HomeMy WebLinkAbout71_Applicant Response to JST Letter
October 8, 2025
Via Email
George Terry
Community Development Director
Jefferson County
RE: Pleasant Harbor Master Planned Resort
Pre-Application Meeting for Preliminary Plan of Subdivision
Dear Mr. Terry:
By email dated September 5, 2025 you requested that Pleasant Harbor Marina and Golf
Resort (“Pleasant Harbor”) respond to comments the County received from the Jamestown
S’Klallam Tribe (“Tribe”) pertaining to Pleasant’s Harbor Preliminary Subdivision Application.
For ease of reference, we have copied the comments and the Tribe’s proposed solutions in the
chart below and added a column with Pleasant Harbor’s response.
As a general comment, many of the Tribe’s comments are directed at interpretations of
plans Pleasant Harbor prepared during the project-specific SEPA SEIS process for the
Development Agreement. These plans were presented as part of the project specific SEIS process,
were commented on and vetted during that process and in some cases were revised as part of that
process before being approved by the County and incorporated as conditions to development as
part of the Development Agreement between the County and Pleasant Harbor. The only way these
plans may be modified is through an amendment to the Development Agreement. The preliminary
plat application does not provide an opportunity to reopen or revisit decisions made in these
approved plans.
Fortunately, it appears that Tribe’s comments do not require revisions but rather
explanation of what is required by the plans. We provide those responses here:
Issue Solution Pleasant Harbor Response
Water quality plans, monitoring
and controls are inconsistent
between documents with no
The County can amend the WQ
plan to indicate that it
supersedes or takes precedent
over other plans in relation to
We do not believe there are any
inconsistencies and without
specifics it is difficult to respond
to this comment. Some of the
Exhibit 71
2 | P a g e
indication as to which standard
will be followed
water quality monitoring,
controls and reporting.
confusion may result from the
fact that there are two water
quality monitoring plans that
are designed to address
different concerns. Appendix O
requires monitoring to ensure
anticipated groundwater
withdrawals are not causing sea
water intrusion into the
groundwater. Appendix N, on
the other hand, addresses
monitoring for contaminants
and is further divided into
monitoring impacts to surface
waters in Pleasant Harbor and
groundwater.
Depending on the plan, the most
prominent language around
water quality standards seems to
be that the resort will not violate
WQ criteria and will take
corrective action if violated. This
"emergency room" response only
requires action if water quality is
degraded beyond State
standards.
There should be a trigger point
that requires assessment,
identification and control as a
preventative measure, rather
than an reactionary measure
once criteria are violated and the
harm has been done. Including a
condition such as "a trigger point
of three consecutive readings
above 10% of seasonal baseline
levels, one reading at or above
20% of seasonal baseline levels,
or state criteria is surpassed -
whichever comes first" is an
example of early detection and
correction condition that will
help address issues before early.
We disagree with the
characterization of the plans as
an “emergency room”
response. The plans have
proactive measures to address
possible problems before water
quality standards are violated.
For example, and without
limitation, in the event sampling
results show three consecutive
increases of contaminant
concentrations (regardless of
whether water quality
standards are violated) Pleasant
Harbor must take additional
steps to investigate the cause of
the increase and take action to
address any project
construction or operation. No
other resort in the region has
similar requirements including
Port Ludlow or Alderbook.
Finally, the Tribe’s focus on the
plans ignores other aspects of
the resort plan aimed at
preventing water quality
impacts in the first place
including, but not limited to,
Exhibit 71
3 | P a g e
construction of a WWTP instead
of a system of LOSSs and zero-
discharge to Hood Canal among
other design elements.
The WWTP and water re-use is
generally a positive attribution of
this project but they can fail or
malfunction and potentially
cause major impacts to nearby
shellfish beds (i.e. bacteria
contamination).
We request that tribes with U&A
in Hood Canal be notified within
48 hours if there is any
unintended, unplanned or
emergency discharge of
untreated or partially treated
water from the plant to the
marine environment.
We are pleased that the Tribe
views the applicant’s decision to
construct a WWTP and re-use
water as a positive project
attribute. We agree.
In the unlikely event of a direct
discharge of untreated or
partially treated water to Hood
Canal the Operator is legally
required to report the discharge
to the Washington Department
of Ecology. Ecology would then
report to potentially affected
parties including, presumably,
the Tribe.
Development will act as
attractant to nearby elk herds
that are a treaty resource -
Dosewallips SP is an example of
this. Vehicle collisions from
increased traffic and lack of
exclusions unnecessarily
imperils this resource and
people's safety.
Add exclusionary, elk-proof
fencing around the resort to
prevent habituation and road
crossings will prevent the vast
majority of collisions. Tribes will
work with Jefferson County to
frame out a condition within the
Prelim Plat Application to add a
layer of specificity of fence
requirements (i.e. min 8 ft, etc)
as discussed in the technical
meeting on 3/14/25.
This comment is disappointing.
Over the last decade Pleasant
Harbor has made a significant
effort to address tribal concerns
regarding elk migration. Elk
exclusionary fencing has been
proposed for the portions of the
resort fronting 101 for over a
decade. The initial plan
prepared by a qualified biologist
recommended scare tactics and
other non-structural methods
before fencing. Pleasant
Harbor, to address various tribal
concerns with that iterative
approach, voluntarily agreed to
construct fencing outright.
The wildlife plan has
contradictions, irregularities and
dubious action points that make
it difficult for us, and eventually
the applicant from interpreting
its standards.
Amend the plan to add
clarification with clear action
points. We can provide some
examples of needed
clarifications.
Again, the applicant clearly
understands its obligation
under the approved Wildlife
Plan and disagrees with the
characterization. To the extent
the confusion derives from
Exhibit 71
4 | P a g e
portions of the plan that
emphasized the use of scare
tactics prior to constructing an
elk fence please note the
response above.
In addition, it should be noted
that Pleasant Harbor redesigned
its entire stormwater plan at
significant expense to avoid
disturbing the wetland in Kettle
B to further limit the impact
development would have on
wildlife.
Thank you for considering these responses. Our team is available if further discussion is
needed.
Sincerely,
John (JT) Cooke
Attorneys for Pleasant Harbor Maring &
Golf Resort LLP
Cc: Client (via email)
Christina Haworth (via email)
Phil Hunsucker (via email)
Exhibit 71