf of Save Our Marsh, Point Edwards would like to thank you for your comments during the open comment period regarding Point Edwards Permit application PLN2020-0054. We have submitted -12- Attachment 9 the Permit to modify a small area located on our north slope and also a required Landscape Management Plan for both West and North slopes. We have taken the open public comments received by you as an opportunity to further consult with experts regarding the subjects you have addressed. The experts we are working with have considerable experience in wildlife habitat management and wildlife habitat conservation including endangered avian species. Also, we have worked with a very qualified Arborist throughout the development of this plan. We will incorporate, amend, and supplement our Permit and SEPA Studies with their guidance and attention to the sensitivity regarding slope integrity and wildlife habitat. We have worked diligently to develop a plan that fosters diversity in plant life so that food and forage for the birds and other wildlife will be enhanced. The wildlife inhabiting our slopes is such an important part of living at Point Edwards and we believe a key reason why Edmonds residents visit. There was an established revegetation plan that was put in place in 2004 for the developer to complete. The revegetation plan reintroduced evergreen trees and native northwest plants that now grow healthy and vibrant on the west slope. It was in 2009 that Point Edwards HOA took over the care of the west and north slope. We own these critical slopes and take our responsibility for them very seriously. We are the stewards of our critical slopes and are passionately interested in the best health of the slope and the health of the wildlife. We are so fortunate to share our slopes with the Edmonds community. It is with great care and compassion that we covet our role. PE wants to be able to maintain and improve the landscape on PE property and is doing so in accordance with guidance from the COE and with consideration toward long term slope integrity and wildlife habitat. The City of Edmonds is a very special place and Point Edwards and the Edmonds community enjoy the marsh, ferry views, mountain views, eagles that soar, and the wildlife that enjoy the critical slopes in so many areas throughout Edmonds but uniquely at Point Edwards and the Marsh. It is our belief and our hope that putting forth the most successful landscape plan, with the greatest impactful results, is imperative and will define our slopes into perpetuity. Yours truly, Bel' Johnson Landscape Manager Point Edwards HOA -13- Attachment 9 Point Edwards staff, Edmonds Marsh advocates find common ground during review of vegetation management plan Posted: March 26, 2021 944 MN&TI "in' Joe Scordino with Save Our Marsh, far left, asks a question of Point Edwards Homeowners Association President Mike Mitchell, center. A Thursday morning field trip drew representatives from Save Our Marsh to the Point Edwards condominiums, where they met with staff from the complex and consultants to get a first-hand view of the Point Edwards plan to manage vegetation on the slope above the Edmonds Marsh and the adjoining Unocal site. According to the group's Facebook Page, concerned Edmonds residents formed Save Our Marsh "to prevent continued degradation of the Edmonds Marsh and to restore and enhance its ecological functions." In the making for several years, the Point Edwards plan will affect 175 trees on the north and west slopes above the marsh. Forty-five of those trees would be removed, 28 coppiced (cut down to stumps but expected to resprout), 78 pruned, and 24 left as -14- Attachment 9 snags. The proposal also includes planting 45 new trees, 201 shrubs, 90 ferns, and other groundcover to increase the species diversity on the project site. No action will be taken on 86 trees. See the full application package here. IL •, _ ` •+ • • .a1,w FOR fY. � ��•.� � �0.,. •O111U,IfL,O�Y�A.O`L W1N• -15- L104 L105 Attachment 9 ._• • alip- IL L103 These three maps show details of which trees are proposed for removal, coppicing and retaining as snags. L103 details the north slope above the fish hatchery. Maps L104 and L105 proceed to the west. IL _ • •—M a -- --- — � y� err- • �.,•wl+..w, a aCsrs ---- -. r • wlw. [-j acs —••— •-• ac1^it '� VON • • • • • 4Nrya..w ..wlwlfl• 1�,'• •fi1•. eyl ••. �r11 �'-' •L(igM !•1g4y�t�M AM!■ •M ' -16- Attachment 9 L 104 • •w� .y E =..sz— -- —• C • � azala -- -- '-• i i • 00 S •••• r•_0 •.__• • M • • •. 00"00*0& - .._ -- •� ice.-__,- • � � �1 - - ' - ----- 040 I i.•• �' ---- ap% i - maw.. ..r..'.,. L105 L103 These three maps show details of which trees are proposed for removal, coppicing and retaining as snags. L103 details the north slope above the fish hatchery. Maps L104 and L105 proceed to the west. -17- Attachment 9 p --- - wry,. W •.: - r= - • i'l • • •0 • - - The proposal has caught the attention of many community members who are concerned about potential negative effects on the marsh environment, wildlife, runoff, and more. Among these are what critics see as the plan's cursory mentions of birds, wildlife and the sheer diversity of species that depend on the marsh for shelter, breeding and foraging (see recent letter to the editor detailing these concerns and the species affected here). M Attachment 9 Edmonds Senior Planner Kernen Lien, who has been overseeing the permitting process, explains the priority of slope and wildlife preservation in the plan. Organized by City of Edmonds Senior Planner Kernen Lien, Thursday's tour provided the opportunity for those concerned about the potential effects of the project on the marsh environment to learn about, ask questions and voice concerns about the proposed work, and have these included in the final plan. Point Edwards, a condominium community overlooking the Edmonds waterfront, has been granted an extension until July 27 to respond to the city's request to include a heron study. They will also use this extension to take another look at the SEPA study, add more bird and wildlife names, and include the man-made storm detention pond between the condo building and the westernmost slope. -19- Attachment 9 Point Edwards Landscape Manager Bel' Johnson points out a copse of alder on the west section of the slope that are proposed for removal (red flagging) and coppicing (blue flagging). In this case the alders proposed for removal are encroaching on existing shore pines, and when gone will give these more room to spread and grow. Coppicing removes the trunks but leaves the root system intact to enhance slope stabilization. Coppiced alders will regrow. "Our primary goal with this project is slope preservation and stabilization," said Point Edwards Landscape Manager Bel' Johnson as she welcomed attendees. "We have worked diligently to develop a plan that fosters diversity in plant life so that food and forage for the birds and other wildlife will be enhanced. The wildlife inhabiting our slopes is an important part of living at Point Edwards and to the Edmonds community as a whole, and this plan aims to retain and enhance these benefits as we move into the future." The project includes the natural areas on north and west slopes that fall within the property boundaries of Point Edwards, which extend roughly 50 feet beyond the existing paved public walkway. Areas further downslope are part of the Chevron/Unocal property and outside the Point Edwards boundary; hence they do not fall within the proposed plan. -20- Attachment 9 A situation the plan hopes to avoid by careful management is trees becoming uprooted during windstorms and due to slope destabilization. This tree is just outside the Point Edwards boundary (indicated by the red stake) on the Unocal property. In addition to enhancing runoff control and water quality, the slope forms a continuous wildlife corridor used by deer, coyote and more than 70 species of birds. Among the tour attendees was Scott Markowitz of the Pilchuck Audubon Society, who has been working with the Save Our Marsh group to identify bird species and how they interact with the marsh environment. -21- Attachment 9 "A primary concern is with the timing of the proposed activities," he stressed. "I want to see any activity such as tree removal, pruning, etc. not coincide with times of nesting and other sensitive periods in the life cycles of these inhabitants." Bel' Johnson, left, and consultant Justina Kraus of Champion Tree Care. Kraus has been the primary source of botanical expertise on the project. This concern was echoed by Point Edwards arborist consultant Justina Kraus, who has been working closely with Point Edwards on the plan. "It's much better to do all the work just once rather than spread it out," she explained. "And it's more than just trees — the shrub understory provides critical shelter and food for wildlife and the less we disturb it the better." Another of Markowitz's concerns is the potential of adding view corridors for the benefit of Point Edwards residents that would create breaks in what is now a continuous wildlife corridor along the north and west slopes. -22- Attachment 9 red -winged blackbird visits the cattails in the made -made storm detention pond between the condo building and the west slope area. While not a natural area, the detention pond is being added to the SEPA study. "There is a high density of different species along this corridor, especially the section just above the fish hatchery where we have observed more than 70 distinct bird species," he explained. "Many travel back and forth through this area in `feeding flocks' and creating gaps carries the potential to disrupt this." Responding directly to this concern, Point Edwards Homeowners Association President Mike Mitchell made it clear that while views are important, other factors take precedence. "People talk about residents wanting to cut trees to maintain views, and as part of our commitment to our residents we are under obligation to preserve views," he explained. "However, we are already losing views due to vegetation growth on the Unocal property [over which Point Edwards has no control]. We also need to maintain slope integrity not only to take care of views, but also maintain the wildlife which is a critical part of the ambiance of living at Point Edwards. For us, in the end, protecting slope integrity and wildlife is a higher goal than views." -23- Attachment 9 Point Edwards Homeowners Association President Mike Mitchell points out the Alders growing on the adjacent Unocal property, which have the potential to block views but are not under the purview of Point Edwards. Mitchell added that in several cases residents asked Landscape Manager Johnson to cut trees to enhance their views and she refused, citing wildlife and slope integrity as the reasons. "And what's wrong with a nice green forest view," observed Johnson. "Point Edwards is a special area. We have formal gardens plus all this natural beauty on the slopes. Add to this the chance to observe, photograph, and interact with a wide diversity of wildlife. It's a resource not just for Point Edwards residents, but for the community as a whole." — Story and photos by Larry Vogel -24- Attachment 9