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HomeMy WebLinkAbout66G_Scagliotti (JST)_2025-09031 Cristina Haworth From:Alex Scagliotti <ascagliotti@jamestowntribe.org> Sent:Wednesday, September 3, 2025 12:17 PM To:George Terry; Cristina Haworth Cc:Allie Taylor; Cynthia Rossi Subject:PHMPR issue-solution matrix Attachments:PHMPR notes for Jeff.Co .docx Hello George and Cristina, While I know you're well-acquainted with our overall concerns, I wanted to provide a simple matrix that summarizes the issues as well as what I feel are relatively straight-forward solutions. I don't think that these solutions are particularly heavy lifts or controversial but let me know what you think. I wanted to provide input before you release your staff report so that you can assess internally and adopt or adapt as County conditions if they are consistent with your authority and role. Note that the solution for including a water quality action trigger point is an example of a condition that we would like to see but the values I included are not fully backed up by relevant data - the County's water quality division would need to weigh in on specific values or percentages. Regardless, I think it's prudent and reasonable to include a condition that requires some corrective action by the applicant and/or County if there is a clear trend toward degradation but before state water quality criteria are surpassed, considering the highly valuable shellfish beds immediately to the north and south of the project area. Also note that these suggestions are exclusively from our environmental staff and separate from our cultural resource staff who have a very different set of concerns as you know. Of course, all of the Tribe's priorities (cultural and environmental) should be considered equally but I thought it might be easiest if we separated out the themes for you all to consider while you're working internally on your staff report. Hope this helps and feel free to give me call with any questions or clarifications. Cheers, Alex Scagliotti Environmental Planner Jamestown S’Klallam Tribe 360-477-9712 ascagliotti@jamestowntribe.org Exhibit 66G Topic Issue Solution WQ Water quality plans, monitoring and controls are inconsistent between documents with no indication as to which standard will be followed The County can amend the WQ plan to indicate that it supersedes or takes precedent over other plans in relation to water quality monitoring, controls and reporting. Depending on the plan, the most prominent language around water quality standards seems to be that the resort will not violate WQ criteria and will take corrective action if violated. This "emergency room" response only requires action if water quality is degraded beyond State standards. There should be a trigger point that requires assessment, identification and control as a preventative measure, rather than an reactionary measure once criteria are violated and the harm has been done. Including a condition such as "a trigger point of three consecutive readings above 10% of seasonal baseline levels, one reading at or above 20% of seasonal baseline levels, or state criteria is surpassed - whichever comes first" is an example of early detection and correction condition that will help address issues before early. The WWTP and water re-use is generally a positive attribution of this project but they can fail or malfunction and potentially cause major impacts to nearby shellfish beds (i.e. bacteria contamination). We request that tribes with U&A in Hood Canal be notified within 48 hours if there is any unintended, unplanned or emergency discharge of untreated or partially treated water from the plant to the marine environment. Wildlife Development will act as attractant to nearby elk herds that are a treaty resource - Dosewallips SP is an example of this. Vehicle collisions from increased traffic and lack of exclusions unnecessarily imperils this resource and people's safety. Add exclusionary, elk-proof fencing around the resort to prevent habituation and road crossings will prevent the vast majority of collisions. Tribes will work with Jefferson County to frame out a condition within the Prelim Plat Application to add a layer of specificity of fence requirements (i.e. min 8 ft, etc) as discussed in the technical meeting on 3/14/25. The wildlife plan has contradictions, irregularities and dubious action points that make it difficult for us, and eventually the applicant from interpreting its standards. Amend the plan to add clarification with clear action points. We can provide some examples of needed clarifications. Shellfish Increased visitation will increase recreational traffic and harvest on and near productive shellfish beds - impacting their productivity and availability to the tribes. Restrict access to tidelands via trail system and provide signage or public education on importance of protecting nearby shellfish beds. Exhibit 66G