Expert Dr. Sarah Cook says peer reviewers sampled the wrong spots in Silverview wetland remand

At a June 3, 2025 hearing before the Kitsap County Hearing Examiner, wetland scientist Dr. Sarah Cook told the panel she had documented a larger wetland on the Silverview property than found by the developer's consultants and that reviewers' attempts to re-sample "adjacent" plots did not visit the same locations she recorded.

Cook testified that she visited the property in September 2020 when vegetation was identifiable and soils were hydrated, recorded 23 field data plots with a submeter GPS, and used standard hydric-soil guidance when she filled data forms. "I have 39 years of experience in wetlands and ecological research," Cook said during direct examination. She added that she recorded GPS points with submeter accuracy and that she would have provided those coordinates to other parties on request: "I would have shared that data. No one called me to ask for it."

Why it matters

The remand ordered by the hearing examiner required party reviewers to re-check locations Cook listed in earlier testimony and to confirm whether hydric-soil indicator A11 (a depleted matrix within the top 12 inches in certain soils) was present at those spots. Cook told the examiner that focusing narrowly on A11 during a remand is not best-available practice in meadow wetlands, where vegetation and seasonal groundwater are critical context and where hydrology may be present only part of the growing season. That dispute matters because the county's designation of wetland area affects mitigation requirements, allowed site layout and building footprints.

What witnesses said

- Dr. Sarah Cook (appellant witness) said she documented 23 data plots and that her field notes and GPS points place the wetland boundary substantially larger than the developer's consultants reported. She used the Munsell color chart and the U.S. Army Corps/Field Indicators guidance to interpret hydric soils and said the A11 indicator she identified fell slightly deeper than the strict A11 depth in two places, which she attributed to historical plowing and profile disturbance. She told the panel that under standard practice investigators compare vegetation at the precise plot location (stakes or GPS) rather than sampling only a nearby, visually similar spot.

- Soundview consultants' representative Phil Scholes and county peer-review consultant Radke (Radike/Radiceke in the record) told the panel they excavated additional test pits in May and October 2024 and in some cases concluded A11 was not present at the spots they sampled. Cook countered the party reviewers' findings, saying their data sheets showed vegetation and redox features consistent with hydric soil at several locations the reviewers labeled "not hydric." She pointed to specific Soundview data plots (for example DP 25—28 in the October sampling) where the reviewers noted redox concentrations within the top 10—12 inches and vegetation/hydrology present.

- Several parties and the examiner discussed the absence of piezometer monitoring on the site. Cook said earlier agency correspondence (Department of Ecology staff) had asked for shallow groundwater monitoring during the growing season and that piezometers would give windows into seasonal groundwater that single short visits can miss.

Key technical points recorded in testimony

- GPS and provenance: Cook said she used submeter GPS for her data plots and that her mapping placed five of her plots clearly within what she calls the central wetland; she said sample plotting by the developer and reviewer teams did not match her vegetation or soil descriptions at the same mapped points. She testified she would share her GPS shapefiles on request.

- A11 and disturbance: Cook showed the hearing copies of the Field Indicators of Hydric Soils and Army Corps guidance; she explained that A11 (a depleted matrix within the top 12 inches in many soils) may appear deeper in profiles disturbed by historic plowing or fill, and that guidance allows judgment in disturbed profiles.

- Seasonality and piezometers: Cook emphasized meadow wetlands can be groundwater fed and hydrology can be demonstrably present only part of the growing season; she said earlier agency staff had recommended short-term piezometer installations in late winter/early spring to capture rising groundwater and remove ambiguity about hydrology during dry months.

- Southwest corner (blackberry/rose area): Cook and the reviewers debated the southwestern corner of the parcel. Cook said her observations and some reviewer data (DP 14 in the record) show hydric soils and wetland vegetation along the southern property edge; Cook testified that the species mix had shifted from Himalayan blackberry to wild rose in places but that both are facultative wetland species and still indicate wet conditions.

What the hearing record shows (process and open issues)

- Parties repeatedly raised that reviewer teams sometimes sampled near rather than at Cook's plotted points; Cook argued the remand required re-sampling at or immediately adjacent to her precise plot locations and that reviewer samples farther upslope or downslope cannot validly supplant her plot data.

- The hearing record contains multiple data forms by Soundview Consultants and Radke that the parties used to argue about vegetation lists, soil colors (Munsell codes), and whether redox concentrations were visible within the top 10—12 inches.

- The examiner admitted earlier documents into the record (Cook's prior report and the field indicators manual) for reference during the remand testimony.

Next steps noted at the hearing

The hearing continues. Participants and the examiner discussed scheduling additional testimony (peer reviewers and county witnesses were expected at subsequent sessions). Cook said she still had her GPS files and would provide them on request; parties were directed to confer about scheduling and whether additional monitoring (piezometers) or narrowly scoped site re-sampling could resolve the contested locations.

Ending

The record shows an explicit technical disagreement: Cook contends reviewers did not sample the same plots she recorded and that seasonal groundwater and vegetation indicators support a larger wetland footprint than the developer has used in site design. Peer reviewers countered that their plots did not meet the A11 criteria at the locations they sampled. The examiner and parties discussed additional monitoring (piezometers) and exchange of precise GPS locations as practical next steps to narrow the factual dispute.