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Home My WebLink About01_Staff ReportSTAFF REPORT Jefferson County Preliminary Plat Application Case No. SUB2023-00025 Issue Date: September 15, 2025 Pleasant Harbor Master Planned Resort Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 2 of 117 Contents Contents .................................................................................................................................... 2 Figures ....................................................................................................................................... 3 Tables ........................................................................................................................................ 3 Exhibits ...................................................................................................................................... 4 SECTION 1. Application Information .......................................................................................... 8 SECTION 2. Recommendation (Summary) ................................................................................ 9 SECTION 3. Definitions and Table of Acronyms ........................................................................10 A. Definitions .....................................................................................................................10 B. Table of Acronyms .........................................................................................................10 SECTION 4. Project Background .............................................................................................. 11 SECTION 5. Property, Vicinity, and Project Description .............................................................13 A. Property Description .....................................................................................................13 B. Project Vicinity ..............................................................................................................14 C. Project Description .......................................................................................................14 SECTION 6. Review Process ....................................................................................................16 A. Regulatory Framework .................................................................................................16 B. Appropriate Filing of Application ....................................................................................16 C. Procedure Type ............................................................................................................17 D. Public Notices ...............................................................................................................18 E. SEPA (Environmental) Review ......................................................................................18 F. Departmental and Affected Agency Review ...................................................................19 SECTION 7. Staff Analysis ........................................................................................................19 A. Comprehensive Plan Compliance ..............................................................................20 B. Development Standards and Regulations ..................................................................22 C. Critical Areas Standards and Shoreline Management Program .................................34 D. Infrastructure and Utilities ..........................................................................................57 E. Public Services ..........................................................................................................84 F. Archaeological, Cultural, and Historic Resources ......................................................86 G. Phasing .....................................................................................................................89 SECTION 8. Approval Criteria—Proposed Findings and Conclusions .......................................92 SECTION 9. Public Comments, Intergovernmental (Tribal) Consultation, Interjurisdictional and Interagency Coordination, and Responses ................................................................................99 Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 3 of 117 SECTION 10. Staff Recommendation ..................................................................................... 107 Figures Figure 1: Excerpt of Jefferson County Zoning Map..................................................................... 9 Figure 2: 2023 Aerial Image ......................................................................................................14 Figure 3: Jefferson County 20-Year Population Projection and Distribution ...............................22 Figure 4: Site-specific zoning map ............................................................................................27 Figure 5: Project site plan .........................................................................................................29 Figure 6: Critical Aquifer Recharge Areas on the property and in the vicinity .............................36 Figure 7: Erosion hazard areas overlaid on the preliminary civil engineering site plan ..............41 Figure 8: Landslide hazard areas on the property and in the vicinity .........................................42 Figure 9: Shoreline slope stability on the property and in the vicinity .........................................43 Figure 10: Seismic Hazard Areas on the property and in the vicinity .........................................46 Figure 11: Wetlands identified by GeoEngineers .......................................................................49 Figure 12: Wetland C Preliminary Impact and Mitigation Figure compared to Golf Course Wetland C Buffer Planting Plan .................................................................................................54 Figure 13: Approximate location of shoreline jurisdiction along south property line ...................56 Figure 14: Stormwater basin map. ............................................................................................58 Figure 15: Proposed stormwater site plan .................................................................................60 Figure 16: Proposed US Highway 101/Black Point Road intersection and site access improvements ...........................................................................................................................63 Figure 17: Proposed secondary access improvements .............................................................63 Figure 18: Proposed right-of-way dedication .............................................................................67 Figure 19: Black Point forestry impact classification map. .........................................................78 Figure 20: Black Point forestry impact classification map with proposed site plan overlaid ........80 Figure 21: Wildlife corridor plan updated June 18, 2025 ............................................................81 Figure 22: Road frontages ........................................................................................................83 Tables Table 1: Adjacent Property Zoning and Land Use Information. ................................................... 9 Table 2: Summary of Proposed Residential Uses ......................................................................15 Table 3: Excerpt of Table 8-2, JCC 18.40.040 ...........................................................................17 Table 4: Summary of proposed land uses .................................................................................28 Table 5: Setbacks required by JCC 17.65.040 on its face. ........................................................31 Table 6: Summary of propose tract purpose/use .......................................................................34 Table 7: Wetland categorization and buffer summary ................................................................50 Table 8: Application of buffer requirements by adjacent land use and probable impact .............51 Table 9: Summary of proposed stormwater treatment methods by basin...................................59 Table 10: Parking requirements by land use ..............................................................................71 Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 4 of 117 Exhibits Pursuant to Rule 4 of the Hearing Examiner’s Rules of Procedure, the following exhibits are entered into the project record: Departmental Report and Analysis Documents 1. Staff Report, issued September 15, 2025 (this document) 2. Summary of Compliance Status for Prior Conditions (EIS, SEIS, Ord. No. 01-0128-08), issued September 15, 2025 3. List of Referenced Documents, issued September 15, 2025 4. Interpretation of Setback Requirements (JCC 17.65.040), issued August 26, 2025 5. Jefferson County Road Standards a. Standards adopted between 1995 and 2011 b. Standards adopted November 21, 2022 (Resolution No. 60-22) Application Forms 6. Preliminary Plat Application, submitted November 20, 2023 7. Supplemental Application – Land Division, submitted November 20, 2023 8. Supplemental Application – Certificate of Water Supply Utility Service for Jefferson County, dated March 19, 2024 9. Stormwater Management Application and Supplemental Application – Stormwater Management Permit, Submitted November 20, 20231 10. Stormwater Calculation Worksheets a. Worksheet for the Hamlet at Pleasant Harbor, dated October 30, 2023 b. Worksheet for the Hamlet at Pleasant Harbor, undated 11. Cover Letter “Pleasant Harbor Master Planned Resort Application for Preliminary Plan of Long Subdivision,” prepared by Houlihan Law, dated November 20, 2023 12. Environmental Review a. SEPA Checklist, revised March 20, 2024 b. Modular Construction Impact on EIS Letter, dated March 13, 2024 13. List of Other Permits Required, submitted March 25, 2024 Water and Sewer Availability and System Planning 14. Certificate of Water Right (Certificate No. G2-20465C), dated May 9, 1975 15. Voluntary Partial Relinquishment of Water Right No. G2-20456C and Correspondence, dated May 1, 2025 and June 25, 2025 16. Certificate of Water Right (Certificate No. G2-21134C), issued April 8, 1977 17. Certificate of Water Right (Certificate No. G2-23623C), issued June 20, 1977 18. Permit to Appropriate Public Waters of the State of Washington (Permit No. G2-27964P), issued July 17, 1992 19. Amended Permit to Appropriate Public Waters of the State of Washington (Permit No. G2- 27964), issued August 14, 2008 20. Superseding Water Right Permit (Water Right No. G2-30436), dated October 11, 2007 21. Superseding Water Right Permit (Water Right No. S2-30437), dated October 11, 2007 1 Under the terms of the Development Agreement, PHMPR was prohibited from submitting development applications at the time the preliminary plat was submitted. The Stormwater Management Application and Supplemental Application – Stormwater Management Permit were submitted as supplemental information to support review of the preliminary plat application. They were not accepted for processing as development permits. A subsequent Stormwater Management Application was submitted for review (case no. ZONS2024-00008). Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 5 of 117 22. Pleasant Harbor Sewer System General Sewer Plan (Draft), prepared by Hatton Godat Pantier, dated June 17, 2022 23. Department of Ecology Approval Letter for the Pleasant Harbor Sewer System General Sewer Plan, dated October 6, 2022 24. Pleasant Harbor Water System Water System Plan (Draft), prepared by Hatton Godat Pantier, dated June 27, 2025 25. Technical Memorandum: Jefferson County Preliminary Plat Comments, prepared by Hatton Godat Pantier, dated August 27, 2025 Technical Studies 26. Pleasant Harbor Preliminary Drainage Report, prepared by Hatton Godat Pantier, dated June 20, 20252 27. Stormwater Pollution Prevention Plan for Pleasant Harbor, prepared by Hatton Godat Pantier, dated June 30, 2023 28. Revised Wildlife Management Plan, prepared by GeoEngineers, dated June 18, 2025 29. Wetland Verification Report, prepared by GeoEngineers, dated October 18, 2024 30. Response Memorandum to Jefferson County Comments Regarding Wetland C Buffer Averaging Plan, prepared by GeoEngineers, dated August 29, 2025 31. Geotechnical Documents: a. Geotechnical Response Letter, prepared by Krazan & Associates, Inc., dated October 15, 2024 b. Geotechnical Engineer of Record Letter, prepared by Krazan & Associates, Inc., dated April 7, 2023 c. Geotechnical Investigation, prepared by Subsurface Group, LLC, dated December 17, 2008, reviewed by Perrone Consulting, Inc. P.S., dated January 23, 2013 d. Draft Infiltration Feasibility Evaluation Letter, prepared by Krazan & Associates, Inc. dated June 10, 2024 e. Limited Geotechnical Engineering Letter: Agra Center / Staff Housing Retaining Wall, prepared by Krazan & Associates, Inc., dated August 21, 2024 f. Limited Geotechnical Engineering Letter – Top of Coastal Bluff/Shoreline Slope Setback and Buffer Clarification, prepared by Krazan & Associates, Inc., dated September 10, 2025 32. Roadway Width Documents: a. Minimum Roadway Width Memorandum, prepared by TENW, dated October 2, 2024 b. Minimum Roadway Width – Response to SUB2025-00025 Technical Review Comments Memorandum, prepared by TENW, dated August 29, 2025 Project Plans and Drawings 33. Preliminary Plat of the Hamlet of Pleasant Harbor, prepared by Hatton Godat Pantier, dated August 28, 2025 34. Preliminary Civil Plans, prepared by Hatton Godat Pantier, dated June 2025 35. Preliminary Site Lighting Plan, prepared by MPE, dated March 14, 2024 36. Landscape Plan, submitted March 25, 2024 2 The report cover is dated June 20, 2024, but the date of signature is June 20, 2025. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 6 of 117 Other Project Documents 37. Project Narrative, submitted March 25, 2024 38. Declaration of Covenants, Conditions, and Restrictions for the Hamlet of Pleasant Harbor (Draft), submitted March 25, 2024 39. The Hamlet of Pleasant Harbor Design Review Guidelines (Draft), submitted March 25, 2024 40. Phasing Response, submitted March 25, 2024 41. Vegetation Management Plan Response, submitted March 25, 2024 42. Cultural Resources Management Plan Response, submitted March 25, 2024 43. Fire Flow Response, submitted March 25, 2024 44. Pleasant Harbor MPR Conservation Easement, dated February 29, 2024 45. Revised Tunicate Monitoring Schedule, submitted March 25, 2024 46. Construction Order Narrative, dated November 17, 2023 47. Draft Grant of Conservation Covenant for Wetlands and Wetland Buffers Located within the Pleasant Harbor Master Planned Resort, submitted August 29, 2025 Legal Notices 48. Request and Approval for Extension of Completeness Review Deadline Email String with John Holbert, dated December 8, 2023 49. Determination of Incomplete Application, dated December 21, 2023 50. Request and Approval for Extension to Resubmittal Deadline Email String with John Holbert, dated March 15, 2024 (latest) 51. Determination of Complete Application, dated April 16, 2024 52. Notice of Application, dated May 1, 2024 53. Notice of Revised Application, issued August 27, 2025 54. Notice of Public Hearing, dated September 24, 2025 Project Correspondence 55. PHMPR Phase 1 Pre-Submittal Comments dated September 29, 2023 56. Comment Response Letter prepared by Statesman, submitted March 25, 2024 57. Technical Review Comments – Planning Discipline with Attachment, dated July 3, 2024 58. Technical Review Comments – Civil Engineering Discipline, dated July 3, 2024 59. Revised Technical Review Comments – Planning and Civil Engineering Disciplines with Attachment, dated August 16, 2024 60. Response to Revised Technical Review Comments prepared by Statesman, dated January 31, 2025 61. Review on Hold for Scope and Fee Negotiation, dated February 4, 2025 62. PHMPR Review Clock Toll Email String with JT Cooke, dated February 5, 2025 63. Resubmittal Cover Letter prepared by Statesman, dated June 23, 2025 64. Summary of Changes Made to Pleasant Harbor Master Planned Resort (“MPR”), Preiminary Plat Drawings, prepared by Statesman, dated September 1, 2025 Public, Agency, and Tribal Comments 65. Public Comments: a. Richard Aramburu on behalf of The Brinnon Group, dated September 6, 2023 b. Richard Aramburu on behalf of The Brinnon Group, dated February 2, 2024 c. Phil Best, Hood Canal Environmental Council, dated February 7, 2024 Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 7 of 117 d. Theresa Crowell, dated May 15, 2024 e. Matthew Iles-Shih, dated May 18, 2024 f. Joan Hendricks, dated May 18, 2024 g. Richard Aramburu on behalf of The Brinnon Group, dated May 21, 2024 h. Richard Aramburu on behalf of The Brinnon Group, dated August 22, 2024 i. Richard Aramburu on behalf of The Brinnon Group, dated January 22, 2025 j. Terence Germaine, dated September 6, 2025 66. Tribal Comments a. Alex Scagliotti, Jamestown S’Klallam Tribe, dated May 8, 2024 b. Cynthia Rossi, Point No Point Treaty Council, dated May 10, 2024 c. Cynthia Rossi, Point No Point Treaty Council, dated May 20, 2024 d. Marla Powers, Port Gamble S’Klallam Tribe, dated May 21, 2024 e. Alex Scagliotti, Jamestown S’Klallam Tribe, dated May 21, 2024 f. Point No Point Treaty Council Letter to Jefferson County Board of Commissioners, dated August 15, 2024 g. Alex Scagliotti, Jamestown S’Klallam Tribe, dated September 3, 2025 67. Agency Comments: a. Andrew Larson, PE ,WSDOT, dated May 15, 2024 b. Mason County Public Utility District No. 1, prepared by Kristin Masteller, dated January 3, 2025 c. Department of Ecology – Wastewater Treatment Email String with David Dougherty, PE, dated January 21, 2025 (latest) d. Department of Ecology – Water Rights Email String with Jeff Marti, dated January 8, 2025 (latest) e. Washington State Department of Transportation Email String with Andrew Larson, PE, and Attachments, dated January 10, 2025 (latest) f. Jefferson County Sheriff’s Office Email String with Acting Sheriff Andy Pernsteiner, dated January 17, 2025 (latest) g. Brinnon Fire Department Email String with Chief Tim Manly, dated February 7, 2025 (latest) h. Brinnon School District Email String with Superintendent Patricia Beathard, dated January 14, 2025 (latest) i. Washington Department of Fish and Wildlife Email String with Brian Calkins, dated August 13, 2024 j. Mason County Public Utility District No. 1 Letter “Power Supply for Pleasant Harbor,” dated August 26, 2025 68. Jefferson County Response to the Brinnon Group and Hood Canal Environmental Council (Revised), dated April 16, 2024 69. Jefferson County Response to Point No Point Treaty Council Letter, dated November 13, 2024 Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 8 of 117 SECTION 1. Application Information Case No.: SUB2023-00025 Project Name: Pleasant Harbor Master Planned Resort Staff Contact: Mandi Roberts, AICP, PLA, Contract Planner Otak, Inc. mandi.roberts@otak.com George Terry, Associate Planner Jefferson County Department of Community Development gterry@co.jefferson.wa.us Touta Phengsavath, PE, Consultant Civil Engineer Otak, Inc. touta.phengsavath@otak.com Applicant: Ryan Hodges Pleasant Harbor Marina and Golf Resort LLP ryanh@statesmangroup.com Owner: Garth Mann Pleasant Harbor Marina and Golf Resort LLP garth.mann@statesmangroup.com Project Description: Preliminary plat application to develop the Pleasant Harbor Master Planned Resort (PHMPR). PHMPR master planned resort zoning was approved by Ordinance No. 01-0128-08 on January 28, 2008. PHMPR is regulated under a Development Agreement (executed on June 6, 2018) with amendments (dated June 4, 2018, and July 22, 2019). The Development Agreement contains a Master Plan in Section 3.2, which controls all development. The project includes the construction of up to 890 residential units; up to 56,608 square feet of commercial space; a recreation/community center with indoor swimming pools, hockey rink, soccer field, go-cart track, racket sports, health spa, restaurants, and pub; a farmer’s market; a conference center; a nine-hole golf course; and other amenities. Facilities to serve the development will be provided, including a wastewater treatment system, a community water system, stormwater management, and internal roads and pedestrian pathways. The preliminary plat will create 150 residential lots for various detached dwelling units for both temporary and permanent occupancy and 29 tracts for residential and commercial buildings, golf course fairways, private roads and utilities, open space, storm drainage, and park-and-ride. No construction is authorized as part of the preliminary plat application. Location: Black Point, south of the unincorporated Brinnon community Existing Land Use: Vacant; the property formerly was used as the American Campground facility. Campground structures have been demolished pursuant to Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 9 of 117 demolition permits issued by DCD. Infrastructure, including roads and septic systems, from the campground remains. Adjacent Properties: See Figure 1, Vicinity Map with Zoning Designations Table 1: Adjacent Property Zoning and Land Use Information. Direction Zone Current Use North RR-5 Single family residential South N/A Hood Canal East RR-20 Single family residential West RR-5 Single family residential Comprehensive Plan: Land Use: MPR-PH; Subarea: Brinnon Figure 1: Excerpt of Jefferson County Zoning Map. Source: Jefferson County Public Land Records GIS Portal. Annotations provided by project review staff. SECTION 2. Recommendation (Summary) Based upon the application, plans, drawings, technical studies, and related materials and the analysis presented in this Staff Report, Staff recommends APPROVAL SUBJECT TO CONDITIONS for on this application for the Pleasant Harbor Master Planned Resort (PHMPR) Preliminary Plat Application, case no. SUB2023-00025. Recommended CONDITIONS OF APPROVAL are listed in Section 10 of this Staff Report. Project Location Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 10 of 117 SECTION 3. Definitions and Table of Acronyms A. Definitions Abbreviated definitions for select technical terms used in this Staff Report are included in footnotes throughout this Staff Report. Terms are defined in Chapter 18.10 of the Jefferson County Code (JCC) and elsewhere in the governing documents for this project. Refer to the applicable code section or document for the complete definition, or for the definition of other terms not defined in this Staff Report.3 B. Table of Acronyms Acronym Meaning ADA Americans with Disabilities Act of 1990 (42 USC 12101 et seq.) ADT Average Daily Traffic BAS Best Available Science BFD Brinnon Fire Department BMPs Best Management Practices BOCC Jefferson County Board of Commissioners BSD Brinnon School District CARA Critical Aquifer Recharge Area DAHP Department of Archaeology and Historic Preservation DCD Department of Community Development, Jefferson County DEIS Draft Environmental Impact Statement DHV Design Hourly Volume DOE Department of Ecology, Washington DOH Department of Health, Washington DS Determination of Significance DSEIS Draft Supplemental Environmental Impact Statement DLS Distribution System Leakage EMS Emergency Management Systems EPH Environmental Public Health, Jefferson County Department of ERU Equivalent Residential Unit FEIS Final Environmental Impact Statement FS&CA Future Staffing & Consultant Agreement FSEIS Final Supplemental Environmental Impact Statement FWHCA Fish and Wildlife Habitat Conservation Area GMHB Western Washington Growth Management Hearings Board gpd Gallons per day IBC International Building Code, as adopted by Chapter 51-50 WAC as modified in JCC 15.05.030(1). Per WAC 51-50-003, the 2021 edition of the IBC has been adopted. IFC International Fire Code, as adopted by Chapter 51-54A WAC as modified in JCC 15.05.030(6). Per WAC 51-54A-003, the 2021 edition of the IFC has been adopted. JCC Jefferson County Code JCSO Jefferson County Sheriff’s Office LUPA Land Use Petition Act (Chapter 36.70C RCW) LOSS Large Onsite Septic System 3 Pursuant to JCC 18.10.005(1), all words shall have their normal and customary meanings, unless specifically defined otherwise in JCC 18.10. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 11 of 117 Master Plan The master plan defined in Development Agreement Section 3.2 and JCC 17.60.040 MOA Memorandum of Agreement MOU Memorandum of Understanding MR Minimum Requirement, in the 2024 Stormwater Management Manual for Western Washington MW Megawatts NPDES National Pollution Discharge Elimination System ODW Office of Drinking Water, Washington Department of Health PHMPR Pleasant Harbor Master Planned Resort PNPTC Point No Point Treaty Council Property The property described in Section 5 of this Staff Report PUD Public Utility District SEPA State Environmental Policy Act (Chapter 43.21C RCW) SIPZ Seawater Intrusion Protection Zone SWMMPSB Stormwater Management Manual for the Puget Sound Basin SWMMWW Stormwater Management Manual for Western Washington THPO Tribal Historic Preservation Officer USACE United States Army Corps of Engineers USDA United States Department of Agriculture WDFW Washington Department of Fish and Wildlife WRS Wetland Rating System WSDOT Washington State Department of Transportation WSP Water System Plan WWSP Wastewater System Plan WWTP Wastewater Treatment Plant SECTION 4. Project Background The PHMPR project has been planned, discussed, and authorized at various planning levels for over 20 years, beginning with the Brinnon Subarea Plan adopted in 2002 and amended in 2004. A programmatic EIS for a master plan on the Black Point peninsula was completed in 2007. A Comprehensive Plan amendment was included in Jefferson County’s 2007 annual amendment docket and was subsequently approved in 2008. A project-level EIS for PHMPR was completed in 2015. Development regulations and a Development Agreement were approved by separate ordinances in 2018. Development must proceed in accordance with the Master Plan, as defined in the development regulations and the Development Agreement. On January 28, 2008, Jefferson County’s Board of County Commissioners (BOCC) approved and adopted a site-specific Comprehensive Plan amendment via Ordinance No. 01-028-08, establishing a Master Planned Resort4 on approximately 237.88 acres of property on the Black Point peninsula in the unincorporated Brinnon community. This approval came after the issuance of a programmatic Final Environmental Impact Statement (FEIS) on November 27, 2007. The Ordinance enumerated 30 conditions of approval, including a requirement to negotiate and execute a Development Agreement. The Ordinance was appealed to the Western Washington Growth Management Hearings Board (GMHB). The GMHB concluded that 4 Master Planned Resorts are regulated under RCW 36.70A.360. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 12 of 117 the ordinance complied with the Growth Management Act, Chapter 36.70A RCW; the Planning Enabling Act, Chapter 36.70 RCW; and SEPA (Chapter 43.21C RCW). The GMHB decision was appealed to the Thurston County Superior Court and then to the Court of Appeals. In 2011, Division 2 of the Court of Appeals upheld the GHMB’s decision.5 In the intervening years, project design advanced and a project-level Final Supplemental Environmental Impact Statement (FSEIS) was issued on December 9, 2015. Development regulations, proposed as amendments to Titles 17 and 18 of the Jefferson County Code (JCC), to implement the PHMPR project were prepared and adopted on June 4, 2018, via Ordinance No. 03-0604-18. This ordinance was appealed to the GMHB and was upheld.6 The required development agreement was negotiated and approved for execution and recording on the same date as the ordinance approving the development regulations, via Ordinance No. 04-0604-18. As adopted on June 4, 2018, the Development Agreement included Amendment 1, which amended the Wildlife Management Plan attached in Appendix P and the Water Quality Monitoring Plan attached in Appendix N. This ordinance adopting the Development Agreement was separately appealed to the Kitsap County Superior Court under the Land Use Petition Act (LUPA)7 and the ordinance was reversed for failing to include a community center and because the adopted phasing of the development contained within the Development Agreement violated JCC 18.15.135. Amendment 2 to the Development Agreement addressed these issues and was approved for execution on July 22, 2019, via Ordinance No. 08-0722-19. After Ordinance No 08-0722-19 was passed in 2019, the developer focused on State permits for the required wastewater treatment system and Group A water system, required by the Development Agreement. The county is not aware of the details of the interaction between State agencies and the developer during this period. On June 5, 2023, PHMPR and Jefferson County entered into a Future Staffing and Consultant Agreement (FS&CA). The FS&CA sets a 60-day review timeline for the surface water quality baseline and report of Best Management Practices (BMPs) to be applied to the project to avoid a violation of water quality criteria. A June 28, 2024, letter from the County’s environmental consultant, Thomas Mergy, LHG determined that these requirements had been or would be satisfied upon agreement to Amendment 1 to the FS&CA. On July 1, 2024, the BOCC executed Amendment 1 to the FS&CA, which concurs that the surface water baseline has been established and adopts the BMPs in Appendix 1 to Amendment 1 to the FS&CA, determining that these requirements have been satisfied and allowing for the submittal of applications for development. PHMPR notified Jefferson County on March 12, 2025 that they intended to make revisions to the preliminary plat. This was confirmed in writing on March 28, 2025. A revised preliminary plat, preliminary civil plan set, and related materials were submitted on June 23, 2025. A revised water system plan was submitted on August 12, 2025. Additional materials related to wetlands, water availability/water system planning, status of electricity availability, and property boundaries were submitted on August 29 and September 1, 2025, along with a revised 5 Brinnon Grp. v. Jefferson Cty., 159 Wn. App. 446, 245 P.3d 789 (2011) 6 Brinnon Group and Brinnon MPR Opposition v. Jefferson County and Pleasant Harbor, Western Washington Growth Management Hearings Board, Case No. 08-2-0014 (Decision on Reconsideration October 14, 2008). 7 Brinnon Group v. Jefferson County and Pleasant Harbor Marina and Golf Resort, LLP, No. 18-2-01758-18. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 13 of 117 preliminary plat drawing set. Additional geotechnical materials were submitted on September 10, 2025. SECTION 5. Property, Vicinity, and Project Description A. Property Description The property consists of approximately 237.88 acres (approximately 10,362,052.8 square feet) on Black Point near the unincorporated community of Brinnon, Washington, on the west side of Hood Canal (Figure 2).8 The project is in all four quarters of Section and in the NW1/4 and NE1/4 of Section 22, Township 25 North, Range 2 West. The property consists of variable topography ranging from flat to an extreme vertical slope. The property is bounded to the north and east by single-family residential development, to the west by single-family residential development and by US Highway 101, and to the south by a 60 to 80 foot high bluff that drops to a beach along Hood Canal. The property was originally homesteaded (in part) and eventually developed and used as the American Campground, including RV campsites, internal access roadways, a lodge, and various outbuildings and accessory structures (see FEIS Appendix 1). Buildings from the campground have been demolished recently in accordance with permits for demolition issued by DCD; infrastructure such as roads and septic systems remain in place. Aside from areas developed for campground facilities, the property is largely forested with existing, mature vegetation. There are steep slopes, erosive soils, landslide hazard areas, and wetlands present on the property. The Brinnon area was historically used by Native American tribes. The blend of forest, rivers and shoreline produced ample salmon and other fish, shellfish, berries, roots, whales, seals, birds, and game sufficient to support numerous thriving communities. Winter village communities are documented along Hood Canal and in particular at the mouth of the Dosewallips and Duckabush Rivers. The Skokomish Tribe, the S’Klallam Tribe,9 the Suquamish Tribe, and the Squaxin Island Tribe have been documented to have used this area for fishing, gathering, and hunting. Culturally significant places are recorded in the project vicinity, and comments submitted by the Point No Point Treaty Council, the Port Gamble S’Klallam Tribe, and the Jamestown S’Klallam Tribe indicate the geologic kettles on the property are culturally significant features. 8 A boundary line modification is currently being negotiated between PHMPR and the adjacent property owner, E Lucille Marley, due to an encroachment. The boundary line modification is the subject of ongoing litigation (Marley v. Pleasant Harbor Marina and Golf Resort, LP, Jefferson County Cause No. 24-4-00214-16). Resolution of this case and modification of the boundary line will not impact the preliminary subdivision in this application. For reference only, the proposed boundary line modification is shown in the preliminary plat drawings (Exhibit 33). 9 The Jamestown S’Klallam Tribe, the Port Gamble S’Klallam Tribe, the Lower Elwha Klallam Tribe are all federally recognized tribes who are successors to the treaty rights of the S’Klallam Tribe. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 14 of 117 Figure 2: 2023 Aerial Image. Source: Jefferson County Public Land Records GIS Portal. Annotations provided by project review staff. B. Project Vicinity The Black Point peninsula contains other development, including low-density single-family residential. Approximately two miles to the north is the unincorporated community of Brinnon and the mouth of the Dosewallips River. To the south is the mouth of the Duckabush River. Both river mouths support shellfish harvesting beds that are widely considered among the healthiest and most productive in the Puget Sound. Farther west are commercially productive timber harvesting lands. C. Project Description Per Ordinance No. 01-0128-08, Division II of Chapter 17 JCC, the Development Agreement, and the FEIS and FSEIS, the project is allowed up to 890 residential units and up to 56,608 square feet of commercial space and must provide related amenities and facilities. The Project Location Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 15 of 117 current application materials identify 822 residential units within the boundaries of the preliminary plat10 in a mix of types for short-term and long-term stay: Table 2: Summary of Proposed Residential Uses. Source: Preliminary Plat Drawings (Exhibit 33) and Preliminary Civil Drawings (Exhibit 34). Project Component Type Units Inn by the Sea Hotel 225 Staff Housing Multifamily Residential (Staff) 52 Cascadia House Condominiums 126 Olympia House Condominiums 126 Eagles Nest Condominiums 56 Sea View Villa Detached Residential 107 Golf Vista Detached Residential 43 Manor Village Multifamily Residential (Senior Living) 14 The Views Condominiums 18 Hawks Landing Condominiums 55 Total Units: 822 Hotel Units 225 Condo Units 381 Multifamily Units 66 Detached Residential 150 The following commercial uses are also identified within the boundaries of the preliminary plat (Sheet 1, Exhibit 34): • Inn by the Sea & Recreation Center, described as hotel and sports arena11 • Event Center described as parking garage and conference center • Golf course, with nine holes shown on the plans The project also includes supporting infrastructure, facilities, and amenities, including: • Highway 101/Black Point Road intersection improvements • Park and ride • Wastewater treatment plant and sewer system and related infrastructure, to be owned by the Pleasant Harbor water and sewer district • Water wells and water system and related infrastructure, to be owned by the Pleasant Harbor water and sewer district • Internal private roadways • Internal pedestrian pathways and golf cart trails • Stormwater management and related infrastructure • Open space, including the 200-foot shoreline buffer preserved in an easement recorded on February 29, 2024 10 According to PHMPR, 66 units will be in the Maritime Village building north of the intersection of US Highway 101 and Black Point Road (Exhibit 34). The remaining two units are existing rental units associated with the Pleasant Harbor Marina (Exhibit 63). 11 Hotel units accounted for in residential unit count. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 16 of 117 The preliminary plat application will create 150 residential lots for the detached dwelling units and 29 tracts for the condominium/multifamily residential, hotel, commercial, recreational, open space, and infrastructure uses described above. SECTION 6. Review Process A. Regulatory Framework The Master Plan governs the development of the PHMPR. All land division and development permits, are governed by the following documents and regulations pursuant to JCC 17.60.060 and Section 6.3 of the Development Agreement: • Development Agreement, including Appendices A-T and including Appendix sub- parts and attachments, executed June 4, 2018 • Amendment 1 to the Development Agreement, executed June 4, 2018 • Amendment 2 to the Development Agreement, executed July 22, 2019 • JCC Title 17, Division II • JCC Title 18 • FS&CA, executed June 5, 2023 • Amendment 1 to the FS&CA, including Appendix 1, executed July 1, 2024 • Mitigation conditions set forth in the FEIS, issued November 27, 2007 • Mitigation conditions set forth in the FSEIS, issued December 9, 2015 With the exception of the FS&CA and its Amendment 1, compliance with these requirements is enforceable through Title 19 JCC pursuant to JCC 17.60.110. The FS&CA was entered into after the adoption of Title 17 JCC Division II, and is therefore not a matter of code enforcement but of contract law. Regulatory documents are available on the County’s website. B. Appropriate Filing of Application Development Agreement Terms The Development Agreement establishes a term and buildout period for the project. The effective term of the agreement in section 2.2 of the Development Agreement is 45 years after the effective date of the Development Agreement or five years after the end of the build-out period described in section 2.3, whichever is sooner. The build-out period described in section 2.3 of the Development Agreement is 25 years from the effective date of the Development Agreement or five years after completion of all the phases described in section 10 of the Development Agreement. The effective date of the Development Agreement is June 4, 2018. The preliminary plat application has been filed timely with respect to the effective term and build-out period. Future Staffing and Consultant Agreement/Water Quality Monitoring Plan Terms Section 2.10 of the FS&CA specifies that PHMPR must “establish [surface water quality] baseline conditions at least 60 days prior to submitting the first development application,” (emphasis added). This provision applies in addition to the performance standard set forth in Sec. VI(2) of the Water Quality Monitoring Plan (Appendix N to the Development Agreement), which states “Prior to the date of application of the application for the first development permit, the Resort must provide a report to the Jefferson County Public Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 17 of 117 Health’s Water Quality Division (JCWQ) of the best management practices to be applied so that when all appropriate combinations of individual best management practices are utilized, the Resort will not cause a violation of water quality criteria,” (emphasis added). Under JCC 18.10.040, a “development application” is “an application for a development permit,” and a “development permit” is “any permit issued by Jefferson County allowing development.” “Development” means “the construction, reconstruction, conversion, structural alteration, relocation, or enlargement of any structure; any grading, excavation, mining, landfill; or any extension of the use of land; dredging, drilling, dumping, filling, earth movement, clearing or removal of vegetation, forest practice activities that are being conducted as a part of a conversion from forestry to non-forestry use, storage of materials or equipment in a designated floodway, or other site disturbance, which either requires a permit, approval, review, or authorization from the county or is proposed by a public agency.” A preliminary plat does not authorize any development as defined in JCC 18.10.040 and is therefore not a development permit or development application. The preliminary plat application was appropriately filed by PHMPR and was properly accepted for review by Jefferson County staff. C. Procedure Type The procedures in Chapter 18.40 JCC apply to this project.12 Table 8-1 in JCC 18.40.040 identifies preliminary long subdivisions (preliminary plats) as Type III decisions.13 Type III decisions are described as “Notice and open record public hearing before the hearing examiner. Final decision by hearing examiner. Appeal to superior court.” Type III decisions follow the process summarized in Table 8-2 in JCC 18.40.040, excerpted below: Table 3: Excerpt of Table 8-2, JCC 18.40.040. Source: Appendix E to the Development Agreement. Action Step Type III Process Recommendation made by: Project Planner14 Final decision made by: Hearing Examiner Notice of Application: Yes Open record public hearing: Yes, before Hearing Examiner, prior to permit decision by the Hearing Examiner Closed record appeal/final decision: No Judicial appeal: Yes Under JCC 18.40.090(2), preapplication conferences are required for Type III decisions. The preapplication conference was held on September 29, 2023 (Exhibit 55). Following the preapplication conference, the Applicant submitted materials for review on November 20, 12 Section 9.1 of the Development Agreement specifies that the “review and approval of proposed development applications proposed by the Developer for the Property shall be pursuant to the Pleasant Harbor MPR Zoning Code (Appendix A) and the County’s Permit Application and Review Procedures/SEPA Implementation, Chapter 18.40 JCC, which is attached in Appendix E. A preliminary plat is not a development application according to the definitions in JCC 18.10 because it does not authorize development. 13 Final long subdivisions (final plats) are Type IV decisions, a different review process that follows preliminary plat and construction of certain infrastructure and improvements. 14 The FS&CA assigns a Contract Planner as the project planner responsible for reviewing and processing applications related to PHPMR. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 18 of 117 2023. The application materials were determined incomplete on December 21, 2023 (Exhibit 49). The Applicant submitted materials in response to the County’s Notice of Incomplete Application on March 25, 2024, and the application was determined complete on April 16, 2024 (Exhibit 51). Following the determination of complete application, Jefferson County issued the Notice of Application (Exhibit 52) in accordance with Article III of Chapter 18.40 JCC, including the requirements in JCC 18.40.240 specific to preliminary plat actions. Department of Community Development (DCD) staff also routed the application materials for interdepartmental and interagency review consistent with JCC 18.40.120 (see Section 6.F of this Staff Report). After the submission of a revised plat and supporting documents by the Applicant, Jefferson County issued a Notice of Revised Application on August 27, 2025 (Exhibit 53). Public comments on the project have continuously been received through the date of this Staff Report and will continue to be accepted until the Hearing Examiner formally closes the project record. Following technical review and the submittal of revised or supplemental application information, a Notice of Public Hearing was issued on September 24, 2025 (Exhibit 54) pursuant to JCC 18.40.230. D. Public Notices The project provided public notice consistent with JCC 18.40. Application Received: November 20, 2023 Determination of Completeness: April 16, 2024 Notice of Application: May 1, 2024 Notice of Revised Application:15 August 27, 2025 Notice of Public Hearing: September 24, 2025 Public Hearing: October 15, 2025 E. SEPA (Environmental) Review Potential environmental impacts from the proposed development have been reviewed in prior environmental documents. A Draft Environmental Impact Statement (DEIS) was issued on September 5, 2007. Comments were addressed and a FEIS was issued on November 27, 2007. Condition 63(b) in Ord. No. 01-0128-08 required a supplemental environmental impact statement to analyze the final configuration of the PHMPR project. A Draft Supplemental Environmental Impact Statement (DSEIS) was issued on November 18, 2014 and a FSEIS was issued on December 9, 2015. The FEIS and FSEIS are available on the County’s website. The Development Agreement provides, in section 9.2.4, that the FEIS and FSEIS “shall constitute compliance to the fullest extent possible under SEPA, as well as Condition 63(b) of Ordinance 01-0128-08, for all subsequent approvals or permits” for the PHMPR project. This section further specifies that Jefferson County “may require additional environmental 15 A Notice of Revised Application is not a mandatory legal notice. It was provided for transparency to alert potential interested parties of Applicant-initiated revisions. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 19 of 117 analysis for a new or modified proposal that materially exceeds the level and range of development reviewed in the Prior EISs.”16 The Applicant provided a SEPA Checklist (Exhibit 12A) dated March 20, 2024, to document the project’s consistency with the FEIS and FSEIS. At the time the SEPA checklist was prepared, the current project proposal included the following departures from the FEIS and FSEIS: • Elimination of the proposed Large Onsite Septic System (LOSS) and drainfield; and • Substitution of Kettle C as the location of the stormwater retention pond in place of Kettle B; and • Use of modular construction techniques instead of conventional construction techniques for some structures, including housing and short-term lodging. These departures remain in the current version of the application materials. The current application includes adjustments to the plat and project design, but do not alter the amount of housing units or nonresidential square footage proposed and revisions to the SEPA Checklist were not required. These project changes do not materially exceed the level and range of development reviewed under the FEIS and FSEIS. The proposed preliminary plat is consistent with the FEIS and FSEIS and further environmental review is not required. F. Departmental and Affected Agency Review Application materials have been reviewed by Jefferson County staff and departments, including Community Development, Building Official/Fire Marshal, Public Works (via consultant), Environmental Public Health (via consultant), and Sheriff’s Office. The project has also been reviewed by potentially affected State and other agencies, including the Brinnon Fire Department, the Brinnon School District, Mason County Public Utility District (PUD) No. 1, the Washington State Department of Transportation (WSDOT), the Department of Ecology (DOE), and the Department of Health’s (DOH) Office of Drinking Water (ODW) consistent with JCC 18.35.320(2).17 Comments received from reviewing departments and agencies have been incorporated into this staff report, and additional review is required for various project-related permits, approvals, and authorizations. SECTION 7. Staff Analysis Rule 4 of the Hearing Examiner Rules of Procedure and JCC 18.40.280(2) require the preparation of a staff report on the proposal that summarizes the comments and recommendations of County departments and affected agencies and special districts, and evaluating the proposal’s consistency with applicable review standards. This Section 7 of the Staff Report provides the analysis of the proposed preliminary subdivision’s consistency with applicable review standards. 16 The Development Agreement refers to the FEIS and FSEIS collectively as the “Prior EISs.” 17 Pursuant to the Development Agreement, the project is vested to the Land Division standards in Chapter 18.35 JCC in effect when the Development Agreement was executed. These standards are set forth in Appendix D to the Development Agreement. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 20 of 117 To provide context for the following analysis, project review criteria are summarized here: • Consistency with Title 18 JCC (the Unified Development Code) or other development regulations adopted under Chapter 36.70A RCW. This includes, through JCC 17.60.060 as described below, the Development Agreement, conditions and requirements of Ord. No. 01-0128-08, and the mitigation measures required in the FEIS and FSEIS. (Source: Chapter 18.40 JCC) • Conformance to all applicable County, State, and Federal zoning, land use, environmental, and health regulations and plans, including, but not limited to, the Jefferson County Comprehensive Plan and the provisions of the Jefferson County Code. (Source: Chapter 18.35 JCC, Chapter 18.40 JCC) • Availability of utilities and other public services necessary to serve the needs of the proposed subdivision. (Source: Chapter 18.35 JCC, Chapter 58.17 RCW) • The proposed subdivision, together with mitigation measures, will have not have an unacceptable adverse effect on the environment under SEPA and under the critical areas ordinance. (Source: Chapter 18.35 JCC, Chapter 18.40 JCC) • Approving the proposed subdivision will serve the public use and interest and adequate provision has been made for the public health, safety, and general welfare. (Source: Chapter 18.35 JCC, Chapter 18.40 JCC, Chapter 58.17 RCW) The complete set of review criteria, together with staff-proposed findings and conclusions, is presented in Section 8 of this Staff Report. A. Comprehensive Plan Compliance 1. Compliance with the Comprehensive Plan is required pursuant to JCC 18.35.310 and JCC 18.40.280(5). 2. Section 8.2 of the Development Agreement requires that the planning goals in Jefferson County’s Comprehensive Plan in effect on the date the Development Agreement was executed serve as the policy guidance and foundation for all future development of PHMPR. This document is hereafter referred to as “the Comprehensive Plan.” 3. The Comprehensive Plan includes relevant policies that inform decision-making related to this project. These include land use policies focused on expanding urban-level development and infrastructure in Urban Growth Areas and Master Planned Resorts; fostering economic development with “small-scale recreational or tourist-related” uses that rely on a rural location and setting; and establishing policy guidance for the development of master planned resorts. 4. Additionally, the Brinnon Subarea Plan, a chapter of the Comprehensive Plan effective when the Development Agreement was executed, identifies the Black Point area as an appropriate location for a possible future Master Planned Resort. 5. The Brinnon Subarea Plan includes relevant policies that inform decision-making related to this project, such as promoting recreational and tourist development consistent with the character of Brinnon; fostering economic development; protecting the natural Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 21 of 117 environment and rural character of the area; and considering the diverse interests of such a project. 6. The required Comprehensive Plan Amendment to establish a master planned resort designation on the subject property was approved on January 28, 2008 (Ord. No. 01- 0128-08). The Amendment includes the following findings relevant to this analysis: (34) Step 5: the Board entered an affirmative statement that consistency with the Jefferson County Comprehensive Plan, specifically Land Use Policies 24.1-24.13, has been achieved by the applicant, as each of the pertinent criteria are met by this proposal. By way of example only, the Board’s affirmative finding that the site of the proposed MPR is better suited to become an MPR than it is to be the site of a commercial timber harvest serves to satisfy the condition laid out in the [Comprehensive Plan] at LNP 24.4, found at p. 3-65 of the [Comprehensive Plan]. The area is zoned Rural Residential and not Commercial Forest under the Growth Management Act, and therefore this finding is not required within the proposal. (35) Step 6: The Board entered an affirmative statement that consistency with the Brinnon Sub-Area Plan, adopted on May 1, 2002, specifically Goals 1.0 and Policies 1.1-1.3, is achieved, as each of the pertinent criteria are met by this proposal. 7. The Comprehensive Plan and Brinnon Subarea Plan goals and policies were used in preparing the Development Agreement and code amendments that apply to this project. The proposal is broadly consistent with applicable goals and policies to establish a master planned resort on Black Point, and this is the first implementing application for the project. When developed consistent with the Development Agreement and applicable codes, standards, and criteria, the project will be consistent with all applicable Comprehensive Plan and Brinnon Subarea Plan goals and policies. 8. Growth expectations for Jefferson County are based on the plans approved in the Development Agreement in the Comprehensive Plan are in Exhibit 1-2 of the Comprehensive Plan (see Figure 3). 9. The current Jefferson County Comprehensive Plan adopted in 2018 specifically mentions Ordinance No. 03-0604-18 (PHMPR development regulations) and Ordinance No. 03-0604-18 (Development Agreement) at page 1-6, where it says: Pleasant Harbor Master Planned Resort: The land use designation was established in 2008, and a final Supplemental Environmental Impact Statement capped the maximum number of development units at 890 with 52 units designated for staff housing and no more than 65% dedicated to time-share and short-term rental units, leaving approximately 293 units for permanent housing. Approval of the Pleasant Harbor Master Planned Resort development regulations was made by the Board of County Commissioners in Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 22 of 117 2018 through Ordinance No. 03-0604-18, and a development agreement approved through Ordinance No. 04-0604-18. This proposal is consistent with the 2018 Jefferson County Comprehensive Plan. Figure 3: Jefferson County 20-Year Population Projection and Distribution. Source: Jefferson County Comprehensive Plan, Exhibit 1-2. B. Development Standards and Regulations Vested Standards 10. RCW 36.70.B.180 states “Unless amended or terminated, a development agreement is enforceable during its term by a party to the agreement. A development agreement and the development standards in the agreement govern during the term of the agreement, or for all or that part of the build-out period specified in the agreement, and may not be subject to an amendment to a zoning ordinance or development standard or regulation or a new zoning ordinance or development standard or regulation adopted after the effective date of the agreement. A permit or approval issued by the county or city after the execution of the development agreement must be consistent with the development agreement. 11. Section 9.3 of the Development Agreement states “To the fullest extent allowed by RCW 36.70B.180, all development proposed on the Property shall be vested to and governed by the terms of this Development Agreement, the Pleasant Harbor MPR chapter of the Jefferson County Zoning Code, and the Unified Development Code, now codified at Title 18 of the Jefferson County Code including, but not limited to, those code standards attached to this Agreement effective on the date of this Agreement and attached as Appendices A-I).” Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 23 of 117 12. Pursuant to section 8 of the Development Agreement and RCW 36.70B.180, the project is vested to the following code provisions which are copied into the appendices listed below: • Development Regulations. “The Master Plan, permitted land uses, and development regulations for development within the Property are set forth in chapter 17.60 of the Jefferson County Code, attached as Appendix A.” Development Agreement, section 8.1. • Development Cap. “Development of the Property shall not exceed 890 residential units, 56,608 square feet of commercial space and indoor and outdoor recreational spaces when completed at full build out.” Development Agreement, section 8.1. • Comprehensive Plan Planning Goals. “The planning goals adopted by the County in the Comprehensive Plan as of the date of recording this Agreement shall be the policy guidance and the foundation for all future development of the Pleasant Harbor MPR.” Development Agreement, section 8.2. • Best Management Practices. “In all future development within the Pleasant Harbor MPR the Developer shall utilize best management practices (“BMP”) and be subject to the County Stormwater Management requirements, JCC 18.30.070(1). A copy of JCC 18.30.070(1) is included in Appendix B to the Development Agreement. JCC 18.30.070(1) is the same now as it was at the time the Development Agreement was executed.18 The County and PHMPR have agreed to a list of BMPs, which is attached to Appendix 1 to Amendment 1 to the FC&SA. • Stormwater in Public Areas. “The Developer shall be responsible for the management of stormwater runoff in all other public areas within the Pleasant Harbor MPR as may be necessary to control stormwater runoff as required by Ordinance 01-0128-08, Condition 63(q).” Development Agreement, section 8.3.2. • Stormwater in Non-Public Areas. “The Developer shall be responsible for the management of stormwater runoff in all private rights-of-ways and other non- public areas such as parking lots or drainage easements, as may be necessary to control stormwater runoff as required by Ordinance 01-0128-08, Condition 63(q).” Development Agreement, section 8.3.3. • Critical Areas. “Critical areas and their associated buffers, as well as allowed uses within the critical areas of the Pleasant Harbor MPR shall be determined based upon the Jefferson the County Critical Area requirements, Chapter 18.22 JCC. A copy of Chapter 18.22 JCC is attached in Appendix C.” Development Agreement, section 8.4.19 18 See Ordinance No. 08-0710-06 and Ordinance No. 14-1210-18. 19 All. Inv. Grp. of Ellensburg, LLC v. City of Ellensburg, 189 Wn. App. 763, 358 P.3d 1227 (2015) held that Alliance Investment Group was not vested to the critical areas ordinance in effect when the application for the short subdivision was complete. All. Inv. Grp. of Ellensburg, LLC is distinguishable because the vesting rules for a short subdivision are in RCW 58.17.033(1) quoted above are different than the vesting rules for development agreements. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 24 of 117 • County Land Division Requirements. “Platting within the Pleasant Harbor MPR shall be pursuant to RCW 58.17 and the County Land Division requirements, Chapter 18.35 JCC, and within the time frames adopted by the County pursuant to the 1995 Regulatory Reform Legislation, ESHB 1724 (ch. 347, Laws of 1995), as codified in Permit Application and Review Procedures/SEPA Implementation, Chapter 18.40 JCC, and vested in accordance with RCW 36.70B.180. A copy of Chapter 18.35 JCC and is attached in Appendix D and a copy of Chapter 18.40 JCC is attached in Appendix E.” Development Agreement, section 8.5. • Shoreline Master Program. “All future development within the Pleasant Harbor MPR shall be subject to the County Shoreline Master Program, Chapter 18.25 JCC. A copy of the applicable Shoreline Master Program requirements are attached as Appendix F.” Development Agreement, section 8.6. • Additional Development Standards. “Additional Development Standards as identified in Chapters 12.05, 12.10, and 18.30 JCC shall also apply to the extent they do not conflict with the terms of this Agreement. A copy of Chapters 12.05, 12.10, and 18.30 JCC are attached in Appendix G.” Development Agreement, section 8.7. • Cultural Resources Management Plan. “The Developer prepared a Cultural Resources Management Plan to assure archaeological investigations and systematic monitoring of the subject property prior to issuing permits; and during construction to maintain site integrity, provide procedures regarding future ground disturbing activity, assure traditional tribal access to cultural properties and activities, and to provide for community education opportunities. Developer shall implement the Cultural Resources Management Plan attached in Appendix Q.” Development Agreement, section 8.8.3. • Wildlife Management Plan. “Developer prepared a Wildlife Management Plan focused on non-lethal strategies developed in the public interest and in consultation with the State of Washington Department of Fish and Wildlife (“WDFW”) and local tribes, to prevent diminishment of tribal wildlife resources cited in the Brinnon Sub-Area Plan (e.g., deer, elk, cougar, waterfowl, osprey, eagles, and bear), to reduce the potential for vehicle collisions on U.S. Hwy 101, to reduce the conflicts resulting from wildlife foraging on high-value landscaping and attraction to fresh water sources, to reduce the dangers to predators attracted to the area by prey or habitat, and to reduce any danger to humans. Developer shall implement the Wildlife Management Plan attached in Appendix P, modified by Amendment 1 attached thereto.” Development Agreement, section 8.8.4. • Neighborhood Water Policy Plan. “The Developer shall provide access to the water system by any neighboring parcels if salt water intrusion becomes an issue for neighboring wells on Black Point where it is proven that the Developer draw Unlike, RCW 58.17.033(1), which contains the vesting rules for a proposed division of land, RCW 36.70B.180 is applicable to development agreements and ties vesting to “development standards in the agreement.” Accordingly, the ruling in All. Inv. Grp. of Ellensburg, LLC does not apply. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 25 of 117 down of potable water has caused the salt water intrusion, and reserve areas for additional recharge wells will be included in case wells fail, are periodically inoperable, or cause mounding. A Neighborhood Water Policy Plan is attached in Appendix O. The Developer will implement the Neighborhood Water Policy Plan.” Development Agreement, section 8.8.5. • Water Quality Monitoring Plan. “The Developer prepared a comprehensive Water Quality Monitoring Plan specific to Pleasant Harbor requiring water collection, testing and an adaptive management program. The monitoring plan shall be funded by a yearly reserve, paid for by the Developer and will include regular offsite sampling of pollution, discharge, and/or contaminant loading, in addition to any onsite monitoring regime. The Developer will implement the Water Quality Monitoring Plan attached in Appendix N, modified by Amendment 1 attached thereto.” Development Agreement, section 8.8.6. • Conservation Easement. “To ensure that natural greenbelts and buffers are maintained and protected, a conservation easement attached in Appendix M will be recorded within 15 days of the effective date of this Agreement. The Developer will implement the Vegetation Management Plan attached in Appendix L. The Developer shall, prior to site disturbance, record a conservation easement protecting any wetlands and their respective buffers identified or created on the Property.” Development Agreement, Section 8.8.7. The applicant has partially satisfied this requirement by recording a conservation easement (record no. 664860) on February 29, 2024 (Exhibit 44). Wetlands and their respective buffers will be placed into a conservation easement as a condition of this preliminary plat. [CONDITION 66] • LEED Shadowing. “The Developer shall use the LEED Shadowing (Leadership in Energy and Environmental Design) and “Green Built” green building rating system standards. These standards, applicable to commercial and residential dwellings respectively, “promote design and construction practices that increase profitability while reducing the negative environmental impacts of buildings and improving occupant health and well-being.” A Narrative Demonstrating Compliance with the Intent of LEED Standards is attached in Appendix T. The Developer will implement LEED Shadowing Standards, but is not required to register with LEED or obtain LEED certificates or approvals.” Development Agreement, section 8.8.9. • International Dark Sky Association Standards. “The Developer shall use the International Dark Sky Association (“IDA”) Zone E-standards for the MPR. These standards are recommended for “areas with intrinsically dark landscapes” such as national parks, areas of outstanding natural beauty, or residential areas where inhabitants have expressed a desire that all light trespass be limited. Dark Sky and Energy Star Approved High Efficiency Lighting Standards is attached in Appendix S. The Developer will implement the Dark Sky and Energy Star Approved High Efficiency Lighting Standards.” Development Agreement, section 8.8.10. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 26 of 117 • Water System. “Water main extensions and potable water system improvements for potable water service that may be required to serve the Pleasant Harbor MPR shall be installed in conformance with the most current approved specifications and requirements as determined by the Washington State Department of Health and shall comply with the Coordinated Water System Plan (“CWSP”) and all other applicable laws, ordinances, rules and regulations. A copy of the applicable CWSP is attached in Appendix H.” Development Agreement, section 8.9. • Sewer. “Sanitary and on-site sewer and future sewer system improvements as required to serve the Developers Property shall be installed in conformance with the most current approved specifications and requirements of the Washington State Department of Health, Washington State Department of Ecology and the County Department of Public Health and all other applicable laws, ordinances, rules and regulations.” Development Agreement, section 8.10. Project Consistency Review 13. A preliminary plat should demonstrate either general conformance to applicable standards or the ability to conform to applicable standards with conditions. In determining project consistency, this Staff Report considers demonstrated conformance to the applicable codes and standards (as vested in the Development Agreement or, if not vested, current development codes and standards) and appropriate conditions that may be necessary to ensure conformance and consistency. This is consistent with the project consistency requirements set forth in JCC 18.40.140 and the allowance in JCC 18.35.310(1) to issue a preliminary approval subject to conditions. Use, Density, and Development Standards 14. Section 8.1 of the Development Agreement, JCC 17.60.070, and the FEIS specify that development shall not exceed 890 residential units, 56,608 square feet of commercial space and indoor and outdoor recreational spaces when completed at full build out. The face of the preliminary plat identifies a total of 822 residential units and an unspecified amount of nonresidential space (Sheet 1, Exhibit 33). The preliminary civil plans (Exhibit 34) identify an additional 66 units in the Maritime Village building, north of Black Point Road and outside the boundaries of the proposed preliminary plat. There are two existing rental units associated with the Pleasant Harbor Marina that will remain and that count toward the total residential cap for the project. The proposed residential units comply with the Development Agreement’s limitations on total development capacity. As noted above, nonresidential square footage is capped and will be calculated and monitored with each construction permit; the total amount of nonresidential space will not exceed the maximum threshold set forth in the Development Agreement and JCC 17.60.070. 15. Development Agreement Sec. 8.1 further specifies that development regulations applicable to the project are set forth in Chapter 17.60 of the Jefferson County Code (Appendix A to the Development Agreement).20 Appendix A to the Development Agreement includes the entirety of Division II of Title 17, Chapters 17.60 through 17.85 20 Appendix A was originally a placeholder and was replaced with the full code amendments in Amendment 1 to the Development Agreement. Amendment 1 to the Development Agreement was approved and adopted on June 4, 2018, the same date the original Development Agreement was approved. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 27 of 117 JCC. The project is vested to all of Division II.21 Division II is codified in Jefferson County’s online County Code and is unchanged from Appendix A as of the date of issuance of this Staff Report. 16. Title 17, Division II, of the Jefferson County Code sets forth various development standards and regulations for PHMPR. The zoning map for the entire master planned resort project is established in Exhibit 3 of the Development Agreement (see Figure 4). The portion of the property from the ordinary high water mark of Hood Canal measured horizontally 200 feet landward is zoned Open Space Reserve (MPR-OSR). This portion of the property has been placed in a conservation easement recorded on February 29, 2024 (record no. 664860) (Exhibit 44) and will not be developed. The portion of the property associated with the Marina at Pleasant Harbor is zoned Marina-Maritime Village (MPR-MV).22 These two portions of the PHMPR addressed in the development regulations and the development agreement are not further analyzed in this staff report, as they are not within the boundaries of the proposed preliminary plat. The remaining portion of the project area is zoned Golf Resort (MPR-GR). Pursuant to JCC 17.65.010, the MPR-GR zone “allows residential and recreational facilities, as well as commercial amenities and services associated with the resort and surrounding community.” Figure 4: Site-specific zoning map. Source: Development Agreement Exhibit 3 (FSEIS Figure 3.18-1). 21 No amendments have been made to Division II of Title 17 JCC since the Development Agreement was executed. 22 The Pleasant Harbor Marina was separately developed. But the parcel number for the marina (APN 502152013) is included in Exhibit 1 to the Development Agreement, the legal description, as “Parcel I.” The future Maritime Village project will be located in this zoning district and will be reviewed at the time a development application is submitted. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 28 of 117 17. Permitted uses are set forth in JCC 17.65.020. The preliminary plat proposes land divisions to create parcels and tracts serving a variety of residential, commercial, recreational, open space, and supportive uses (see Figure 5). As described on the preliminary civil drawings, the area of the proposed preliminary plat will include the primary uses listed in Table 4. Table 4: Summary of proposed land uses. Source: Preliminary Civil Drawing Set (Sheet 1, Exhibit 34). Proposed Use Use Type per 17.65.020 Allowed By Residential units – detached residential lots (Sea View Villas, Golf Vistas) Residential uses including single- family and multifamily structures, condominiums, townhouses, apartments, lofts, villas, time-share and other fractionally owned accommodations, short-term visitor accommodation units and short-term rental units with occupancies equal to or less than 30 days 17.65.020(1) Residential units – multi- family (Cascadia House, Olympia House, Eagle’s Nest, The Manor Village, The Views, Hawk’s Landing) Residential uses including single- family and multifamily structures, condominiums, townhouses, apartments, lofts, villas, time-share and other fractionally owned accommodations, short-term visitor accommodation units and short-term rental units with occupancies equal to or less than 30 days 17.65.020(1) Community/Recreation Center Indoor and outdoor resort-related recreational facilities, including but not limited to tennis courts, swimming pools, spa services, hiking trails, bicycle paths, ropes courses, amphitheater, and other recreational uses consistent with the nature of master planned resort 17.65.020(4) Conference Center Visitor oriented amenities 17.65.020(2) Nine-Hole Golf Course Indoor and outdoor resort-related recreational facilities, including but not limited to tennis courts, swimming pools, spa services, hiking trails, bicycle paths, ropes courses, amphitheater, and other recreational uses consistent with the nature of master planned resort 17.65.020(4) 18. As described in Table 4, the proposed primary uses are all allowed under JCC 17.65.020, and the preliminary plat design includes a variety of lots and tracts designed to support the various structures containing these uses. Conceptual building footprints have been provided for the hotel/lodge, other multifamily structures, and nonresidential Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 29 of 117 structures, and the tracts are adequately sized to accommodate these. Conceptual building footprints have not been provided for the 150 residential lots, but the Applicant has indicated that they “are comfortable with the lots and tracts as they have been outlined at this preliminary level,” and that “[t]he building envelope requirement in JCC 18.35.400(4)(g) does not apply” because “[t]he purpose of this requirement is to map code-required setbacks on each lot,” (Exhibit 60). PHMPR added notations to the preliminary plat to address separation between buildings, setback requirements from the top of the steep slope for Lots 108-117, and property line setbacks for Tracts D, F, I, X-7, X-12, and X-14 (Sheet 10 of the Preliminary Plat of the Hamlet of Pleasant Harbor, Exhibit 33). Figure 5: Project site plan. Source: Preliminary Civil Drawings (Sheet 1, Exhibit 34). Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 30 of 117 19. The project must include 52 units of multifamily staff housing on the property, pursuant to the FEIS.23 A housing-related MOU is adopted in Appendix J to the Development Agreement that further specifies the staff housing “will be available at the Resort to accommodate a workforce from 104 to 208 employees (52 Double Occupancy per Bedroom suites),” and that “[t]his affordable staff housing will be located above the Agra- Center/Staff Quarters, a multi-use structure in the golf course/resort area.” The staff housing is proposed in a separate structure adjacent to the AgraCenter; this design change that is acceptable to Jefferson County. The conceptual building footprint and tract are sized appropriately to accommodate the staff housing use. Verification of the location, total number of provided units, and layout of units to accommodate the required occupancy will occur with construction permits. 20. The project also includes accessory uses and infrastructure necessary to serve the primary uses. These accessory uses are allowed as “other similar uses consistent with the purpose of this zone and MPR as determined by the department of community development. These uses include the parking structure, Highway 101/Black Point Road intersection improvements, park-and-ride facility, greenhouse, wastewater treatment plant and sewer system and related infrastructure, water wells and water system and related infrastructure, internal private roadways, internal pedestrian and golf cart paths, stormwater management facilities and related infrastructure, and preserved open space. The proposed preliminary plat layout will support the development of uses allowed on the property as part of the master planned resort. Verification of proposed uses and occupancies will occur with each building permit. 21. Pursuant to JCC 17.60.070, short-term visitor accommodation units and short-term rental units must constitute at least 65 percent of the total units on the property. The proposal includes a mix of hotel, condominium, senior living (in a multifamily building), staff housing (in a multifamily building), and detached housing units. Information on the intended occupancy for each unit or unit type has not been provided and is not required for the division of land. The proposed unit types are appropriate for both short-term and long-term occupancy, and the tracts and lots have been sized appropriately to accommodate the proposed units. The Applicant is required to meet the requirements in JCC 17.60.070 for occupancy, and verification of compliance will occur as plat phases are constructed and then annually [CONDITION 69]. 22. Building height is limited pursuant to JCC 17.65.030. A preliminary plat does not authorize construction of infrastructure or buildings, and height was not reviewed for this application. Building height will be reviewed with building permits for each structure. 23 Public Services: Housing. FEIS Chapter 5, pg. 5-7. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 31 of 117 23. JCC 17.65.040 states: (1) All structures24 shall be set back25 at least 20 feet from the Pleasant Harbor MPR boundary lines and adjacent MPR zones. Minimum building setback from State Route 101 right-of-way is 35 feet. Minimum setback from Black Point Road right-of-way is 20 feet. (2) All buildings not attached or having common walls shall be separated by a minimum distance of 10 feet, as measured from foundation to foundation. (Emphasis added.) Because of the very broad definition of “structure,” on its face, this section appears to require all structures to meet the following requirements: Table 5: Setbacks required by JCC 17.65.040 on its face. Boundary Minimum Setback Distance MPR Boundary 20 feet Adjacent MPR Zones 20 feet State Route 101 Right-of-Way 35 feet Black Point Road Right-of-Way 20 feet But JCC 17.65.040 cannot be read in isolation and must be read in context and consistent with the entire legislative scheme. The purpose of interpreting provisions of a legislative scheme together with related provisions is to achieve a harmonious and unified legislative scheme that maintains the integrity of the respective ordinances. The rule that ordinances should be construed together applies with peculiar force to ordinances passed at the same session of the Legislature. It is to be presumed that such acts are imbued with the same spirit and actuated by the same policy, and they are to be construed together as if parts of the same act. They should be so construed, if possible, as to harmonize, and force and effect should be given to the provisions of each. If, however, they are necessarily inconsistent, an ordinance which deals with the common subject-matter in a minute and particular way will prevail over one of a more general nature; and of two inconsistent ordinances enacted at the same session that will prevail which takes effect at the later date. Along with Ordinance No. 04-0604-18, which adopted development regulations for the PHMPR, Ordinance No. 03-0604-18 and Ordinance No. 08-0722-19, which adopted and amended the Development Agreement, the Jefferson County Code provisions copied into Appendices A through G of the Development Agreement are part of the same legislative scheme. JCC 17.65.040(1) must be read within context of Chapter 17.65 JCC 24 “Structure” is defined in JCC 18.10.190 to mean “a permanent or temporary edifice or building or any piece of work artificially built up or composed of parts joined together in some definite manner, whether installed on, above, or below the surface of the ground or water, except for vessels (WAC 173-27-030).” This definition is the same as it was when the development agreement was adopted by Ordinance No. 04-0604-18. 25 “Setback” is defined in JCC 18.10.190 to mean “the distance a structure is placed behind a specified line or topographic feature.” This definition is the same as it was when the development agreement was adopted by Ordinance No. 04-0604-18. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 32 of 117 as a whole and in harmony with other applicable Jefferson County ordinances within the legislative scheme, whether codified or not. Ordinance No. 03-0604-18 (development regulations) and Ordinance No. 04-0604-18 (Development Agreement) were adopted on the same day, June 4, 2018. JCC 18.25.270(1)(c) states, “The county should recognize and honor buffers and setbacks established by existing plats, preliminary plats, issued permits, binding site plans (BSPs) and site plan approval advance determinations (SPAADs), and by development agreements that are consistent with Chapter 36.70B RCW.”26 (Emphasis added.) Figure 2 in Appendix P to the Development Agreement shows the approximate locations of “structures” and “setbacks” as defined in JCC 18.10.190. Scaling on the site plan shows that some of these “structures” and “setbacks” in the MPR-GR-Zone are less than 20 feet from the Pleasant Harbor MPR boundary lines and adjacent MPR zones. Accordingly, JCC 17.65.040 does not require a 20-foot setback from the Pleasant Harbor MPR boundary lines and adjacent MPR zones for all “structures” in the MPR-GG zone. Except for buildings, discussed below, structures and setbacks shown on Figure 2 in Appendix P to the Development Agreement should be recognize and honored pursuant to JCC 18.25.270(1)(c). Harmonizing the entire legislative scheme, the Unified Development Code Administrator issued a code interpretation on August 26, 2025 (Exhibit 4) that determined: 1. JCC 17.65.040(1) must be harmonized with other code provisions and ordinances within the legislative scheme. JCC 17.65.040(1) does not require a 20-foot setback from the PHMPR boundary lines and adjacent MPR zones for apply to all “structures” in the MPR-GG zone. Structures and setbacks shown on Figure 2 in Appendix P to the Development Agreement should be recognize and honored pursuant to JCC 18.25.270(1)(c), except for buildings and roads, which are discussed below. 2. Buildings. The 20-foot setback requirement in JCC 17.65.040 does apply to all buildings within the MPR-GR zone. From reading together JCC 17.65.040(1), the definition of “structure” in JCC 18.10.190, and the customary meaning of “building” read together, the legislative intent of JCC 17.65.040(1) was to require 20-foot setbacks for buildings within the MPR-GR zone. 3. Roads. Road locations and setbacks are shown on Figure 2 in Appendix P to the Development Agreement and should be recognized and honored pursuant to JCC 18.25.270(1)(c). In addition, the general requirement in JCC 17.65.040(1) cannot prevail over the minute and particular requirements for roads and their setbacks in JCC 18.30.080, JCC 18.30.050(3)(d), and Table 6-1 in JCC 18.30.050. Accordingly, the detailed requirements in JCC 18.30.080 Table 6-1 in JCC 18.30.050 apply within the MPR-GR zone and are not superseded by the 26 Chapter 36.70B RCW is the Local Project Review Act. RCW 36.70B.170 to .210 are the sections that pertain to development agreements. The Development Agreement for PHMPR complies with these sections and, in any event, was never challenged timely as failing to meet the requirements of these sections. As noted above, RCW 36.70B.180 contains the vesting rules for development agreements. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 33 of 117 20-foot setback requirement in JCC 17.65.040(1). The 20-foot setback requirement in JCC 17.65.040(1) does not apply to setbacks for roads. 4. Pathways. The FSEIS requires an internal pathway and circulation system as a mitigation measure. See FSEIS at 1-38. Pathways are “structures” under JCC 17.65.040(1). Pathways are not shown on Figure 2 in Appendix P to the Development Agreement. Accordingly, pathways must satisfy the 20-foot setback requirement in JCC 17.65.040(1). 5. Fences. The setback requirement in JCC 17.65.040 does not apply to fences within the MPR-GR zone per Table 6-1 in JCC 18.30.050, note 5. No 20-foot setback for any fence is required by JCC 17.65.040. 6. Tee Boxes. The setback requirement in JCC 17.65.040 does not apply to “mailboxes; wells; pump houses; bus shelters; septic systems and drainfields (except in the SMP); landscaping (including berms); utility apparatus such as poles, wires, pedestals, manholes, and vaults” within the MPR-GR zone per Table 6-1 in JCC 18.30.050, note 6. (Emphasis added.) For the types of structures listed in Table 6-1 in JCC 18.30.050, note 6, no 20-foot setback within the MPR-GG zone is required by JCC 17.65.040. For example, a tee box on a golf course is a berm and its placement on a golf course is part of the landscaping. 7. Critical Area and Shoreline Master Program Setbacks. Based on JCC 17.60.060, more restrictive setback provisions in Chapter 18.22 JCC and Chapter 18.25 JCC apply, regardless of the language in JCC 17.65.040(1). 8. Wildlife Corridors. Wildlife corridors required by the Development Agreement are not “structures” as used in JCC 17.65.040(1). Wildlife corridors may be used to satisfy any setbacks required by JCC 17.65.040(1). The Unified Development Code Administrator followed the requirements for code interpretations in article IV of Chapter 18.40 JCC, including the analysis outlined in JCC 18.40.360(4). This Staff Report applies the code interpretation to the preliminary plat application. [CONDITION 13] 24. Proposed Plat Notes 25, 26, 27, and 28 address general setback requirements from the boundary of the master planned resort in the absence of the code interpretation (Exhibit 4): 25. Tract I, X-12 & X14, shall have a 20’ from MPR boundary line building restriction, per JCC 17.65.040(2). 26. Tract D, shall have a building setback of 35’ from US Hwy 101 right-of-way, and a 20’ setback from the Black Point Road right-of-way, per JCC 14.65.040(1). 27. Tract X-7 and F, shall have a building setback of 20’ from the Black Point Road right-of-way, per JCC 17.65.040(1). 28. All lots and tracts associated shall be follow JCC 17.65.040(1)(2) setbacks. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 34 of 117 These plat notes are generally acceptable to ensure compliance with JCC 17.65.040 as interpreted by the Development Code Administrator (Exhibit 4), JCC 18.30.080, JCC 18.30.050(3)(d), and Table 6-1 in JCC 18.30.050. Corrections will be required for the final plat as a condition of approval. [CONDITION 5] 25. Buildings not attached or having common walls are also required to be separated by at least 10 feet, as measured from foundation to foundation. Proposed Plat Note 23 (Sheet 10, Exhibit 33) addresses this separation requirement, stating “Lots 1-150, shall have a building envelope setback of 10’ from a neighboring building and shall be restricted from building in any easement within the lot, per JCC 17.65.040(2).” Verification of compliance will occur with construction permits. 26. Footprints have been provided for all buildings except detached residential units to be constructed on Lots 1-150. Buildings are shown on the following tracts: Table 6: Summary of propose tract purpose/use. Source: Sheet 10, Exhibit 33. Tract Proposed Building X-3 Sewer lift station X-5 Olympia House X-6 Cascadia House X-7 Staff housing and AgraCenter X-8 Wastewater treatment plant X-9 The Inn by the Sea and recreation center X-10 Parkade and convention center X-11 The Luxe (also identified as The Views on the preliminary civil plans) X-12 Eagle’s Nest X-13 Hawk Landing (also identified as Hawks Landing on the preliminary civil plans) X-14 The Manor Village These tracts are adequately sized to accommodate their intended uses, including applicable setback requirements. 27. Although conceptual building footprints have not been provided for Lots 1-150, the Applicant has indicated that they “are comfortable with the lots and tracts as they have been outlined at this preliminary level,” and that “[t]he building envelope requirement in JCC 18.35.400(4)(g) does not apply” because “[t]he purpose of this requirement is to map code-required setbacks on each lot,” (Exhibit 60). The residential lots range from approximately 50 feet in width to approximately 80 feet in width, which appears to be adequate to support detached and semi-attached (duplex) style dwelling units with the required building separation. Compliance will be verified with final plat and with construction permits. C. Critical Areas Standards and Shoreline Management Program Critical Areas – General 28. Section 8.4 of the Development Agreement specifies that the project is vested to the critical areas standards in effect when the Development Agreement was executed. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 35 of 117 29. RCW 36.70B.180 states: Unless amended or terminated, a development agreement is enforceable during its term by a party to the agreement. A development agreement and the development standards in the agreement govern during the term of the agreement, or for all or that part of the build-out period specified in the agreement, and may not be subject to an amendment to a zoning ordinance or development standard or regulation or a new zoning ordinance or development standard or regulation adopted after the effective date of the agreement. A permit or approval issued by the county or city after the execution of the development agreement must be consistent with the development agreement. 30. Section 8.4 of the PHMPR Development Agreement identifies the applicable critical areas standards: Critical areas and their associated buffers, as well as allowed uses within the critical areas of the Pleasant Harbor MPR shall be determined based upon the Jefferson the County Critical Area requirements, Chapter 18.22 JCC. A copy of Chapter 18.22 JCC is attached in Appendix C. (Emphasis added.) Accordingly the standards for critical areas (Chapter 18.22 JCC) are included in Appendix C of the Development Agreement. 31. The subject property contains areas mapped by Jefferson County as Critical Aquifer Recharge Areas (CARAs), geologically hazardous areas, and wetlands. Jefferson County maps the approximate location and extent of critical areas in its Public Land Records GIS portal. The maps are not regulatory but provide an indication for additional site investigation (see JCC 18.22.030). Excerpts of the map are included in this report to provide an indication of where critical areas are generally present. Technical studies and reports prepared by qualified professionals have been submitted with the application (Exhibits 26, 27, 29, 30, and 31A-F) and/or are included with the FEIS and FSEIS. These reports include field verification of the location and extent of critical areas and are the basis for determining regulatory compliance in this Staff Report. Critical Aquifer Recharge Areas 32. As shown in Figure 6, the subject property includes CARAs pursuant to JCC 18.22.100(1). Figure 6 also shows wellhead protection zones identified by Jefferson County, a special aquifer recharge protection area identified in JCC 18.22.100(3), and coastal seawater intrusion protection zones (SIPZ)27 identified in JCC 18.22.100(4). 27 Coastal SIPZ are the area defined as 1,320 feet inland from a coastline. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 36 of 117 Figure 6: Critical Aquifer Recharge Areas on the property and in the vicinity. Source: Jefferson County Public Land Records Interactive Map. Annotations provided by project review staff. 33. The additional CARA protection standards in JCC 18.22.130 apply to the commercial and industrial uses proposed on the property pursuant to JCC 18.22.100(2). The relevant standards for this project include additional stormwater disposal requirements, regulations for golf courses, hazardous materials storage, well drilling, land division, and building permits. There are additional SIPZ regulations within these standards, as well. CARA Additional Protection Standards 34. The additional stormwater standards in JCC 18.22.130(2)(a) refer to the Stormwater Management Manual for the Puget Sound Basin and Chapter 18.30 JCC. The Stormwater Management Manual for the Puget Sound Basin (SWMMPSB) was published in 1992 and subsequently replaced by the Stormwater Management Manual for Western Washington (SWMMWW). Compliance with the SWMMWW meets or exceeds the standards in the SWMMPSB. 35. The golf course standards in JCC 18.22.130(4) require development and operation in a manner consistent with the most current edition of Best Management Practices for Golf Course Development and Operation published by King County in 1993.28 This is also a requirement set forth in the mitigation conditions from the FEIS and the FSEIS. This 28 No updates have been made since the 1993 publication. Best Management Practices for Golf Course Development and Operation is available online at: https://your.kingcounty.gov/dnrp/library/water-and-land/stormwater/stormwater- pollution-prevention-manual/Best%20Manangement%20Practices%20for%20Golf%20Course.pdf Project Location Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 37 of 117 manual focuses in large part on operation and maintenance considerations, and compliance with these BMPs will be verified with construction permits for the golf course. [CONDITION 12] 36. The BMPs applicable to planning and design are categorized in the “Wildlife Habitat,” “Water Consumption and Conservation,” “Hydrology and Water Quality Control,” “Geology and Groundwater,” and “Water Quality and Management Chemical Selection” sections and include: a. Wildlife Habitat BMPs • Determine if the proposal can be accommodated by avoiding or minimizing impacts to environmentally sensitive areas, such as wetlands, riparian corridors, and other habitat areas. • Where mitigation is not practical or feasible, avoid sites with substantial environmental constraints. • Locate high use areas away from sensitive habitats to reduce impacts of noise and other disturbances. • Course layout should include upland buffers to serve as transition zones between active use areas and wildlife habitat. • Maintain sources of food, water, and shelter for local wildlife populations. • Design roughs and naturally vegetated strips to provide linkages between habitat areas • Maintain access for migratory species to habitual routes, food sources, and breeding grounds. • Preserve and maintain natural vegetation. • Retain mature significant trees, preferably in groups, where possible • Retain dead trees and snags, downed logs, and brush piles within roughs. • Identify wetlands and evaluate their functions and values according to adopted King County procedures. • Avoid altering ground water flow patterns and other characteristics. The project is required to implement a Vegetation Management Plan (Appendix L to the Development Agreement and attached exhibit) and a Wildlife Management Plan (Appendix P to the Development Agreement). These Plans specify the specific actions PHMPR is required to take in the design, construction, and operation of the resort. The golf course elements of the project are generally to be located away from environmentally sensitive areas, in particular Wetland B and the shoreline bluff. Where the golf course elements are not located away from sensitive areas, technical reports and studies affirm the project will protect ecological function and value (Exhibits 29 and 31C). The golf course itself is nine holes, which is smaller than the usual 18-hole golf course, and does not include other usual and customary features of larger courses such as a clubhouse, pro shop, etc. This overall reduction in the scale of the course mitigates potential impacts as documented in the FSEIS.29 29 See FSEIS section 1.3, Summary of Environmental Impacts, pg. 1-4-20. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 38 of 117 The course layout includes buffers and large areas of undisturbed existing, mature vegetation have been identified on the landscape plan (Exhibit 36). In the conservation easements along the shoreline, the Highway 101 right-of-way, and around wetlands, vegetation will be managed to balance habitat values and public safety, consistent with the Vegetation Management Plan. The project has been designed to achieve the applicable Wildlife Habitat BMPs. b. Water Consumption and Conservation BMPs • Evaluate availability of groundwater and potential for water reuse. • Evaluate the applicability of course design that reduces the irrigated turf area. The application includes a draft water system plan documenting rights for domestic and irrigation water and water use efficiency measures (Exhibit 24). PHMPR has indicated it will implement water reuse, using the treated water stored in Lake Pleasant for irrigation (Exhibit 24). The water system plan has not yet been approved (see Utilities – Water and Sewer section of this Staff Report). As described above, the golf course has been reduced in size to nine holes. The project has been designed to achieve the applicable Water Consumption and Conservation BMPs. c. Hydrology and Water Control BMPs • Areas devoted to tees, greens, and fairways should be minimized to the extent compatible with the intended users (standard of play) of the course. • Minimum buffer and setback requirements for streams, swales, and wetlands should be as mandated in the King County Sensitive Areas Ordinance.30 As described above, the golf course has been reduced in size to nine holes, thereby minimizing areas devoted to tees, greens, and fairways while maintaining the standard of play for intended users. If buffer averaging is approved pursuant to Chapter 18.22 JCC (see Wetlands section, below), the project will meet applicable wetland buffer requirements. The project has been designed to achieve the applicable Hydrology and Water Control BMPs. d. Geology and Groundwater BMPs • Avoid all unnecessary clearing, and avoid disturbing slopes greater than 40 percent and over 20 feet in height. • Maintain natural buffers around wetlands, lakes, ponds, and streams. • For high erosion hazard areas, existing [vegetation] should be preserved to the maximum extent possible. The Applicant provided a geotechnical report that includes recommendations for development on steep slopes and in erosion hazard areas (Exhibit 31C; discussed further in the Geologically Hazardous Areas section, below). The project meets applicable buffer requirements for wetlands using the buffer averaging provisions 30 Best Available Science (BAS) has evolved since Best Management Practices for Golf Course Development and Operation was published in 1993. Compliance with Appendix C of the Development Agreement (Chapter 18.22 JCC) would meet or exceed the 1993-era standards for environmentally sensitive areas. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 39 of 117 allowed in Chapter 18.22 JCC, discussed in Section 7.C of this Staff Report. The project has been designed to achieve the applicable Geology and Groundwater BMPs. e. Water Quality and Management Chemical Selection • Design the maintenance/operations yard in conformance with all OSHA and Washington State Department of Ecology technical manual requirements for storage and use of hazardous materials. • Incorporate stormwater quality BMP facilities into course design. These may include infiltration, filtration, wet ponds, biofiltration swales, and artificial/constructed wetlands. The maintenance facility for the golf course is the proposed AgraCenter building. The AgraCenter is located away from critical areas and buffers and is substantially screened by topography and existing, mature vegetation. The AgraCenter and any outdoor maintenance and operations yard will be required to conform to OSHA and DOE standards for the storage and use of hazardous materials. [CONDITION 12] The project includes stormwater BMPs that are integrated into the property at various locations, including around the golf course elements of the project. The project is required to achieve zero discharge of stormwater and has been designed in accordance with the 2024 SWMMWW for that purpose. The project has been designed to achieve the applicable Water Quality and Management Chemical Selection BMPs. CARA Land Division Requirements 37. Land division standards are set forth in JCC 18.22.130(8)(b). This section requires applications for land division to include specific and conclusive proof of adequate supplies of potable water through a qualifying hydrogeologic assessment (within an aquifer recharge area report) that demonstrates the creation of new lots and corresponding use of water will not impact the subject aquifer such that water quality is degraded by seawater intrusion. 38. Seawater intrusion was evaluated by the Department of Ecology in its 2010 hydrogeologic memo issued to support issuance of new water rights for the project. The memo was analyzed in the FSEIS, which concluded that “seawater intrusion was not a widespread problem on [Black Point] peninsula, although there were two areas near the shoreline where it appears to be occurring in the sea level aquifer. Two wells in these areas had higher chloride concentrations at a level indicative of seawater intrusion (see Appendix F). Historical data in other wells indicated there is not widespread seawater intrusion, although future periodic monitoring of groundwater levels, chloride concentrations, and specific conductance in select wells were recommended.”31 39. These findings support a positive determination by the Department of Ecology under RCW 90.44 that the proposed well(s) do not impair existing rights or nearby wells, the proposed wells do not impact surface water, and the proposed wells are not a detriment 31 See FSEIS pg. 3.2-3. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 40 of 117 to the public welfare. The memo includes conditions for ongoing monitoring, and those are incorporated into the recommendation of this Staff Report. [CONDITION 12] The proposal satisfies the requirements in JCC 18.22.130(8)(b). 40. PHMPR is required to conduct ongoing monitoring for potential saltwater intrusion under the Development Agreement’s Water Quality Monitoring Plan (Appendix N) and by the hydrogeologic memo. If saltwater intrusion does impact existing domestic wells, the Neighborhood Water Policy (Development Agreement Appendix O) requires PHMPR to allow impacted users to connect to PHMPR’s water system. CARA Coastal SIPZ 41. JCC 18.22.130(d)(1) identifies voluntary and mandatory actions for projects located in coastal SIPZ. For this project, the applicable mandatory action is a requirement that building permits use a DOH-approved public water system, if available. PHMPR is proposing to develop a public water system; all buildings will be required to connect to that system. [CONDITION 70] As conditioned, the project will comply with this requirement. Geologically Hazardous Areas 42. The geotechnical reports prepared for the project evaluate erosion hazards, landslide hazards, and seismic hazards. These reports include Krazan & Associates, Inc.’s October 15, 2024 “Jefferson County Review Comments Response Letter,” (Exhibit 31A) which validates the analysis, findings, conclusions, and recommendations of the “Final Draft Geotechnical Investigation – Pleasant Harbor Marina and Golf Resort – Jefferson County, Washington – Project No. SG0801” report dated January 23, 2013. This report is a cover letter from Perrone Consulting, Inc. P.S. that references the “Geotechnical Investigation – Pleasant Harbor Marina and Golf Resort – Brinnon, Washington” report prepared by Subsurface Group, LLC and dated December 17, 2008 (Exhibit 31C). The 2008 report has been validated by Krazan & Associates, Inc.’s response letter. Erosion Hazard Areas 43. Erosion hazard areas are defined in JCC 18.22.160(2)(a) as “Areas containing soil or soil complexes described and mapped within the United States Department of Agriculture [USDA], Soil Conservation Service, Soil Survey for Jefferson County as having a severe or very severe erosion hazard potential.” 32 The geotechnical report identifies areas of moderate erosion potential on slopes that are greater than 40 percent inclination (see Figure 7) and severe erosion potential along the very steep coastal bluff at the south end of the property (Exhibit 31A and 31C). The report includes recommendations to mitigate erosion impacts, including: • Limiting development on long, steep slopes, especially slopes underlain by soils prone to erosion. • Limiting disturbance of existing ground surface and natural vegetation before revegetating to its natural state. 32 The Soil Survey for Jefferson County is available online at: https://archive.org/details/usda-soil-survey-of-jefferson- county-area-washington-1975/page/15/mode/1up?view=theater&q=Co Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 41 of 117 • Protect permanent cut slopes with rockery walls, ecology blocks, and engineered retaining wall structures. • Implement specific temporary erosion and sediment control measures (see Page 12, Exhibit 31C). 44. The project design responds to the erosion hazard areas, with improvements generally located around the moderate erosion hazard areas identified on the plans (see Figure 7). The severe erosion hazard areas are permanently protected in the conservation easement recorded on February 29, 2024 (record no. 664860) (Exhibit 44); limited restoration and vegetation management are the only work that will occur within the easement area. The project is required to incorporate and adhere to all geotechnical recommendations in the report. [CONDITION 56] Figure 7: Erosion hazard areas overlaid on the preliminary civil engineering site plan . Source: Exhibit 31C and Exhibit 34. Overlay provided by project review staff. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 42 of 117 Landslide Hazard Areas 45. Landslide hazard areas are defined by JCC 18.22.160(2)(b) as “Areas potentially subject to mass movement due to a combination of geologic, topographic and hydrologic factors including: (i) areas of historic failures or potentially unstable slopes, such as: (A) Areas described and mapped as having severe or very severe building limitations for dwellings without basements within the [USDA] Soil Conservation Service, Soil Survey for Jefferson County; (B) Areas described and mapped as recent or old landslides or slopes of unstable materials within the Washington State Department of Ecology Coastal Zone Atlas of Jefferson County; and (C) Areas described and mapped as areas of poor natural stability, former landslides and recent landslides by the Washington State Department of Natural Resources, Division of Geology and Earth Resources; (ii) Areas potentially unstable as a result of rapid stream incision, stream bank erosion, or undercutting by wave action; and (iii) Areas with any indications of earth movement, such as: (A) Rockslides; (B) Earthflows; (C) Mudflows; and (D) Landslides.”33 34 Jefferson County’s Public Land Records online interactive map identifies areas of slight and high landslide hazard on the subject property (see Figure 8). Figure 8: Landslide hazard areas on the property and in the vicinity. Source: Jefferson County Public Land Records Interactive Map. Annotations provided by project review staff. 33 This definition is from Appendix C to the Development Agreement. 34 The definition in Appendix C differs slightly in wording from the definition used to evaluate the site in the preparation of the 2008 geotechnical investigation. The 2013 review, however, affirms the findings, conclusions, and recommendations in the 2008 study. Project Location Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 43 of 117 46. Jefferson County’s Public Land Records online interactive map also identifies areas of shoreline slope instability and stable slopes (see Figure 9). On the subject property, there are recent landslides, unstable slopes identified due to old landslides, and intermediate slopes. There are also some identified areas of stable slopes. Figure 9: Shoreline slope stability on the property and in the vicinity. Source: Jefferson County Public Land Records Interactive Map. Annotations provided by project review staff. 47. The geotechnical report (Exhibit 31C) states that “[t]he upland areas of the Golf Course and Maritime Village sites, which are comprised of dense granular glacial soils and which are sloped at or less than 1½H:1V (67%) generally have an adequate factor of safety against slope instability even though portions of the site satisfy the Jefferson County criteria for landslide hazard areas,” (emphasis added). The report determined that the landslide hazard areas on the subject property are the same as the erosion hazard areas (see Figure 7, above), including the coastal bluff. The report recommends a 100-foot setback from the top of the coastal bluff “for all buildings, roadways, and infrastructure facilities,” and includes additional recommendations for construction activities (Exhibit 31C). A supplemental Limited Geotechnical Engineering Letter – Top of Coastal Bluff/Shoreline Slope Setback and Buffer Clarification prepared by Krazan & Associates, Inc., dated September 10, 2025, clarifies that the following facilities should be allowed within the 100-foot setback but should not be allowed within the minimum 30- foot buffer set forth in JCC 18.22.170(6)(f): single- and multi-used paths, tee boxes, Project Location Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 44 of 117 and/or stormwater conveyance systems including berms, ditches, and swales (Exhibit 31F). Pursuant to JCC 18.22.170(6)(g), an additional five-foot building setback applies from the edge of any landslide hazard area buffer; the geotechnical report specifies the total distance of the setback from top of slope for buildings, roadways, and infrastructure facilities is 100 feet (Exhibit 31C) and no additional five-foot building setback is required for these facilities. The applicant is required to incorporate all geotechnical recommendations into the project. [CONDITION 56] 48. The top of the coastal bluff and the 100-foot setback are identified on the plans but are incomplete on the west side of the property near the south side of Tract X-14 and on the south side of the property east of Lot 103 (see Sheets 19, 23, and 26, Exhibit 33). The base 30-foot base landslide hazard area buffer is not identified on the plans. The Applicant will be required to identify the full extent of the top of slope, 30-foot buffer, and 100-foot setback on the property. [CONDITION 57] Portions of Lots 108-117 and Tracts C, X-3, X-4, and X-14 are in the setback area. The lots are intended for residential development. Tracts X-3 and X-4 are reserved for open space and golf course development. Tract X-14 is reserved for The Manor Village, an independent living elder care facility. Tract C is the coastal bluff easement area. Tracts X-3, X-4, and X-14 also contain proposed improvements or easements for proposed improvements including pedestrian trails, drainage, and sanitary sewer lift station. Infrastructure is not allowed in the 30-foot steep slope buffer. [CONDITION 60] 49. Pursuant to JCC 18.22.170(9)(b), a project application cannot be approved unless the geotechnical report certifies all of the following: a. There is minimal landslide hazard as proven by a lack of evidence of landslide activity in the vicinity in the past. The report concludes that “the project sites have a low to moderate potential for slope instability. The upland areas of the Golf Course and Maritime Village sites…generally have an adequate factor of safety against slope instability even though portions of the site satisfy the Jefferson County criteria for landslide hazard areas. Marginally stable slopes meeting criteria D [Slopes equal to or greater than 40% and equal to or greater than 10 feet in height] were confined to steeper slopes in two upland areas. One area was altered by human activity and the second area includes the shoreline bluff.” The report further notes that “the project sites are generally stable although the bluff area of the Golf Course site is subject to wave erosion. Our site reconnaissance and review of LIDAR maps does not indicate landslide features in the upland area behind the bluff. We did not observe any evidence in the topography, vegetation, surficial geologic conditions, or the existing structures, of deep-seated bluff instability. The glacial soils exposed in the bluff possess relatively high strength but can be subject to erosion and spalling from waves, repeated wetting/drying and freezing/thawing cycles,” (Exhibit 31C). The report does not identify any prior landslide activity, except in the area of the shoreline bluff. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 45 of 117 b. An analysis of slope stability indicates that the proposal will not be subject to risk of landslide, or the proposal or the landslide hazard area can be modified so that hazards are eliminated. The report includes appropriate recommendations to protect the proposal and landslide hazard area. These recommendations include establishing a minimum 100 foot setback from the top of the coastal bluff, as well as requiring that “[c]onstruction activities should be completed in accordance with the recommendations in this report for erosion control, site drainage, and earthwork and in accordance with Jefferson County Critical Lands Ordinances,” (Exhibit 31C). c. The proposal will not increase surface water discharge or sedimentation to adjacent properties beyond predevelopment conditions. The report includes appropriate recommendations to prevent surface water discharge and sedimentation offsite. As noted above, the report requires adherence to recommendations for erosion control and site drainage, and there are additional clearing and grading requirements in Chapter 18.22 JCC related to clearing and grading in geologically hazardous areas that must also be met. d. The proposal will not decrease slope stability on adjacent properties. The report includes detailed project design and construction recommendations in Section 11 that, if followed, will not decrease slope stability on adjacent properties. The recommendations are appropriately detailed to apply even though the project layout has been revised since the report was written. Verification of appropriate integration of recommendations into the design of specific project elements will occur with construction permits for those project elements. e. All newly created building sites will be stable under normal geologic and hydrogeologic conditions (if applicable). The report includes detailed project design and construction recommendations in Section 11 that, if followed, will ensure stability under normal geologic and hydrogeologic conditions. The recommendations are appropriately detailed to apply even though the project layout has been revised since the report was written. Verification of appropriate integration of recommendations into the design of specific project elements, and confirmation of stability under normal geologic and hydrogeologic conditions, will occur with construction permits for those project elements. All review criteria are addressed in the report analysis, conclusions, and recommendations sections. The report was prepared by a qualified professional geotechnical engineering firm and stamped by a licensed professional geotechnical engineer and a licensed engineering geologist. The 2013 and 2024 validations of the 2008 report affirm the findings, conclusions, and recommendations and are also stamped by qualified professionals. The geotechnical report is adequate for preliminary plat application review and decision-making. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 46 of 117 Seismic Hazard Areas 50. Jefferson County’s Public Land Records geodatabase identifies areas of seismic hazard on the subject property (see Figure 10). The geotechnical report notes that “[g]eologic hazards associated with earthquakes can include: 1. fault rupture of the ground surface; 2. liquefaction or loss of saturated soil strength and; 3. slope instability by ground shaking; 4. ground settlement.” The report concludes that the potential for ground fault rupturing during an earthquake is low to moderate; that soils at the property generally have a low susceptibility to liquefaction, although localized liquefaction of loose beach deposits could occur on the shores of Hood Canal; that there is low to moderate possibility for soil movement on slopes with ground shaking; and that the possibility of ground settlement due to an earthquake is low (Exhibit 31C). 51. Pursuant to JCC 18.22.170(9)(c), a project application that includes work in a seismic hazard area cannot be approved unless the geotechnical report demonstrates that the proposed project adequately protects the public safety. The geotechnical report includes recommendations that, if followed, will adequately protect the public safety. Figure 10: Seismic Hazard Areas on the property and in the vicinity. Source: Jefferson County Public Land Records Interactive Map. Annotations provided by project review staff. 52. Protection standards for geologically hazardous areas are set forth in JCC 18.22.170. Pursuant to JCC 18.22.170(1), projects on properties with geologically hazardous areas or their buffers must adhere to these requirements. Project Location Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 47 of 117 53. Drainage and erosion control is regulated under JCC 18.22.170(2). This subsection requires a drainage and erosion control plan to minimize sedimentation of adjacent properties during and after construction and to prevent runoff from being directed across a marine bluff, landslide hazard area, or ravine. The required drainage and stormwater control plan information is presented in the stormwater drainage study (Exhibit 26) and on the preliminary civil plans (Exhibit 34). Additionally, the project is required to achieve zero discharge from the property, and will comply with the water quality-related BMPs set forth in Attachment 1 to Amendment 1 to the FS&CA. As conditioned, the project will satisfy these requirements. 54. Pursuant to JCC 18.22.170(2)(a)(ii), an applicant proposing to create a new parcel within a known geologically hazardous area must submit and have approved a drainage and erosion control plan. Requirements for a drainage and erosion control plan are set forth in JCC 18.22.410. The purpose of the plan is to address best management practices that are physical, structural, or managerial that, when used singly or in combination, prevent or reduce pollution of water. The design standards and information requirements for submission of drainage and erosion control plans are required to be consistent with the 2024 SWMMWW. The applicant provided a drainage report (Exhibit 26) demonstrating that the project will meet the requirements in JCC 18.22.170(2) to evaluate and recommend methods to minimize sedimentation of adjacent properties during and after construction and to avoid directing surface drainage across the face of a marine bluff, landslide hazard area, or ravine. As conditioned, the project satisfies the requirements for erosion hazard areas. Compliance will be verified with construction permits. 55. Pursuant to JCC 18.22.170(3)(b)(i), an applicant proposing to create a new parcel in a geologically hazardous area must submit and have approved a grading plan. Requirements for a grading plan are set forth in JCC 18.22.430. The purpose of this plan is to identify earthwork on the property, along with proposed and existing contours and cross sections. The Applicant submitted the following information that satisfies the requirements in JCC 18.22.430(3): a. Geotechnical report. This includes a description of the general vicinity of the property, including geologic history relevant to understanding site grading with respect to geologic hazards, as required by JCC 18.22.430(3)(a). This also includes a discussion and evaluation of the potential impact of the proposed grading on the property as required by JCC 18.22.430(3)(f) and recommendations on appropriate protection mechanisms as required by JCC 18.22.430(3)(g). See Exhibit 31C. b. Site survey. This includes the property limits and existing contours as required by JCC 18.22.430(3)(b). See Sheets 3-9 of Exhibit 33. c. Preliminary civil engineering plan set. This includes the proposed grading, stormwater/drainage information, and building and structure locations as required by JCC 18.22.430(3)(c)-(e). See Exhibit 34. These engineering drawings are preliminary and not for construction, and further review will be performed with construction permits. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 48 of 117 d. Drainage report. This includes additional information about existing property conditions, facility sizing information, and utilities information to support the drainage requirements in JCC 18.22.430(3)(b)-(d). See Exhibit 26. As conditioned, the project meets the requirements for a grading plan that will result in no impacts to adjacent properties and will protect the public safety on the property. 56. The information submitted with the application is adequate for preliminary plat review. There are clearing and grading requirements set forth in JCC 18.22.170(3)(a) and Chapter 18.30 JCC that will apply during construction. There are also vegetation retention requirements in JCC 18.22.170(4) that are applicable to construction. These will be reviewed with construction permits for site grading, infrastructure, and other facilities and/or buildings. 57. Buffer requirements, including minimum buffers and field marking, are regulated in JCC 18.22.170(5) through (8). Pursuant to JCC 18.22.170(6)(b), the landslide hazard area buffer is determined by the geotechnical report recommendations. As discussed above, the geotechnical report recommends a minimum setback of 100 feet from the top of slope of the coastal bluff for buildings, roadways, and infrastructure (Exhibit 31C); single- and multi-use paths, tee boxes, and stormwater conveyance systems including berms, ditches, and swales may be located within the setback area provided a minimum 30-foot buffer from the top of slope is maintained (Exhibit 31F). JCC 18.22.170(6)(g) requires an additional five-foot building setback from the edge of the buffer. The additional five-foot building setback was not identified on the plans and will be required as a condition of approval. [CONDITION 57] The buffer will not be reduced or increased pursuant to JCC 18.22.170(7) or (8). 58. This 30-foot buffer is required to remain naturally vegetated and/or must be restored if there are temporary construction impacts pursuant to JCC 18.22.170(6)(c). Minor pruning and vegetation maintenance may be allowed by the development code administrator upon request pursuant to JCC 18.22.170(6)(d). [CONDITION 60] Wetlands 59. The Applicant provided a wetland verification report prepared by GeoEngineers, dated October 18, 2024 (Exhibit 29). The report is signed by Courtney Stoker and Jennifer Dadisman, who are Professional Wetland Scientists, and overseen by Joseph Callaghan, a Principal Biologist. Pursuant to JCC 18.22.330(3)(a), the report has been prepared by a qualified wetland evaluator. 60. This report validates prior wetlands investigation and reporting prepared in 2006 and 2008. The report evaluates three wetlands present on the subject property, identified as Wetlands B, C, and D (see Figure 11 ), determined based on the 1997 DOE Washington State Wetlands Identification and Delineation Manual, as well as the U.S. Army Corps of Engineers (USACE) Wetlands Delineation Manual (1987) and Regional Supplement to the USACE Wetland Delineation Manual: Western Mountains, Valleys, and Coast Region (2010). This meets the requirements for designation under JCC 18.22.300(2). Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 49 of 117 Sources for information consistent with the nonexclusive list in JCC 18.22.300(3) are listed in the report. Figure 11 : Wetlands identified by GeoEngineers. Source: GeoEngineers Wetland Verification Report, dated October 18, 2024 (Exhibit 29). 61. The report notes that the project is vested to the standards from Chapter 18.22 JCC in effect in March 2008, consistent with section 8.4 of the Development Agreement.35 In 35 See Development Agreement section 8.4 and Appendix C. The vesting requirements for development agreements are in RCW 36.70B.180. (“A development agreement and the development standards in the agreement govern during the term of the agreement, or for all or that part of the build -out period specified in the agreement, and may not be subject to an amendment to a zoning ordinance or development standard or regulation or a new zoning ordinance or Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 50 of 117 March 2008, these standards included the use of DOE’s 2004 Wetland Rating System (WRS) for Western Washington for wetlands classification. The version of JCC 18.22.300(1) in effect when the Development Agreement was approved- requires the use of DOE’s 2004 WRS or as amended. The amended version is DOE’s 2014 Rating system for Western Washington for wetlands classification.36 DOE published conversion tables for translating 2004 WRS scores to 2014 WRS scores,37 and County Staff have applied the conversions to the wetland report findings. 62. Based on a field evaluation, the report classifies Wetland B as a Type III wetland with a 2004 WRS habitat score of 22 points; Wetland C is classified as a Type III wetland with a 2004 WRS habitat score of 19; and Wetland D is classified as a Type III wetland with a 204 WRS habitat score of 24. Translated to the 2014 WRS using DOE’s conversion tables, the habitat scores for Wetlands B and D are in the range of 5-738 and the habitat score for Wetland C is 3-4.39 The total functional score for the wetlands based on the 2004 WRS are 44, 43, and 46, respectively. This translates to a range of 16-19 points in the 2014 WRS for all three wetlands. See Table 5 for a summary of the wetland study findings and conversion to the 2014 WRS scoring system. Table 7: Wetland categorization and buffer summary. Source: GeoEngineers Wetland Verification Report (Exhibit 29), DOE 2004-2014 WRS Conversion Tables. Wetland Category 2004 Wetland Rating System 2014 Wetland Rating System Habitat Score Total Score Habitat Score Range Total Score Range B III 22 44 5-7 16-19 C III 19 43 3-4 16-19 D III 24 46 5-7 16-19 63. JCC 18.22.330(3)40 describes the general method for determining the wetland buffer, considering the category of the wetland, the wetland rating scores, and the impact level of the proposed adjacent land use(s). The project uses the Professionally Delineated Boundary Option for determining the buffer distance, consistent with JCC 18.22.330(3)(c)(ii). The standard wetland buffer requirements are further described in JCC 18.22.330(6)(b), which applies buffer widths based on the wetlands category as determined by the total score on the rating form for the 2014 WRS and the expected level of impact of the proposed adjacent land use, using Tables 18.22.330(1) through (3). The code administrator, per JCC 18.22.330(6)(b)(ii), may determine that the proposed land use will have a lesser level of impact on the wetland than indicated by similar land uses on the list. The buffer width tables rely on the 2014 WRS scoring system, and this development standard or regulation adopted after the effective date of the agreement. A permit or approval issued by the county or city after the execution of the development agreement must be consistent with the development agreement.” 36 This system is also currently in effect. 37 The conversion tables are available online at: https://ecology.wa.gov/water-shorelines/wetlands/tools- resources/rating-systems 38 Modified to 6-7 in July 2018, shortly after the execution of the Development Agreement. 39 Modified to 3-5 in July 2018, shortly after the execution of the Development Agreement. 40 This is the vested provision in Appendix C to the Development Agreement. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 51 of 117 report uses the converted score ranges presented in Table 5 for determining the applicable buffer width: a. Wetland B is in the center and bottom of Kettle B. Adjacent land uses will include passive open space, golf course fairways, and paved paths for golf carts and active recreational use. Pursuant to Table 18.22.330(2), these are moderate impact land uses and the regulatory buffer is 110 feet. b. Wetland C is in an upland area to the southeast of Wetland B. Adjacent land uses will include single-family lots less than one acre in size and paved paths for golf carts and active recreational use. Pursuant to Table 18.22.330(3), these are high impact land uses and the regulatory buffer is 80 feet. c. Wetland D is on the east side of the property and crosses the property line onto adjoining land. Adjacent land uses on the subject property will include golf course fairway, paved paths for golf carts and active recreational uses, passive open space, and stormwater detention. Pursuant to Table 18.22.330(2), these are moderate impact land uses and the regulatory buffer is 110 feet. Table 8: Application of buffer requirements by adjacent land use and probable impact . Source: JCC 18.22.330. Wetland Category Adjacent Land Use Impact Classification Regulatory Buffer B III Passive open space, golf course fairways, paved paths Moderate 110 feet C III Single-family residential <1 acre lots, tee boxes, paved paths High 80 feet D III Golf course fairway, paved paths, passive open space, stormwater detention Moderate 110 feet 64. The project plans propose buffer widths of 150 feet for Wetlands B and D (Exhibit 29), exceeding the minimum requirements. 65. The project plans propose buffer averaging around Wetland C (see Figure 12). Buffer averaging is allowed pursuant to JCC 18.22.330(8) upon submission of a report by a qualified professional that the buffer reduction will not have any adverse impact on the existing functions and values of the wetlands, and consistent with the following criteria: a. The buffer averaging does not have any adverse impact on the functions and values of the wetland. The Response Memorandum to Jefferson County Comments Regarding Wetland C Buffer Averaging Plan (Exhibit 30) indicates that “the wetland buffer will remain and is densely vegetated with a forested vegetation community and a well- developed understory. In addition, this area will be protected and part of a wildlife corridor through the property. The project will not change the wetland outlet or vegetation community in the wetland or buffer, which could influence hydrologic Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 52 of 117 and water quality functions and values provided by the wetland. Also, the wetland is part of a wildlife corridor for vegetation and vegetation will not be impacted; therefore, habitat functions will still be provided. The functions and values of the wetland will not be impacted as a result of the buffer averaging.” (Emphasis added.) In addition to the Response Memorandum to Jefferson County Comments Regarding Wetland C Buffer Averaging Plan (Exhibit 30), wetland buffer averaging was evaluated in the preparation of the FEIS and FSEIS. Appendix J to the FSEIS is a Wetland and Wetland Buffer Mitigation Plan, and includes information about buffer averaging around Wetland C. In the Wetland and Wetland Buffer Mitigation Plan, buffer impacts were analyzed on the east side of Wetland C’s buffer (see Figure 12). The proposed buffer averaging areas (reduction and expansion) do not match exactly. The Wetland and Wetland Buffer Mitigation Plan considered a reduction area of 4,323 square feet, whereas the current proposal is for a reduction area of approximately 6,445 square feet (an increase of approximately 49 percent) (Exhibit 30). The analysis supporting the Wetland and Wetland Buffer Mitigation Plan, however, is useful in understanding whether the current proposal will result in any adverse impact on the existing functions and values of Wetland C. As noted in the Wetland and Wetland Buffer Mitigation Plan, the buffer reduction areas are heavily impacted by prior development; this can be seen also in the current application documents, where former campground roads pass through the northern and eastern portions of Wetland C’s buffer. With the implementation of the Wetland and Wetland Buffer Mitigation Plan, the FSEIS found that the project will not result in a significant adverse environmental impact in Wetland C. Based on the current analysis presented in the Response Memorandum to Jefferson County Comments Regarding Wetland C Buffer Averaging Plan (Exhibit 30), the current proposal will not have an adverse impact on Wetland C. b. The total area contained within the buffer averaging is no less than that which would be contained within the prescribed buffer, and the buffer boundary remains more or less parallel to the wetland boundary in order to avoid the creation of panhandles. The current proposal reduces the buffer around Wetland C by approximately 6,445 square feet on the east side and increases the buffer by approximately 6,445 square feet on the west side (Exhibit 30). The total area contained within the buffer averaging is no less than what would be contained within the prescribed buffer. As shown in Figure 12, the buffer remains approximately parallel to the boundary of Wetland C and this is confirmed in the Response Memorandum to Jefferson County Comments Regarding Wetland C Buffer Averaging Plan (Exhibit 30). The buffer averaging plan is consistent with this requirement. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 53 of 117 c. The most sensitive, or highest value, areas of the wetland have the widest buffer dimensions, and the buffer boundary takes into account variations in slope, soils, or vegetation to optimize the overall effectiveness of the buffer. The Response Memorandum to Jefferson County Comments Regarding Wetland C Buffer Averaging Plan (Exhibit 30) indicates that site and habitat conditions were evaluated when creating the buffer averaging plan. The Memorandum describes the wetland and buffer area as “relatively consistent,” with the reduction and increase areas being similar in slope, soil, and vegetation conditions (Exhibit 30). Based on this analysis, Wetland C does not have parts that are most sensitive or highest value; as noted above, however, the proposed buffer reduction areas are impacted by prior campground development whereas unimpacted areas are proposed to remain intact and undisturbed. Based on the analysis presented in the Response Memorandum to Jefferson County Comments Regarding Wetland C Buffer Averaging Plan (Exhibit 30), the proposal satisfies this criterion. d. The minimum buffer width is no less than 75 percent of the standard prescribed buffer width. The Wetland Verification Report (Exhibit 29), Response Memorandum to Jefferson County Comments Regarding Wetland C Buffer Averaging Plan (Exhibit 30), and the preliminary plat drawings (Exhibit 33) indicate the buffer will be no less than 60 feet deep, which is 75 percent of the standard buffer width of 80 feet (80 feet * 75% = 60 feet). The buffer averaging plan is consistent with this requirement. e. The buffer has not been reduced in accordance with [JCC 18.22.330(5)]. Buffer averaging is not allowed if the width of the entire buffer has been reduced already. The buffer around Wetland C has not already been reduced, and it is eligible for buffer averaging. Remainder of page intentionally left blank. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 54 of 117 Wetland C Buffer Averaging: Current Proposal Wetland C Buffer Averaging: 2012 Buffer Averaging Plan Figure 121: Wetland C Preliminary Impact and Mitigation Figure compared to Golf Course Wetland C Buffer Planting Plan. Source: Figure 3, GeoEngineers Wetland Verification Report (Exhibit 29) Figure 12, GeoEngineers Wetland and Wetland Buffer Mitigation Plan (FSEIS Appendix J). 66. Pursuant to JCC 18.22.330(4), a drainage and erosion control plan consistent with JCC 18.22.410 must be submitted and approved. The plan is also required to discuss, evaluate, and recommend methods to minimize sedimentation of designated wetlands during and after construction. As discussed above in the analysis about geologically hazardous areas, the Applicant submitted a drainage report (Exhibit 26) and preliminary civil drawings (Exhibit 34). Compliance with the 2024 SWMMWW is required, and specific sediment control measures will be reviewed with construction permits. 67. Pursuant to JCC 17.65.050, all provisions of existing Jefferson County Code regarding critical areas and their buffers apply, and wetland buffers once determined are to be placed in a permanent conservation easement. Placing wetlands and their buffers in a conservation easement is also required by Condition 63(s) of Ord. No. 01-0128-08 (Appendix K of the Development Agreement) and a mitigation condition in the FSEIS that states “[t]he final wetland critical area buffers will be marked and left undisturbed for Wetlands C and DA condition of approval will ensure wetland buffers are placed in permanent conservation easements.” [CONDITION 66] Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 55 of 117 68. Buffers are required to be marked in the field with a permanent physical indicator pursuant to JCC 18.22.330(5)(a). This will be required with the installation of infrastructure. [CONDITION 68] 69. Mitigation requirements are set forth in JCC 18.22.350 and the FEIS and FSEIS. The Wetland and Wetland Buffer Mitigation Plan included as Appendix J to the FSEIS establishes the required mitigation consistent with JCC 18.22.350. Mitigation measures primarily include the restoration of buffers around wetlands through the removal of infrastructure and invasive plants and replanting with native species. Mitigation must be completed prior to final plat. [CONDITION 63] Other Critical Areas 70. Frequently flooded areas are regulated under JCC 18.22.140-150, which refers to standards adopted in Jefferson County’s floodplain management ordinance, Chapter 15.15 JCC. Designation criteria for frequently flooded areas are set forth in JCC 15.15.060. There are no areas meeting the designation criteria on the subject property. 71. Fish and wildlife habitat conservation areas (FWHCAs) are regulated under JCC 18.22.195-280. Designation criteria for FWHCAs are set forth in JCC 18.22.200. There are no areas meeting the designation criteria on the subject property. 18.25 JCC Shoreline Master Program 72. Sec. 8.6 of the Development Agreement specifies that the Shoreline Master Program (SMP) in effect when the Development Agreement was executed applies to the project. The SMP (Chapter 18.25 JCC) is included as Appendix F to the Development Agreement. References to the SMP or JCC 18.25 and its subsections in this section of the Staff Report refer to the SMP in Appendix F. 73. Pursuant to JCC 18.25.020, the SMP applies to the shoreline jurisdiction. According to RCW 90.58.030, The shoreline jurisdiction includes those areas extending landward for 200 feet in all directions as measured on a horizontal plane from the ordinary high water mark; floodways and contiguous floodplain areas landward 200 feet from such floodways; and all wetlands and river deltas associated with the streams, lakes, and tidal waters which are subject to the provisions of Chapter 90.58 RCW. Hood Canal is a shoreline of the state and the shoreline jurisdiction applies from the ordinary high water mark of Hood Canal landward 200 feet on the subject property (see Figure 13). 74. Only portions of the property within the shoreline jurisdiction are regulated under the SMP. The entirety of the shoreline jurisdiction was placed into a conservation easement on February 29, 2024 (Exhibit 44) and no further land division or development is proposed within the shoreline jurisdiction. The proposal complies with the SMP. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 56 of 117 Figure 13: Approximate location of shoreline jurisdiction along south property line. Source: Preliminary Civil Engineering Drawings (Exhibit 34). Annotations provided by project review staff. Approximate Location of Shoreline Jurisdiction Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 57 of 117 D. Infrastructure and Utilities Infrastructure – General 75. RCW 58.17.110 and the approval criteria in JCC 18.35.310 require subdivisions to make appropriate provisions for the public health, safety, and general welfare and for such open spaces, drainage ways, streets or roads, alleys, other public ways, transit stops, potable water supplies, sanitary wastes, parks and recreation, playgrounds, schools and schoolgrounds and all other relevant facts, including sidewalks and other planning features that assure safe walking conditions for students who only walk to and from school. This section of the staff report analyzes infrastructure, including: stormwater/drainage, transportation (streets and roads, pedestrian circulation, parking), water, sewer, and other utilities. This section also addresses other infrastructure, including landscaping, lighting, and signage. Stormwater 76. Section 8.3 and Appendix B of the Development Agreement specify the stormwater standards applicable to the project. Section 8.3.1 vests the project to the County stormwater management requirements in place when the Development Agreement was executed. JCC 18.30.070 as set forth in Appendix B of the Development Agreement is the same as the current version,41 which says: All new development and redevelopment must conform to the standards and minimum requirements set by the most current version of the Washington Department of Ecology Stormwater Management Manual for Western Washington (SMM) and obtain a stormwater management permit if required by subsection (5) of this section. The administrator may require additional measures as indicated by the environmental review or other site plan review. JCC 18.30.070(1) (emphasis added). Accordingly, this project must meet Minimum Requirements (MR) 1 through 9 in the 2024 SWMMWW. These requirements include preparation of a stormwater site plan (MR1) and a construction stormwater pollution prevention plan (MR2), source control of pollution (MR3), preservation of natural drainage systems and outfalls (MR4), on-site stormwater management (MR5), runoff treatment (MR6), flow control (MR7), wetlands protection (MR8), and ongoing operational and maintenance requirements (MR9). 77. The FEIS requires that all water on the property be collected and either used appropriately on the property, routed to the storage ponds, or infiltrated into the groundwater aquifer.42 Zero stormwater discharge is allowed to leave the property. 78. The Drainage Report prepared by Hatton Godat Pantier, dated June 20, 2025,43 was updated under new signature on June 20, 2025 (Exhibit 26). According to section 1.4 of 41 See Ordinance No. 08-0710-06 and Ordinance No. 14-1210-18. 42 Mitigating Conditions: Water Resources. FEIS Chapter 5, pg. 5-4. 43 The report cover is dated June 20, 2024, but the date of signature is June 20, 2025. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 58 of 117 the report, “[d]rainage facilities include bioretention swales, infiltration ponds, a stormwater pump, and underground infiltration galleries with stormfilters. 79. The report indicates that “[t]he site is divided into 13 basins for stormwater analysis,” shown in Figure 14 (Exhibit 26). The basins are further described in section 8.1 of the report. Figure 14: Stormwater basin map. Source: Drainage Report prepared by Hatton Godat Pantier, dated June 20, 2025 (Exhibit 26). Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 59 of 117 80. Stormwater in the basins will be treated through a variety of methods, depending on project design and existing conditions, described in Table 9, below (Exhibit 26). A stormwater site plan was provided in the drainage report and is shown in Figure 15 (Exhibit 26). Table 9: Summary of proposed stormwater treatment methods by basin. Source: Drainage Report prepared by Hatton Godat Pantier, dated June 20, 2024 and revised June 20, 2025 (Exhibit 26). Stormwater Basin Proposed Treatment 1 Stormfilter vault and underground infiltration gallery 2 Stormwater pond in existing topographic depression 3 No treatment described; Drainage Report figures show stormwater pond in existing topographic depression 4 Stormfilter vault and retention pond 5 Infiltration treatment pond 6 Conveyed via piping and swales to a storm pump that includes a buffer pond 7 Stormwater pond in existing topographic depression; stormfilter prior to infiltration 8 Stormfilter vault and underground infiltration gallery 9 Wet pond for treatment then retention pond for metered release prior to being released to the Bypass basin, matching existing flow patterns 10 Offsite flow to the north, as in current, undeveloped conditions Kettle B Basin No treatment described, drains to existing wetlands Kettle C Basin Storage for reclaimed water Bypass Basin Predominantly undisturbed; runoff cannot be collected and infiltrated Remainder of page intentionally left blank. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 60 of 117 Figure 15: Proposed stormwater site plan. Source: Drainage Report prepared by Hatton Godat Pantier, dated June 20, 2025 (Exhibit 26). Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 61 of 117 81. Stormwater treatment for Basin 3 is not clearly characterized in the Drainage Report. The report does, however, show proposed Storm Pond 2 in an existing topographic depression within Basin 3 and later indicates that “infiltration treatment is proposed for basins 2, 3, and 5 through 9,” (see Page 17, Exhibit 26). This is adequate to determine appropriate provisions have been made for stormwater in support of a preliminary plat application, but additional clarification and verification of compliance will be required with construction permits. [CONDITION 45] 82. Proposed stormwater treatment is not described for Kettle B Basin. Kettle B Basin is described as “largely undeveloped” in the Drainage Report and the Drainage Report notes that flow from undeveloped portions of this Basin will retain existing flow patterns. Drainage pathways for development associated with Lots 33-43, Tracts X-9-X-11, or the golf course improvements in Tract X-1 (fairways, tee boxes, golf cart/shared use paths) are not discussed. [CONDITION 46] 83. Stormwater treatment for the remaining basins will be through a variety of methods, including: stormwater vaults and infiltration galleries, vegetated stormwater ponds, retention of existing patterns (sheet flow), and retention for reclaimed water usage (Kettle C Basin only). These proposed treatment methods and facilities were selected based on the project proposal and existing site and soil conditions. Impervious and pervious surface area in the basins were considered in selection of facilities (Exhibit 26). Based on the level of project design, they appear to be appropriately sized and located for the planned improvements and demonstrate general conformance to the 2024 SWMMWW. Further review and verification of compliance will be completed with construction permits. Transportation—General 84. Primary access to the property is from US Highway 101 at the intersection with Black Point Road. Secondary access to the property is available on the east side of the property, also from Black Point Road. A traffic impact analysis was performed with the FEIS and FSEIS. The project will generate approximately 3,840 daily net trips.44 There are no planned roadway improvements by WSDOT or Jefferson County along US Highway 101 or Black Point Road that will impact the project. As a result of project- related traffic impacts, the FEIS and FSEIS required the following improvements be provided as mitigation: • Fully fund and construct associated improvements for Black Point Road to meet County standards from US Highway 101 to the project entrance.45 • Provide adequate sight distance to the east of the proposed main site driveways onto Black Point to improve and maximize entering and exit sight distances.46 • At the US Highway 101 and Black Point Road intersection, provide a southbound left-turn lane as part of project development. The expansion of the existing T- 44 Net project trip generation is estimated at 4,100 daily trips, less approximately 260 daily shuttle bus trips for a total of 3,840. 45 Mitigating Conditions: Transportation. FEIS Chapter 5, pg. 5-5. 46 Mitigating Conditions: Transportation. FEIS Chapter 5, pg. 5-5. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 62 of 117 intersection would also provide for a median refuge area for left turns from Black Point Road onto US Highway 101.47 • Provide a northbound right-turn pocket or taper at US Highway 101 at the Black Point Road intersection under the Statesman proposal.48 • Residents of the Maritime Village shall be given access to the golf course resort without traveling US Highway 101. A detailed traffic design to accommodate traffic on US Highway 101 returning to the resort must be developed, with further traffic analysis and design approval by WSDOT and Jefferson County.49 • Reconstruct the Black Point Road approach to US Highway 101 with adjacent left turning lanes, a widened approach onto US Highway 101, and an “entry treatment” on Black Point Road at US Highway 101. The proposed site access concept would also include a consolidated intersection onto Black Point Road with a realignment of the WDFW boat launch at Pleasant Harbor either in a combined or separate intersection.50 • Provide all access roads and internal roads available for public use to County road standards. Private drives may be to a lesser standard approved by the Public Works Department and emergency service providers during the preliminary plat phase if desired by the applicant.51 • Provide an internal pathway and circulation system within the site that would not impact County or State highways, would provide for pedestrian and bicycle circulation between the two main development districts, and would allow US HWY 101 bicycle traffic bypass through the resort (i.e., Black Point properties and Maritime Village).52 • The preliminary plat approval for the golf course portion of the resort should evaluate trip management plans as an alternative to simple roadway expansion. This may include: Provide a van or small shuttle bus for guests and tenants to utilize on an as-needed basis for use in group trip making, coordinated events, airport shuttle, and other miscellaneous traffic. All such services shall be coordinated with Jefferson Transit to schedule expanded service as necessary to the resort as well as consider joint opportunities to provide layover or transit service and facilities within the site.53 47 Mitigating Conditions: Transportation. FEIS Chapter 5, pg. 5-5. 48 Mitigating Conditions: Transportation. FEIS Chapter 5, pg. 5-5. 49 Mitigating Conditions: Transportation. FEIS Chapter 5, pg. 5-5. 50 Mitigating Conditions: Transportation. FEIS Chapter 5, pg. 5-5. 51 Mitigating Conditions: Transportation. FEIS Chapter 5, pg. 5-5. 52 Mitigating Conditions: Transportation. FEIS Chapter 5, pg. 5-5. 53 Mitigating Conditions: Transportation. FEIS Chapter 5, pg. 5-5. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 63 of 117 • To reduce off-site traffic impacts and reduce on-site circulation, the applicant has proposed the following: o A shuttle bus system for airport shuttle services and excursions to local destinations. o An on-site fleet of electric carts for internal travel within the Golf Course/Resort area, the Maritime Village, and the Marina area. o An on-site layover and transit zone in the southeast corner of the U.S. Hwy 101 and Black Point Road intersection to accommodate intercommunity transfers between Jefferson and Mason Transit systems as well as access to public transportation systems.54 Transportation—Access 85. Figures 16 and 17 show the proposed access improvements (Exhibit 34). The project proposal will re-align the intersection of Black Point Road with US Highway 101 by shifting the west end of Black Point Road southward, creating an approximately 90- degree intersection with US Highway 101 to improve sight distance. The project proposal also includes the required southbound left-turn lane and right-turn pocket on US Highway 101 and a left-turn pocket for the property to the south. Improvements are tapered into the existing roadway at the north and south ends of the limits of construction. Figure 16: Proposed US Highway 101/Black Point Road intersection and site access improvements. Source: Preliminary Civil Plans (Sheet 1, Exhibit 34). Figure 17: Proposed secondary access improvements. Source: Preliminary Civil Plans (Sheet 1, Exhibit 34). 86. All improvements in the US Highway 101 right-of-way are subject to WSDOT review and approval. All improvements in the Black Point Road right-of-way must be made to Jefferson County roadway standards and are subject to Jeferson County Public Works review and approval. Amendment 2 to the Development Agreement requires 54 Transportation. FSEIS, pg. 1-38. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 64 of 117 construction of these improvements in Phase 1 of development. Verification of construction or financial security will be required to build subsequent project phases; if the project is not phased, approval of improvements will be required prior to final plat approval. 87. The preliminary civil plans appear to show sidewalks on the east side of US Highway 101 (Exhibit 34). Actual roadway improvements within WSDOT’s right-of-way, including any sidewalks and/or potential intersection control for bicycle and pedestrian safety, will be determined by WSDOT during their review. These sidewalks were not further analyzed in this Staff Report. 88. The cover letter submitted with the June 23, 2025, indicates that using the existing main entrance at its current location on Old Black Point Road will create a better line of sight down Black Point Road toward US Highway 101 (Page 6, Exhibit 63). Per the June 23, 2025 letter, to retain the current entrance “Jefferson Co Public Works would need to release Old Black Point Road to the MPR or MPR would connect to the Co road and work with Public Works to make the intersection improvement.” Old Black Point Road is an easement reserved for roads and utilities that is identified in property descriptions in the preliminary plat but is not shown on the site survey (Exhibit 33). Releasing existing County-owned easements for ingress and egress/roads requires review and recording an easement release instrument. Release of Old Black Point Road is not shown on the preliminary plat and no written request for release has been submitted. [CONDITION 19] 89. The Maritime Village project component originally was proposed at the Pleasant Harbor Marina but was relocated to the upland golf resort portion of the project. Maritime Village not within the boundaries of the preliminary plat, but it is proposed to be accessed on the north leg of the main entrance intersection and will be integrated into the proposed circulation. The FEIS requires that “[r]esidents of the Maritime Village be given access to the golf course resort without traveling US Highway 101.”55 The FEIS also requires the project to “[p]rovide an internal pathway and circulation system within the property that would not impact County or State highways, would provide for pedestrian and bicycle circulation between the two main development districts, and would allow US Highway 101 bicycle traffic bypass through the resort (i.e. Black Point properties and Maritime Village).”56 The sidewalks and/or nonmotorized/shared-use path must be extended into this intersection. [CONDITION 20] Extension of the connection between the upland golf resort and marina portions of the project will be required with development permits for Maritime Village. 90. The FEIS requires an “entry treatment” on Black Point Road at US Highway 101.57 An “entry treatment” has not been proposed but will be reviewed with construction permits for the Black Point Road improvements and/or future sign permits. 55 Mitigating Conditions: Transportation. FEIS Chapter 5, pg. 5-5. 56 Mitigating Conditions: Transportation. FEIS Chapter 5, pg. 5-5. 57 Mitigating Conditions: Transportation. FEIS Chapter 5, pg. 5-5. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 65 of 117 91. The FEIS requires reconstruction of the Black Point Road approach to US Highway 101 to include a consolidated intersection onto Black Point Road with a realignment of the WDFW boat launch at Pleasant Harbor either in a combined or separate intersection.58 Construction of the boat launch ramp will occur in Phase 2 pursuant to Section 10 of the Development Agreement (as amended). In the current proposal, realignment of WDFW’s boat launch access will be at a separate intersection on Black Point Road. Adjustments to WDFW’s boat launch access must be coordinated with and approved by WDFW and Jefferson County Public Works prior to issuing construction permits that affect the access. Improvements must be made as part of the first phase of development and will be reviewed with construction permits at that time. 92. The secondary access serves the AgraCenter storage and maintenance facility, the wastewater treatment plant, and staff housing. It will also provide emergency/fire access and must be designed and maintained to support a ladder truck or similar fire apparatus. [CONDITION 21] An additional access road for maintaining stormwater facilities (Storm Pond 3) is also proposed and will require a road approach permit. [CONDITION 22] Transportation—Roads 93. The project includes an internal vehicular road network to connect all major project areas around the property. The FEIS requires PHMPR to “[p]rovide all access roads and internal roads available for public use to County road standards. Private drives may be to a lesser standard approved by the Public Works Department and emergency service providers during the preliminary plat phase if desired by the applicant.”59 All internal access roads are private roads set aside in Tracts A and B or in easements reserved for ingress, egress, and utilities. The application materials do not indicate which roads will be available for public use or how access will be managed; this Staff Report assumes all roads will be available for public use to access residential units and various resort amenities and facilities, but PHMPR may adjust access prior to or during construction permit review for affected roads. [CONDITION 26] 94. Road standards are set forth in JCC 18.30.080(1)(a) through (f), and the Department of Public Works has adopted additional road standards (Exhibits 5A and 5B). The road standards are applied based on average daily traffic (ADT) estimates and, for roads exceeding 1,000 ADT, design hourly volume (DHV). ADT estimates were provided in a Minimum Roadway Width – Response to SUB2023-00025 Technical Review Comments memorandum prepared by TENW (Exhibit 32B). This memorandum identifies proposed roadway widths by segment based on ADT, but some ADT estimates exceed 1,000 and DHV estimates were not included in the memo. The DHV information must be submitted for review prior to issuing construction permits for the roads. Based on the preliminary road sections included in the preliminary civil plans (Sheet 15, Exhibit 34), the proposed internal access roads do not appear to meet Jefferson County road standards and do not include the required separation between vehicular travel lanes and the multi-use path (see Transportation – Pedestrian Circulation section, below). The memorandum indicates that the road sections shown in the preliminary civil plans will be revised to shift 58 Mitigating Conditions: Transportation. FEIS Chapter 5, pg. 5-5. 59 Mitigating Conditions: Transportation. FEIS Chapter 5, pg. 5-5. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 66 of 117 the shared-use path to the outside of the stormwater bioswale throughout the site to achieve required separation between the shared-use path and vehicular travel lanes (Exhibit 32B). A deviation request for each road section not meeting Jefferson County standards must be submitted, reviewed, and approved prior to issuing construction permits for the roads. [CONDITION 26] The FSEIS identifies a “reduction of roadway width to the minimum acceptable to Jefferson County and the local fire district”60 as a method to reduce stormwater runoff, and Jefferson County will consider this condition in making any decisions on deviation requests. 95. JCC 18.30.080(1)(g) allows the Department of Public Works to require a traffic analysis. This was submitted and reviewed with the FEIS and FSEIS and mitigation measures have been incorporated into the project design. No further traffic analysis is required. 96. JCC 18.30.080(1)(h) requires subdivision road systems to provide access to the public road system at two locations. The project takes access from Black Point Road, which is a public road, in two locations. Black Point Road connects to US Highway 101 and ends at Lackawanna Beach on the eastern shore of the Black Point peninsula. Although Black Point Road is not a through-road, there are no alternatives for a different access point to the Jefferson County road network. JCC 18.30.080(1)(h) allows a reduction to one access location based on a finding that a single access location is adequate to protect the public health, safety, and welfare. Transportation impacts and safety were analyzed in the traffic study during the FEIS and FSEIS processes and the access was found to be acceptable. The Fire Marshal reviewed the access with respect to emergency response and evacuation and determined that the proposed accesses are adequate to protect the public health, safety, and welfare provided egress is maintained and, if ingress is controlled, emergency response vehicles are accommodated. [CONDITION 21] The project satisfies both the plain language of the requirement and the intended purpose of the requirement. 97. Access from arterial and collector roads is restricted per JCC 18.30.080(1)(i). Black Point Road is a local access road. The project meets this requirement. 98. The project is required to make appropriate provision for transit and school bus stops per JCC 18.30.080(1)(k). The project design includes space for a future park and ride in what is currently a gravel parking lot used occasionally by County vehicles as a layover space. The gravel lot is located at the southeast corner of the intersection of US Highway 101 and Black Point Road. This area could also be used as a school bus stop, if determined to be necessary. The project is also required per the MOU with Jefferson Transit Authority (Appendix J04 to the Development Agreement) to provide on-site transit stops and to post bus schedule information, which will be verified with construction permits. Appropriate provision has been made for transit and school bus stops. 99. The project has approximately 225.67 feet of frontage along Black Point Road, which is a County road. Pursuant to JCC 18.30.080(1)(l), when a proposed subdivision is adjacent to a County road, a right-of-way 30 feet in width from the roadway centerline 60 3.2-3 Mitigation Measures, Transportation. 2015 FSEIS Chapter 3.2, pg. 3.2-20. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 67 of 117 shall be conveyed to Jefferson County, if such right-of-way has not been previously conveyed. The existing right-of-way width from the centerline along the project’s frontage is 30 feet. 100. The preliminary plat identifies approximately 7,300 square feet of right-of-way dedication along Black Point Road at the southeast corner of the intersection with US Highway 101 (see Figure 18). Figure 18: Proposed right-of-way dedication. Source: Sheet 11, Exhibit 33. Annotations provided by County review staff. Proposed Right of Way Dedication Area Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 68 of 117 101. Dedications can be accepted following the criteria in JCC 18.30.080(2)(b)(ii)(A): a. The road right-of-way is at least 60 feet in width and is dedicated to Jefferson County in fee simple. The Black Point Road right-of-way is a total of 80 feet wide in the proposed dedication area.61 The proposed dedication area will add a roughly triangularly shaped area to the south side of the westernmost end of the right-of-way, increasing the width at the intersection and tapering eastward into the existing right-of-way. A condition will require it to be dedicated to Jefferson County in fee simple. [CONDITION 28] b. The road meets all other county standards. The intersection will be reconstructed and Black Point Road will be slightly realigned. Black Point Road will be required to meet adopted County road standards, and this will be verified during construction permit review. [CONDITION 29] As a matter of policy for ongoing maintenance of public roads, Public Works typically requests that right-of-way dedication extend beyond the edge of pavement. Final configuration of the dedication area will be determined between PHMPR and Public Works, and approval of the right-of-way dedication area is required prior to final plat approval. [CONDITION 27] c. An evaluation by the county engineer deems the road to be of general public benefit. The road dedication is necessary because the intersection between Black Point Road and US Highway 101 will be redesigned and improved. The changing intersection conditions will necessitate a realignment of Black Point Road such that it will not fit within the current right-of-way. The intersection improvements and realignment will mitigate traffic impacts from the project and are required for public safety. The County Engineer must deem the dedication to be of general public benefit prior to final plat approval. [CONDITION 30] The County Engineer will review the final dedication area prior to final plat approval. [CONDITION 27] 102. JCC 18.30.080(1)(m) requires easements for private roads providing access to and/or internal circulation within subdivisions to be 60 feet in width. The main internal road network will be developed in two private road tracts (A and B), except that access to the Olympia House, Cascadia House, Manor Village, Hawks Landing, and Eagles Nest buildings will be in easements reserved for ingress, egress, and utilities. All tracts and easements are approximately 24 feet wide (Exhibit 33), with anticipated two-way travel in 10 foot wide lanes, for a total paved width of 20 feet plus either unpaved shoulder or paved multi-use trail (Exhibit 33, Sheet 15 of Exhibit 34, Exhibit 32A, and Exhibit 32B). 61 The Black Point Road alignment is not centered in the right-of-way. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 69 of 117 103. JCC 18.30.080(1)(m) allows easement width to be reduced on the recommendation of the Public Works Department based on a finding that the public health, safety, and welfare will be protected and that the easement width is adequate for the construction and maintenance of roads and utilities. Where reduced access easement widths are proposed, parallel utilities easements may be required. 104. The proposed width of the easement is adequate for the anticipated vehicular traffic on the property, as well as emergency access. The Brinnon Fire Chief had no concerns about fire access in the proposed layout (Exhibit 67G), and the Fire Marshal determined that the proposed road widths could be acceptable if the project demonstrates that emergency access will be adequate. [CONDITION 31] The Minimum Roadway Width – Response to SUB2023-00025 Technical Review Comments memorandum prepared by Michael Read, PE, of TENW, dated October 2, 2024, concludes that the proposed road widths are consistent with the 2018 International Fire Code and the American Association of State Highway and Transportation Officials’ (AASHTO) A Policy on Geometric Design of Highways and Streets. The access easement is combined with a utility easement; JCC 18.30.080(1)(m) states that, where reduced access easement widths are proposed, parallel utilities easements may be required. The combined utility easements are acceptable, but final easement location and width will be determined based on as-built conditions of installed utilities prior to final plat approval. [CONDITION 33] Public health, safety, and welfare will be protected by providing access for both pedestrians and vehicles, including fire apparatus, consistent with the International Fire Code and adopted engineering standards. 105. Parallel 10-foot-wide utility easements are shown on both sides of the road tracts, and an overlapping 15-foot-wide pedestrian easement is shown on at least one side of the road tracts. The parallel utility easements along the private road tracts will support adequate access for the construction and maintenance of both roads and utilities. 106. Applicable requirements in JCC 18.30.080(1)(n) through (q) and (s) are requirements to be addressed between preliminary plat approval and final plat. Transportation—Pedestrian Circulation 107. In addition to the vehicular road network, the project design includes a multi-use path system serving golf carts, pedestrians, and bicyclists. The paths generally run parallel to the proposed vehicular roads, as well as extending throughout the golf course fairways. The FEIS requires an internal pathway and circulation system within the property that would not impact County or State highways, could provide for pedestrian and bicycle circulation between the two main development districts, and would allow US Highway 101 bicycle traffic bypass through the resort.62 With the proposed shuttle system required by the FSEIS and in the Jefferson Transit and Parks and Recreation MOUs (Appendix J07 to the Development Agreement), the proposed internal pathway system will not impact County roads or US Highway 101. The required connection between the upland golf resort and the marina (the two main development districts) is 62 Mitigation Measures: Transportation. FEIS Chapter 5, pg. 5-5. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 70 of 117 not shown on the preliminary plat but must be provided as part of the road network required in phase 1 of the development under Amendment 2 to the Development Agreement. That connection will also allow bicycles to bypass US Highway 101. [CONDITION 25] 108. Developments must make appropriate provision to ensure safe walking conditions for pedestrians and for students who walk to and from school pursuant to JCC 18.30.080(1)(j). The 15-foot pedestrian easements along the road tracts extend throughout the property and connect all major project features internally and with Black Point Road. The project is a resort and, pursuant to the MOU between PHMPR and the Brinnon School District (Appendix J01 to the Development Agreement), “[s]easonal recreational home are not expected to add students to the school district, so no impacts are expected from that component of the resort population. Since the proposed Resort Staff Housing is intended for both resort staff and Brinnon residents, it is expected that some of these units would be occupied by families with school-aged children.” The Brinnon School is located approximately 3.7 miles from the intersection of Black Point Road and US Highway 101, and Highway 101 lacks sidewalks; it is unlikely that students will walk from PHMPR to school. If there is a student population in the staff housing building, children may walk to a bus stop. The preliminary civil plans show a direct sidewalk connection between the staff housing building and the internal roads, which lead to the probable bus stop location at the gravel parking lot on US Highway 101 (Exhibit 34). The sidewalk and any necessary road crossing(s) for internal access roads, at Black Point Road, or at the US Highway 101/Black Point Road intersection will be reviewed with construction permits by Jefferson County and/or WSDOT. 109. The proposed road sections (Sheet 15 of Exhibit 34) indicate the multi-use path will not be separated from the vehicular travel lanes. A minimum three-foot separation or a concrete barrier is required in WSDOT’s Design Manual M 22-01 (Exhibits 1515-4 and 1515-6 in Chapter 1515 Shared-Use Paths) for two-way shared-use paths adjacent to roadways with travel speeds up to 35 miles per hour. These standards are applicable pursuant to JCC 18.30.080(1)(a). Pursuant to the Minimum Roadway Width – Response to SUB2023-00025 Technical Review Comments memorandum prepared by TENW (Exhibit 32B), the road sections will be revised to shift the shared-use path to the outside of the stormwater bioswale throughout the site to achieve the required separation between the path and vehicular travel lanes. This will be verified with construction permits for the roads and paths. [CONDITION 34] 110. Pedestrian circulation standards in JCC 18.30.090 do not apply to this project. There are no connections to public trails referenced in any adopted County plan for public trails. Transportation—Parking and Off-Street Loading 111. Parking standards set forth in JCC 18.30.100 (Appendix G to the Development Agreement) apply to the project. Pursuant to JCC 18.30.100(1)(c), a parking layout plan must be submitted for approval at the time of application for any permit or land use activity required by this code. The Applicant did not submit a parking layout plan because parking is more appropriately reviewed with construction permits. Jefferson Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 71 of 117 County required a conceptual level of information related to parking to determine that parking would be accounted for on the property. 112. Minimum parking standards are set forth in Table 6-2, Minimum Number of Parking Spaces Required for Different Land Uses in JCC 18.30.100. Table 10, below, excerpts the relevant requirements. Table 10: Parking requirements by land use. Source: JCC 18.30 Table 6-2 (Appendix G of the Development Agreement). Use Parking Requirement Drinking and/or eating establishments 1 per 100 square feet or 1 per 3 seats, whichever is greater. Seasonal outside seating does not require additional parking Hotel/Motel 1 per guest room plus 1 per employee Personal and Professional Services and Offices 1 space per 300 square feet plus 1 per employee, but not fewer than 3 spaces Retail Sales and Services 1 per 300 square feet Multifamily Residential (3+ Units) 1.5 per dwelling unit Single-Family Residential 2 per dwelling unit Small-Scale Recreational and Tourist Uses Determined by the administrator All Utilities and Related Uses Determined by the administrator 113. The FSEIS indicates that approximately 1,550 parking stalls will be provided in a mix of structured (approximately 887 stalls) and surface parking (approximately 663 stalls), which is adequate to serve the maximum development capacity on the property. According to the Pleasant Harbor FSEIS Transportation Impact Study (Appendix L to the FSEIS), occasional deficits will be addressed through the implementation of an on-site shuttle system, valet parking, and other on-site parking. A parking garage with approximately 600 stalls has been identified on the plans, serving the Inn by the Sea, the recreation center, and the conference center portions of the project (Exhibit 34). Parking for single-family residences (107 Sea View Villa lots and 43 Golf Vista lots) will be accommodated on each of the residential lots. The civil plans show a surface parking lot adjacent to the staff housing building with approximately 125 stalls, including five accessible stalls (Exhibit 34). The Applicant has indicated that parking for the Eagle’s Nest, Olympia House, and Cascadia House will likely be accommodated in underground parking garages; this could change during final design. Information on parking for the Hawks Landing and Manor Village buildings was not provided. Administrative and maintenance workers will likely be working from professional offices and/or the AgraCenter building, and parking for those workers would be accounted for at the office or maintenance yard locations. Conformance with applicable parking requirements will be reviewed with each construction permit application for all buildings and uses that require parking. [CONDITION 24] Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 72 of 117 114. The project must provide the requisite number of accessible stalls per the Americans with Disabilities Act (ADA), including van-accessible stalls per Chapter 11 of the IBC. The project is also required to meet the standards for off-street loading spaces set forth in JCC 18.30.110 in Appendix G to the Development Agreement. Compliance with these standards will be reviewed with construction permits for each building. Utilities—Sewer and Water 115. The project will be served by community water and sewer systems. PHMPR proposes to operate a new Group A water system and a new wastewater system and treatment plant. Formation of a water and sewer district is required in Phase 1b of the project phasing plan, section 10.1.3 of the Development Agreement (Amendment 2). 116. The new Group A water system is required by Condition 63(n) of Ord. No. 01- 0128-08.63 A Group A water system is a system with 15 or more service connections that serve 25 or more people for 60 or more days per year. DOH’s Office of Drinking Water (ODW) is responsible for reviewing and approving proposed water system plans. The Pleasant Harbor Water System Plan (WSP) (Exhibit 24) is in review by ODW and must be approved prior to construction of infrastructure. [CONDITION 38] New structures using potable water must be connected to the Pleasant Harbor water system. [CONDITION 70] 117. The Applicant has provided the following water rights documentation to document adequate water to serve the development: a. Certificate of Water Right (Certificate No. G2-20465C), dated May 9, 1975 (Exhibit 14) b. Certificate of Water Right (Certificate No. G2-21134C), issued April 8, 1977 (Exhibit 16) c. Certificate of Water Right (Certificate No. G2-23626C), issued June 20, 1977 (Exhibit 17) d. Permit to Appropriate Public Waters of the State of Washington (Permit No. G2- 27964P), issued July 17, 1992 (Exhibit 18) e. Amended Permit to Appropriate Public Waters of the State of Washington (Permit No. G2-27964), issued August 14, 2008 (Exhibit 19) f. Superseding Water Right Permit (Water Right No. G2-30436), dated October 11, 2007 (Exhibit 20) g. Superseding Water Right Permit (Water Right No. S2-30437), dated October 11, 2007 (Exhibit 21) 118. DOE made a preliminary finding that Water Right Certificate G2-20465C “has been either wholly or partially relinquished because of non-use,” (Exhibit 67D). Subsequently, Statesman voluntarily relinquished a majority of Water Right Certificate G2-20465C (Exhibit 15). Per DOE, “[t]he total domestic use will be limited to the amount 63 This condition states: “Approval of a Class A Water System by the Washington Department of Health, and approval of a Water Rights Certificate by the Department of Ecology shall be required prior to applying for any Jefferson County permits for plats or any new development.” This is a two-part condition that requires approval of a new Group A water system for the project and, separately, requires approval of a water rights certificate prior to applying for the plat. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 73 of 117 authorized for community domestic purposes by groundwater permit G2-3036 (121 acre- feet per year, 300 gallons per minute) in addition to the amount remaining with groundwater certificate G2-20465C (5.6 acre feet year, 15 gallons per minute), for a total of 126.6 acre feet per year,” (Exhibit 15). The project as a whole, including both domestic and irrigation uses authorized by the permits and remaining certificate rights, may not exceed 254 acre-feet per year and a withdrawal rate of 300 gallons per minute (Exhibit 15). PHMPR’s Water Right Self-Assessment Form for Water System Plan (Section 10.3, Exhibit 24) identifies an additional 14.1 acre-feet per year of water available for domestic use from water right permit no. G2-21134C (Exhibit 16), a permit associated with the Pleasant Tides water system. This right was not evaluated in DOE’s correspondence and must be addressed during ODW’s review of the WSP.64 119. The Pleasant Harbor WSP prepared by Hatton Godat Pantier dated June 27, 2025, projects total domestic annual water demand of 143.1 acre-feet per year based on water usage of 200 gallons per day (gpd) per equivalent residential unit (ERU) (Section 2.7, Exhibit 24), approximately 2.4 acre-feet per year (approximately 1.7%) more than the water available for domestic use under the water rights claimed in the Water Right Self-Assessment Form for Water System Plan (Section 10.3, Exhibit 24). The WSP notes that the Pleasant Harbor Water System would need to acquire an additional 2.5 acre-feet per year of water rights or reduce demand by approximately 2.5 percent below current estimates (Section 2.7, Exhibit 24). The use of reclaimed water was not factored into water demand estimates. The plan proposes to meter and record actual water usage and make performance-based adjustments to the forecasted water demand in the WSP (Section 2.7, Exhibit 24). The Applicant submitted a Technical Memorandum prepared by Hatton Godat Pantier dated August 27, 2025, to provide additional information about the deficiency in water rights (Exhibit 25). According to this memorandum, the WSP “is a PLANNING document. It is intended to forecast water demand 10 and 20 years into the future, in part, to identify areas of concern. This Planning tool at times may forecast deficiencies such as a shortage of water rights, source production, storage capacity, or other operational, financial, or water quality aspects of a Group A Public Water Supply. “Deficiencies” in any of these areas is a look into the future. It is not a criteria suggesting approvability of the water system plan. It is, in effect, a “task list” for areas of improvement over time,” (Exhibit 25). According to the Applicant, deficiencies such as this are normal. The total shortfall amounts to approximately 15 units (Exhibit 25). 120. The deficiency is further discussed in the memo with respect to additional DOH requirements for water system planning (Exhibit 25). According to the memo, DOH requires an allocation for distribution system leakage (DSL). This DSL accounts for water lost due to leaking pipes. Without the five percent DSL allocation provided in the WSP, the system would have 3.3 percent more water rights than needed for the project. The memo further notes that a new system built to current standards is highly unlikely to leak at a rate approaching five percent and actual DSL is expected to be significantly less. 64 During WSP review, DOE will review and validate all water rights claimed for this project. The review process is anticipated to include DOE and/or ODW taking any necessary actions to formally assign the 14.1 acre feet per year from the Pleasant Tides water system to the Pleasant Harbor water system. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 74 of 117 121. As noted above, the WSP calculates water usage at 200gpd per ERU. The project is required by Condition 63(o) of Ord. No. 01-028-08 to calculate water usage at 175gpd per ERU. According to the technical memo, if water use were calculated based on 175gpd per ERU, the Pleasant Harbor water system “is expected to have 8.5% EXCESS of water rights rather than a deficit,” (Exhibit 25). Further, Condition 63(o) also notes that PHMPR’s water usage goal is 70gpd per ERU. In addition to the use of low- flow fixtures and reclaimed water (Exhibit 25), PHMPR plans to pursue performance- based reduction in water usage (Exhibit 24). According to the memo, DOH requires two years of water system data demonstrating lower water demand to approve a reduced water use figure for the WSP. 122. Nevertheless, the WSP acknowledges that either improved conservation and water use efficiency or rights to approximately 2.5 acre-feet per year of additional domestic water could be needed (Exhibit 24). DOE notes that existing limitations on water availability do “not foreclose the Project from obtaining additional water supply from other sources if necessary for the development of the full project,” (Exhibit 15). There are reasonable and feasible alternatives for addressing the potential deficiency in water availability. 123. WSP approval must be provided prior to issuing construction permits for water infrastructure, and the WSP must conform to DOH Group A Public Water Systems Waterworks Standards and Jefferson County’s Coordinated Water System Plan Design and Construction Standards. [CONDITIONS 39 and 41] In its WSP approval, DOH will approve a certain number of connections to the water system based on the projected demand; upon approval of performance-based water demand reduction, remaining connections can be considered (Exhibit 25). 124. The water system must also achieve a fire flow rate of 2,000 gallons per minute pursuant to the International Fire Code (IFC). [CONDITION 49] The phasing plan in Amendment 2 to the Development Agreement requires the water system to be built in Phase 1 of project development. 125. Following construction of the water system and establishment of the Pleasant Harbor water and sewer district, the district will issue Certificates of Water Availability for each new building permit that includes a connection to the water system. 126. The FEIS states: “Any project approval for the resort shall contain a condition that the applicant demonstrates entitlement to sufficient water rights to serve the approved phase from WDOE (water rights, transfer, and/or rainwater harvesting rights and use conditions) prior to preliminary plat approval and construction of any facilities on the property.”65 For the preliminary plat approval, the written analysis provided in the technical memorandum (Exhibit 25) will satisfy this requirement. [CONDITION 40] PHMPR has stated it will pursue water reclamation and reuse as a method of reducing water consumption on the property and achieving the water usage goal of 70gpd per 65 3.2-3 Mitigation Measures, Water Resources, FEIS, pg. 5-3. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 75 of 117 ERU. The proposed stormwater pond in Kettle C may be used for irrigation. Buildings may include reclaimed water infrastructure. Rainwater harvesting is identified in the FSEIS as a measure that could minimize requirements for irrigation with potable water.66 There are additional water use efficiency measures specified in Chapter 4 of the WSP (Exhibit 24). These measures will be reviewed with construction permits as appropriate. 127. A new wastewater treatment system will serve the proposed development. This includes construction of a new wastewater treatment plant (WWTP) and associated sewer lines, pump stations, and related infrastructure. The Wastewater System Plan (WWSP) (Exhibit 22) has been approved by the Department of Ecology (Exhibit 23). The phasing plan in Amendment 2 to the Development Agreement requires the wastewater system to be built in phase 1 of project development. The wastewater system must be designed and constructed in accordance with DOE’s “Criteria for Sewage Works Design (August 2008).” Water and sewer line crossing must conform to Jefferson County Department of Environmental Public Health’s (EPH) “Water/Sewer Line Crossing Policy.” [CONDITION 41] 128. Per the FEIS, any project approval for the golf course area requires construction and operation permits for a wastewater treatment system for the project by DOE and an operational plan to be in place as a condition of final plat approval and construction of any structures for occupancy or residency.67 This is a condition of approval of the preliminary plat. [CONDITION 38] 129. Saltwater intrusion into existing residential wells on the Black Point peninsula was a concern raised during environmental review with the FEIS and FSEIS. Hydrogeologic memos were provided by the Department of Ecology for the FSEIS (Appendix F to the FSEIS), and the memos determined that saltwater intrusion was not a widespread problem on the peninsula. Condition 63(p) of Ord. No. 01-0128-08 required PHMPR to establish a neighborhood water policy for Statesman to provide access to the water system by ay neighboring parcels if saltwater intrusion becomes an issue and to reserve areas for recharge wells in case wells fail, are periodically inoperable, or cause mounding. The required neighborhood water policy is included as Appendix O to the Development Agreement. Recharge well reserve areas have been identified on the preliminary plat drawings. In several areas, the well reserve radii overlap with proposed improvements, and it is unclear if the improvements are compatible with the purpose of the recharge wells. Aquifer recharge wells are regulated by DOE68 and the US Environmental Protection Agency (EPA).69 Aquifer recharge requires substantial environmental review and permitting efforts, with strict requirements for the quality of water to be injected into the aquifer through the well. 66 3.2-3 Mitigation Measures, Water Resources. 2015 FSEIS Chapter 3.2, pg. 3.2 -19. 67 Mitigation Measures: Water Resources. FEIS Chapter 5, pg. 5-3. 68 “Aquifer storage, recovery, & recharge,” Department of Ecology. https://ecology.wa.gov/water-shorelines/water- supply/water-recovery-solutions/aquifer-storage-recovery-recharge 69 “Aquifer Recharge and Aquifer Storage and Recovery,” US EPA. https://www.epa.gov/uic/aquifer-recharge-and- aquifer-storage-and-recovery Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 76 of 117 Utilities—Electric 130. Under the FSEIS mitigating conditions, 70 the project is required to use grid electricity. Mason County Public Utility District (PUD) No. 1 is the electric purveyor for the property. Condition 63(bb) of Ord. No. 01-0128-08 requires verification of the ability to provide adequate electrical power from Mason County PUD No. 1. Mason County PUD No. 1 completed a capacity analysis of the power system and confirmed that two megawatts of power (2MW) is currently available to the project (Exhibit 67J). The project needs an estimated 3 MW of power. Mason County PUD No. 1 has indicated any power supply greater than 0.5 MW requires a Large Load Agreement to determine the necessary system improvements with associated costs and timeline (Exhibit 67B); County staff is not aware of the execution of a Large Load Agreement. PHMPR has paid a deposit to Mason County PUD No. 1 “to begin the process for creating a reimbursement agreement for the engineering, design and construction work to upgrade PUD facilities to increase power supply for future phases of development, along with a cost-of-service analysis to determine power rates and terms of power service,” (Exhibit 67J). PHMPR must verify adequate power supply prior to final plat approval. [CONDITION 43] Utilities—Other 131. CenturyLink provides telecommunication service in south Jefferson County. According to the FSEIS, satellite internet service would be provided for the project.71 132. Solid waste collection will be managed by Jefferson County Public Works. Review of solid waste collection locations and loading space for service vehicles will occur with construction permits for each building. Lighting Standards 133. Lighting standards set forth in JCC 18.30.140 (Appendix G to the Development Agreement) apply to the project. The Applicant submitted conceptual lighting information (Exhibit 35). The conceptual lighting information is not detailed enough to determine compliance with the applicable lighting requirements, but this level of detail is more appropriately reviewed with construction permits. The Applicant must provide additional information about fixture design, scale, and intensity with construction permits for infrastructure and buildings that include exterior lighting. 134. The project is also required to comply with DarkSky lighting standards set forth in Appendix S to the Development Agreement. The Applicant must provide adequate detail with construction permits for infrastructure and buildings that include exterior lighting to verify compliance with those standards. Landscaping 135. A substantial portion of the property will remain as undisturbed vegetation, open space, and landscaping. The Applicant provided a landscaping plan identifying conceptual plantings across the property (Exhibit 36). 70 3.10-4 Mitigation Measures, Air Quality. 2015 FSEIS Chapter 3.10, pg. 3.10-9. 71 3.16-2 Impacts, Utilities. 2015 FSEIS Chapter 3.16, pg. 3.16-6. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 77 of 117 136. Condition 63(u) of Ord. No. 01-0128-08 states that, “[i]n keeping with the MPR designation as located in a setting of natural amenities, and in order to satisfy the requirements of the Shoreline Master Program, the greenbelts of the shoreline should be retained and maintained as they currently exist in order to provide for screening of facilities and amenities so that all the uses within the MPR are harmonious with each other, and in order to incorporate and retain, as much as feasible, the preservation of natural features, historic sites, and public views. In keeping with the Comprehensive Plan Land Use Policy 24.9, the site plan for the MPR shall be designed to blend with the natural setting and to the maximum extent possible, screen the development from the adjacent rural areas. Evergreen trees and understory should remain as undisturbed as possible. Statesman shall infill plants where appropriate with indigenous trees and shrubs.” As described in Section 7.C of this Staff Report, a conservation easement (record no. 664860) permanently protects the coastal bluff area within 200 feet of the ordinary high water mark of Hood Canal (Exhibit 44). Existing vegetation will be preserved in this area, and it will be restored where existing improvements will be demolished. The proposal satisfies the first part of this condition. 137. In its June 23, 2025, resubmittal, PHMPR documented a number of changes intended to minimize grading and retain existing vegetation (Exhibit 63). The site design appears generally to respond to existing topography while still accomplishing the project. 138. The landscaping plan (Exhibit 36) shows conceptual areas of undisturbed vegetation and areas with ornamental or functional landscaping and xeriscaping. The landscaping plan was not updated with the June 23, 2025, resubmittal, but a number of design changes were made to retain existing trees and mature vegetation. 139. Condition 63(v) of Ord. No. 01-0128-08 states “[i]n keeping with an approved landscaping and grading plan, and in order to satisfy the intent of JCC 18.15.135(6) and with special emphasis at Maritime Village, the buildings will be constructed and placed in such a way that they will blend into the terrain and landscape with park-like greenbelts between the buildings.” Information about design intent in the placement of buildings with respect to existing topography and vegetation was not provided. The preliminary landscape plan indicates that undisturbed natural vegetation will be present in various locations, and low-water-demand ground cover (identified as xeriscaping) will be established on regraded slopes (Exhibit 36). The landscaping plan was not updated with the June 23, 2025, resubmittal. All portions of the property that are not developed with buildings or infrastructure will be landscaped. Further compliance with landscaping requirements will occur with construction permits for infrastructure, golf course fairways, and buildings. 140. Condition 63(w) of Ord. No. 01-0128-08 requires construction of the buildings to be completed in a manner that strives to preserve trees 10 inches in diameter at breast height (dbh) or more. In the June 23, 2025, resubmittal, a number of design changes were made to retain existing trees and mature vegetation. A Vegetation Management Plan was adopted as Appendix L to the Development Agreement. The Vegetation Management Plan primarily establishes vegetation management practices to alter Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 78 of 117 vegetation for view maintenance and fire safety, and address slope stability, noxious weeds, and danger (hazard) trees. The Vegetation Management Plan also includes a Forest Report appendix that rates areas of existing vegetation on the property and maps and defines the ratings for forestry sub-units (see Figure 19). Figure 19: Black Point forestry impact classification map. Source: Figure 13, Forestry Report, Vegetation Management Plan, Appendix L to the Development Agreement. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 79 of 117 141. Based on the sub-unit description in the Forestry Report, areas identified as BP-1 and BP-200 are the least impacted and with the largest trees. BP-1 sub-areas are described as having “larger trees than are found in other Black Point timbered areas, as defined by height and diameter. Overall health and/or stand condition is acceptable for long term retention where that option is within approved plans for development.”72 Several of these areas will be impacted to some extent under the current proposal (see Figure 20); there were, however, also impacts to these stands of trees in the site plan analyzed in the FSEIS. Condition 63(2) of Ord. No. 01-0128-08 is aspirational, but PHMPR should consider describing whether the impacts are greater, lesser, or approximately the same under the current proposal. Remainder of page intentionally left blank. 72 Forest Report, pg. 20. Vegetation Management Plan, Appendix L to the Development Agreement. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 80 of 117 Figure 20: Black Point forestry impact classification map with proposed site plan overlaid . Source: Figure 13, Forestry Report, Vegetation Management Plan, Appendix L to the Development Agreement and Sheet 1, Exhibit 34. Overlay provided by Jefferson County project review staff.73 Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 81 of 117 142. The FSEIS requires designated vegetated corridors to extend throughout the property and be left undisturbed.74 The corridors should connect to on- and offsite forested areas and should remain undisturbed. The corridors are intended to consist of native vegetation that provides typical forest habitat and food sources for wildlife. The corridors are identified in the Wildlife Management Plan adopted as Appendix P to the Development Agreement. The Applicant provided an updated wildlife corridor plan based on the current site layout (Exhibit 28). The wildlife corridor plan shows large habitat areas and wildlife connections around the property (see Figure 21). Based on information provided in the landscape plan (Exhibit 36), the corridors identified on the wildlife corridor plan consist of a mix of undisturbed native vegetation, screening vegetation, and low-water-demand vegetation (described as xeriscaping). The corridors exclude the golf course fairways, consistent with the Wildlife Management Plan. Figure 21: Wildlife corridor plan updated June 18, 2025. Source: Wildlife Management Plan prepared by GeoEngineers, dated June 18, 2025 (Exhibit 29). 73 The Forestry Report and the Preliminary Civil Drawings use different base projections for mapping and the overlay shows only approximate locations of project improvements. This Figure is illustrative only. 74 3.4-3 Mitigation Measures, Fish and Wildlife. 2015 FSEIS Chapter 3.4, pg. 3.4-9. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 82 of 117 143. While the corridors will not be entirely undisturbed, they appear to include large areas of undisturbed vegetation. Proposed plantings will be required to consist of native or naturalized vegetation and drought-tolerant vegetation that will serve similar habitat goals. This will be reviewed with construction permits. 144. The FEIS also identifies some landscape requirements, including: maintaining natural open spaces along the shoreline bluff, along the property perimeter where practical with the golf course layout, between golf course fairways, and at the upper portion of the development; ensuring retention of selected significant stands of trees along the coastal bluff to reduce visibility of the property from the south; and providing landscaping between US Highway 101 and the new access road on the upland side of Maritime Village.75 As described above, the coastal bluff has been placed into a conservation easement (record no. 664860) (Exhibit 44) and the area within 200 feet of the ordinary high water mark of Hood Canal will be maintained as a vegetated buffer. Open spaces are present throughout most of the property based on the information in the landscape plan (Exhibit 36), with vegetation present around the property perimeter, between golf course fairways, and surrounding various areas of the development. Maritime Village is not within the preliminary plat boundaries. 145. Landscaping is required for all multifamily residential, commercial, and small- scale recreational and tourist uses. The standards in JCC 18.30.130 in Appendix G to the Development Agreement apply to the project. Under these standards, landscaping must be provided in various contexts meeting one of the following three landscaping screen types described in JCC 18.30.130(3): a. Screen-A: a “full screen” that functions as a visual barrier and consisting of a mix of primarily evergreen trees and shrubs generally interspersed to form a continuous year-round screen that grows to at least eight feet in height within two growing seasons. b. Screen-B: a “filtered screen” that functions as a visual separator and consisting of a mix of evergreen and deciduous trees and shrubs generally interspersed to create a filtered screen that grows to at least eight feet in height within two growing seasons. c. Screen-C: a “see-through screen” that functions as a partial visual separator to soften the appearances of parking areas and building elevations and consisting of a mix of evergreen and deciduous trees or shrubs generally interspersed to create a continuous canopy. 146. Road frontages must be landscaped with a minimum 10-foot depth of Screen-C landscaping along the road frontage pursuant to JCC 18.30.130(4). The property fronts along US Highway 101 at two discontinuous locations on the west side of the property (see Figure 22). A separate property owner controls the parcel between these two frontages, and it is not part of the proposal. 75 Mitigation Measures: Rural Character/Aesthetics. FEIS Chapter 5, pg. 5 -8. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 83 of 117 Figure 22: Road frontages. Source: Jefferson County Public Land Records GIS Database. 147. There is no vegetation in the northernmost frontage area on the property. The project will be required to provide Screen-C landscaping in this area consistent with JCC 18.30.130, and this will be reviewed with construction permits. The existing, mature vegetation in the southern frontage area meets the requirements for Screen-C landscaping and the project design shows the area to be retained undisturbed. The proposed subdivision layout can accommodate the required road frontage landscaping depth. 148. Interior lot line landscaping must meet the requirements in JCC 18.30.130(5). Pursuant to JCC 18.22.130(5)(a), 15 feet of Screen-A landscaping is required between commercial, industrial or small-scale recreational and tourist development along any portion adjacent to a residential use or district. The project is surrounded on all sides by Property Boundary US 101 Frontage – Landscaping Required US 101 Frontage – Landscaping Required No US 101 Frontage – No Landscaping Required Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 84 of 117 Rural Residential zoning (RR-5 and RR-20) (see Figure 1). Project elements are adjacent to these districts along the north property line (the Recreation Center, Inn by the Sea, Conference Center, and parking garage) and along the northeast property line (staff housing, AgraCenter, surface parking lot, stormwater facilities, sewer lift station). The proposed subdivision layout cannot accommodate the required interior lot line landscaping depth. Pursuant to JCC 18.30.130(2)(b), however, the development code administrator may authorize variations to the landscaping and screening requirements, and the Applicant is required to seek this approval during construction permitting or revise the project layout to accommodate the landscaping requirements. [CONDITION 14] 149. The Applicant submitted a conceptual landscaping plan (Exhibit 36). A complete landscape plan must be submitted with construction permits demonstrating compliance with applicable landscaping requirements for road frontages, interior lot lines, and surface parking lots. Landscape maintenance will also be addressed with construction permits. Signs 150. Standards for signs set forth in JCC 18.30.150 (Appendix G to the Development Agreement) apply to the project. Information about the location, types, and design of signs was not submitted with this application. Separate sign permits are required for each regulated sign and detailed will review with those permits. E. Public Services 151. RCW 58.17.110 requires subdivisions to make appropriate provisions for the public health, safety, and general welfare and for such open spaces, drainage ways, streets or roads, alleys, other public ways, transit stops, potable water supplies, sanitary wastes, parks and recreation, playgrounds, schools and schoolgrounds and all other relevant facts, including sidewalks and other planning features that assure safe walking conditions for students who only walk to and from school. This section of the staff report analyzes public services impacts and mitigation. 152. According to Section 8.11 of the Development Agreement, the scale and intensity of the proposed development will impact the ability of Jefferson County to provide adequate public services and PHMPR was required to negotiate and enter into MOUs to provide necessary support and mitigate impacts. The MOUs are included as Appendix J to the Development Agreement. 153. School impacts are mitigated through an MOU with the Brinnon School District (BSD). According to the MOU, seasonal recreational homes are not expected to add students to the school district, but some school-age children may live in the on-site staff housing. Mitigation measures include direct payments to BSD for services on property, bonuses for employment-age students in BSD working at the Resort, publishing opportunities for Resort visitors to make financial contributions to BSD, and educational opportunities to learn about the technology and industry sectors used at the Resort. The BSD requested additional information about inflation-based adjustments to the direct payment mitigation measures, but no other comments were provided (Exhibit 67H). The Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 85 of 117 MOU provides adequate mitigation for the project and there are no design implications to be further analyzed for preliminary plat. 154. Fire and emergency management systems (EMS) impacts are mitigated through an MOU with Jefferson County Fire District No. 4, also known as the Brinnon Fire Department (BFD). Impacts are mitigated through the use of Firewise Standards76 to reduce wildfire-related responses from BFD. BFD had no comments on the design (Exhibit 67G). The MOU provides adequate mitigation and there are no design implications to be further analyzed for preliminary plat. The FEIS identifies several conditions related to fire and EMS for preliminary plat approval. [CONDITIONS 49-53] 155. The Jefferson County Fire Marshal reviewed the proposal and commented on the proposed project design. The Fire Marshal is satisfied with the mitigation provided by the MOU to provide adequate service, but identified several concerns related to project design, emergency access, and fire protection: a. Accessibility Standards. An analysis of access to proposed buildings by fire apparatus and by emergency response personnel was not provided with the application. As noted in the Transportation sections of this Staff Report, above, road widths are narrower than Jefferson County Public Works’ adopted standards and must be demonstrated to allow access by fire apparatus, including ladder truck for aerial response. A fire apparatus turning radius analysis is required as a condition of approval prior to construction of roads. [CONDITIONS 31-32] b. Fire Hydrants. Proposed hydrant spacing, location, and flow analysis was included in the water system plan (Exhibit 24). If the structure requires sprinklers or fire flow, water availability must be proven prior to building permit approval. [CONDITION 50] The Applicant must provide a Certificate of Water Availability with the building permit application. c. Fire Flow. IFC 507.1 requires an approved water supply capable of supplying to required fire flow, and this must be verified with construction permits. [CONDITION 49] 156. Police services impacts are mitigated through an MOU with the Jefferson County Sheriff’s Office (JCSO). JCSO anticipates additional services and call volumes in south Jefferson County as a result of the project. PHMPR is required to provide facilities for JCSO use at the Resort, security systems and video monitoring, private security that varies by phase of construction and operation, First Responder certification or better for security staff, relationship-building between JCSO and PHMPR’s security staff, and the funding of an additional JCSO deputy if certain conditions are met. JCSO had no comments on the proposal (Exhibit 67F). The MOU provides adequate mitigation and there are no design implications to be further analyzed for preliminary plat. 76 Firewise is a program by the National Fire Protection Association that teaches people how to adapt to living with wildfire. Firewise standards emphasize risk reduction through site and building design and vegetation management. The program toolkit can be downloaded at: https://www.nfpa.org/-/media/project/storefront/catalog/files/firewise/band- together/firewise_band_together_toolkit.pdf?rev=b70bbb145d5346118a59270b7e375a73 Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 86 of 117 157. Transportation impacts are partially mitigated through an MOU with Jefferson Transit Authority. Jefferson Transit Route 1 (the Brinnon route) provides public transportation service in south Jefferson County, and currently stops at the intersection of US Highway 101 and Black Point Road. PHMPR is required to provide on-site transit stops as part of the first phase of the development, prominently display and maintain a current bus schedule, consult with Jefferson Transit Authority for review of bus pull-outs, and operate a Resort shuttle from May to September annually. The MOU provides adequate mitigation. Design components of the MOU will be reviewed and addressed during construction permits for infrastructure and the US Highway 101/Black Point Road intersection improvements. 158. Impacts to the Jefferson General Hospital in Port Townsend and Mason General Hospital in Shelton are mitigated through an MOU with Jefferson Healthcare. The Brinnon community does not have a medical facility, and the closest clinic is in Quilcene and supported by Jefferson General Hospital. PHMPR is required to provide on-site clinic space staffed by a qualified provider paid and equipped by the Resort, training Resort staff to First Responder level or better, certifying Resort staff for other emergency medical response support, pursuing EMT-B and/or EMT-1 training in partnership with Jefferson Healthcare, providing community support as needed, relationship-building with local EMS staff, and providing a location for a helicopter landing zone. The helicopter landing zone is identified on the project plans and can be adequately accommodated (Exhibit 33). The MOU provides sufficient mitigation and there are no other design implications to be further analyzed for preliminary plat. 159. Parks and recreation impacts are mitigated through an MOU with Jefferson County. PHMPR is required to prominently post information for all park and recreation services, provide a shuttle to nearby park and recreation facilities from June to September annually, allow Brinnon residents free access to passive facilities on the property, allow the participation or rental of active and indoor facilities for a reasonable fee, and allow access to Resort amenities by Jefferson County parks and Recreation programs for a nominal fee. The MOU provides adequate mitigation and there are no design implications to be further analyzed for preliminary plat. F. Archaeological, Cultural, and Historic Resources 160. The Port Gamble S’Klallam Tribe, Jamestown S’Klallam Tribe, and their consortium, the Point No Point Treaty Council (PNPTC), have been involved in and commented on the project at numerous points in its decades-long history. In the PNPTC’s August 15, 2024, letter (Exhibit 66F), the following major concerns were identified: a. Shellfish Resources Protection and Management. The resort is located between public beaches on the Duckabush and Dosewallips Rivers, which provide significant commercial, ceremonial, and subsistence harvest opportunities to Tribes. An increase in visitors and recreational use will increase harvest pressure, and water quality degradation could be caused by stormwater runoff at the resort. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 87 of 117 b. Water Quality Protection and Management. A water quality and shellfish protection plan with adaptive management measures to protect shellfish resources should be adopted. c. Revisions to Project Management Plan. The project management plan should be revised to eliminate the use of persistent pollutants and replace them with substances allowed for use under the agricultural national organic program. d. Urbanization. Urbanization of the area will increase the prevalence of pollutants in a rural area, negatively impacting fish and shellfish resources. e. Wildlife Protection and Habitat Management Plan. The Wildlife Management Plan does not adequately exclude elk from the property. f. Cultural Resources Protection and Stewardship. Kettles B and C and adjacent wetlands should be preserved for traditional property evaluation and protection of natural resources. The kettles should not be used for stormwater or wastewater management. Greater coordination should occur with Tribal Historic Preservation Officers (THPOs). g. Incorporation of Tribal Comments. The Port Gamble S’Klallam Tribe provided a detailed list of concerns and issues that were not incorporated into the Development Agreement and current project proposal. 161. Jefferson County provided a comprehensive response to the PNPTC’s comment letter on November 13, 2024 (Exhibit 69), including several appendices related to prior documents, decisions, and correspondence. The County’s response letter provides detailed information about Jefferson County’s position with respect to each comment in the PNPTC, environmental analysis conducted, regulations in place, and other commentary. In particular: a. Significant improvements have been made to the project proposal, development regulations, and Development Agreement as a result of Tribal participation. This includes reducing the golf course from 18 holes to nine holes, increasing protections for the kettles in the Development Agreement, and improving water quality monitoring and best management practices requirements, among others. b. As part of the Development Agreement, the project is required to conduct periodic surface water and groundwater quality monitoring, and to follow best management practices and an adaptive management program to ensure no violation of water quality criteria occurs (Appendix N to the Development Agreement and Appendix 1 to Amendment 1 to the FS&CA). c. The project is required to use the Best Management Practices for Golf Course Design and Management Practices (Appendix H to the FSEIS) and King County’s Best Management Practices for Golf Course Development and Operation in selecting, using, and storing chemicals for maintaining the golf course fairways. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 88 of 117 d. The Applicant has indicated they prefer a greater extent of fencing to exclude elk in lieu of flashing signage tied to electronic elk collars. According to WDFW and the Tribes, the elk collars are no longer being maintained, and flashing signage will not address wildlife-human interactions. Extended fencing is consistent with the Tribes’ request to more fully physically exclude elk from the property. e. The County is bound by prior decisions in the implementation of the Development Agreement. Preservation of Kettle B is greater than the minimum required. Listing of the property in the State or National Register of Historic Places does not impose any obligation on a property owner or restrict the owner’s rights to develop the property, and the protections in the Development Agreement are greater than could be expected solely from eligibility for listing in a Register. 162. Jefferson County has previously and continuously responded to the Port Gamble S’Klallam Tribe, Jamestown S’Klallam Tribe, and PNPTC’s comments. An appropriate level of review was performed at each stage of the project’s development and the Development Agreement and development regulations apply appropriate protections to address the concerns of the Tribes and PNPTC. 163. A primary concern not otherwise addressed is the exclusion of elk from the golf resort. The Wildlife Management Plan (Appendix P to the Development Agreement) addresses management strategies for deer, Roosevelt elk, cougar, bears, waterfowl, osprey, and eagles. The Tribes and PNPTC indicated that wildlife management strategies for elk are insufficient and are concerned that elk entering or remaining on the property will impact the Tribes’ ability to exercise their hunting rights. The methods identified in the Wildlife Management Plan include escalating strategies as follows: a. Scare tactics consisting of visual, auditory, and olfactory deterrents. The Wildlife management plan notes these are considered temporary because the animals will get used to them with repeated exposure. b. Flashing signage associated with collared elk in the resident herds. c. Installation of a west-oriented fence in any open areas where elk could access golf course fairways for browse. The wildlife management plan states that this will be installed as a method of last resort, and only if there are more than four elk on the property at one time after the implementation of scare tactics. WDFW does not maintain electronic collars on elk in either of the resident herds in the project vicinity (Exhibit 67I) but notes that collars exist and are the property of the PNPTC. Tribal staff have indicated that the collars are no longer being maintained, and warning signage will be ineffective. The Applicant has verbally stated a preference to install the fence during initial development in lieu of the flashing signage.77 This is adequate to fulfill the escalating requirements in the Wildlife Management Plan as well 77 Verbal discussion with Applicant. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 89 of 117 as satisfy Tribal concerns related to excluding elk from the property. A condition will require the installation of the elk fence with preliminary facilities. [CONDITION 15] 164. The project contains areas identified by the Port Gamble S’Klallam Tribe, Jamestown S’Klallam Tribe, and Point No Point Treaty Council as culturally significant and the requirements in JCC 18.30.160 apply to the project. 165. Pursuant to JCC 18.30.160(1), development activity is not allowed until the property has been inspected and a written evaluation is provided by a qualified archaeologist. Archaeological investigation was conducted and reported in 2006 in the Cultural Resources Assessment for the Proposed Pleasant Harbor Marina and Golf Resort by Camille Mather of Cultural Resource Consultants, Inc., and in 2008 in the 2008 Archaeological Monitoring of Geotechnical Explorations for the Pleasant Harbor Golf Resort by Margaret Berger of Cultural Resource Consultants, Inc. These documents were reviewed with the FSEIS.78 These investigations did not find any prehistoric or historic archaeological resources. 166. An Archaeological Monitoring and Inadvertent Discovery Protocol is included as Appendix Q to the Development Agreement. Adherence to this document is required during any ground-disturbing activities, consistent with JCC 18.30.160(2). 167. The Port Gamble S’Klallam Tribe submitted a Traditional Cultural Properties form to the Washington State Department of Archaeology and Historic Preservation (DAHP) in 2018. To the best of County Staff’s ability to discern, the process to determine eligibility for listing on the State or National Registers of Historic Places was not completed.79 County Staff understands that the subject of the Traditional Cultural Properties form was primarily the two geologic kettles present on the property. Under Ord. No. 01-0128-08, the possibility of preserving one of the two kettles was considered and memorialized in Condition 63(h) (Appendix K to the Development Agreement). The project design will preserve Kettle B intact even though neither kettle was required to be preserved and neither kettle has been determined to be eligible for listing in a state or national register. The project is consistent with JCC 18.30.160(3), which requires development adjacent to sites which are listed or eligible for listing in a state or national register to be located so as to complement the historic site and prohibits development that degrades or destroys the historic character of the property. Further, the Applicant has been in communication with representatives from the Port Gamble S’Klallam Tribe, the Jamestown S’Klallam Tribe, the Point No Point Treaty Council, and the Skokomish Tribe to participate in a collaborative effort to install educational signage about cultural history and significance (Exhibit 42). G. Phasing 168. The components in each phase of development are set forth in Section 10 of the Development Agreement, which was replaced entirely in Amendment 2 to the 78 3.13 Cultural And Archaeological Resources. FSEIS Chapter 3.13, pp. 13.13 -1-4. 79 County staff requested information from the Port Gamble S’Klallam Tribe, Jamestown S’Klallam Tribe, and Point No Point Treaty Council and from DAHP staff, but as of the date of this report, no information was provided by any entity. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 90 of 117 Development Agreement as a result of Kitsap County Superior Court’s decision in The Brinnon Group v. Jefferson County and Pleasant Harbor Marina and Golf Resort, LLP on March 28, 2019.80 This decision resulted from a Land Use Petition Act appeal on the original Development Agreement. The decision upheld Jefferson County’s decision to approve the Development Agreement, except for the phasing plan in the Development Agreement. The revised phasing plan (Sec. 10.1.1 in the Development Agreement as amended) states: Pleasant Harbor MPR is a planned resort that is capable of being developed in independent and severable components or “phases.” Future development of the Pleasant Harbor MPR and all associated infrastructure, including roads and utilities, may be reviewed, permitted, and constructed and/or bonded in phases or sub-phases. A phasing plan (consisting of three phases) for development of the Pleasant Harbor MPR is attached as Exhibit 4. Each phase may further be broken down into discrete sub-phases as conditions dictate, but each primary phased [sic] must be constructed in the order set forth [in Sec. 10 of the Development Agreement].” 169. Section 10.1.2 of the Development Agreement (as amended) states that the developer will comply with JCC 18.35.135 which, at the time the Development Agreement was prepared, stated “if a master planned resort will be phased, each phase must contain adequate infrastructure, open space, recreational facilities, landscaping, and all other conditions” sufficient to stand alone if no subsequent phases are developed. PHMPR is required to complete or bond all necessary infrastructure to support a phase or sub-phase sufficient for that phase or sub-phase to stand alone, prior to obtaining approval for a subsequent phase. Based on Sections 10.1.1 and 10.1.2 of the Development Agreement (as amended), phasing is allowed but is not mandatory; if the project is phased, it must follow the phasing plan as adopted in Amendment 2 to the Development Agreement. The phasing plan includes: a. Phase 1: Preliminary site infrastructure and resort amenities. i. Sub-Phase 1a: 1. Site clearing, grading, and construction of the golf course, road network, building footprints, and stormwater storage 2. US Highway 101 and Black Point Road intersection improvements 3. Wastewater treatment plant 4. Road construction with services 5. Begin implementation of the vegetation management plan 6. Create construction materials processing location ii. Sub-Phase 1b: 1. Construction of the LOSS drainfield81 (wastewater treatment plant backup system) 2. Water storage tank with distribution piping 3. Transit stop 80 Brinnon Group v. Jefferson County and Pleasant Harbor Marina and Golf Resort, LLP, Kitsap County Superior Court, No. 18-2-01758-18. 81 The large on-site septic system is no longer included in the project proposal. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 91 of 117 4. Sanitary sewer pump stations 5. Sea View Villas (up to 162 units)82 6. Golf Vistas (up to 90 units)83 7. Community/Recreation Center 8. Conference Center/spa (including 208 units, spa services, pool, water slides, commercial space, and sports courts) 9. Maintenance building (also identified as the AgraCenter) 10. Staff housing 11. Form Pleasant Harbor Utility District iii. The following public amenities must be provided in Phase 1 and made available to the general public for a fee to be established by the Developer: 1. Nine-hole golf course 2. Spa services 3. Sports courts 4. Pool 5. Water slides 6. Community Center/Recreation Center b. Phase 2: Additional residential units and commercial space. i. Maritime Village building (66 units and 21,000 square feet of commercial space) ii. Golf Terrace halfway house (172 units) (now Cascadia House, Olympia House, or Eagle’s Nest Condominiums) iii. New water well iv. Sea View Villas and Golf Vistas (see Sub-Phase 1b) v. Black Point Road reconstruction and access to WDFW boat launch c. Phase 3: Remaining residential units. i. Golf Terrace (140 units) (now Cascadia House, Olympia House, or Eagle’s Nest condominiums) ii. Remaining Sea View Villas and Golf Vistas 170. With changes to the types of housing units provided (eliminating/reducing semi- attached and detached Sea View Villa and Golf Vista units and increasing condominium/multifamily units), compliance with section 10 of the Development Agreement (as amended) will be determined by total units assigned to each phase, rather than named project components. Section 10 of the Development Agreement (as amended) sets forth phasing requirements consistent with JCC 18.35.330. [CONDITION 6] 82 These units will be constructed during all phases and the number of units constructed in each phase may vary. Phase 1 shall not be deemed complete until and unless all other improvements in Phase 1 are complete. 83 These units will be constructed during all phases and the number of units constructed in each phase may vary. Phase 1 shall not be deemed complete until and unless all other improvements in Phase 1 are complete. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 92 of 117 171. In addition to the infrastructure and facilities specifically described above, section 10.2 of the Development Agreement (as amended) requires that each phase must include “adequate preliminary facilities” to service each phase. Preliminary facilities include: water system, wastewater treatment system, road network, landscaping, and parking. Jefferson County’s approval of a phase or sub-phase must include review the preliminary facilities for the entire phase. This review can occur at with the preliminary plat or with future permits and authorizations. Per section 10.2.6, a final plat may be recorded only if all the preliminary facilities necessary to serve the lots and tracts in the plat are complete. 172. Phasing is also addressed in the applicable land division regulations, JCC 18.35.330 (set forth in Appendix D to the Development Agreement). Pursuant to this section where phasing is proposed, preliminary plat approval must be granted for the entire subdivision. The plat includes the following project note: “Delineation of Phases: Section 10 of the Development Agreement and Exhibit 4 delineate the required components for phased final plat approval of the subdivision. As required by JCC 18.35.330 and JCC 18.35.660, phased final plat approval of the subdivision shall be conditioned upon completion of the proposed phases in the order described in Section 10 of the Development Agreement and revised Exhibit 4 approved in Ordinance No. 08- 0722-19. The Applicant has satisfied minimum requirements to include the entire development in the preliminary plat and section 10 of the Development Agreement (as amended) delineates phases. 173. Compliance with the phasing plan in section 10 of the Development Agreement (as amended) will be verified with construction permits for infrastructure to be built between preliminary and final plat phases, and with construction permits for the preliminary facilities, resort amenities, and residential units. Final plat approval for any phase will not be granted until section 10.2 of the Development Agreement (as amended) is satisfied. SECTION 8. Approval Criteria—Proposed Findings and Conclusions A. JCC 18.40.280(2) requires this staff report to include proposed findings, conclusions, and recommendations for disposition of the development application (the proposed preliminary plat application). This Section 8 of this Staff Report provides the proposed findings and conclusions. Section 10 of this Staff Report provides the proposed recommendation and conditions. B. JCC 18.35.310 establishes review criteria or long subdivisions. The project is vested to the version of Chapter 18.35 JCC in effect when the Development Agreement was Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 93 of 117 executed, and these regulations are included in Appendix D to the Development Agreement.84 The applicable review criteria are: 1. Long subdivisions shall be given preliminary approval, including preliminary approval subject to conditions, upon finding by the county that all of the following have been satisfied: a. The proposed subdivision conforms to all applicable county, state and federal zoning, land use, environmental and health regulations, and plans, including, but not limited to, the following: i. The Jefferson County Comprehensive Plan; and ii. The provisions of this code, including any incorporated standards. STAFF FINDINGS: As described in Section 7.A of this Staff Report, the project is consistent with and implements the Jefferson County Comprehensive Plan, including the Brinnon Subarea Plan, as required in section 8.2 of the Development Agreement.85 The Comprehensive Plan establishes, at a policy level, that a master planned resort should be located on the Black Point peninsula. The project advances goals related to expanding urban-level development and infrastructure in master planned resorts and implementing policies crafted to guide development of master planned resorts. The BOCC, in its findings for Ord. No. 01-0128-08, determined that the project is consistent with the Comprehensive Plan, in particular Land Use Policies 24.1-24.13, and each of the criteria applicable to the proposal had been met. The BOCC further found that the project is consistent with the Brinnon Subarea Plan, Goal 1.0, and Policies 1.1-1.3, and each of the criteria applicable to the proposal had been met. As further documented in Section 7.B of this Staff Report, with conditions the project complies or will comply with applicable zoning, land use, environmental, and health regulations. The project consists of land divisions to support master planned resort uses. Environmental (SEPA) review was completed at a programmatic and at a project level with the FEIS and FSEIS, and with conditions the project will meet applicable development thresholds. Further environmental analysis was performed to evaluate critical areas, including critical aquifer recharge areas, geologically hazardous areas, and wetlands, and with conditions the project will meet applicable standards for development near these areas. The project is designed to and, with conditions, will protect public health through provision of appropriate utilities, drainage, roadway design, and other features. b. Utilities and other public services necessary to serve the needs of the proposed subdivision shall be made available, including open spaces, drainage ways, roads, streets, other public ways, potable water, transit 84 Development Agreement section 8.5. 85 This section requires that the Comprehensive Plan in effect on the date the Development Agreement was executed serves as the policy guidance and foundation for project development. The applicable plan is the 2004 -2017 Comprehensive Plan. The Brinnon Subarea Plan is adopted as part of the Comprehensive Plan and is unchanged since its amendment in 2004. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 94 of 117 facilities, sewage disposal, parks, playgrounds, schools, sidewalks and other improvements that assure safe walking conditions for students who walk to and from school. STAFF FINDINGS: As conditioned, the project has provided for utilities and other public services necessary to serve the needs of the proposed project proposal and to mitigate its impact on the surrounding community. PHMPR will establish the Pleasant Harbor Utility District to own, manage, and maintain the Pleasant Harbor Water System and Pleasant Harbor Wastewater System. A draft WSP and WWSP have been provided, and the WWSP has received approval from DOE. WSP plan approval will be required as a condition of approval prior to issuing construction permits for infrastructure and WSP will include resolution of the deficiency in total domestic water availability to DOE’s satisfaction. Stormwater management will comply with the 2024 SWMMWW and a Drainage Report has been prepared with proposed facilities that provide the necessary detention, flow control, and water quality treatment. An internal transportation network allowing for vehicular, pedestrian, bicycle, and golf cart access has been provided, and road sections will be amended to address safety for non- vehicular modes. The transportation network has been designed to ensure safe walking conditions for students that may be present on the property. The project includes substantial open spaces and resort amenity facilities throughout the property that provide wildlife habitat conservation as well as recreational opportunities. Memoranda of Understanding have been executed with BSD, BFD, JCSO, Jefferson Transit Authority, Jefferson Healthcare, and Jefferson County (for housing and parks and recreation) to satisfy applicable requirements in Ord. No. 01-0128-08 and the FEIS and FSEIS. Conditions of approval are recommended to ensure the proposed facilities and necessary services are adequate and consistent with applicable code requirements and standards. With conditions, the project has made available utilities and other public services. c. The probable significant adverse environmental impacts of the proposed subdivision, together with any practical means of mitigating adverse impacts, have been considered such that the proposal will not have an unacceptable adverse effect upon the quality of the environment, in accordance with the State Environmental Policy Act (SEPA) implementing provisions contained within Chapter 18.40 JCC and Chapter 43.21C RCW. STAFF FINDINGS: As described in Section 6.E of this Staff Report, a programmatic FEIS was issued in 2007 and a project-level FSEIS was issued in 2015 to evaluate the proposal. The FEIS and FSEIS evaluated potential probably significant adverse environmental impacts and recommended mitigation measures. Compliance with the mitigation measures is mandatory pursuant to JCC 17.60.060. As described in Section 7.B of this Staff Report, the project has incorporated the required mitigation measures or, with conditions, will meet the mitigation measures set forth in the FEIS and FSEIS. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 95 of 117 The probable significant adverse environmental impacts of the proposed subdivision, together with any practical means of mitigating adverse impacts, have been considered such that the proposal will not have an unacceptable adverse effect upon the quality of the environment, in accordance with the State Environmental Policy Act (SEPA) implementing provisions contained within Chapter 18.40 JCC and Chapter 43.21C RCW. d. Approving the proposed subdivision will serve the public use and interest and adequate provision has been made for the public health, safety, and general welfare. STAFF FINDINGS: The project as proposed and conditioned advances the public use and interest and makes adequate provision for public health, safety, and general welfare. The project is consistent with the Jefferson County Comprehensive Plan, a document that safeguards the public interest and public health, safety, and general welfare at a policy level. The project is also consistent with the Brinnon Subarea Plan, which focuses on the public use, interest, health, safety, and general welfare of the Brinnon community at a policy level. The Jefferson County Comprehensive Plan and the Brinnon Subarea Plan are implemented by the development regulations set forth in the Jefferson County Code, including Titles 17 and 18. With its basis in Title 18 JCC, the development agreement also implements the Jefferson County Comprehensive Plan and the Brinnon Subarea Plan. With conditions, the proposed land division meets applicable standards and policies in place to serve the public use and interest and protect the public health, safety, and general welfare. STAFF FINDINGS: The project proposal has satisfied the conditions related to Comprehensive Plan consistency; land use, zoning, environmental, and public health regulations consistency; adequate provision of utilities and public services to support the development; SEPA review and incorporation of required mitigation measures; protection of the public use and interest; and adequate provision for the public health, safety, and general welfare. 2. Notwithstanding approval criteria set forth in subsection (1) of this section, in accordance with RCW 58.17.120, as now adopted and hereafter amended, a proposed subdivision may be denied because of flood, inundation or swamp conditions. Where any portion of the proposed subdivision lies within both a flood control zone, as specified by Chapter 86.16 RCW, and either the 100-year floodplain or the regulatory floodway, the county shall not approve the preliminary plat unless: (a) The applicant has demonstrated to the satisfaction of the hearing examiner that no feasible alternative exists to locating lots and building envelopes within the 100-year floodplain; and (b) It imposes a condition requiring the applicant to comply with Article VI-F of Chapter 18.15 JCC86 and any written recommendations of the Washington State Department of Ecology. In such 86 Chapter 18.15 JCC was recodified into Chapter 18.22 JCC. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 96 of 117 cases, the county shall issue no development permit associated with the proposed short subdivision until flood control problems have been resolved. STAFF FINDINGS: The project is not located within a flood control zone, 100- year floodplain, or regulatory floodway. The criteria in this section do not apply. 3. Pursuant to RCW 86.56.345 current year and any delinquent taxes must be paid before approval of any subdivision. STAFF FINDINGS: As of the date of this Staff Report, all properties are current on taxes. Property tax payments will be verified prior to final plat approval. C. JCC 18.40.280(5) also includes applicable review criteria. This section specifies that, in addition to the approval criteria listed elsewhere in the Unified Development Code, the hearing examiner shall not approve a proposed development unless he/she first makes the following findings and conclusions: 1. The development adequately mitigates impacts identified under Articles VI-D through VI-I of Chapter 18.15 JCC87 (i.e., environmentally sensitive areas) and Article X of [Chapter 18.40 JCC] (i.e., SEPA implementing provisions). STAFF FINDINGS: Articles VI-D through VI-I of Chapter 18.15 formerly contained regulations for Environmentally Sensitive Areas District Overlays, but were repealed in 2008. Environmentally sensitive areas regulations were codified in Chapter 18.22 JCC at that time. The project is vested under Section 8.4 of the Development Agreement to the critical areas standards that were in place when the Development Agreement was executed, adopted as Appendix C to the Development Agreement. As described in Section 7.B of this Staff Report, the project has provided reports and other information to investigate and characterize the variety of environmentally sensitive (critical) areas present on the subject property and to review and analyze the proposal and potential impacts therefrom. With conditions, the project meets applicable standards for development in or near critical areas and their buffers. As described in Section 6.E of this Staff Report, the project was reviewed under SEPA at a programmatic level in 2007 and at a project-specific level in 2015. The FEIS and FSEIS contain mitigation measures that must be implemented to achieve no significant adverse environmental impact. Adherence to mitigation measures is mandatory pursuant to JCC 17.60.060(2) and enforceable through Title 19 of the Jefferson County Code. Section 7.B of this Staff Report documents the incorporation of SEPA mitigation measures where appropriate to the preliminary plat. Future analysis of compliance with applicable SEPA mitigation measures is required in all phases of permitting, land division, and project development and operation. With conditions, the project has addressed environmental impacts and SEPA mitigation measures appropriate to this stage of project review. 87 Chapter 18.15 JCC was recodified into Chapter 18.22 JCC. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 97 of 117 2. The development is consistent with the Jefferson County Comprehensive Plan and meets the requirements and intent of this Unified Development Code. STAFF FINDINGS: Compliance with the Jefferson County Comprehensive Plan, the Brinnon Subarea Plan, and applicable development standards in the Jefferson County Code are discussed in Section 8.B of this Staff Report. As noted in the Staff Findings in that Section 8.B, the project is consistent with and implements the Jefferson County Comprehensive Plan and the Brinnon Subarea Plan, per the analysis in Section 7.A of this Staff Report. With conditions, the project is also consistent with applicable development standards in the Jefferson County Code, as documented in the analysis in Section 7.B of this Staff Report. 3. The development is not detrimental to the public health, safety, and welfare. STAFF FINDINGS: The project is being developed under applicable codes and standards set forth in the Jefferson County Code, the Development Agreement (including Amendment 1 and Amendment 2), and the FS&CA (including Amendment 1). These codes and standards were adopted to protect the public health, safety, and welfare and development consistent with the codes and standards is presumed to be not detrimental to the public health, safety, and welfare. Further, the project was reviewed under a FEIS and FSEIS and is required pursuant to JCC 17.60.060(2) to implement the mitigation measures identified therein. This includes measures to eliminate and/or mitigate potential impacts such that there are no adverse impacts to the public health, safety, and welfare. 4. For subdivision applications, findings and conclusions shall be issued in conformance with Chapter 18.35 JCC and RCW 58.17.110.88 STAFF FINDINGS: The proposal is for a preliminary subdivision. Staff findings and conclusions for Chapter 18.35 JCC are provided in Subsection 8.B and are not duplicated here. RCW 58.17.110(2) requires the County to make written findings that: (a) Appropriate provisions are made for the public health, safety, and general welfare and for such open spaces, drainage ways, streets or roads, alleys, other public ways, transit stops, potable water supplies, sanitary wastes, parks and recreation, playgrounds, schools and schoolgrounds and all other relevant facts, including sidewalks and other planning features that assure safe walking conditions for students who only walk to and from school; and 88 These criteria apply to preliminary subdivision applications. Preliminary subdivision applications are Type III processes decided by the Hearing Examiner. Final subdivisions are Type IV applications decided by the Board of County Commissioners. The Hearing Examiner is required to make findings with respect to the criteria in RCW 58.17.110; therefore these criteria must be considered in the Hearing Examiner’s review and decision -making processes. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 98 of 117 (b) The public use and interest will be served by the platting of such subdivision and dedication. If it finds that the proposed subdivision and dedication make such appropriate provisions and that the public use and interest will be served, then the legislative body shall approve the proposed subdivision and dedication. With respect to RCW 58.17.110(2)(a), the project has made adequate provisions for the public health, safety, and welfare. The project, as conditioned, is in general conformance with applicable plans, policies, codes, standards, and the Development Agreement (including Amendment 1 and Amendment 2). The project design includes adequate provision of open spaces, drainage ways, streets and roads, other public and private ways, potable water supplies, sanitary wastes, parks and recreation, and playgrounds. An MOU with the BSD makes adequate provision for schools and schoolgrounds. Separate walking paths are proposed and will support safe walking routes for children. Compliance with specific standards and criteria will occur with each construction permit. With respect to RCW 58.17.110(2)(b), the public use and interest is served by platting the subdivision. The proposal, as conditioned, implements the Jefferson County Comprehensive Plan and the Brinnon Subarea Plan, which both identify a master planned resort on Black Point. The project will be developed in accordance with applicable standards in the Jefferson County Code, the Development Agreement (including Amendment 1 and Amendment 2), the FS&CA (including Amendment 1), and the mitigation measures in the FEIS and FSEIS to protect the public health, welfare, and safety. The project will provide additional amenities accessible both to local residents in the Brinnon community as well as contributions to Jefferson County quality of life and economic prospects. This will be verified as appropriate with construction permits. Findings and conclusions documenting satisfaction of the criteria in RCW 58.17.110 are required for the final plat. D. Staff concludes that, as conditioned, the proposal meets the goals, policies, and implementation recommendations and requirements set forth in the applicable Jefferson County Comprehensive Plan, Brinnon Subarea Plan, Development Agreement (including Amendment 1 and Amendment 2) with exhibits and appendices, Jefferson County Code, and the FS&CA (including Amendment 1). E. Staff concludes that, as conditioned, the proposal is consistent with applicable Federal and State laws and regulations, to the extent that Jefferson County can make such a determination. F. Staff concludes that, as conditioned, the public use and interest are served by approving the proposal and that the proposal makes adequate provisions for the public health, safety, and general welfare. The proposed preliminary plat addresses the relevant factors to be considered. Appropriate provisions are made for potable water supply, sanitary waste, and other utilities, streets, open spaces, and drainage ways. Impacts to Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 99 of 117 schools, transit, parks and recreation facilities, emergency services, police, and healthcare have been identified and mitigated. Sidewalks provide safe walking routes to school bus stops in the event that school-aged children live on the property. SECTION 9. Public Comments, Intergovernmental (Tribal) Consultation, Interjurisdictional and Interagency Coordination, and Responses Public comments were submitted prior to the Notice of Application, during the Notice of Application public comment period, and after the Notice of Application public comment period. Comments are briefly summarized below, and can be found in full in Exhibits 65-67 (including sub-parts). Name Summary of Comments and County Action Richard Aramburu On behalf of The Brinnon Group 705 2nd Avenue, Ste 1300 Seattle, WA 98104 September 6, 2023 See Exhibit 65A This document was referenced in Mr. Aramburu’s May 21, 2025 letter. It was submitted prior to the application submittal and the County did not provide a formal response. Richard Aramburu On behalf of The Brinnon Group 705 2nd Avenue, Ste 1300 Seattle, WA 98104 February 2, 2024 See Exhibit 65B Summary of Comments: The preliminary plat application is inconsistent with the Development Agreement and is missing information about preliminary facilities and required amenities. The project owner has a history of unfulfilled promises for future amenities with other development projects. PHMPR appears to be engaging in illegal pre-sale activities, with inaccurate project information. Comments request the denial of the application and Jefferson County Prosecuting Attorney’s Office to immediately commence enforcement actions to prevent pre-sales. County Action: Comments provided to Applicant. Consolidated response from Jefferson County to Mr. Aramburu and Mr. Best sent April 16, 2024 (Exhibit 68) Phil Best Hood Canal Environmental Council PO Box 87 Seabeck, WA 98380 Summary of Comments: Request for Jefferson County to decline review of the application and to prevent illegal pre-sales. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 100 of 117 Name Summary of Comments and County Action February 7, 2024 See Exhibit 65C Endorses the February 2, 2024, letter from Richard Aramburu on behalf of the Brinnon Group. County Action: Comments provided to Applicant. Consolidated response to Mr. Aramburu and Mr. Best sent April 16, 2024 (Exhibit 68) Alex Scagliotti Jamestown S’Klallam Tribe 1033 Old Blyn Highway Sequim, WA 98382 May 8, 2024 See Exhibit 66A Summary of Comments: Request for extension of public comment period. County Action: Extension declined pursuant to JCC 18.40.220(1). Comments have been continually accepted from the Notice of Application until the Hearing Examiner closes the project record. Cynthia Rossi Point No Point Treaty Council 19472 Powder Hill Place NE, Ste. 210 Poulsbo WA 98370 May 10, 2024 See Exhibit 66B Summary of Comments: Request for technical (project review) meeting and extension of public comment period. County Action: Extension declined pursuant to JCC 18.40.220(1). Comments have been continually accepted from the Notice of Application until the Hearing Examiner closes the project record. Technical meetings have been held approximately monthly from June 2024 through August 2025. Theresa Crowell 240 Robinson Road Brinnon, WA 98320 May 15, 2024 See Exhibit 65D Summary of Comments: Saltwater intrusion affecting aquifer/residential well. County Action: Comments provided to Applicant. Comments considered in technical review; saltwater intrusion was evaluated with the FEIS and FSEIS and a neighborhood water policy was incorporated into the Development Agreement. Andrew Larson, PE WSDOT 310 Maple Park Avenue SE PO Box 47300 Olympia, WA 98504 May 15, 2024 See Exhibit 67A Summary of Comments: Request for updated TIA. County Action: Comments provided to Applicant for follow up. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 101 of 117 Name Summary of Comments and County Action Matthew Iles-Shih No address provided. May 18, 2024 See Exhibit 65E Summary of Comments: Request for clarification of perimeter fencing, noting that fencing along the east side of the property will disrupt wildlife habitat and behavior. Request for clarification of stormwater management requirements, noting “Storm Pond #5” at the northeastern border could accumulate pollution that may impact water quality in the aquifer. Request for information about protecting the aquifer and surface water with respect to other potential sources of pollution (fertilizers and pesticides). Request for information about ongoing water quantity and quality management that may impact neighbors. County Action: Comments provided to Applicant. Comments considered in technical review; elk exclusion fencing and stormwater information were requested. Water quality was addressed in the FEIS and FEIS and a water quality monitoring plan was incorporated into the Development Agreement. Joan Hendricks 1592 Duckabush Road Brinnon, WA 98320 May 18, 2024 See Exhibit 65F Summary of Comments: Objection to project based on impacts to marine environment, lack of financial certainty, lack of information about US Highway 101/Black Point Road improvements, and lack of wastewater system plan information. Comments note the Pleasant Harbor Resort website is confusing. Comments note a concern about prior code violation related to logging. County Action: Comments provided to Applicant. Comments considered in technical review. Environmental impacts were analyzed in the FEIS and FSEIS. Cynthia Rossi Point No Point Treaty Council 19472 Powder Hill Place NE, Ste. 210 Poulsbo WA 98370 Summary of Comments: Objection to project based on impacts to shellfish resources, wildlife habitat, water quality, and cultural resources. Concerns center on Tribal treaty rights Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 102 of 117 Name Summary of Comments and County Action May 20, 2024 See Exhibit 66C and the use of resources for cultural, economic, and subsistence purposes by members of the Tribes. Comments note that prior Tribal comments were not incorporated into the Development Agreement for the project. County Action: Comments provided to Applicant. Technical meetings have been held approximately monthly from June 2024 through August 2025 to discuss Tribal concerns. Comments considered in technical review. Marla Powers Port Gamble S’Klallam Tribe 31912 Little Boston Road NE Kingston, WA 98346 May 21, 2024 See Exhibit 66D Summary of Comments: Copy of comment letter dated August 9, 2017, from the late Port Gamble S’Klallam Tribe Chair Jeromy Sullivan, incorporated by reference. August 9, 2017, letter objects to the project based on impacts to cultural resources, water quality, adjacent properties (due to design and allowable density, and related impacts), and wildlife resources. Concerns center on Tribal treaty rights and the use of resources for cultural, economic, and subsistence purposes by members of the Tribes. August 9, 2017, letter notes that consultation has been flawed. County Action: Comments provided to Applicant. Technical meetings have been held approximately monthly from June 2024 through August 2025 to discuss Tribal concerns. Comments considered in technical review. Alex Scagliotti Jamestown S’Klallam Tribe 1033 Old Blyn Highway Sequim, WA 98382 May 21, 2024 See Exhibit 66E Summary of Comments: Stormwater design should clearly indicate how pollution will be controlled, including long-term monitoring plans, to protect shellfish resources. Wildlife management plan should include input from Tribal wildlife biologists, especially related to elk. Shellfish resources must be protected from impacts related to water quality and habitat degradation. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 103 of 117 Name Summary of Comments and County Action Cultural resources studies must be updated to include a traditional cultural property and cultural landscape study. County Action: Comments provided to Applicant. Technical meetings have been held approximately monthly from June 2024 through August 2025 to discuss Tribal concerns. Comments considered in technical review. Richard Aramburu On behalf of The Brinnon Group 705 2nd Avenue, Ste 1300 Seattle, WA 98104 May 21, 2024 See Exhibit 65G Summary of Comments: Objection to the project and request for denial of the application as not consistent with the Development Agreement or Washington State law. Landscape and vegetation management plans do not demonstrate adequate provisions for open space areas, and wildfire risk reduction is not addressed. The project does not comply with phasing requirements. The application lacks adequate information related to treatment and disposal of sanitary wastes. The application lacks information about adequate provision of potable water. The application lacks information about adequate fire flow. The “Sequence of Construction” information with the application does not reference phasing or timing with respect to the preliminary plat review process. Trees to be preserved have not been identified, and information about their species has not been provided. PHMPR appears to be engaging in illegal pre-sale activities, with inaccurate project information. Project financing is uncertain, as is financial responsibility for maintenance for each lot, condominium, and commercial building. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 104 of 117 Name Summary of Comments and County Action County Action: Comments provided to Applicant. Comments considered in technical review and information on landscaping, vegetation management, phasing, and fire flow was requested. Richard Aramburu On behalf of The Brinnon Group 705 2nd Avenue, Ste 1300 Seattle, WA 98104 August 22, 2024 See Exhibit 65H Summary of Comments: Objection to revising technical review comments. The original technical review comments were issued on July 3, 2024, and the revised technical review comments were issued on August 16, 2024. County Action: Comments provided to Applicant. Richard Aramburu On behalf of The Brinnon Group 705 2nd Avenue, Ste 1300 Seattle, WA 98104 January 22, 2025 See Exhibit 65I Summary of Comments: Request denial of preliminary plat application if it contains uses or structures not permissible in the underlying zoning. County Action: Comments provided to Applicant. No action taken as the proposed modular construction can be allowed. Kristin Masteller, General Manager Mason County PUD No. 1 N 21971 Highway 101 Shelton, WA 98584 January 3, 2025 See Exhibit 67B Summary of Comments: Statement of available power supply (0.5MW) and requirements for obtaining additional power for the project. County Action: Comments provided to Applicant. Comments considered in technical review and information on electric supply was requested. David Dougherty, PE Department of Ecology – Water Quality Program PO Box 47775 Olympia, WA 98504 January 6, 2025 – January 21, 2025 (email string) See Exhibit 67C Summary of Comments: Information on approval of wastewater treatment system plan. Statement of no further comment. Noted plans and specifications for the wastewater treatment system must still be provided to DOE for review and approval prior to issuing a permit for the wastewater treatment system. County Action: Comments provided to Applicant. Jeff Marti Department of Ecology – Water Resources Program Summary of Comments: Summary of available water rights (superseding water right permits G2-30436 and S2-3437) and Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 105 of 117 Name Summary of Comments and County Action PO Box 47775 Olympia, WA 98504 January 3, 2025 – January 8, 2025 (email string) See Exhibit 67D information about preliminary finding of whole or partial relinquishment of American Campground certificate of water right (G2-20465). County Action: Comments provided to Applicant. Additional water right/availability information requested. Andrew Larson, PE WSDOT 310 Maple Park Avenue SE PO Box 47300 Olympia, WA 98504 January 6, 2025 - January 10, 2025 (email string) See Exhibit 67E Summary of Comments: Summary of WSDOT’s review and permit requirements. County Action: Comments provided to Applicant. Acting Sheriff Andy Pernsteiner Jefferson County Sheriff’s Office 79 Elkins Road Port Hadlock, WA 98339 January 3, 2025 – January 17, 2025 (email string) See Exhibit 67F Summary of Comments: Statement of no concern. County Action: Comments provided to Applicant. Chief Tim Manly Brinnon Fire Department 272 School House Road PO Box 42 Brinnon, WA 98320 January 3, 2025 – February 7, 2025 (email string) See Exhibit 67G Summary of Comments: Statement of full support. Statement of no concern about proposed roadway width, adequacy for fire access, and implementation of Firewise site design standards. County Action: Comments provided to Applicant. Further consultation with Fire Marshal. Superintendent Patricia Beathard Brinnon School District 46 Schoolhouse Road Brinnon, WA 98320 January 3, 2025 – January 14, 2025 (email string) See Exhibit 67H Summary of Comments: Request for information about when housing will become available. Request for considering inflation in dollar amounts in MOU. County Action: Comments provided to Applicant. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 106 of 117 Name Summary of Comments and County Action Brian Calkins Washington Department of Fish and Wildlife 48 Devonshire Road Montesano, WA 98563 August 13, 2024 See Exhibit 67I Summary of Comments: Confirmation that WDFW does not maintain electronic elk collars and will not place new collars in the vicinity. County Action: Comments provided to Applicant. Comments considered in staff analysis and conditions related to elk exclusion fence recommended. Chris Tom, Vice Chairman Port Gamble S’Klallam Tribe W. Ron Allen, Chairman Jamestown S’Klallam Tribe Point No Point Treaty Council 19472 Powder Hill Place NE, Ste. 210 Poulsbo WA 98370 August 15, 2024 See Exhibit 66F Summary of Comments: Objection to project and process. Tribal comments have not been addressed. Concerns related to shellfish harvest pressure, water quality County Action: Detailed response provided by BOCC on November 13, 2024. Kristin Masteller, General Manager Mason County PUD No. 1 N 21971 Highway 101 Shelton, WA 98584 August 26, 2025 See Exhibit 67J Summary of Comments: Information on reception completion of power system capacity analysis and deposit for future reimbursement agreement. County Action: Comments considered in staff analysis. Alex Scagliotti Jamestown S’Klallam Tribe 1033 Old Blyn Highway Sequim, WA 98382 September 3, 2025 See Exhibit 66G Summary of Comments: Summary of Jamestown S’Klallam Tribe environmental staff’s concerns about the PHMPR project. Concerns relate to water quality/monitoring and reporting, wildlife management, and shellfish harvest pressure. County Action: Comments provided to Applicant for a written response/ Terence Germaine 104 Rhododendron Lane Brinnon, WA 98320 September 6, 2025 Summary of Comments: Objection to project. County Action: Comments provided to Applicant. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 107 of 117 Name Summary of Comments and County Action See Exhibit 65J SECTION 10. Staff Recommendation For this application, Staff recommends APPROVAL SUBJECT TO CONDITIONS. Staff recommends, based upon the application, plans, drawings, technical studies, and related materials and the analysis presented in this Staff Report, the following conditions be applied to the Pleasant Harbor Master Planned Resort (PHMPR) Preliminary Plat Application, case no. SUB2023-00025: Conditions Applicable to Preliminary Plat Expiration and Preparing the Final Plat 1. This preliminary approval of the plat shall expire five years from the date the preliminary approval becomes final pursuant to JCC 18.35.400 as set forth in Appendix D to the Development Agreement. 2. A Final Plat shall be submitted to Jefferson County in the form and manner prescribed in JCC 18.35.370 as set forth in Appendix D of the Development Agreement. The Final Plat shall be in substantial conformance with the lot and tract configuration and road layout and design set forth in Exhibit 33. Any modifications to the preliminary plat must be requested in writing and reviewed subject to the standards and procedure for minor and major modifications in JCC 18.35.340 as set forth in Appendix E to the Development Agreement. 3. The following shall be included on the final plat drawing, with final proposed text subject to approval by the Development Code Administrator or his designee: a. A statement that the subdivision has been made with the free consent and in accordance with the desire of the owner or owners. This shall include a signature block for the owner, whose signature shall be written and notarized on the final plat document once the document is accepted by Jefferson County as being ready for final approval and recording. b. A certificate giving a full and correct description of the lands divided as they appear on the final plat. c. Survey requirements consistent with WAC 332-130-050 and JCC 18.35.370 as set forth in Appendix D of the Development Agreement. d. Correct legal description of all new lots and tracts in the plat. e. New easements to be recorded with the final plat, including their legal descriptions and associated dedication blocks. f. Certificates for the Community Development Director, Public Works Director, and Board of County Commissioners signature block approvals. g. Certificate of Payment for Jefferson County taxes and assessments containing Assessor and Treasurer signature blocks. h. County Finance Manager signature block. i. Auditor’s recording certificate. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 108 of 117 j. If a financial institution appears on the title report at the time of final plat approval, the signature of an official authorized to sign on behalf of the financial institution’s interest shall be included on the final plat drawing. 4. The following shall be deleted from the final plat drawing: setback lines, conceptual building footprints (building envelopes shall be provided pursuant to JCC 18.35.370(3)(k)), street improvement details, and other items not relevant to the division of land and/or plat recording unless specified in JCC 18.35.370. 5. Plat Notes shall be revised as follows: a. Plat Note 24 shall read: Except as noted below, Lots 108-117 and Tracts C, X-3, X-4, and X-14 shall have a setback for all structures of 100 feet from the top of the steep slope indicated on the Plat Maps. Single- and multi-use paths, tee boxes, and stormwater conveyance facilities including berms, ditches, and swales shall have a setback of 30 feet from the top of the steep slope. b. Plat Note 25 shall read: Tract I, X-12, and X-14 shall have a setback of 20 feet from the outer boundary of the Master Planned Resort per JCC 17.65.040(1). c. Plat Note 28 shall read: All lots and tracts associated with this Plat of the Hamlet of Pleasant Harbor shall follow setback requirements set forth in JCC 17.65.040. d. A new Plat Note shall be added to read: The coastal bluff shall have 30-foot buffer from the top of the steep slope. No new structures shall be located within the buffer. Single- and multi-use paths, tee boxes, and stormwater conveyance facilities including berms, ditches, and swales, are allowed within the 100-foot setback from the top of the steep slope described in Plat Note 24, provided they are not located within the 30-foot buffer. The Applicant may make minor adjustments to the Plat Note language specified in this condition; provided, all plat note language will be reviewed by Jefferson County and determined acceptable prior to granting final plat approval. 6. Phased approval of the final plat is allowed pursuant to JCC 18.35.330. Section 10 and Exhibit 4 of the Development Agreement (as amended) delineate the phases of the subdivision that are to be developed in increments as required by JCC 18.35.330 and JCC 18.35.660. Submission of a final plat application for less than the entire area of the preliminary plat shall adhere to the delineation of phases, the order of phases, and all other requirements for phasing set forth in section 10 and Exhibit 4 of the Development Agreement (as amended). 7. A recent title report (dated within 30 days of the date of the application) and information on lot closures shall be provided with the application for final plat. 8. The Applicant shall obtain approval for the proposed road names within the plat. A Road Name Petition for each road shall be submitted to the Department of Community Development for review. Road Name Petitions shall be submitted with each application for final plat that includes an unnamed road. Approved road names shall be shown on the final plat drawing. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 109 of 117 9. The Applicant shall obtain addresses for each building and applicable structure as required pursuant to RCW 58.17.280. An Address Permit for each building or structure requiring an address shall be submitted to the Department of Community Development for review. Address Permits may be deferred to each applicable Building Permit for each building or structure requiring an address. Addresses obtained prior to final plat approval shall be shown on the final plat drawing. 10. Prior to approval and recording of the final plat, the applicant shall obtain approval from Jefferson County of the covenants, conditions, and restrictions. Additionally, the Parties agree to address residential cap issues and entry for maintenance and repair for stormwater facilities, roads, and other infrastructure. PHMPR and Jefferson County may enter into a separate Right of Entry agreement or similar legal instrument for these purposes. General Conditions of Approval 11. The project shall comply with the Development Agreement, as amended. 12. The project shall comply with applicable mitigation measures in the Master Plan for the development as described in Section 3.2 of the Development Agreement and JCC 17.60.040. The Master Plan requires compliance with the FEIS, FSEIS, Development Agreement (as amended), and Ord. No. 01-0128-08, all of which are incorporated as conditions of this preliminary plat approval. 13. The code interpretation for JCC 17.65.040 issued on August 26, 2025, and included in Exhibit 4 applies to this project. Setbacks in the MPR-GR zone shall be interpreted, applied, and administered consistent with this code interpretation. 14. PHMPR shall either revise the project proposal such that all lots and tracts accommodate the required interior lot line landscaping requirements set forth in JCC 18.30.130(5) or shall submit a request in writing to reduce the required screening landscaping between the proposed development and the adjacent Rural Residential zones. The written request shall address the approval criteria set forth in JCC 18.30.130(2)(b) in Appendix G to the Development Agreement and shall demonstrate how proposed landscaping will fulfill the intent of the required Screen-A landscaping with less than the required width. The written request may, at the sole discretion of the Development Code Administrator, require submittal of accompanying landscaping plans and/or details, including proposed species selection and sizing information. Actual landscape design shall be reviewed with construction permits and may be consolidated with or separate from review of the written request for reduction in screening landscaping. 15. PHMPR shall install the west-oriented fence identified in the Wildlife Management Plan’s (Appendix P to the Development Agreement) strategies for deterring elk from using the property in lieu of the installation of flashing signage. The fence shall be installed, at a minimum, along the westernmost property lines south of the main access road and north of the westernmost proposed residential neighborhood. In the event that the design of the plat changes between preliminary plat approval and final plat, the location and extent of the fence may be revised such that it excludes elk from golf course fairways and open space Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 110 of 117 that are attractive food sources. The fence shall meet or exceed the minimum requirements for height and materials set forth in the Wildlife Management Plan. The fence shall be installed with infrastructure and shall be complete and inspected prior to final plat approval. Conditions Applicable to Developing Infrastructure 16. PHMPR shall construct or bond the preliminary facilities consistent with section 10.2.1 through 10.2.5 of Amendment 2 to the Development Agreement prior to final plat approval. Transportation 17. Access easements from the Jefferson County road system to the subdivision shall be provided consistent with JCC 18.30.080. Easements shall be shown on the final plat. The final language of the easement(s) shall be provided to and approved by Jefferson County prior to final plat approval. 18. PHPMR shall establish an agreement for the continuing maintenance of private roads either by recording a separate instrument and referencing said instrument on the final plat or by declaring a maintenance agreement on the plat. The agreement shall be provided to and approved by Jefferson County prior to final plat approval. 19. Any proposed release of Old Black Point Road requires recording a formal release of easement after review and approval by Jefferson County. Nothing in this Decision shall be construed to have reviewed or approved release of Old Black Point Road or any other County-owned public ingress and egress/road easement. 20. The main entrance intersection shall include pedestrian and bicycle access, including any appropriate intersection control, sufficient to connect the preliminary plat to future development in the Maritime Village zone and to the Pleasant Harbor Marina zone. Such pedestrian and bicycle access shall be designed to satisfy the transportation mitigation measures set forth in the FEIS. 21. The secondary entrance on the east side of the property shall be designed and maintained to provide fire access in perpetuity. Construction permits for the driveway shall demonstrate, to the Fire Marshal’s satisfaction, the ability of the road to support the weight of fire apparatus that may be needed in an emergency, including but not limited to a ladder truck. If access through this entrance will be limited by a gate or similar means, the Fire Marshal shall review any proposed gates or other means of limiting access and PHMPR shall work with the Fire Marshal during construction permit review to determine an appropriate access control device (i.e., with a permit for a gate) to incorporate fire access (i.e., installation of Knox boxes or similar devices acceptable to the Fire Marshal) and to ensure unimpeded egress in case of evacuation. 22. New or altered intersections on Black Point Road, including but not limited to the maintenance area access and the proposed maintenance road for Storm Pond 3, require a Road Approach Permit from Jefferson County. The Road Approach Permit shall be obtained prior to construction related to said driveways. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 111 of 117 23. All roads within the preliminary plat shall be considered to be “available for public use” and shall be designed to Jefferson County’s adopted road standards pursuant to transportation mitigation conditions in the FEIS. If PHMPR determines that any roads will not be available for public use, PHPMR shall provide a drawing clearly depicting such roads and the drawing shall be accompanied by a written description of how access will be controlled to prevent public use. This information shall be submitted prior to or concurrent with construction permits for affected roads. 24. PHMPR shall provide a parking layout plan with each construction permit for an occupancy that requires parking pursuant to JCC 18.30.100. Where a use is specifically listed, parking shall be calculated consistent with the requirements for that use. Where a use is not specifically listed, parking shall be determined by the administrator pursuant to requirements for Small-Scale Recreational and Tourist Uses in Table 6-2 Minimum Number of Parking Spaces Required for Different Land Uses. Modification of parking requirements shall be allowed pursuant to JCC 18.30.100(1)(a)(iii) and JCC 18.30.100(1)(g). The administrator retains the right to require a parking study prepared by a licensed civil engineer to support a parking determination for Small-Scale Recreational and Tourist Uses. 25. PHMPR shall provide an improved shared-use path connection between the golf resort and the Pleasant Harbor Marina. This shared-use path shall be constructed or bonded prior to final plat approval. 26. For roads with Average Daily Traffic (ADT) exceeding 1,000, PHMPR shall provide design hourly volume (DHV) projections for each internal access road. Based on the ADT and DHV projections, Jefferson County shall identify the applicable standard roadway section for each internal access road. Where PHMPR proposes to deviate from Jefferson County’s assigned standard road sections, one deviation request per road shall be made in writing prior to or concurrent with construction permits for the subject road(s). Deviations must be approved prior to or concurrent with construction permits for affected roads. If a request for deviation is not approved, the Applicant shall revise the plat to accommodate Jefferson County’s assigned standard road sections. 27. Jefferson County Public Works shall review and approve the proposed Black Point Road right-of-way dedication area prior to final plat approval. The final size and configuration of the dedication area shall accommodate all proposed Black Point Road improvements intended to be transferred to and accepted for maintenance by Jefferson County Public Works, and may be required to extend beyond the edge of pavement by a distance determined during Public Works’ review to accommodate utilities and maintenance. Prior to final plat approval, PHMPR shall request and the County Engineer shall provide a written statement deeming the proposed Black Point Road right-of-way dedication to be of general public benefit. 28. The proposed Black Point Road right-of-way dedication area shall be dedicated to Jefferson County in fee simple. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 112 of 117 29. Improvements to Black Point Road, including the re-alignment and proposed right-of-way dedication area, shall be designed to meet adopted Jefferson County road standards. This shall be demonstrated with construction permits for said Black Point Road improvements. 30. Prior to final plat approval, PHMPR shall request and the County Engineer shall provide a written statement deeming the proposed Black Point Road right-of-way dedication to be of general public benefit. 31. Roads must be consistent with adopted Jefferson County roads standards in width and construction. Where aerial apparatus access is required, roads must withstand 75,000 pounds of weight to support water tender for fire access. PHMPR may request, in writing, a deviation from adopted Jefferson County road standards. The deviation shall demonstrate adequacy for emergency access, including by aerial apparatus/ladder truck. A deviation shall not be granted for bearing weight. Deviations shall be approved prior to or concurrent with construction permits for affected roads. 32. Any deviation request for width shall be accompanied by a fire apparatus turning radius analysis. Such analysis shall be coordinated with the Fire Marshal and shall consider actual fire apparatus likely to be needed for emergency response. The Fire Marshal, in his sole discretion, shall determine the adequacy of the analysis and suitability of roads for fire apparatus access and shall issue a written determination of adequacy for the deviation. The deviation shall be reviewed by Public Works and shall not be approved without the Fire Marshal’s written determination of adequacy. 33. Final easement width and location shall be amended based on as-built conditions of roads, paths, and utilities. Final easement width and location shall consider access for maintenance. Final easement width and location will be reviewed with the final plat application. 34. Two-way shared-use paths (also described in the Staff Report as multi-use paths) shall meet WSDOT’s adopted standards in Chapter 1515 of the WSDOT Design Manual M 22-01. The proposed roadway sections shall be revised to accommodate either minimum three foot separation (preferred) or a concrete barrier as shown in Exhibits 1515-4 and 1515-6 of the WSDOT Design Manual M 22-01. Utilities 35. All existing and proposed new utilities serving each phase shall be installed or relocated underground prior to final plat approval for that phase. 36. Improvements for potable water and sanitary sewer serving each phase shall be installed or bonded prior to final plat approval for that phase. All construction of potable water and sanitary sewer (wastewater) facilities shall be in accordance with the standards, specifications, and regulations of the Washington State Department of Health and the Washington State Department of Ecology. Written verification from the Washington State Department of Health and/or the Washington State Department of Ecology that all improvements have been installed and completed must be provided to Jefferson County prior to approval of the final plat for each phase. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 113 of 117 37. The new Pleasant Harbor water and sewer district shall be established consistent with Section 10 of Amendment 2 to the Development Agreement and the Washington State Department of Health’s Office of Drinking Water requirements. Final location and size of sewer and water utility easements shall be recorded with the final plat and conveyed to the Pleasant Harbor water and sewer district when formed. Any temporary uses shall comply with applicable requirements for fire, safety, and sanitation. 38. PHMPR shall provide documentation from the Washington State Department of Health’s Office of Drinking Water approving or conditionally/provisionally approving the water system plan prior to issuing construction permits that include water system infrastructure. 39. The Pleasant Harbor Water System Plan shall conform to the Washington State Department of Health’s Group A Public Water Systems Waterworks Standards and to Jefferson County’s Coordinated Water System Plan Design and Construction Standards. 40. The written analysis provided in Exhibit 25 is sufficient to demonstrate entitlement to adequate water rights to serve the preliminary plat. Approval of the water system plan by the Washington State Department of Health’s Office of Drinking Water shall satisfy the FEIS condition to demonstrate sufficient entitlement for the final plat. Upon approval of the water system plan, PHMPR shall provide water availability information with each development application for a use that will connect to the Pleasant Harbor Water System. 41. The wastewater (sewer) system shall be designed and constructed in accordance with the Washington State Department of Ecology’s “Criteria for Sewage Works Design” dated August 2008, or as amended, replaced, or revised. Water and sewer line crossing shall conform to Jefferson County Environmental Public Health’s “Water/Sewer Line Crossing Policy.” An additional easement may be required to facilitate horizon separation requirements. 42. Construction and operation permits for the wastewater treatment system shall be obtained by PHMPR from the Washington State Department of Ecology. The approved operational plan shall be provided to Jefferson County prior to final plat approval and prior to issuing construction permits for any structures or buildings to be served by the wastewater treatment system. 43. Prior to Jefferson County issuing construction permits that include electrical infrastructure for a phase, PHMPR shall provide documentation from Mason County PUD No. 1 to demonstrate that the project can be sufficiently served with electricity for that phase. Verification of adequate electric supply shall be provided prior to final plat approval for that phase. Jefferson County may, in its sole discretion, request additional information about the feasibility of electrical service following submittal of any documents related to this condition. Stormwater 44. Stormwater discharge shall meet the requirements set forth in the version of the Stormwater Management Manual for Western Washington and the current Department of Ecology National Pollutant Discharge Elimination System (NPDES) requirements, if applicable, in Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 114 of 117 effect at the time each construction permit is determined complete. Verification of compliance will occur with construction permits. 45. Proposed stormwater treatment for Basin 3 shall be provided in an update or addendum to the Drainage Report. The update or addendum shall be provided prior to or accompanying the earlier of either the first construction permit application submitted for work in Basin 3 or the final plat application. 46. Proposed stormwater treatment for Kettle B Basin shall be provided in an update or addendum to the Drainage Report. The update or addendum shall be provided prior to or accompanying the earlier of either the first construction permit application submitted for work in Kettle B Basin or the final plat application. 47. Each stormwater facility shall have an easement granting Jefferson County access for maintenance and inspections. These easements shall be shown on the final plat. The final language of the easements shall be approved by Jefferson County prior to final plat approval. 48. Drainage shall be managed privately through an Owner’s Association, utility district, or similar entity or shall be incorporated into the Conditions, Covenants, and Restrictions (CC&Rs). If incorporated into CC&Rs, Jefferson County shall be allowed right of entry to perform maintenance work if PHMPR fails to appropriately discharge its responsibilities and charge back to PHMPR. PHMPR and Jefferson County may enter into a separate Right of Entry agreement or similar legal instrument for this purpose in lieu of addressing drainage management through CC&Rs. Fire Suppression 49. PHMPR shall ensure the water system will provide for adequate sustainable fire flow as specified by Title 15 JCC. Demonstration of adequate fire flow shall be provided to the Fire Marshal following construction of an approved water system. An additional easement may be required to facilitate horizon separation requirements. 50. All buildings requiring automatic sprinkler systems as defined in IFC 903 and 905 shall include internal sprinkler systems with FDC connections. FDC locations shall be reviewed prior to construction of infrastructure. Internal sprinkler systems shall be reviewed with building permits. 51. PHMPR shall incorporate Firewise design standards in the layout of the proposed resort, as appropriate and approved by the local fire authority. 52. All subsurface parking will provide fire systems, including air handling, water, and emergency access and egress. These systems shall be reviewed with building permits. 53. PHMPR shall install hydrants and related fire suppression equipment at the maintenance area as approved by the Fire Marshal. Fire suppression equipment required by the FEIS mitigating conditions has already been installed at the Pleasant Harbor marina. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 115 of 117 Other 54. Mailbox locations shall be approved by the Brinnon postmaster and the Department of Public Works prior to installation to ensure compliance with required intersection sight distances and that they do not interfere with traffic operations or pedestrian travel paths. Conditions Applicable to Critical Areas 55. Where residential lots include a critical area, its buffer, and/or an easement for same, a Notice on Title shall be recorded describing the presence of the critical area, buffer, setback, easement (if applicable), and a statement that limitations on actions in or affecting such areas may exist. Geologically Hazardous Areas 56. The recommendations and conditions set forth in the following geotechnical documents shall be incorporated into the project design and followed during construction and operation of the resort: a. “Jefferson County Review Comments Response Letter” prepared by Krazan & Associates, Inc., dated October 15, 2024, including any documents referenced therein. b. “Final Draft Geotechnical Investigation – Pleasant Harbor Marina and Golf Resort – Jefferson County, Washington – Project No. SG0801” prepared by Perrone Consulting, Inc., dated January 23, 2013, including any documents referenced therein. c. “Geotechnical Investigation – Pleasant Harbor Marina and Golf Resort – Brinnon, Washington” report prepared by Subsurface Group, LLC, dated December 17, 2008, including any documents referenced therein. d. “Limited Geotechnical Engineering Letter – Top of Coastal Bluff/Shoreline Slope Setback and Buffer Clarification” prepared by Krazan & Associates, Inc., dated September 10, 2025, including any documents referenced therein. Any recommendations set forth in the geotechnical documents shall be included as conditions to be satisfied prior to applicable permits, approvals, and authorizations for land division or development activity on the property. 57. The top of slope of the coastal bluff on the west side of the property shall be determined by a geotechnical engineer or equivalent qualified professional. The geographic extent of the top of slope, the base 30-foot landslide hazard area buffer, and the 100-foot setback applicable to buildings, roadways, and infrastructure facilities as described in JCC 18.22.170 and the geotechnical documents shall be shown on all relevant plans, including but not limited to the final plat and plans for infrastructure or building construction in the vicinity. Relevance of this information shall be determined by the development code administrator in his sole discretion. All improvements shall adhere to the buffer and setback requirements established in the geotechnical documents and JCC 18.22.170. 58. A permanent physical separation along the boundary of the 30-foot landslide hazard area buffer shall be installed and permanently maintained pursuant to JCC 18.22.170(5). The method of physical separation shall be submitted to Jefferson County for review and approval prior to installation. Physical separations shall be installed, inspected, and approved prior to final plat approval. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 116 of 117 59. Landslide hazard areas and their buffers shall be shown on the final plat. 60. Existing improvements shall be removed from the coastal bluff’s 30-foot buffer and the buffer area fully restored with native vegetation, consistent with the environmental mitigation measures identified in the FEIS and FSEIS and adopted in JCC 17.60.060(2). The buffer shall remain naturally vegetated and any construction-related impacts shall immediately be restored. Minor pruning and vegetation may be allowed with an approved written request pursuant to JCC 18.22.170(6)(d) as adopted in Appendix C to the Development Agreement. 61. PHMPR shall monitor water quality consistent with Appendix N to the Development Agreement and the Best Management Practices set forth in Amendment 1 to the Future Staffing and Consultant Agreement. 62. Construction permit applications for improvements that are impacted by geologically hazardous areas shall demonstrate the incorporation and integration of recommendations in the geotechnical report, or an amended geotechnical report shall be provided. Construction permit applications for improvements that are potentially impacted by geologically hazardous areas shall be accompanied by a statement from a qualified professional certifying that the proposal complies with the review criteria set forth in JCC 18.22.170(9)(b). Wetlands 63. The recommendations and conditions set forth in the Wetland Verification Report prepared by GeoEngineers, dated October 18, 2024, including documents reviewed and incorporated by reference into the Report, as set forth in Exhibit 29 and the Wetland and Wetland Buffer Mitigation Plan Report prepared by GeoEngineers, dated January 26, 2012, as set forth in Appendix J to the FSEIS shall be followed. Mitigation shall be fully implemented, or financial guarantees provided to Jefferson County in the form of a bond, prior to approval of the final plat. 64. Wetland buffer averaging around Wetland C is approved and shall conform to the buffer averaging plan presented in the Wetland Verification Report dated October 18, 2024 (Exhibit 29), and evaluated in the Response Memorandum to Jefferson County Comments Regarding Wetland C Buffer Averaging Plan (Exhibit 30). The final (averaged) buffer around Wetland C shall be shown on the final plat and shall be included in the permanent conservation easement required by Condition 66 prior to recording either the easement or the final plat documents. 65. Modifications to the approved buffer averaging plan shall be reviewed as a modification to the preliminary plat. 66. Wetlands and their buffers shall be placed into permanent conservation easements. Easements shall be shown on the final plat. The final language of the easement(s) and legal descriptions for easement locations (wetlands and their buffers) shall be provided to and approved by Jefferson County prior to recording. Jefferson County Staff Report Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued September 15, 2025 EXHIBIT 1 Page 117 of 117 67. Mitigation required pursuant to the Wetland and Wetland Buffer Mitigation Plan included as Appendix J to the FSEIS shall be completed to Jefferson County’s satisfaction prior to approval of the final plat. 68. A permanent physical separation along the boundary between Wetland C’s buffers and adjoining residential lots shall be installed and shall be permanently maintained. The method of physical separation shall be submitted to Jefferson County for review and approval prior to installation. Physical separations shall be installed, inspected, and approved prior to final plat approval. Conditions Applicable to Operation 69. The Resort shall be operated such that residential units achieve the residential use restrictions set forth in JCC 17.60.070. A report of short-term visitor accommodations and short-term rental units compared to long-term residential uses shall be provided to Jefferson County following construction of each phase of the plat. Following construction of all phases, PHMPR shall provide a report upon request by the Development Code Administrator, provided that reports will not be required more than once per calendar year. If the proportion of short-term units does not meet the minimum requirements set forth in JCC 17.60.070, PHMPR shall provide a written plan of action to correct the deficiency within a reasonable timeframe to be determined by the development code administrator. 70. All buildings and structures to be served by potable water shall be connected to the Pleasant Harbor Water System.