HomeMy WebLinkAbout79_Allie Taylor_JeffersonDCD_PleasantHarborMPRSUB2023-00025_FINALLetter_10142025
ATTN: Hearing Examiner October 14, 2025
Jefferson County
Department of Community Development
621 Sheridan St.
Port Townsend, WA 98368
RE: Pleasant Harbor Master Planned Resort, File No. SUB2023-00025
Dear Hearing Examiner, Mr. Terry, and Jefferson County Department of Community
Development,
On behalf of the Jamestown S’Klallam Tribe (JST), the JST Tribal Historic Preservation Office
(THPO) and JST Natural Resource Department respectfully submit the following comments
regarding the revised preliminary plat application for the Pleasant Harbor Master Plan Resort
in Brinnon, Jefferson County, Washington (SUB2023-00025). Please see the specific
concerns and recommendations below:
1. Cultural Resources:
This section is written in concurrence with the Port Gamble S’Klallam Cultural Resources
Department and Tribal Historic Preservation Officer, currently in transition, who share the
same concerns and intention to protect this sacred landscape in perpetuity.
Concern 1A:
Appendix Q of the Development Agreement titled, Proposed Plan for Archaeological
Monitoring and Inadvertent Discovery Protocol has incorrect Tribal contact information.
Additionally, the maps showing the archeological monitoring locations are illegible and use
project plans from 2012. These project plans have been changed over the course of 13 years
since this document was written. It is difficult to determine which areas require
archaeological monitoring (see figure 1.).
Recommendation 1A:
JST recommends Jefferson County Department of Community Development (DCD)
condition the SUB2023-00025 to require an update and/or addendum to Appendix Q,
Proposed Plan for Archaeological Monitoring and Inadvertent Discovery Protocol to include
the corrected tribal contact information and updated maps to modern standards.
Additionally, we recommend this update and/or addendum be conducted in consultation
with affected tribes.
Figure 1. Excerpt from Appendix O/Q Proposed Plan for Archaeological Monitoring and Inadvertent
Discovery Protocol.
Concern 1B:
Jefferson County DCD has repeatedly refused to require mitigation for impacts on our
sacred sites and traditional cultural properties. The Staff Report Jefferson County
Preliminary Plat Application Case No. SUB2023-00025 has no conditions regarding cultural
resource concerns. The JST THPO has provided comments on these cultural resource
concerns listed as follows: 2018 comment prior to the finalization of the Development
Agreement (see Attachment A), has made multiple verbal comments in virtual staff level
meetings between the Jefferson County DCD, JST, Port Gamble S’Klallam Tribe (PGST), and
the Point No Point Treaty Council (PNPTC) between the dates of June 11, 2024 and
September 29, 2025, verbal comments in the Government to Government Meeting between
Jefferson County, the JST, and PGST on May 28th, 2025, and formal comment letter dating
September 11th, 2025 (see Attachment B).
These comments listed above all requested that Kettle Ponds B and C and adjacent
wetlands be preserved for traditional property evaluation and protection of cultural
resources as well as the request for the removal of inappropriate language used in the
Development Agreement. An excerpt of this inappropriate language is provided below from
page 4 of the Development 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.”
To this date, these comments have been dismissed by Jefferson County DCD, who
continually states the County has “no authority to change the prior determinations” (see
Attachment C). However, JST THPO commented on the concerns of the inappropriate
language included in the Development Agreement prior to its finalization.
Recommendation 1B:
JST continues to request that Jefferson County DCD condition the Preliminary Plat Permit
SUB2023-00025 to preserve and protect our traditional cultural properties. The JST requests
that Kettle Ponds B and C and adjacent wetlands be preserved for traditional property
evaluation and protection of cultural resources. The use of these sacred sites for storm
water management is insulting from the JST’s perspective, and we believe the destruction of
these wetlands promotes the erasure of tribal cultural practices. JST recommends
permitting SUB2023-0025 in accordance with RCW 43.21C.020 to “preserve important
historic, cultural, and natural aspects of our National Heritage”, 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.”.
Additionally, Jefferson County Code 18.30.160 (4) states “Archaeological sites are
subjected to Chapter 27.44 RCW (Indian Graves and Records) and Chapter 27.53 RCW
(Archaeological Sites and Records) and must comply with Chapter 25-48 WAC
(Archaeological Excavation and Removal Permit). Archaeological excavations are allowed
subject to applicable state laws.”. Chapter 27.53.040 RCW states the following:
“All sites, objects, structures, artifacts, implements, and locations of prehistorical
or archaeological interest, whether previously recorded or still unrecognized,
including, but not limited to, those pertaining to prehistoric and historic
American Indian or aboriginal burials, campsites, dwellings, and habitation sites,
including rock shelters and caves, their artifacts and implements of culture such as
projectile points, arrowheads, skeletal remains, grave goods, basketry, pestles,
mauls and grinding stones, knives, scrapers, rock carvings and paintings, and other
implements and artifacts of any material that are located in, on, or under the surface
of any lands or waters owned by or under the possession, custody, or control of the
state of Washington or any county, city, or political subdivision of the state are hereby
declared to be archaeological resources.”
JST believes this traditional cultural property meets the definition of archaeological
resources in RCW 27.53.040 and therefore we recommend Jefferson County DCD comply
with Jefferson County Code 18.30.160 (4), Chapter 27.53 RCW, and Chapter 25-48 WAC by
conditioning the SUB2023-0025 permit in accordance with these regulations.
Concern 1C:
Jefferson County DCD does not have expertise in the cultural resources management
field. However, Jefferson County DCD has continued to refuse recommendations by
specialists in the cultural resources management field as well as the tribal knowledge
from affected tribe(s) (see examples provided in section 1B of this letter and Attachments
D and E).
Recommendation 1C:
The JST recommends the Jefferson County DCD acknowledge and implement the original
recommendations provided by experts in the field at the Washington State Department of
Archaeology and Historic Preservation. These recommendations were documented in the
comment letter dated April 9, 2018 (See Attachment D):
“ … the information we have evaluated indicates the kettles are of cultural and
spiritual importance to the Tribe(s). … The kettles would qualify as both a Traditional
Cultural Property as well as a Cultural Landscape and would be eligible for listing in
the National Register of Historic Places… 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 [sic] traditional
cultural property study. The Cultural Resources Management Plan for this project
[was] almost 10 years ago needs to be updated based on the eventual development
approved.”
The JST urges Jefferson County DCD 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
federal regulation, the THPO strongly recommends Jefferson County work to 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.
2.Natural Resources
Concern 2A:
We appreciate the water quality protections included within the plat plans/governance
documents such as the “no discharge to Hood Canal” standard, the onsite wastewater
treatment system and the various monitoring plans. We have spent extensive time
reviewing the governing documents and while we are generally supportive of the
protections put in place, there remain several outstanding issues can be resolved without
placing additional restrictions on the applicant nor require new amendments to the
agreements.
This project has gone through innumerable iterations, adaptations and phases over
multiple decades. This has resulted in a patchwork of discordant conditions and
requirements that govern ambient water quality monitoring and protection. The various
applicable standards are in at least five different documents, none of which cross
reference other standards and none of which provide a complete picture of the
requirements. Jefferson County staff have assured us that while these standards are
located throughout different documents, they are all applicable to the management of the
resort. However, effective policy should not require a site manager, member of the public
or the County itself to sift through all the governing documents to understand what the
water quality requirements are for the management of the resort. This type of organization
leads to confusion for all involved (including our Tribal staff) and can easily result in
inconsistent tracking and implementation to the detriment of the near-shore environment.
Several examples of these unconsolidated or conflicting standards include:
a.“In the event that water quality shows any sign of deterioration, Jefferson County shall
consult with the owners and operators of the resort, the local residents and state
agencies concerning the source of the change.” P. 11 in Amendment 2.
b.“If sampling results show three consecutive increases in concentrations of any one of
the water quality parameters sampled under this Agreement, the Developer shall take
steps to identify the cause of the increase.” P. 41 of Development Agreement.
c.For any violation of water quality criteria, the Resort shall take immediate steps to
correct the violation and shall remedy any impact to water quality caused by the
Resort. If any violation of water quality criteria occurs, the Resort shall modify existing
best management practices or apply further water pollution control measures,
selected or approved by Ecology or JCWQ, to achieve compliance with water quality
criteria.” (Appendix N p. 5)
d.“Should any changes in water quality be identified, the County and agencies with
jurisdiction may require changes in operation to end, minimize, and/or mitigate any
recent activities causing adverse change. The resort will be required to participate in an
adaptive management program to rectify the problem, including eliminating the source,
mitigating and treating to avoid the problem, or taking other steps necessary and
appropriate to preserve water quality for any source tied to the resort or resort marina
operations.” FEIS Chapter 3, p. 4)
e.“For any violation of water quality criteria, PHMPR shall:
i.Take immediate steps to correct the violation and shall remedy any impact to
water quality caused by the MPR: and
ii.Modify existing best management practices or apply further water pollution
control measures. selected or approved by the Washington Department of
Ecology or JCQW, to achieve compliance with water quality criteria.” (p. 7-8 of
the First Amendment to Future Staffing and Consultant Agreement)
Recommendation 2A:
We recognize that the governing documents such as the Development Agreement, MOUs
and various amendments that dictate water quality monitoring and management are not
the subject of the public comment at this stage. However, since the preliminary plat
application includes the wastewater treatment plant placement, stormwater design, roads
and resort layout that all affect water quality, we believe this is an appropriate time to
clarify how the water quality monitoring and management is implemented.
We recommend that approval of the preliminary plat application be conditioned by:
-Adding a summary and a reference list of all water quality requirements in the
Development Agreement, FEIS chapter 3, Amendment 2, the First Amendment to
the Future Staffing and Consultant Agreement, and any other document that
dictates water quality management to Appendix N—Water Quality Monitoring Plan.
This does not change the applicant's obligations; it simply adds clarity and
transparency to a complex project. Within the table shall be an indication of which
requirement is superior, in the event of an inconsistency.
o Alternatively, the County could create a separate document outlining all
water quality monitoring and action requirements. A single-sentence edit in
Appendix N referencing this new resource would be a minor change and
should not require a formal amendment. This is in line with other recent
small, non-substantive changes to amendments and agreements that have
not required formal processes.
-The Development Agreement requires an annual assessment of BMPs and adaptive
management to be applied if the resort or marina are not meeting standards
outlined in the governing documents. If additional clarifications, amendments or
additions to Appendix N are not possible, we recommend, at a minimum, that the
County and resort specifically include a review of all applicable water quality
monitoring and control measures in this annual review and apply adaptive
management of operations if any standard is not being met. It is Jamestown’s
expectation that this annual assessment would generate a publicly available
summary report.
Concern 2B:
Pleasant Harbor sits at the junction of two elk herds – the Dosewallips herd and the
Duckabush herd. While they currently rarely cross highway 101 to Black Point, a novel
system of landscaped plants, fairways and gardens that are watered and fertilized
throughout the year will act as an attractant. We acknowledge the developer agreed to
include a “west-oriented fence” between the highway and the property, which is an
important partial step towards reducing conflicts, vehicle collisions and mortalities,
property damage and the need for lethal control. Tribal biologists recognize that this will
not be sufficient to prevent harm to the herds, drivers on Highway 101 and the property
itself.
Recommendation 2B:
The only sure way to prevent these types of conflicts is with a complete exclusionary fence
around the grounds with cattle guards at the entrances. Doing so will prevent dangerous
collisions, damage to the herds and human-wildlife conflicts. Preventing conflicts from
happening from the outset is much more effective than attempting to counteract a learned
behavior by a herd. We recommend including a condition that is sufficiently protective of
both wildlife and people, such that:
PH MPR shall install a continuous elk-exclusion fence around the entire property
perimeter, replacing the proposed flashing signage and noise/light-based deterrents
outlined in the Wildlife Management Plan (Development Plan, Appendix P). The
fence must meet or exceed the standards set the Wildlife Management Plan
(Revision 4, dated June 18, 2025), including a minimum height of 8 feet and
sufficient visibility to deter elk.
All entries and exits into the property must be equipped with cattle guards of at least
8 feet in width to prevent elk access while maintaining vehicle passage.
Fence and cattle guard construction must be completed, including all associated
infrastructure, and pass inspection prior to any site construction and final plat
approval.
If the plat design changes between preliminary and final approval, the fencing layout
may be adjusted; however, the total fenced area must not be reduced. Elk must be
excluded from golf course fairways and other open spaces that offer attractive
forage.
If the County does not believe that it has the authority to condition plat approval on a fully
exclusionary fence plan, it does have the authority to require adaptive management and
updates to BMPs during the annual BMP review under the Development Agreement.
Therefore, at a minimum, we recommend that the fencing plan be adaptable and
dependent upon a performance-based approach such that if a west-oriented fence fails to
prevent elk incursion onto the property on two or more occasions in a given calendar year,
the County will require additional exclusionary fencing until there are no occurrences of elk
crossing onto the property.
In summary the JST is very concerned with the following items:
•Incorrect tribal contact information and illegible maps in Appendix Q of the
Development Agreement titled Proposed Plan for Archaeological Monitoring and
Inadvertent Discovery Protocol.
•Destruction of critical aspects of our traditional cultural property including the
potential impacts to Kettle Ponds B and C and adjacent wetlands.
•Jefferson County DCD’s refusal to acknowledge recommendations made by experts
in the cultural resource management field.
•Unconsolidated or conflicting water quality standards.
•Insufficient protections for Duckabush elk herd and drivers on Highway 101 and the
property itself.
We hope you find our recommendations are both useful and well aligned with the Jefferson
County Comprehensive Plan goals. Thank you for the opportunity to comment on this
project. If you need any additional information, please contact me at 360-681-4638 or
THPO@jamestowntribe.org
Sincerely,
Allie Rae Taylor
Tribal Historic Preservation Officer
Jamestown S’Klallam Tribe
And
Alex Scagliotti
Environmental Planner
Jamestown S’Klallam Tribe
cc.W. Ron Allen, Chairman of the Jamestown S’Klallam Tribe and CEO
Loni Greninger, Vice Chairwoman of the Jamestown S’Klallam Tribe and Culture
Department Director
Hansi Hals, JST Natural Resources Director
Allyson Brooks, State Historic Preservation Officer, Department of Archaeology and
Historic Preservation
Randy Harder, PNPTC Executive Director
Laura Price, PGST Interim THPO and Cultural Director
George Terry, Jefferson County DCD Associate Planner
Josh Peters, Jefferson County Administrator
Attachments:
Attachment A – April 2018 JST THPO Comment Letter Re: Pleasant Harbor Master
Planned Resort Development Agreement
Attachment B – September 11, 2025 JST THPO Comment Letter Re: Revised
Preliminary Plat Application for the Pleasant Harbor Master Plan Resort, File No.
SUB2023-00025)
Attachment C – Jefferson County DCD Comment Letter Re: Response to September
11, 2025 Comments on Revised Preliminary Plat Application for the Pleasant Harbor
Master Planned Resort [SUB2023-00025]
Attachment D - Archaeology – DAHP Comments for Public Hearing for Pleasant
Harbor MPR Development
Attachment E - JC Response to DAHP
Attachment A – April 2018 JST THPO Comment Letter Re: Pleasant Harbor Master Planned
Resort Development Agreement
Attachment B – September 11, 2025 JST THPO Comment Letter Re: Revised Preliminary Plat
Application for the Pleasant Harbor Master Plan Resort, File No. SUB2023-00025)
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.”
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
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
Attachment C – Jefferson County DCD Comment Letter Re: Response to September 11,
2025 Comments on Revised Preliminary Plat Application for the Pleasant Harbor Master
Planned Resort [SUB2023-00025]
Attachment D - Archaeology – DAHP Comments for Public Hearing for Pleasant Harbor MPR
Development
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
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—ReportsAdviceInformation 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
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
Attachment E - JC Response to DAHP