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HomeMy WebLinkAbout66H_2025-0912_Taylor (JST)ATTN: George Terry September 11, 2025 Associate Planner Jefferson County Department of Community Development 621 Sheridan St. Port Townsend, WA 98368 RE: Revised Preliminary Plat Application for the Pleasant Harbor Master Plan Resort, File No. SUB2023-00025 Dear George Terry, The Jamestown S’Klallam Tribal Historic Preservation Office (THPO) has received and reviewed your notice for the revised preliminary plat application for the Pleasant Harbor Master Plan Resort in Brinnon, Jefferson County, Washington. It is the THPO’s understanding that there have been no modifications to the application that would provide protection and/or mitigation for the impacts to the traditional cultural property located within the project area. The THPO has made efforts to notify Jefferson County of the importance of this location including the 2018 comment letter (See Attachment 1), verbal comments during numerous staff level meetings between Jefferson County, the Jamestown S’Klallam Tribe (JST), Port Gamble S’Klallam Tribe (PGST) and the Point No Point Treaty Council (PNPTC), as well as verbal comments during the official Government to Government meeting on May 28th, 2025 between Jefferson County Board of County Commissioners, JST, and the PGST. The THPO continues to request that Jefferson County condition the Preliminary Plat Permit to preserve and protect the traditional cultural property. The THPO requests that Kettle Ponds B and C and adjacent wetlands be preserved for traditional property evaluation and protection of cultural resources. The Kettles should not be used for storm water or wastewater management plans and the destruction of wetlands on-site should be avoided. The initial State Environmental Protection Act (SEPA) review failed to properly document or address areas of cultural importance as required per questions 13(a) and 13 (b) of the SEPA checklist: “Are there any buildings, structures, or sites, located on or near the site that are over 45 years old and listed in or eligible for listing in the national, state or local preservation registers located on or near the site?” and “Are there any landmarks, features, or other evidence of Indian or historic use or occupation? This may include human burials or old cemeteries. Are there any material evidence, artifacts, or areas of cultural importance on or near the site? Please list any professional studies conducted at the site to identify such resources.” Exhibit 66H The only cultural resource inventory work completed for this project was conducted in 2006. This report studied if there were material remains within the project area. However, material remains are often not associated nor are they a prerequisite of traditional cultural property. Therefore, this nearly 20-year-old inventory does not follow the Washington State Standards for Cultural Resources Reporting provided by the Department of Archaeology and Historic Preservation (DAHP) (https://dahp.wa.gov/project-review/washington-state-standards-for- cultural-resource-reporting). While this inventory discussed the importance of the Kettles to the concerned tribes, it made no effort to officially record the traditional cultural property, integrate the results of identification activities into the planning process, nor elicit effective communication with all concerned Tribes. The Development Agreement puts the onus on concerned Tribes to document this site and nominate this traditional cultural property for the National Register of Historic Places by stating the following: “If, prior to Developer applying for a grading or building permit for the Pleasant Harbor MPR, the PGST applies for and receives a recommendation from the State Advisory Council on Historic Preservation that either Kettle B or C is eligible for listing in the National Register of Historic Places, the Developer shall: (A) Preserve either Kettle B or C by preventing the selected kettle from being used for any stormwater storage; and, (B) Consult with the PGST to arrive at a kettle management plan where the PGST would enhance the selected kettle by removing invasive vegetation and planting it with native vegetation found at the time of its use by native people, and to develop and install an educational signs that explain the significance of the kettles to native people.” This language has been something the THPO has voiced our disagreement with since 2018 prior to the finalization of the Development Agreement through comments that were never addressed in consultation (Attachment 1). It is not the responsibility of the tribes to document these resources, nor prove they are significant. It is however Jefferson County’s and the DAHP’s responsibility to ensure these resources are properly recorded and Jefferson County’s responsibility to permit the project in accordance with RCW 43.21C.020 to “preserve important historic, cultural, and natural aspects of our National Heritage” and RWC 43.21.030 (b) to “Study, develop, and describe appropriate alternatives to recommend courses of action in any proposal which involves conflicts concerning alternative uses of available resources.” Finally, it is clear Jefferson County has failed to recognize the importance of traditional cultural properties and tribal knowledge based on the County’s response to the PNPTC’s comments on cultural resources (see Attachment 2 and 3) and DAHP’s recommendations (see Attachment 4 and 5). The THPO urges Jefferson County to acknowledge that tribes “possess special expertise in assessing the eligibility of historic properties that may possess religious and cultural significance to them.” This is something the United States Federal Government has recognized through 36 CFR Section 800.4 c(1). While this project is not subjected to this regulation, the THPO strongly recommends Jefferson County work to Exhibit 66H implement this into their local regulations, correct the inappropriate language in the Development Agreement, and recognize the importance of tribal knowledge regarding the identification of our cultural resources and traditional cultural properties. Thank you for the opportunity to comment on this project. If you need any additional information, please contact me at 360-681-4638 or ataylor@jamestowntribe.org Sincerely, Allie Rae Taylor Tribal Historic Preservation Officer Jamestown S’Klallam Tribe cc. W. Ron Allen, JST Tribal Council Chairman and CEO Loni Greninger, JST Tribal Council Vice Chairwoman and Culture Department Director Hansi Hals, JST Natural Resources Director Allyson Brooks, DAHP State Historic Preservation Officer Randy Harder, PNPTC Executive Director Laura Price, PGST Interim THPO and Cultural Director Josh Peters, Jefferson County Administrator Attachments: 1. Stamped 268 2. Pleasant Harbor MPR – Preliminary Plat Application, Case SUB2023-00025 August 15th, 2024 Letter 3. Excerpt from Report Responding to Point No Point Treaty Council’s August 15, 2024 Letter for Pleasant Harbor Master Planned Report – Preliminary Plat Application DCD File No. SUB2023-00025 4. Stamped 235 5. JC Response to DAHP Exhibit 66H Attachment 1 - Stamped 268 Exhibit 66H Exhibit 66H Exhibit 66H Attachment 2 - Pleasant Harbor MPR – Preliminary Plat Application, Case SUB2023- 00025 August 15th, 2024 Letter Exhibit 66H 19472 Powder Hill Place NE, Suite 210 Poulsbo, Washington 98370 Phone (360) 297-3422 Fax (360) 297-3413 August 15, 2024 Commissioners Kate Dean, Heidi Eisenhour, and Greg Brotherton Jefferson County Commission 1820 Jefferson Street Port Townsend, WA 98368 Re: Pleasant Harbor MPR - Preliminary Plat Application, Case No. SUB2023-00025 Dear Commissioners, Our Tribes, the Jamestown S’Klallam (JST) and Port Gamble S’Klallam (PGST) Tribes, and our consortium, the Point No Point Treaty Council (PNPTC) want to express our many concerns regarding the Application for the Pleasant Harbor Plat, Case No. SUB2023-00025. Beginning in 1997, the PNPTC and our Tribes have provided comments to Jefferson County and participated in discussions and hearings to review this project. Yet, for over 20 years now, our comments have not been addressed, especially now in the current project proposal, plat application, and associated documents. Our Tribes have commented on the proposed MPR at each step in the review process. We have repeatedly commented on the potentially harmful effects and the impacts to important Treaty reserved resources that could be lost if the project were to move forward as proposed. Again, to date, we feel that these concerns have not been adequately addressed. Over the years we have provided comments from our organization and our Tribes (2001, 2006, 2007, 2015, 2018, 2019, 2024) regarding this project, and we are deeply concerned about the potential adverse effects on our cultural resources and Treaty Rights. These concerns stem from the loss of wetlands and rare kettle ponds, increased traffic affecting fisheries access, intensity of land use for commercial and residential development, significant alteration of hydrology, clearing and grading, increased impermeable surface, wildlife impacts, use of persistent pollutants, impacts to shellfish, storm water impacts, wastewater issues, and other project effects. A summary of some of the major concerns and deficiencies in the current application follows, which still contains many issues we have commented on over the years: Shellfish Resources Protection and Management The Pleasant Harbor MPR (PH MPR) will be located between two public beaches on the Duckabush and Dosewallips, which provide both significant commercial and ceremonial/ subsistence harvest opportunities to Tribes with Usual and Accustomed fishing rights in the area. The two delta flats are among the most important intertidal areas to the tribal harvesters based on acreage available, healthy habitats available, and existing natural manila clam and pacific oyster production. Exhibit 66H PNPTC Letter to Jefferson County re Pleasant Harbor MPR, Case SUB2023-00025 Page 2 of 5 8/14/2024 19472 Powder Hill Place NE, Suite 210 Poulsbo, Washington 98370 Phone (360) 297-3422 Fax (360) 297-3413 Any increase in visitors and recreational use is expected to increase the harvest pressure on the Duckabush and Dosewallips tidelands. Additionally, any system overflows into the Duckabush or contaminated storm water runoff from the increase in impervious areas could result in poor water quality in the rivers leading to problems with shellfish on the tidelands. Obviously, a closure of these tidelands by DOH due to water quality issues would have severe cultural and economic impact on the S’Klallam Tribes. Water Quality Protection and Management Our Tribes would like Jefferson County to require a water quality and shellfish protection plan with adaptive management measures so that we are reassured the treaty resource is retained over time. We would expect and be pleased to review the required plans and suggest that they incorporate, at a minimum, the following: • Water quality monitoring in waters connected to tribal fisheries and shellfish harvesting areas, including monitoring for pollutants, • An evaluation of alternatives for constructing additional swales and contours near roadways to redirect storm water runoff away from Hood Canal, particularly in the areas of Phase 1 construction. Revisions to the project management plan are also needed to eliminate the use of persistent pollutants and replace them with substances allowed for use under the agricultural national organic program. We request that the draft revised management plan be provided to tribal natural resources staff for review and comment. The urbanization of the area by the development of the proposed PH MPR will increase the prevalence of toxic heavy metals, persistent organic pollutants and other contaminants of emerging concern in this rural area. The increase in the prevalence of these pollutants will likely have a negative effect on fish and shellfish resources inhabiting PH MPR and the surrounding areas, including the Dosewallips and Duckabush River Estuaries. Wildlife Protection and Habitat Management Plan While the recent Wildlife Management Plan’s (published 3/12/2024) goals describe an attempt to address some of the Tribes’ most significant wildlife-related concerns, the methods proposed to reduce harm to elk herds are flawed and will not accomplish the Plan’s goals. This plan only identifies one west-oriented fence, and that it is not enough to exclude elk from the premises. Elk should be completely excluded from the PH MPR via fencing all around the project area because elk are highly mobile. By excluding elk entirely, it could remove other issues that are not currently addressed in the Wildlife Management Plan. Some of those issues are: • vehicle-wildlife collisions. • damage to ornamental plantings and landscaping. • changes in habitat use by the elk herd, as a response to newly created food sources. Exhibit 66H PNPTC Letter to Jefferson County re Pleasant Harbor MPR, Case SUB2023-00025 Page 3 of 5 8/14/2024 19472 Powder Hill Place NE, Suite 210 Poulsbo, Washington 98370 Phone (360) 297-3422 Fax (360) 297-3413 • the presence of divots and elk feces on the golf course. • potentially dangerous interactions between elk and visitors, residences, and their pets. The Wildlife Management Plan greatly underestimates how significant elk use (and damage) could be to the PH MPR site. Through the tribally led elk monitoring program, our biologists know that the Duckabush elk herd consists of up to 40 adult elk (which eat roughly the same amount of browse as 25 full grown bovine cows). The Duckabush herd crosses to the east side of Highway 101 (immediately south of the PH MPR) on a limited basis only, likely because there are few novel resources and few high value feeding areas. However, elk use will change after habitat conditions are significantly altered and novel food sources (e.g. fertilized and watered fields) are installed. The Dosewallips elk herd (which lives roughly 5 miles north of the project) regularly crosses to the east side of Highway 101 to graze on the fields maintained by Dosewallips State Park. The elk are there for hundreds (possibly thousands) of hours each year, despite the presence of dozens to hundreds of campers/visitors and all the noise and disturbance associated with people. Once elk are accustomed to a new and high-value food source, deterring future use will be incredibly challenging. The Wildlife Management Plan proposes temporary deterrence techniques to be implemented if elk begin to use PH MPR site. However, the proposed flashing lights and loud noises are unlikely to deter elk use but may disturb residents and visitors. Cultural Resources Protection and Stewardship Tribes continue to request that Kettle Ponds B and C and adjacent wetlands be preserved for traditional property evaluation and protection of cultural resources. Storm water and wastewater management plans should avoid the destruction of wetlands and use of these Kettles for storm water and treated wastewater storage. Contact should be made with the PGST and JST Tribal Historic Preservation Officers (THPO) (and other regional tribes) directly regarding these matters. The Kettle ponds are sacred, cultural relics, and are rare biological features and should be preserved. Development Agreement does not Incorporate Tribal Comments/Revisions In the letter from the Port Gamble S’Klallam tribe (dated April 9, 2018), there was a 19-page detailed list of concerns and issues that have not been remedied in the current Development Plan and its Amendments. Below are some concerns related to (but not limited to) the following areas: • Concerns related to the density, intensity of use, unlimited terms/build-out period, lack of enforceability and specificity, sequencing issue with the Development regulations, and failure to meet required provisions and conditions of the Ordinance 01-0128-08. • Need for reduction in overall density of the PH MPR • Need for conditional approval structure for the PH MPR Exhibit 66H PNPTC Letter to Jefferson County re Pleasant Harbor MPR, Case SUB2023-00025 Page 4 of 5 8/14/2024 19472 Powder Hill Place NE, Suite 210 Poulsbo, Washington 98370 Phone (360) 297-3422 Fax (360) 297-3413 • Need for enforceability and specificity in the Development Agreement (and associated appendices) and development regulations • Need for meaningful consultation between Jefferson County and the area Tribes. • Need to correct for noncompliance with Ordinance 01-0128-08 of nearby natural resources including the protection of shellfish harvesting areas • Need for compliance with protection of critical areas with current standards that should include standards related to 6PPD, water quality, climate change impacts, etc. • Need for a closer examination of the PH MPR’s water plan and impacts to the kettle ponds for use as water storage, etc. There needs to be a thorough independent study of hydrologic function and relationship between groundwater, surface water, and runoff, aquifer recharge, contamination by pollutants related to pesticides and golf course management, or other treated surfaces. • Need for a better water quality monitoring plan. The proposed plan lacks scope and sample frequency. • Need for wastewater treatment plan. According to the “Fully Executed Development Agreement with appendices” this is still pending. • Need for the implementation of the revisions and actions proposed by the late PGST Tribal Chair Jeromy Sullivan (from letter dated April 9, 2018) for the development agreement and amendments. We appreciate the County’s willingness to regularly meet with Tribal staff regarding this project. However, our concerns have not yet been adequately addressed in these meetings. The meetings themselves have been too short in duration and seem to only cover updates as to what the County’s staff and consultant have been working on, leaving little time to discuss next steps and responses to our comments and suggestions. Our tribes are deeply concerned about these issues and look forward to addressing them together before the application and project moves forward. We are encouraged by the County’s offer to schedule recurring, quarterly meetings with our Tribes to discuss future projects as they arise. It is our hope that developing a consistent, collaborative line of communication will enable us to work effectively to address Tribal concerns related not only to the Pleasant Harbor project, but future development proposals as well. Sincerely, Chris Tom, Vice Chairman W. Ron Allen, Chairman Port Gamble S’Klallam Tribe Jamestown S’Klallam Tribe Exhibit 66H PNPTC Letter to Jefferson County re Pleasant Harbor MPR, Case SUB2023-00025 Page 5 of 5 8/14/2024 19472 Powder Hill Place NE, Suite 210 Poulsbo, Washington 98370 Phone (360) 297-3422 Fax (360) 297-3413 Cc: Amber Caldera, Chairwoman, Port Gamble S’Klallam Tribe Guy Miller, Chairman, Skokomish Tribe Joseph Pavel, NR Director, Skokomish Tribe Frances Charles, Chairwoman, Lower Elwha Klallam Tribe Russ Hepfer, Vice Chair, Lower Elwha Klallam Tribe Hansi Hals, NR Director, Jamestown S’Klallam Tribe Roma Call, NR Director Port Gamble S’Klallam Tribe Randy Harder, PNPTC Director Cristina Haworth, SJC Alliance George Terry, Jefferson County Josh Peters, Jefferson County Exhibit 66H Attachment 3 - Excerpt from Report Responding to Point No Point Treaty Council’s August 15, 2024 Letter for Pleasant Harbor Master Planned Report – Preliminary Plat Application DCD File No. SUB2023-00025 Exhibit 66H Report Responding to Point No Point Treaty Council’s August 15, 2024 Letter - Page 51 10. COUNTY’S RESPONSE TO COMMENT 4E. More fencing of the PHMPR should address this comment. See also the Response to Comment 4A, above. D. PNPTC COMMENT 5 (“Cultural Resources Protection and Stewardship”). 1. PNPTC COMMENT 5A. “Tribes continue to request that Kettle Ponds B and C and adjacent wetlands be preserved for traditional property evaluation and protection of cultural resources. Storm water and wastewater management plans should avoid the destruction of wetlands and use of these Kettles for storm water and treated wastewater storage.” 2. COUNTY’S RESPONSE TO COMMENT 5A. The Development Agreement, Vegetation Management Plan (Appendix L), Forest Report Appendix at 20, says: BP-2K Sub-Areas (11.8% of total BP area) These areas are identified as “Glacial Kettles” in historical information and in Geotech field evaluations of the site. ‘Kettle’ areas have been logged in the past as can be seen on aerial imagery (see Figure 13) and by observation on site. Skid trail evidence and tree stand regeneration status within the kettle boundaries is also visible. The county’s ability to offer additional protection of kettle ponds “and adjacent wetlands for traditional property evaluation and protection of cultural resources” is limited by prior decisions made in the development process as required by state law and the Jefferson County Code. First, in 2008, the county adopted Ordinance No. 01-0128-08. Condition 63 of that ordinance states:  Condition 63(h): “The possible ecological impact of the development’s water plan that alters kettles for use as water storage must be examined, and possibly one kettle preserved.” (Emphasis added.)  Condition 63(i): “Any study done at the project level pursuant to SEPA (RCW 43.21C) shall include a distinct report by a mutually chosen environmental scientist on the impacts to the hydrology and hydrogeology of the MPR location of the developer s intention to use one of the existing kettles for water storage. Said report shall be peer-reviewed by a second scientist mutually chosen by the developer and the county. The developer will bear the financial cost of these reports.”  Condition 63(j): “Tribes should be consulted regarding cultural resources, and possibly one kettle preserved as a cultural resource.” Exhibit 66H Report Responding to Point No Point Treaty Council’s August 15, 2024 Letter - Page 52 Second, these three conditions were satisfied in the 2015 FSEIS and the Development Agreement that was adopted in Ordinance No. 04-0604-18 and Ordinance No. 08-0722-19. The parties and the tribes discussed the importance of kettles on the Property to the PGST’s cultural history. The PGST has applied for including of any Traditional Cultural Properties on the National Register of Historic Places as of the date of this Agreement. If, prior to Developer applying for a grading or building permit for the Pleasant Harbor MPR, the PGST applies for and receives a recommendation from the State Advisory Council on Historic Preservation that either Kettle B or C is eligible for listing in the National Register of Historic Places, the Developer shall: (A) Preserve either Kettle B or C by preventing the selected kettle from being used for any stormwater storage; and, (B) Consult with the PGST to arrive at a kettle management plan where the PGST would enhance the selected kettle by removing invasive vegetation and planting it with native vegetation found at the time of its use by native people, and to develop and install an educational signs that explain the significance of the kettles to native people. This provision does not restrict or otherwise prevent Developer from exercising its right to object to any application that kettles are culturally significant. Development Agreement, section 5 (emphasis added). The Developer has applied for a stormwater permit (ZONS2024-00004). The County does not issue a separate clearing or grading permit, so preliminary grading was reviewed as part of the installation of stormwater measures. County staff does not believe this is the type of “grading permit” contemplated in section 5 of the Development Agreement. As a result, it is likely the Developer can be required by the county to consult with your tribes on a kettle management plan, up until a grading permit application is submitted to the county by the Developer. 3. PNPTC COMMENT 5B. “Contact should be made with the PGST and JST Tribal Historic Preservation Officers (THPO) (and other regional tribes) directly regarding these matters. The Kettle ponds are sacred, cultural relics, and are rare biological features and should be preserved.” 4. COUNTY’S RESPONSE TO COMMENT 5B. The county has had recent discussions directly regarding the Kettle ponds with the PGST, the JST, and the PNPTC. The county also has reached out to the Skokomish Indian Tribe and the Lower Elwha Klallam Tribe. Washington State has processes in place to protect tribal culture. These processes mainly involve tribal consultation and historical investigation. We realize that as the years have passed tribes have become more and more aware of their cultural history and ceremonial sites. We Exhibit 66H Report Responding to Point No Point Treaty Council’s August 15, 2024 Letter - Page 53 also understand the location of ceremonial sites of tribes have been kept secret in order to prevent disturbances of tribes’ sacred places. Under Washington law, the county has been required to take actions that relied on past tribal consultation and historical investigation described below. Jefferson County believes it has conducted both the required tribal consultation and historical investigation for the decisions it made in the ordinances it adopted for the zoning, the development regulations and the development agreement for the PHMPR. Nevertheless, the principle of adaptive management permeates the development agreement and its appendices and provides tribes a means of participation in future phases of the project for the purpose of protecting their cultural resources. On January 12, 2012, Cultural Resource Consultants prepared for PHMR a Cultural Resources Management Plan for Archaeological Monitoring and Inadvertent Discovery (“Cultural Resources Management Plan”). The Cultural Resources Management Plan states: “Subsurface investigations focused on archeologically sensitive landforms; that is, those environments most likely to contain naturally buried archaeology identified in collaboration with cultural resources staff of the Skokomish Tribe (e.g., kettles, vantage points, the bluff edge).” Cultural Resources Management Plant at 1. There were 22 probes in kettle basins and 32 probes along the kettle margins and rims. Id. On May 11, 2012, Don Coleman on behalf of PHMR wrote to Josh Wisniewski at PGST. The letter states: In order to protect known and unknown archaeological and cultural resources, and to comply with Jefferson County Ordinance 01-0128-08 condition 63(k) as well as state laws governing the protection of those resources (RCW 27.53, RCW 27.44). (sic) We are submitting for your review our cultural resources management plan that includes monitoring and inadvertent discovery processes and procedures. Please review and submit any comments in writing by June 15, 2012. PGST did not respond. On January 14, 2013, the Washington Department of Archeology and Historic Preservation (WDAHP) approved the Cultural Resources Management Plan. The WDAHP noted in its letter that three tribes have concurred with the Cultural Resources Management Plan and three others did not comment. The Skokomish Tribe approved the Cultural Resources Management Plan on the same day as WDAHP, January 14, 2013. WDAHP’s January 14, 2013 letter is copied to Josh Wisnieweksi, a representative PGST. Exhibit 66H Report Responding to Point No Point Treaty Council’s August 15, 2024 Letter - Page 54 Kettles are a common geological feature wherever glaciers retreat, including in Western Washington. According the Washington Department of Natural Resources (DNR): “Glacial kettles are depressions that form when a retreating glacier leaves a bit of ice behind which then becomes buried by sediment shed from glacial streams. When the block of ice melts, the sediment collapses, forming a kettle. Kettles can be dry or filled with water, depending on their depth and the level of groundwater in the area.”74 See Figure 13, right.75 Through the Public Records Act, we received a copy of the DAHP file and found no consultation with DNR or any expert in geology. All we found in the DAHP file discussing the kettles comes from a group who advocates on behalf of the PGST, the Port Townsend Native Connections Action Group in a piece called “Save the Black Point Kettles.” In that piece, the advocacy group claims, without any proof whatever, that: “We think they are the only kettles on the Olympic Peninsula, and they are dry except for shallow ephemeral ponds in springtime. Most kettles in Washington and across the country are kettle ponds, filled with water, so because these are deep and dry, they are much more significant.” As explained by DNR on its web page, all of the land and waterways in the Puget Lowland region, including the Hood Canal and the kettles at Black Point were shaped, at least in part, by the glacial ice of the Puget Lobe Ice Sheet.76 Kettles are found wherever glaciation occurs. The entire Hood Canal area was impacted by Puget Lobe Ice Sheet. See Figure 14, below.77 “The alpine glaciers that nest year round high in the Olympic Mountains are relicts of the recent ice age, which began about 2 million years ago. During the last ice advance about 15,000 years ago, a large sheet of ice, called the Cordilleran Ice Sheet, moved down from western Canada and into Washington. The ice sheet crept southward into the northern Puget Sound region and bumped up against the Olympics, where it split into two lobes. One lobe went out into the Strait of Juan de Fuca toward the Pacific Ocean, and the Puget Lobe moved south and filled what is now the Puget Lowland. Deposits from this glaciation can be found on the eastern and northern 74 https://www.dnr.wa.gov/programs-and-services/geology/glaciers#glacial-landforms. 75 See https://www.dnr.wa.gov/geology-glossary#geologic-features.45. 76 https://www.dnr.wa.gov/publications/ger presentations coe glacial landforms puget lowland.pdf?snr867. 77 https://www.dnr.wa.gov/programs-and-services/geology/explore-popular-geology/geologic-provinces- washington/olympic#geologic-history. See also Washington Geologic Society, Bulletin No. 8, Plate XXII (1913). Exhibit 66H Report Responding to Point No Point Treaty Council’s August 15, 2024 Letter - Page 55 edges of this province.”78 Counting Whidbey Island, Black Point and Olympia alone, there are at least several dozen known kettles in the Puget Sound region. 78 https://www.dnr.wa.gov/programs-and-services/geology/explore-popular-geology/geologic-provinces- washington/olympic#geologic-history. Exhibit 66H Report Responding to Point No Point Treaty Council’s August 15, 2024 Letter - Page 56 Just north of the Hood Canal, on Whidbey Island, the Ebey’s Reserve features the Kettles Trail System.79 WDNR’s GM-58, Geologic Map shows kettles on Whidbey Island on Figure 15, below.80 Indeed, a large notch in the Whidbey Island bluff that is very visible from Port Townsend is a remnant of a kettle. 79 https://www.islandcountywa.gov/PublicWorks/Parks/Pages/kettles-trails.aspx. See also https://www.nps.gov/ebla/planyourvisit/upload/050514-trails-map.pdf and https://washingtonlandscape.blogspot.com/2012/12/kettles-and-dunes-on-whidbey.html. 80 http://www.dnr.wa.gov/Publications/ger_gm58_geol_map_coupeville_24k.pdf. Exhibit 66H Report Responding to Point No Point Treaty Council’s August 15, 2024 Letter - Page 57 Another example of nearby kettles is the Budd Inlet Kettle Train, just south of Olympia, where there is a cluster of kettles where many ice blocks were buried by sediment from the receding glacier.81 In the Budd Inlet Kettle Train shown in Figure 16, below, kettles are outlined with dashed red lines.82 Glaciers covered the entire Hood Canal area during the Pleistocene era. Soil samples taken by the Washington Geologic Society prove the entire Hood Canal area, including Black Point, is covered with Pleistocene surface deposits, indicating glacial activity. Washington Geologic Society, Bulletin No. 8, Plate XXII (1913). 81 https://www.dnr.wa.gov/geology-glossary#geologic-features.45. 82 Id. Exhibit 66H Report Responding to Point No Point Treaty Council’s August 15, 2024 Letter - Page 58 On Black Point alone, there are at least six kettles as can be seen in DNR’s Lidar image of Black Point, in Figure 17, below.83 83 Id. Exhibit 66H Attachment 4 - Stamped 235 Exhibit 66H tic .-CQ,(&, effbocc From: Kaehler, Gretchen (DAHP) <Gretchen.Kaehler@DAHP.wa.gov> Sent: Monday, April 09, 2018 3:33 PM To: jeffbocc Cc: shlanayl@skokomish.org; thpo@pgst.nsn.us; Bill White (bill.white@Elwha.org); David Brownell (dbrownell@jamestowntribe.org); wpburden@aol.com Subject: Re: Comments for Public Hearing on Black Point-Pleasant Harbor Master Planed Development Attachments: 081106-13-JE_040918_B lack Point Kettles_Pleasant Harbor Master Plan (DAHP).pdf Please see our attached comments for this project. Please feel free to contact me if you have any questions. Best, Gretchen Gretchen Kaehler Assistant State Archaeologist, Local Governments Department of Archaeology and Historic Preservation (DAHP) P: 360-586-3088 C: 360-628-2755 Exhibit 66H April 9, 2018 Ms. Kate Dean County Commissioner Jefferson County PO Box 1220 Port Townsend, WA98368 Allyson Brooks Ph.D., Director State Historic Preservation Officer In future correspondence please refer to: Project Tracking Code: 081106 -13 -JE Property: Statesman Group Master Planned Resort in Brinnon's Black Point and Pleasant Harbor Marina, Jefferson Co. Re: Archaeology-DAHP Comments for Public Hearing for Pleasant Harbor MPR Development Dear Ms. Dean: The Washington State Department of Archaeology and Historic Preservation (DAHP) has been involved in the review of the proposed development since 2006. While we have some information regarding archaeological materials within the project, there is no information regarding consultation or review undertaken for cultural values. New information has been presented regarding the geological and cultural value of the project area within the past months. RCW 43.21C.020 recognizes the responsibility to "Preserve important historic, cultural, and natural aspects of our national heritage. " Further, RCW 43.21.030 (b) Guidelines for state agencies, local governments—Statements—Reports AdviceInformation states (e) Study, develop, and describe appropriate alternatives to recommended courses of action in any proposal which involves unresolved conflicts concerning alternative uses of available resources. Question 13(b) of the SEPA checklist asks: Are there any landmarks, features, or other evidence ofIndian or historic use or occupation? This may include human burials or old cemeteries. Are there any material evidence, artifacts, or areas of cultural importance on or near the site? Please list any professional studies conducted at the site to idents such resources. The cultural importance of the project area was not addressed in any of the studies or documents agencies or public relied upon to make comments or decisions regarding the development. The project are contains unique and geologically significant features. In additional we have a draft Traditional Cultural Property form submitted by the Port Gamble S'Klallam Tribe. While the form is not complete at this time the information we have evaluated indicates the kettles are of cultural and spiritual importance to the Tribe(s). There is a precontact archaeological site recorded in the project area which supports the longtime use of the area by native peoples. Coupled with the uniqueness of the geological features, the kettles would qualify as both a Traditional Cultural Property (TCP) as well as a Cultural Landscape (CL) and would be eligible for listing in the National Register of Historic Places (NRNP). STATg State of Washington • Department of Archaeology & Historic Preservation P.O. Box 48343 • Olympia, Washington 98504-8343 • (360) 586-3065 _ z www.dahp.wa.gov 0byrsao Exhibit 66H The cultural resources studies conducted for the project did not discover or report either the geological or cultural value of the kettles nor was it sufficient for the scope of the project which would disturb or destroy the features that make the kettles and landscape culturally and geologically remarkable. Nor was this information reported in the Supplemental Environmental Impact Statement (SEIS). We recommend that the project be redesigned to preserve the kettles and the unique cultural landscape. We would also request that the cultural resources study be updated to include an traditional cultural property study. The Cultural Resources Management Plan (CRMP) for this project almost 10 years ago needs to be updated based on the eventual development approved. Thank you for the opportunity to review and comment. If you have any questions, please contact me Sincerely, Gretchen Kaehler Assistant State Archaeologist, Local Governments 360) 586-3088 gretchen.kaehler(2dahp.wa.gov cc. Kris Miller, THPO, Skokomish Tribe Bill White, Archaeologist, Lower Elwha S'Klallam Tribe David Brownell, Cultural Resources, Jamestown S'Klallam Tribe Stormy Purser, THPO, Port Gamble S'Klallam Tribe Lys Burden, Native Connection Action Group Exhibit 66H Attachment 5 - JC Response to DAHP Exhibit 66H Exhibit 66H Exhibit 66H Exhibit 66H Exhibit 66H Exhibit 66H Exhibit 66H Exhibit 66H Exhibit 66H Exhibit 66H Exhibit 66H Exhibit 66H Exhibit 66H Exhibit 66H Exhibit 66H Exhibit 66H