HomeMy WebLinkAbout78_Marla Powers_2025-10-14 PGST Pleasant Harbor Prelim CommentsPORT GAMBLE S’KLALLAM TRIBE
NATURAL RESOURCES DEPARTMENT
31912 Little Boston Rd. NE – Kingston, WA 98346
Page 1
October 14, 2025
George Terry, Associate Planner
Department of Community Development
Jefferson County
621 Sheridan Street
Port Townsend, WA 98367
Email: GTerry@co.jefferson.wa.us
RE: Pleasant Harbor Master Planned Resort, Case No. SUB2023-00025
Dear Mr. Terry,
Thank you for the opportunity to comment on permit application SUB2023-00025, the Preliminary
Plat of The Hamlet of Pleasant Harbor, for the Pleasant Harbor Master Planned Resort (PHMPR).
The proposed project is in an ecologically and culturally significant area of the Port Gamble
S’Klallam Tribe (Tribe). It is located in the Tribe’s usual and accustomed grounds and stations
(U&A) where the Tribe has rights under the Treaty of Point No Point. The Tribe is invested in the
preservation of reserved tribal treaty rights to fish, hunt, and gather in their U&A, as well as the
preservation of the ecosystems that support those rights. This proposal is part of a long-standing
land use and development proposal for which the Tribe has strong concerns due to the impacts related
to cultural resources, water quality, shellfish, forest, wildlife, and other resources. These concerns
have been placed on record on many occasions.
A. Cultural Resources Management Plan
The Tribe continues to have strong concerns over the impacts to cultural resources proposed by the
PHMPR project. For many years the Tribe has communicated its concerns that the PHMPR will
directly impact the kettles, which are important cultural resources for the Tribe. The Washington
Department of Archaeology and Historic Preservation and the tribes have recommended that the
project be redesigned to preserve the kettles and the unique cultural landscape. A traditional property
study was recommended as part of the cultural resources study. Yet the developer and the County
have proceeded with the project as designed, impacting the kettles. The Tribe continues to be
committed to addressing cultural concerns and requests that the developer engage with the tribes in
this process. The Cultural Resources Management Plan proposed for the PHMPR project is over 10
years old and needs to be updated based on the eventual development approved.
Recommendations:
1. Work with the tribes to update the Cultural Resources Management Plan and Inadvertent
Discovery Plan. The tribal contacts and other information in these plans are not current and should
be updated before moving forward with the project.
2. Since the Developer and the County have not taken any action to redesign the project to preserve
PORT GAMBLE S’KLALLAM TRIBE
NATURAL RESOURCES DEPARTMENT
31912 Little Boston Rd. NE – Kingston, WA 98346
Page 2
the kettles and cultural landscape, at minimum we recommend working with the tribes to develop
a Kettle Management Plan that properly protects, preserves, and provides educational
opportunities to share or keep confidential cultural sites within this development. Six months
should be allocated to complete this process. The Kettle Management Plan should be submitted to
Jefferson County for inclusion in the project files and recording with the Assessor.
3. Implementation of the updated Cultural Resources Management Plan and Kettle Management
Plan should be completed prior to any Certificate of Occupancy for the plat.
B. Water Quality Management
The PHMPR includes five separate water quality plans with conflicting information creating
considerable ambiguity regarding the water quality monitoring. With the increase in traffic, population
and activities at the site, water quality management is a high priority. In addition, the existing plans do
not include water quality monitoring for the retention pond. The site will be designed such that runoff
travels into the kettle pond. If the developer plans on using it for irrigation, then it should be monitored
for human and environmental health purposes.
Recommendations:
4. The developer create one clear, concise water quality monitoring plan for the tribes and others to
review. The County can amend the WQ plan to indicate that it supersedes or takes precedent over
other plans in relation to water quality monitoring, controls and reporting.
5. The developer will develop, in coordination with the tribes, a section of the water quality
monitoring plan for the monitoring of the retention pond.
C. Forest Management
The Tribe maintains the importance of retaining trees in the development project, with special
importance paid to mature stands that provide cover and habitat. There has not been a clear report of
tree retention in this development plan. The PHMPR does not identify a standard for tree retention.
Recommendations:
6. Provide a tree retention report identifying the number of trees that have been retained recently and
plans for future tree retention. This information will help inform the Tribe and others of the
resource protections and environmental impacts of the PHMPR project.
D. Wildlife Management
The existing Wildlife Plan is unclear and has conflicting strategies. The plan calls for partial
fencing along one section of the PHMPR property, which does not address the critical concerns
that have been communicated over the years. The risk of collisions with elk on the roadway and elk
habituation to the resort golf course is high. The partial fence plan is not sufficient to exclude and
deter elk from crossing the road and entering the property.
PORT GAMBLE S’KLALLAM TRIBE
NATURAL RESOURCES DEPARTMENT
31912 Little Boston Rd. NE – Kingston, WA 98346
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Recommendation:
7. Install an exclusionary elk-proof fence that is at least 8 feet high and surrounds the entire
resort property to prevent habituation and road crossings. We recommend working with the
tribes to update the Wildlife Plan and to clarify the details of the fencing and wildlife
management strategies.
E. Shellfish Management
The Duckabush and Dosewallips Rivers are adjacent to the PHMPR project and are significant
shellfish harvesting areas for the Tribe. Recreational impacts from the increased population at
PHMPR are likely to impact shellfish resources and have the potential to trigger shellfish closures.
Recommendations:
8. The developer, County, and State agencies work together to monitor the shellfish beaches to
identify any increase in recreational harvesters and to manage the resource appropriately. In
addition, signage, public education, and shellfish harvest management best management
practices should be provided.
F. Traffic and Growth Management
There are several concerns associated with an increase in traffic and increase in local population
associated with the PHMPR project. We are concerned that the increase in traffic associated with
vehicles entering and exiting the PHMPR project will cause an increase in runoff pollution in
nearby marine and freshwater habitats. We are also concerned about boat ramp congestion and an
increase in vessels in Pleasant Harbor. The increase in population is also likely to increase light
pollution, impacting wildlife species. Overall, the significant growth anticipated by the PHMPR
project will affect the rural character of Brinnon.
Recommendations:
9. The developer, County, and WSDOT work together to develop a stormwater management
plan for the roads leading to the PHMPR project.
10. Developer is to submit a monitoring plan for boat usage and parking at the marina, identifying
solutions for overflow parking.
11. Ensure the Dark Sky standards for the PHMPR, including simple measures to prevent light
pollution, are fully enforced.
G. Compliance & Enforcement
The Tribe has concerns regarding the lack of compliance and enforcement of standards. The PHMPR
does not include a mechanism to alert the tribe and others of any violations of the agreed plans, nor a
clear pathway for catching and reporting violations.
PORT GAMBLE S’KLALLAM TRIBE
NATURAL RESOURCES DEPARTMENT
31912 Little Boston Rd. NE – Kingston, WA 98346
Page 4
Recommendations:
12. The County will work with the tribes and others to agree on standards that must be met for
resource management, including standards for water quality management, tree retention, wildlife
management, kettle pond management, shellfish management, stormwater management and other
resource management. An exceedance of an agreed standard would require an assessment,
identification and control as a preventative measure, rather than a reactionary measure once
criteria are violated and the harm has been done. The County will continue to work with the tribes
after construction to ensure that government-to-government communication remains open and any
violations or lack of compliance are reported.
13. During construction, the developer is to schedule regular meetings with the Tribe to provide
updates on construction.
14. Post construction, the site manager/homeowners association is to schedule quarterly meetings with
the Tribe to review resource management reports and assessments.
15. The Tribes with U&A in Hood Canal must be notified within 48 hours if there is any unintended,
unplanned or emergency discharge of untreated or partially treated water from the wastewater
treatment plant to the marine environment.
Thank you again for providing the opportunity to provide comments on the permit application. If
you have any further questions or comments, please contact me anytime.
Sincerely,
Marla Powers, Environmental Planner
Natural Resources Department
Port Gamble S’Klallam Tribe
(360)297-6292
Email: mpowers@pgst.nsn.us
CC: Roma Call, Director Department of Natural Resources, Port Gamble S’Klallam Tribe
Juanita Holtyn, Historic Preservation Officer, PGST
Jefferson County Public Comment email: planning@co.jefferson.wa.us