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HomeMy WebLinkAbout74_2025-1010_FINAL Addendum to Staff ReportExhibit 74 ADDENDUM TO STAFF REPORT Jefferson County Preliminary Plat Application Case No. SUB2023-00025 Issue Date: October 10, 2025 Pleasant Harbor Master Planned Resort Jefferson County Staff Report ADDENDUM Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued October 10, 2025 EXHIBIT 74 Page 2 of 24 Contents Figures .............................................................................................................................. 2 Tables .............................................................................................................................. 2 Exhibits .............................................................................................................................. 2 SECTION 1. Application Information ........................................................................................... 3 SECTION 2. Definitions and Table of Acronyms .......................................................................... 4 A. Definitions ...................................................................................................................... 4 B. Table of Acronyms ........................................................................................................... 4 SECTION 3. Additional Analysis in Response to Public Comments ............................................. 5 A. Public Comments Received ........................................................................................... 5 B. Corrections to Staff Report ........................................................................................... 10 C. Supplemental Analysis ................................................................................................. 10 1. Public Notices and Issuance of Staff Report ................................................... 10 2. Phasing and Role of Preliminary Plat in Project Development ........................ 11 3. Clarification of Appropriate Level of Review ................................................... 11 4. Clarification of Residential Thresholds Approved ............................................ 12 5. Road Safety & Traffic ..................................................................................... 13 6. Water Availability ............................................................................................ 13 7. Project Inconsistent with Rural Character ....................................................... 15 8. Wastewater Treatment ................................................................................... 16 9. Project Lacks Adequate Fire Access and Safety............................................. 16 10. Project is Environmentally Unsound ............................................................. 17 11. Perimeter (Elk Exclusion) Fencing ................................................................ 18 12. Other Comments .......................................................................................... 19 SECTION 4. Proposed Changes to Findings and Conclusions ................................................. 24 SECTION 5. Proposed Changes to Staff Recommendation ...................................................... 24 Figures Figure 1: Existing and tentative proposed locations for water source wells ........................... 14 Figure 2: Summary of overall project timeline. ....................................................................... 21 Figure 3: Excerpt of Preliminary Civil Plans (Sheet 23, Exhibit 33) ........................................ 23 Tables Table 1: Adjacent Property Zoning and Land Use Information. ................................................ 4 Exhibits See Exhibit Log for Jefferson County Preliminary Plat Application Case No. SUB2023-00025, issued October 10, 2025. Jefferson County Staff Report ADDENDUM Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued October 10, 2025 EXHIBIT 74 Page 3 of 24 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 ADDENDUM Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued October 10, 2025 EXHIBIT 74 Page 4 of 24 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 SECTION 2. 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.1 B. Table of Acronyms Acronym Meaning BMPs Best Management Practices CC&Rs Covenants, Conditions, and Restrictions DCD Department of Community Development, Jefferson County DOE Department of Ecology, Washington DOH Department of Health, Washington FDC Fire Department Connection FEIS Final Environmental Impact Statement FS&CA Future Staffing & Consultant Agreement FSEIS Final Supplemental Environmental Impact Statement 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 JST Jamestown S’Klallam Tribe L&I Labor and Industries, Washington Department of LOSS Large Onsite Septic System Master Plan The master plan defined in Development Agreement Section 3.2 and JCC 17.60.040 MOU Memorandum of Understanding ODW Office of Drinking Water, Washington Department of Health OSS Onsite Septic System 1 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 ADDENDUM Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued October 10, 2025 EXHIBIT 74 Page 5 of 24 PHMPR Pleasant Harbor Master Planned Resort PGST Port Gamble S’Klallam Tribe PNPTC Point No Point Treaty Council Property The property described in Section 5 of this Staff Report RCW Revised Code of Washington SWMMWW Stormwater Management Manual for Western Washington TESC Temporary Erosion and Sediment Control WAC Washington Administrative Code WSDOT Washington State Department of Transportation WSP Water System Plan SECTION 3. Additional Analysis in Response to Public Comments As described in Section 6.D of the Staff Report issued on September 15, 2025, a Notice of Revised Application was issued on August 27, 2025. A 14-day public comment period was used in the Notice of Revised Application, and the comment period ended at 5:00pm on September 16, 2025. A total of 14 new public and Tribal comments were submitted in response to the Notice of Revised Application. Pursuant to JCC 18.40.280(2) as set forth in Appendix E to the Development Agreement, a project staff report is required to include and consider all written public comments on the application. This Addendum to Staff Report presents additional information to appropriately include and consider these additional public comments. A. Public Comments Received As described in Section 3, public comments were submitted in response to the Notice of Revised Application. Comments are briefly summarized and can be found in full in Exhibits 65K-65X and 66H. Name Summary of Comments and County Action Jamestown S'Klallam Tribe Allie Taylor September 11, 2025 See Exhibit 66H Summary of Comments: Request to preserve and protect traditional cultural property (Kettles B and C and adjacent wetlands). Flaws in FEIS and FSEIS processes related to evaluation of cultural resources. Cultural resource inventory is outdated and does not comply with current Washington State Standards for Cultural Resources Reporting provided by the Department of Archaeology and Historic Preservation. Inappropriate burden on Tribes to document and nominate site. County Action: Response provided on October 8, 2025. See Exhibit 70 (Jefferson County response) and Exhibit 71 (Applicant response). Jac Dufresne September 12, 2025 Summary of Comments: Opposed based on financial feasibility, environmental impacts, and incompatibility with rural Jefferson County Staff Report ADDENDUM Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued October 10, 2025 EXHIBIT 74 Page 6 of 24 Name Summary of Comments and County Action See Exhibit 65K community. Impacts are traffic, pollution, safety risks. County Action: Analyzed in Addendum to Staff Report. See Sections 3.C.7, 3.C.9, 3.C.10, and 3.C.12. Cindy Ger September 12, 2025 See Exhibit 65L Summary of Comments: Opposed based on lack of information in application and potential impacts. Key issues are traffic with no plans to update Black Point Road/US 101 intersection; lack of adequate water; impacts to aquifer; financial feasibility. Inappropriate time to sell lots. County Action: Analyzed in Addendum to Staff Report. See Sections 3.C.5, 3.C.63.C.10, and 3.C.12. Bob Carson September 12, 2025 See Exhibit 65M Summary of Comments: Opposed based on permeability of underlying soils and sediments and potential pollution in Hood Canal, saltwater intrusion. County Action: Analyzed in Addendum to Staff Report. See Section 3.C.10. Julia Cochrane September 14, 2025 See Exhibit 65N Summary of Comments: Opposed based on financial feasibility; timing of lot sales vs. construction of amenities; golf course design; incompatibility with rural character; no plans for US 101/Black Point Road intersection; insufficient fire flow. County Action: Analyzed in Addendum to Staff Report. See Sections 3.C.2, 3.C.3, 3.C.5, 3.C.6, 3.C.7, and 3.C.12. Black Point Advocates Residents of Brinnon September 15, 2025 See Exhibit 65O Summary of Comments: Opposed. Key issues are population density/ incompatibility with rural community; overwhelm of existing infrastructure; reliance on out-of-town workers; lack of access to amenities for Brinnon residents; preservation of natural attractions/ resources; preference for septic vs. sewer to reduce air and water pollution; light, noise, traffic, solid Jefferson County Staff Report ADDENDUM Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued October 10, 2025 EXHIBIT 74 Page 7 of 24 Name Summary of Comments and County Action waste, and air quality impacts; reduction of natural space; displacement of wildlife. County Action: Analyzed in Addendum to Staff Report. See Sections 3.C.7, 3.C.8, and 3.C.10. Sierra Club North Olympic Group Darlene Schanfald, Ph.D. September 15, 2025 See Exhibit 65P Summary of Comments: Opposed based on environmental impacts. Key issues: water availability; pollution related to sewer treatment plant/ unregulated influent contaminants/ sewage discharge impact on algal blooms and dead zones; emergency evacuation; traffic and air pollution; groundwater runoff/ pollution; golf course maintenance needs (water); protection of in-stream water flows; responsibilities for maintenance by HOA/ residents. County Action: Analyzed in Addendum to Staff Report. See Sections 3.C.6, 3.C.8, 3.C.10, and 3.C.12. Matthew Iles-Shih September 15, 2025 See Exhibit 65Q Summary of Comments: Request for clarification on key issues: extent of perimeter fencing; stormwater management and protection of aquifer and surface water resources; protection of aquifer and surface water with respect to pollution-generating activities (fertilizers, pesticides); ongoing management of water quality and quantity and impacts on neighbors. County Action: Analyzed in Addendum to Staff Report. See Sections 3.C.6, 3.C.10, and 3.C.11. Lys Burden September 16, 2025 See Exhibit 65R Summary of Comments: Opposed based on noncompliance with State laws. Key issues: order of construction/ failure to build amenities and hotel first; pattern of performance by Statesman; financial feasibility; US 101/Black Point Road intersection improvements; inappropriate time to develop lots. County Action: Analyzed in Addendum to Staff Report. See Sections 3.C.2, 3.C.5, and 3.C.12. Jefferson County Staff Report ADDENDUM Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued October 10, 2025 EXHIBIT 74 Page 8 of 24 Name Summary of Comments and County Action Laura Straight September 16, 2025 See Exhibit 65S Summary of Comments: Opposed based on financial feasibility; modular construction and noncompliance with State laws; water availability; small lots are incompatible with rural character; emergency access inadequate; no plans for US 101/Black Point Road intersection improvements; pattern of performance by Statesman. County Action: Analyzed in Addendum to Staff Report. See Sections 3.C.5, 3.C.6, 3.C.9, and 3.C.12. Beth Stroh-Stern September 16, 2025 See Exhibit 65T Summary of Comments: Opposed due to intensity of use, traffic, loss of natural beauty and resources, water quality impacts (runoff, pollution). Concerns about loss of mature vegetation necessary to protect Pleasant Harbor and Hood Canal. Concerns about work possibly performed without permits, mitigation (replanting) not provided. County Action: Analyzed in Addendum to Staff Report. See Sections 3.C.6, 3.C.7, 3.C.10, and 3.C.12. Lou Leet September 16, 2025 See Exhibit 65U Summary of Comments: Opposed based on financial feasibility; emergency response and security; small lots are incompatible with rural character; no plans for US 101/Black Point Road intersection improvements; water availability for fire flow; emergency evacuation; police availability. County Action: Analyzed in Addendum to Staff Report. See Sections 3.C.5, 3.C.6, 3.C.7, 3.C.9, 3.C.12. Joanie Hendricks September 16, 2025 See Exhibit 65V Summary of Comments: Opposed based on financial feasibility; inappropriate time to sell lots/ missing amenities; vague and unrealistic amenities; no plans for US 101/Black Point Road intersection improvements. County Action: Analyzed in Addendum to Staff Report. See Sections 3.C.3, 3.C.5 and 3.C.12. Jefferson County Staff Report ADDENDUM Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued October 10, 2025 EXHIBIT 74 Page 9 of 24 Name Summary of Comments and County Action Rick Aramburu The Brinnon Group September 16, 2025 See Exhibit 65W Summary of Comments: Opposed based on: phasing and order of construction inconsistent with Amendment 2 to Development Agreement; lack of progress on construction of resort amenities; Statesman’s history of performance on other projects; lack of detailed location and design information about various resort amenities; ambiguity in some site features; water and sewer district not yet formed; lack of water availability for fire flow (structure and wildland fires); lack of sufficient water rights; lack of information about “independent living elder care facility;” stormwater information lacks clarity; missing CC&Rs. County Action: Analyzed in Addendum to Staff Report. See Sections 3.C.2, 3.C.6, 3.C.10, and 3.C.12. Bob Carson September 27, 2025 See Exhibit 65X Summary of Comments: Opposed based on permeability of underlying soils and sediments and potential pollution in Hood Canal, saltwater intrusion, density, traffic. Noise from go-kart track could impact marine mammals. County Action: Analyzed in Addendum to Staff Report. See Sections 3.C.10 and 3.C.12. Point No Point Treaty Council Cynthia Rossi October 9, 2025 See Exhibit 66I Summary of Comments: Requests for edits to conditions of approval and amendments to governing documents. Key issues include: extent and design of elk exclusion fencing and the integration of cattle grates/guards; water quality monitoring; protection of shellfish resources; improved Tribal consultation and communication; protection of cultural resources. County Action: Most issues addressed in November 13, 2024, letter from Board of County Commissioners to PNPTC. Additional information addressed in Section 7.F of the Staff Report (Exhibit 1). Jefferson County Staff Report ADDENDUM Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued October 10, 2025 EXHIBIT 74 Page 10 of 24 B. Corrections to Staff Report Staff has identified the following errors in the Staff Report: 1. Incorrect Water System Plan. The version of Exhibit 24, Water System Plan, originally posted on the City’s “2025 PHMPR Public Hearing” webpage is an older version that was replaced with an update dated June 27, 2025. The June 27, 2025, version of the water system plan (WSP) is the version that was analyzed in the Staff Report and submitted into the record as Exhibit 24. C. Supplemental Analysis Public comments identified several areas of concern. This Addendum to Staff Report provides additional analysis to respond to substantive issues. 1. Public Notices and Issuance of Staff Report Notice of Issuing Staff Report not Required As described in Section 7.B of the Staff Report (Exhibit 1), this project is vested to the application procedures set forth in Chapter 18.40 JCC (Appendix E to the Development Agreement). Section 6.C of the Staff Report describes the procedural requirements, which include issuing a Notice of Application and a Notice of Public Hearing pursuant to JCC 18.40.150(2). Jefferson County issued an additional Notice of Revised Application as a courtesy to interested parties because project revisions submitted on June 23, 2025, changed some elements of the proposal, although the proposal remains consistent with the overall development thresholds analyzed in the Final Environmental Impact Statement (FEIS) and Final Supplemental Environmental Impact Statement (FSEIS). The procedural requirements in Chapter 18.40 JCC do not require notification when a staff report or recommendation is issued. Information about the availability of project documents was included in the Notice of Public Hearing issued on September 24, 2025. Incorrect RCW Reference in Notice of Revised Application The Notice of Revised Application, a notice issued voluntarily by Jefferson County as a courtesy to interested parties, inadvertently included a reference to RCW 58.17.095(2). This RCW states, “The applicant has seven days from receipt of the comments to respond thereto.” This RCW does not apply because Jefferson County is holding a public hearing for this preliminary plat. RCW 58.17.095 allows municipalities to adopt an ordinance that allows them to process preliminary plats without a public hearing. If a jurisdiction adopts such an ordinance, then the comment and response periods apply. Project Location An error was identified in the parcel numbers included in the Notice of Public Hearing: “308913 US 101, Brinnon, WA 98320 (Parcel Nos.502153020, 502153021, 502153022, 503153023, 503154002, 50215300, 502152005, 502153003),” (emphasis added). The correct parcel number is 502153003. The Notice of Public Hearing also included both a street address and a vicinity map, which are sufficient to ensure interested parties can locate the project proposal and provide meaningful substantive comment on the application. Jefferson County Staff Report ADDENDUM Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued October 10, 2025 EXHIBIT 74 Page 11 of 24 2. Phasing and Role of Preliminary Plat in Project Development Phasing Compliance Comments express skepticism and serious concerns about the project’s adherence to phasing requirements in Amendment 2 to the Development Agreement. Phasing was analyzed in Section 7.G of the Staff Report (see paragraphs 168-173, Exhibit 1). Compliance with phasing is mandatory pursuant to Amendment 2 to the Development Agreement, and Jefferson County will follow all appropriate procedures to ensure the project meets these requirements. One comment also dissects the Construction Order Narrative (Exhibit 46). Conditions of approval are recommended to ensure the project will meet the phasing requirements in Amendment 2 to the Development Agreement, regardless of the Applicant’s proposed construction sequence from November 2023. Role of Preliminary Plat in Project Development Several comments indicate that this is an inappropriate time to sell lots. Lots are not created with a preliminary plat and cannot be sold as a result of any decision on this application. A preliminary plat is a “neat and approximate drawing of a proposed subdivision showing the general layout of streets and alleys, lots, blocks, and other elements of a subdivision consistent with [Chapter 58.17 RCW]. The preliminary plat shall be the basis for the approval or disapproval of the general layout of a subdivision,” as set forth in RCW 58.17.020(14). The purpose of the preliminary plat is to consider various factors described in RCW 58.17.110, which states that “The…county legislative body shall inquire into the public use and interest proposed to be served by the establishment of the subdivision and dedication. It shall determine: (a) If appropriate provisions are made for, but not limited to, the public health, safety, and general welfare, for 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 shall consider 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 (b) whether the public interest will be served by the subdivision and dedication.” The preliminary plat approval authorizes the general layout of the subdivision, provided it meets this review standard. Following preliminary plat, infrastructure and other development requirements must be completed and accepted by Jefferson County prior to considering a final plat application. Only after a final plat (that contains residential lots and tracts, if the project is platted in phases) has been approved and recorded with Jefferson County can residential lots and tracts be sold. 3. Clarification of Appropriate Level of Review A central point made in many comments related to phasing is the lack of both conceptual and detailed design information for various resort amenities and facilities. Comments indicate that the plat lacks information about the locations of certain facilities or amenities, and that there are no detailed plans or drawings of the facilities and amenities available to determine if the plat will meet the definition of a master planned resort as described in RCW 36.70A.360. The required components of the Pleasant Harbor Master Planned Resort (PHMPR) are established in the master plan (section 3.2 of the Development Agreement and JCC 17.60.040). The master plan describes the specific facilities the project must provide to constitute a master planned resort consistent with RCW 36.70A.360. Jefferson County Staff Report ADDENDUM Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued October 10, 2025 EXHIBIT 74 Page 12 of 24 As an implementing application, the preliminary plat application must demonstrate consistency with the master plan at a level appropriate for the division of land. A preliminary plat application does not authorize “development” or other construction activities; according to RCW 58.17.020(14), it is a “neat and approximate drawing of a proposed subdivision showing the general layout of streets and alleys, lots, blocks, and other elements of a subdivision consistent with [Chapter 58.17 RCW]. The preliminary plat shall be the basis for the approval or disapproval of the general layout of a subdivision.” Because the purpose of a preliminary plat application is to consider the general layout of the proposed subdivision and not to authorize construction, detailed construction and engineering drawings are not required. Similarly, certain standards for building massing, including height, are also not reviewed with the preliminary plat because they are not germane to the layout of the proposed subdivision. Pursuant to the Hearing Examiner Rules of Procedure, the “moving party” (the applicant) “shall have the burden of proof as to the material factual issues, except where applicable code provision, state law, or Washington common law provides otherwise,” (see Rule 5.14(j)). For Type III land use decisions, including this preliminary plat application, the burden of proof is “a preponderance of the evidence and the burden is on the applicant to demonstrate compliance with applicable policies, regulations, and laws,” (see Rule 5.14(j)(ii)). This means that, although Jefferson County reviews for compliance, the applicant is responsible for submitting an application that is consistent with the governing documents and all applicable policies, regulations, and laws. 4. Clarification of Residential Thresholds Approved Some comments indicate that the total residential development thresholds reviewed in the FEIS and FSEIS and established in section 3.2 of the Development Agreement and JCC 17.60.070 are confusing. The FEIS and FSEIS considered short- and long-term rentals as well as permanent residences in the same “residential” use category, likely due to how water use is calculated. The 890 residential units authorized in the Development Agreement and JCC 17.60.070 include the following: • Short-term visitor accommodation, including hotel or motel units • Multifamily dwelling units, such as staff housing and apartments • Condominiums • Townhouses • Single-family dwelling units • And all other uses intended for long-term and short-term occupation A key distinction that is not typical for other projects is that hotel units and similar short-term rental units (such as the bed and breakfast houses in the Pleasant Harbor Marina district) are counted toward the residential cap in this project. Hotels are more usually classified as a commercial use, rather than a residential use, possibly leading to confusion about the amount of residential development proposed on this site. The project will include 225 hotel units, 66 multifamily units, 381 condominium units, and 150 detached residential units. Off-site residential uses include the two existing bed and breakfasts and the Maritime Village building (66 units). Refer to Table 2 in the Staff Report (Exhibit 1) for a breakdown of the residential uses proposed in the upland golf resort, that will be accommodated within the preliminary plat. Jefferson County Staff Report ADDENDUM Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued October 10, 2025 EXHIBIT 74 Page 13 of 24 5. Road Safety & Traffic US Highway 101/Black Point Road Intersection Improvements Not Complete Many comments indicate that the project may be deficient because the improvements required at the intersection of US Highway 101 and Black Point Road have not been completed. As described in section 10 of the Development Agreement (as amended), the intersection improvements must occur as part of phase 1 of the project. The FEIS includes mitigation measures for the design of the intersection improvements. The Washington State Department of Transportation (WSDOT) will review the portion of the intersection within the US Highway 101 right-of-way and Jefferson County will review the portion of the intersection within Black Point Road. See Section 7.D of the Staff Report for additional information (see paragraphs 84-91, Exhibit 1). As of the date of this Addendum to Staff Report, no permit applications have been filed for the intersection improvements. The improvements must be completed or bonded prior to completion of phase 1 of the project. It is typical for intersection improvements to be permitted and constructed between the preliminary plat and final plat actions on a project. Traffic One comment indicates that US Highway 101 and the Brinnon-area street network cannot handle the traffic the project will generate. Traffic was analyzed in the FEIS and FSEIS and mitigating conditions were proposed. To the extent appropriate for preliminary plat, those mitigating conditions have been incorporated into the project design. Verification of compliance with other mitigating conditions will occur with permits appropriate to those mitigating conditions. See Section 7.D of the Staff Report for more information on transportation considerations. 6. Water Availability Comments raise concerns about the availability of water and protection of surface and groundwater sources. Stormwater Management One comment raises concerns about the impact of stormwater on ground and surface water resources. Stormwater was analyzed primarily in Section 7.D of the Staff Report (see paragraphs 70-83, Exhibit 1). Information about proposed stormwater treatment was provided in the Drainage Report submitted with the application (Exhibit 26). As noted in the staff report, all stormwater must be collected for on-site infiltration; no off-site discharge is allowed. Stormwater design must comply with the current adopted Stormwater Management Manual for Western Washington (SWMMWW) in effect when permits are submitted. The SWMMWW is published by the Department of Ecology with the express purpose of controlling the quantity and quality of stormwater produced by new development and redevelopment to comply with water quality standards and contribute to the protection of beneficial uses of receiving waters. This is accomplished through application of appropriate minimum requirements and best management practices (BMPs). The current adopted SWMMWW is the 2024 edition. The SWMMWW establishes minimum requirements for water quality treatment prior to infiltration and compliance is reviewed with each development application that is submitted. Jefferson County Staff Report ADDENDUM Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued October 10, 2025 EXHIBIT 74 Page 14 of 24 Water Source One comment indicates that the water source is unclear. Chapter 3 of the WSP (Exhibit 24) provides a system inventory and analysis. According to the water source inventory section 3.3.1, the proposed Pleasant Harbor Water System has one existing well (the American Campground well) that will be rehabilitated to bring it into compliance with applicable provisions for Group A public water supplies set forth in WAC 246-290, including the source approval requirements in WAC 246-290-130. Up to two additional water source wells are proposed to meet the water supply demand of the upland golf resort. The American Campground well and two additional wells are all potable water source wells that will supply domestic water usage and fire flow needs; irrigation will be provided by detained stormwater and reclaimed water. The American Campground well is shown on the plat in Tract X-2 adjacent to Hole No. 3 (Sheet 21, Exhibit 33). Appendix 8 in the WSP (Exhibit 24) identifies tentative locations for new source wells (Figure 1). Figure 1: Existing and tentative proposed locations for water source wells. Source: Draft Water System Plan, dated June 27, 2025 Adequacy for Emergency Response Many comments express concern about the adequacy of water availability in emergency situations involving either structure or wildland (forest) fires. Water rights documentation was provided with the application (Exhibits 14-21). Water availability was analyzed in Section 7.D of the Staff Report (see paragraphs 115-126, Exhibit 1). As described in the staff report, a WSP has been prepared by a professional engineer (Exhibit 24), and the water system must achieve a fire flow rate of 2,000 gallons per minute pursuant to the International Fire Code (IFC). The Existing American Campground Source Well (SO-1) Proposed Source Well (SO-3) Proposed Source Well (SO-2) Jefferson County Staff Report ADDENDUM Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued October 10, 2025 EXHIBIT 74 Page 15 of 24 Jefferson County Coordinated Water System Plan (CWSP) adopts fire flow and maximum fire hydrant spacing standards, which are: • Residential: 750 GPM; 30 minute duration • Commercial: 1000 GPM; 60 minute duration • Multi-Family Residential: 1000 GPM; 60 minute duration • Industrial: 1500 GPM; 60 minute duration These standards exceed the minimums set forth in WAC 246-293-640. The water system must be designed to achieve these minimum fire flow standards and actual performance will be verified with construction permits and inspections (Exhibit 72). Appendix 10 of the WSP includes a section on fire flow modeling that will be validated after source well development and testing. The WSP has not yet been approved by the Office of Drinking Water (ODW) at the Washington Department of Health (DOH). An approved plan must be provided prior to issuing construction permits for water infrastructure. According to the Fire Marshal (Exhibit 72), Jefferson County typically uses mutual aid, water tenders, fire breaks, and air support to fight fires in a rural setting. The project is required, through its MOU with the Brinnon Fire Department (Appendix J02 to the Development Agreement), to comply with Firewise standards such as providing defensible space around buildings and using ignition resistant construction standards. Under the IFC, certain building occupancy types and uses also require the installation of automatic sprinkler systems, which will be verified with construction permits as applicable. The developer must provide for and accommodate minimum fire safety standards and equipment during construction, prior to having functional fire hydrants. Per the Fire Marshal, “Jefferson County requires developers to collaborate with the county and provide a detailed scope of work involved at each phase of construction. This could include portable tanks or water trucks as well as pumps or other equipment depending on the activity and or construction details,” (Exhibit 72). 7. Project Inconsistent with Rural Character Comments indicate that “small” lots on narrow roads are inappropriate for a rural area. The proposed lots range in size from approximately 0.12 acres (5,100 square feet) to 0.54 acres (23,350 square feet), with most lots approximately 0.15-0.20 acres in size. These are typical sizes for urban and suburban development. The PHMPR project is a master planned resort as described in RCW 36.70A.360. Counties planning under the Growth Management Act (GMA), including Jefferson County, can permit master planned resorts which “may constitute urban growth outside of urban growth areas as limited by” RCW 36.70A.360. The project as contemplated in the Brinnon Sub-Area Plan, Comprehensive Plan, FEIS, FSEIS, Development Agreement, and applicable development regulations constitutes urban growth outside of an urban growth area consistent with this section. The size and scale of the lots meet the intention of a master planned resort and are appropriate for this project even though the project is in a rural area. Jefferson County Staff Report ADDENDUM Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued October 10, 2025 EXHIBIT 74 Page 16 of 24 8. Wastewater Treatment One comment indicates a preference for on-site septic (OSS) treatment for wastewater, compared to the proposal to use a community sewer (wastewater treatment plant). According to the DOH, “septic systems (or on-site sewage systems) are underground wastewater treatment structures that [individuals] own and operate.”2 “OSS systems that are properly designed, installed, and maintained can effectively treat residential wastewater for a long time. However, system failures can and do occur. When this happens both public health and the environment are threatened. An OSS failure can be caused by bad system design, improper maintenance, or simply because the system has reached the end of its life expectancy. System owners are often not aware when their OSS has stopped functioning properly and failing OSS are not detected. There are many documented cased where failing OSS have polluted surrounding areas.”3 PHMPR originally included a large on-site septic system (LOSS) as an interim measure until the wastewater treatment plant could be installed and functional. The LOSS was removed in favor of installing the wastewater treatment plant at the outset. A wastewater treatment plan is preferable to multiple OSS. Not only does this remove the potential for undetected failure in individual septic systems, wastewater treatment plans have annual testing and reporting requirements and are subject to permits issued by the Department of Ecology (DOE).4 Annual reports provide information for DOE inspectors to ensure compliance with applicable requirements; inform statewide management of wastewater and biosolids treatment; and are publicly available.5 Treated water must meet State standards; a portion of the water will be reclaimed for re-use in non-potable purposes such as irrigation. 9. Project Lacks Adequate Fire Access and Safety Commenters are concerned about the ability to evacuate the site in the event of an emergency and with cooperation with and support for Jefferson County in managing an evacuation. Commenters are also concerned about fire access within the site. Impacts to fire response and other emergency services were analyzed in the FEIS and FSEIS and mitigating conditions were adopted. PHMPR entered into a Memorandum of Understanding (MOU) with the Brinnon Fire District, which was adopted as Appendix J02 to the Development Agreement. Adherence to the mitigating conditions in the FEIS, FSEIS, and MOU are mandatory pursuant to section 3.2 of the Development Agreement and JCC 17.60.060. Impacts to public services and fire safety were analyzed in Section 7.E of the Staff Report (see paragraphs 157-155, Exhibit 1). The Fire Marshal has reviewed the proposal and determined that two points of ingress and egress are required. These have been provided at the main entrance near the intersection of US Highway 101 and Black Point Road and at a secondary entrance near the intended staff housing and AgraCenter location further west on Black Point Road. The project must meet applicable requirements in the IFC for the design of roadways and buildings to ensure public safety in the event of a fire. Road requirements include (but are not 2 https://doh.wa.gov/community-and-environment/wastewater-management/septic-system 3 https://doh.wa.gov/community-and-environment/wastewater-management/site-sewage-systems-oss 4 https://ecology.wa.gov/waste-toxics/reducing-recycling-waste/biosolids/learn-about/permit-actions 5 https://ecology.wa.gov/regulations-permits/permits-certifications/biosolids-facilities-fees-forms-annual- report#AnnualReports Jefferson County Staff Report ADDENDUM Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued October 10, 2025 EXHIBIT 74 Page 17 of 24 limited to) width, turning radius, and bearing weight to support fire apparatus. Building requirements include (but are not limited to) the use of fire-rated materials, sprinkler systems, and fire hydrant/fire department connection (FDC) locations. These are reviewed with construction permits for infrastructure and buildings. 10. Project is Environmentally Unsound Pollution from Chemicals and Stormwater Comments raised concerns about environmental impacts from pollution generated by PHMPR. Environmental impacts were analyzed in the FEIS and FSEIS and mitigating conditions are required. Mitigating conditions include (but are not limited to): a. Implementation of the Best Management Practices for Golf Course Development and Operation manual published by King County in 1993. Portions of this manual applicable to site design and the preliminary plat application were analyzed in Section 7.C of the Staff Report (see paragraphs 34-36 in Exhibit 1). This manual includes requirements for selecting, using, and storing chemicals to maintain the golf course, and compliance with these requirements will be reviewed with applicable development applications for the golf course. b. Use of native species in landscaping and adherence to the Vegetation Management Plan adopted as Appendix L to the Development Agreement. c. Mandatory zero stormwater discharge from the site. All stormwater must be collected and infiltrated on site with no direct discharge to surface water sources. d. Compliance with the current adopted SWMMWW in effect when permits are submitted. The SWMMWW is published by the Department of Ecology with the express purpose of controlling the quantity and quality of stormwater produced by new development and redevelopment to comply with water quality standards and contribute to the protection of beneficial uses of receiving waters. This is accomplished through application of appropriate minimum requirements and BMPs. The current adopted SWMMWW is the 2024 edition. The SWMMWW establishes minimum requirements for water quality treatment prior to infiltration and compliance is reviewed with each development application that is submitted. The project is required to incorporate and comply with these and all other mitigating conditions pursuant to section 3.2 of the Development Agreement and JCC 17.60.040. Failure to comply with the conditions is enforceable under JCC Title 19 (Code Compliance). Additional water quality best management practices for development and operation of the golf resort are adopted in Appendix 1 of Amendment 1 to the Future Staffing and Consultant Agreement (FS&CA). Saltwater Intrusion Saltwater intrusion was evaluated in the FSEIS and is based, in part, on a Hydrogeologic Memo prepared by the DOE. As described in Section 7.D of the Staff Report (see paragraph 129, Jefferson County Staff Report ADDENDUM Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued October 10, 2025 EXHIBIT 74 Page 18 of 24 Exhibit 1), DOE found that saltwater intrusion was not a widespread problem on the Black Point peninsula. As noted in Section 7.C of the Staff Report (see paragraph 40, Exhibit 1), PHMPR is required to conduct ongoing water quality monitoring for potential saltwater intrusion. If saltwater intrusion does impact existing domestic wells, the Neighborhood Water Policy adopted in Appendix O to the Development Agreement requires PHMPR to allow impacted well owners to connect to PHMPR’s water system. Water Quality Monitoring Water quality monitoring in Pleasant Harbor and at three groundwater monitoring wells on the upland golf resort property is mandatory. Water quality monitoring must follow all requirements set forth in the Water Quality Monitoring Plan adopted as Appendix N to the Development Agreement and in the Best Management Practices adopted in Appendix 1 of Amendment 1 to the Development Agreement. The Water Quality Monitoring Plan establishes the criteria for monitoring surface and groundwater quality, which are consistent with the Department of Ecology’s regulations in WAC 173-201A-210 and WAC 173-200-040. Vegetation Removal and Slope Stability Several comments highlight the loss of vegetation and resultant impacts to slope stability. Slope stability was studied in the FEIS and FSEIS, and additional geotechnical information has been analyzed for this application (see Exhibits 31A-F). Recommended conditions require the project to incorporate and adhere to all geotechnical recommendations. Slope stability has been adequately addressed for the preliminary plat application (see Section 7.C of the Staff Report, Exhibit 1). Additional analysis is required for construction permit applications to review structural aspects of building and infrastructure design. Preservation of Natural Resources and Scenic Beauty Comments also indicate concerns about vegetation removal and the loss of scenic or aesthetic value in the project vicinity. As a matter of policy, Jefferson County has determined that the Black Point peninsula is an appropriate location for a master planned resort because of the scenic beauty of this location. Pursuant to RCW 36.70A.360(1), a master planned resort is “a self-contained and fully integrated planned unit development, in a setting of significant natural amenities, with primary focus on destination resort facilities consisting of short-term visitor accommodations associated with a range of developed on-site indoor or outdoor recreational facilities,” (emphasis added). Development of the project is consistent with applicable comprehensive plan policies, including policies in the Brinnon Sub-Area Plan, as described in Section 7.A of the Staff Report (Exhibit 1). 11. Perimeter (Elk Exclusion) Fencing Comments requested additional information about the proposed perimeter fencing used to exclude elk from the site. The comment noted concerns about fencing the east side of the property, including potential impacts to the ecology of the Black Point peninsula. Exclusion of elk has been a consistent concern of the Port Gamble S’Klallam Tribe (PGST) and Jamestown S’Klallam Tribe (JST). In lieu of proximity-activated flashing signage, the Applicant proposes to install the exclusion fence described in the Wildlife Management Plan adopted as Jefferson County Staff Report ADDENDUM Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued October 10, 2025 EXHIBIT 74 Page 19 of 24 Appendix P to the Development Agreement. The Wildlife Management Plan provides an adaptive approach to wildlife management with a series of escalating measures to discourage browsing and foraging on the property. Installation of the fence is consistent with the Wildlife Management Plan and represents an escalated intervention compared to the flashing signage The fence is desirable to the PGST and JST, as no electronic collars that would activate flashing signage are currently maintained on the herds present in the greater Brinnon area. This is further discussed in Section 7.F of the Staff Report (see paragraph 163, Exhibit 1). Staff recommends a condition of approval for this approach to elk exclusion (see Condition 15, Section 10, Exhibit 1). No detailed information about the design, height, location, or extent of the fencing is included in the preliminary plat application. The recommended condition of approval requires the fence to 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 that are attractive food sources.” The intention of the condition is to minimize the initial extent of the fence while maintaining a successful barrier to elk presence on the golf course. The condition requires the fence to be installed with site infrastructure, prior to final plat approval. 12. Other Comments Proposed Uses Comments indicate concern about uses identified on the preliminary plat drawings and preliminary civil drawings (Exhibits 33 and 34), including both the modular construction facility and the independent living elder care facility. For the purposes of land division, these uses appear to be consistent with the types of uses allowed on the site, which include: • JCC 17.65.020(1): 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. Senior housing is a type of residential use and is consistent with the allowance for residential uses on the site. Further review will occur with construction permits for the senior housing building. • JCC 17.80.050(1)(b): Addition of uses that do not modify the recreational nature and intent of the resort. The proposed modular construction facility, as currently understood by Jefferson County, will be a temporary construction use that will not remain permanently operated on the site. The proposed modular construction facility is located within the AgraCenter building and will be removed following the termination of modular construction activities so that the AgraCenter can be used for its final intended purpose as a maintenance facility. The temporary nature of the proposed modular construction facility ensures that the recreational nature and intent of the resort is not modified. Further review will occur with construction permits for the AgraCenter, and any change of use in the AgraCenter Jefferson County Staff Report ADDENDUM Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued October 10, 2025 EXHIBIT 74 Page 20 of 24 building will require a new building permit to verify the use meets applicable standards in the master plan and in adopted building and life safety codes. No further information about these proposed uses is required to review the preliminary plat application. Work Approved On Site Some commenters are concerned about work being performed on the property, and question whether permits were issued, if appropriate temporary erosion and sediment control (runoff and pollution prevention) measures have been implemented, and if replanting to mitigate for the loss of vegetation is required. PHMPR has received a Forest Practices Application approval from the Washington Department of Natural Resources (DNR) to conduct timber harvest on the site. This activity “converts” forestry “units” (harvests identified stands of trees) on the site. This permit is administered by DNR. PHMPR has also received the following permits from Jefferson County: ● Demolition Permits (case nos. DEMO2024-10, DEMO2024-12, DEMO2024-13, DEMO2024-14, DEMO2024-15, DEMO2024-16, DEMO2024-17, DEMO2024-18, DEMO2024-19, DEMO2024-20, DEMO2024-21, DEMO2024-22, DEMO2024-23, DEMO2024-24, DEMO2024-25, DEMO2024-26, DEMO2024-27, DEMO2024-28) Scope of Work: The Applicant is proposing to demolish 18 derelict structures that exist in poor and dilapidated condition on the site. Work identified in the submittals includes removal of the structures; existing paving, septic systems, and foundations/slabs will be left in place. ● Stormwater Permit (case no. ZONS2024-00008) Scope of Work: Install all temporary erosion and sediment control (TESC) measures for the entire scope of construction, consistent with mitigation requirements in the FEIS and applicable water quality regulations and BMPs, which are included in Appendix 1 to the FS&CA. Work also includes limited, preliminary site grading necessary to improve construction access. PHMPR has received the required construction stormwater general permit from DOE to conduct ground-disturbing activity. This permit is on file with Jefferson County. Work being performed on the site is consistent with permits issued by Jefferson County and other agencies with jurisdiction and permitting authority. Complaints have been received and investigated by Jefferson County and DOE, and no violations have been found. Application for, approval and issuance of, and performance on development permits is not a criterion Jefferson Couty can consider in making its decision on the preliminary plat application. Violations associated with issued permits or nonexempt work performed without a permit would be addressed through a code enforcement action under Title 19 JCC. Jefferson County is obligated to review project-related proposals and permits for consistency with the Development Agreement (as amended) and its exhibits and appendices, the FEIS and FSEIS, the FS&CA (as Jefferson County Staff Report ADDENDUM Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued October 10, 2025 EXHIBIT 74 Page 21 of 24 amended), Division II of Title 17 JCC, and other relevant provisions of the Jefferson County Code. None of these governing documents or regulations address other permits and this cannot be considered in the review or decision-making process. Financial Feasibility of Project and Owner’s Performance on Other Projects Many comments raised concerns about the financial feasibility of the project and potential taxpayer liability for a project that was never completed, with some citing examples of Statesman projects in other locations. These are not criteria Jefferson County can consider in making its decision on the preliminary plat application. Jefferson County is obligated to review project-related proposals and permits for consistency with the Development Agreement (as amended) and its exhibits and appendices, the FEIS and FSEIS, the FS&CA (as amended), Division II of Title 17 JCC, and other relevant provisions of the Jefferson County Code. None of these governing documents or regulations address financial feasibility or past project performance and these cannot be considered in the review or decision-making process. Lack of Progress Comments raise concerns about the lack of progress on infrastructure and construction at the site. Section 4 of the Staff Report summarizes relevant background information necessary to understand the protracted project timeline. Figure 2 provides a graphic summary of the same information. A significant amount of time was spent completing various regulatory steps, such as conducting and finalizing two environmental impact statements, negotiating the development agreement, responding to and processing appeals, and similar activities. Following completion of the development agreement, Jefferson County and PHMPR worked to resolve a billing dispute that culminated in the execution of the FS&CA for the project, absorbing some additional time. It is not unusual that the project has not made progress on construction of infrastructure or resort amenities. 2002-2004: Brinnon Sub-Area Plan adopted 2008: Comp. Plan Amd. adopted; GMHB appeal filed; Judicial appeal filed 2007: FEIS issued 2011: GMHB and judicial appeals concluded 2015: FSEIS issued 2023: Pre-app conference; Prelim. plat application submitted 2018: Dev. Regs adopted; GMHB appeal filed; Dev. Agmt. approved; LUPA appeal filed 2019: GMHB and LUPA appeals concluded; Amd. 2 to Dev. Agmt. approved Figure 2: Summary of overall project timeline. Jefferson County Staff Report ADDENDUM Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued October 10, 2025 EXHIBIT 74 Page 22 of 24 Further, construction progress to date is not a criterion Jefferson County can consider in making its decision on any development applications. Jefferson County is obligated to review project- related proposals and permits for consistency with the Development Agreement (as amended) and its exhibits and appendices, the FEIS and FSEIS, the FS&CA (as amended), Division II of Title 17 JCC, and other relevant provisions of the Jefferson County Code. None of these governing documents or regulations address construction progress to date and this cannot be considered in the review or decision-making process. Amenity and Golf Course Design Comments indicate that amenities are vague and unrealistic or have some design deficiencies. The preliminary subdivision is a land division application that establishes an intended lot and tract layout; no development activity is authorized as part of this application. Construction permits for amenities must include the necessary detail for review and issuance. Jefferson County will review applications based on applicable criteria contained in the Development Agreement (as amended) and its exhibits and appendices, the FEIS and FSEIS, the FS&CA (as amended), Division II of Title 17 JCC, and other relevant provisions of the Jefferson County Code. Where there are no standards adopted (such as distances between golf fairways and tees), Jefferson County cannot require design changes. Where there are adopted standards, Jefferson County will require compliance consistent with the governing documents and regulations. As described in Section 7.B of the Staff Report (see paragraphs 17-18, Exhibit 1), the proposed tracts will accommodate the amenities required as part of the master plan. Detailed design for any amenities is not a requirement for preliminary plat review. Noise One comment indicated probable noise impacts on marine mammals in Hood Canal. Noise is regulated by Chapter 8.70 JCC, Noise Control. Noise generated on the site, both during construction and during long-term operation of the resort, must meet applicable noise levels that are consistent with State regulations set forth in Chapter 173-60 WAC. Noise is reviewed with applicable construction permits and is enforceable through Title 19 JCC. Noise is not a review criterion for land division applications. Use of Modular Construction Comments indicated that the Applicant has not obtained any Washington State Department of Labor and Industries (L&I) authorizations for the proposed modular construction. L&I is the agency with jurisdiction over factory-assembled structures and modular structures. Method of construction is not a criterion Jefferson County can consider in making its decision on a preliminary plat application. Jefferson County is obligated to review project-related proposals and permits for consistency with the Development Agreement (as amended) and its exhibits and appendices, the FEIS and FSEIS, the FS&CA (as amended), Division II of Title 17 JCC, and other relevant provisions of the Jefferson County Code. None of these governing documents or regulations address method of construction for a preliminary plat application and this cannot be considered in the review or decision-making process for this proposal. Jefferson County Staff Report ADDENDUM Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued October 10, 2025 EXHIBIT 74 Page 23 of 24 CC&Rs and the Role of the Homeowner’s Association A draft Declaration of Covenants, Conditions, and Restrictions for the Hamlet of Pleasant Harbor (CC&Rs) and a draft of The Hamlet of Pleasant Harbor Design Review Guidelines were submitted with the application and are included in the project record as Exhibits 38 and 39, respectively. Further review and analysis will occur prior to recording with any final plat application to ensure relevant County interests have been adequately addressed. Management and maintenance of common areas is addressed in the draft CC&Rs. Stormwater Pump Station One comment highlights an inconsistency between the preliminary plat drawings (Exhibit 33) and the preliminary civil drawings (Exhibit 34) with respect to a stormwater pump station. The stormwater pump is mentioned in the Drainage Report (Exhibit 26), which notes that “[r]unoff from Basin 6 will be conveyed via piping and swales to a storm pump that includes a buffer pond. The storm pump discharges into Basin 5’s conveyance system to be treated and infiltrated in the Basin 5 pond.” The pump and stormwater forcemain are shown on Sheet 13 of the preliminary civil drawings (Exhibit 34), but they are not shown on the preliminary plat and a sewer lift station is shown instead. The preliminary plat (Sheet 23, Exhibit 33) does identify a drainage easement that will support the stormwater pond and pump station. A condition of approval will require conformance of the stormwater features between the plan sets, and verification will occur with construction permits. [CONDITION 71] Figure 3: Excerpt of Preliminary Civil Plans (Sheet 23, Exhibit 33). Annotations provided by Jefferson County review staff. The comment further indicates concern about pumping large volumes of stormwater. Stormwater pumps are allowed under the 2024 SWMMWW to meet Minimum Requirement 7 (Flow Control). DOE does not have guidance on pump design. If a pump is required (e.g. due to the topography of the project site), it must be designed to ensure that the discharge from the site meets the Flow Control Performance Standard within this Minimum Requirement. The Flow Control BMP modeling must consider the flow from the pump into the storage area of the Flow Easement for storm pump station and pond Easement for storm forcemain Jefferson County Staff Report ADDENDUM Pleasant Harbor Master Planned Resort (SUB2023-00025) Issued October 10, 2025 EXHIBIT 74 Page 24 of 24 Control BMP. Further, the requirements for Pond #4 (located within Basin 5) must match requirements in the 2024 SWMMWW for BMP T7.10: Infiltration Ponds. An emergency overflow spillway is shown on the preliminary civil plans (Exhibit 34) and overflow would pond in a low point on the northeast side of the golf course. In addition to the emergency spillway, the stormwater pump system will need emergency overflow/plan to accommodate system failure or power outage. Further review will occur with construction permits to verify the project meets the requirements of the 2024 SWMMWW and that no offsite discharge of stormwater will occur. SECTION 4. Proposed Changes to Findings and Conclusions Based on the foregoing supplemental analysis, Staff does not propose any changes to findings and conclusions. SECTION 5. Proposed Changes to Staff Recommendation Based on the foregoing supplemental analysis, Staff does not propose any changes to the recommendation for conditional approval. Staff recommends one new condition of approval: 71. The stormwater pump station associated with Basin 6 near Hole No. 5 in Tract X-3 shall be shown on the plat and conformed with the civil drawings and drainage report. Final easement locations shall reflect as-built conditions.