HomeMy WebLinkAbout66E_2024-0521 Scagliotti (JST)
May 21, 2024
Josh Peters
Director, Department of Community Development
Jefferson County
621 Sheridan St.
Port Townsend, WA 98368
Re: Pleasant Harbor Master Planned Resort, Case No. SUB2023-00025
Dear Director Peters,
We extend our appreciation for the opportunity to provide comments on the proposed
development plans for the Pleasant Harbor Master Planned Resort. The Jamestown S’Klallam
Tribe values the engagement efforts made by Jefferson County in this matter. The Tribe has
strong interest in the preservation of tribal treaty rights to fish, hunt and gather in their Usual and
Accustomed areas as well as the preservation of the ecosystems that support these rights. In
addition, due to the likelihood of encountering Tribal cultural resources in this traditional fishing
and trading area of the S’Klallam Peoples, sufficient surveys and protections for these resources
are critical to historic preservation and cultural identity of the Jamestown S’Klallam Tribe.
Due to the complexity and size of this proposed resort, the myriad implications to tribal treaty
rights within the Usual and Accustomed Area of the JST, and the short comment period for this
phase of the development, our staff have not been able to fully review the documents provided
by the County. At this time, the Tribe has not identified support or objections for plan elements
until we learn more details of the proposed options and how they have evolved from past
iterations of the MPR, but we look forward to our continuing involvement in this process.
However, based on past reviews and comments of the JST and its partners, we are submitting
several tribal priorities that should be considered and addressed at this early stage. We will
follow up at a later date with more specific, detailed and solution-oriented comments before the
public hearing that has yet to be scheduled and
Sincerely,
Alex Scagliotti – Environmental Planner – ascagliotti@jamestowntribe.org
Allie Taylor – Tribal Historic Preservation Officer – ataylor@jamestowntribe.org
Jamestown S’Klallam Tribe
1033 Old Blyn Highway
Sequim, WA 98382
Exhibit 66E
1. Stormwater: The stormwater design for the MPR should clearly indicate how it will
prevent pollutants from entering marine and estuarine waters and include regular, long-
term monitoring to ensure that any impacts are identified and remediated early so as not
to impact high-value shellfish beds near the site. Special attention should be paid to
excess nutrient loads and pesticides that are regularly applied to golf courses and how
buffers, bioretention, infiltration and an Integrated Pest Management plan will be used to
prevent these pollutants from entering waterways that the Tribe relies on. A third-party
certification from a well-known organization such as Salmon Safe will help ensure high
standards for the design and maintenance of operations and provide assurance to the JST
that the MPR is protecting treaty resources.
2. Wildlife: A wildlife management plan should include input and contributions from tribal
wildlife biologists in order to prevent, reduce or mitigate human-wildlife conflicts –
especially with regards to a nearby elk herd. Manicured and cultivated landscaping and
golf course act as an attractant to ungulates and other interdependent wildlife of the same
ecological community – i.e. their predators. A robust and adaptive plan should adequately
address the potential impacts such as increased vehicle strikes, property damage or
human habituation.
3. Adjacent shellfish beds: Shellfish populations that are both abundant and safe to
consume are imperative to JST members, its economic interests and cultural practices.
Two very productive shellfish beds utilized by the Tribe are in the immediate vicinity due
in part to the high ecological function of the Dosewallips and Duckabush river deltas and
surrounding tidelands. These resources could be impacted by reduced water quality and
habitat alteration. Concerns such as treated wastewater discharges should be addressed
with documentation, verification and remediation plans to ensure pollutants like fecal
coliform and Harmful Algal Bloom-causing nutrients will not increase due to resort
operations.
4. Cultural resources surveys and discoveries: The proposed project is located in an area
of very high to moderate risk of encountering cultural resources based on the DAHP
predictive model. Previous project consultation letters indicate the cultural significance of
the Black Point and Pleasant Harbor landscape to the S’Klallam and Skokomish people.
While a cultural resource study was conducted in 2006, the study is outdated and does not
adequately review the project area for traditional cultural properties or cultural
landscapes. Without a traditional cultural property and cultural landscape study we cannot
properly review the project impacts to the landscape and our resources.
Exhibit 66E