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HomeMy WebLinkAbout82_2025-10-15 PGST Pleasant Harbor Addendum w attachmentPORT GAMBLE S’KLALLAM TRIBE NATURAL RESOURCES DEPARTMENT 31912 Little Boston Rd. NE – Kingston, WA 98346 Page 1 October 15, 2025 Gary McLean Office of the Hearing Examiner Jefferson County 1820 Jefferson Street, Port Townsend, WA 98368 RE: Pleasant Harbor Master Planned Resort, Case No. SUB2023-00025 This is an addendum, to be submitted to supplement the Port Gamble S’Klallam tribe’s letter, to be added to the official record regarding the review of the Pleasant Harbor Master Planned Resort Preliminary Plat. After hearing the presentations at the October 15, 2025, meeting, and upon further review, we wish to provide additional clarification of comments for consideration by Jefferson County staff and for the record. These additions are intended to assist in ensuring a comprehensive and accurate assessment of the Port Gamble S’Klallam Tribe’s concerns. • The Port Gamble S’Klallam Tribe’s position is not unopposed. The Tribe would prefer that this project not continue; however, as the development proceeds, the Tribe’s position is not unopposed, but willing to work with the county on conditions of approval if the development is not rejected. • The Washington State Department of Archeology and Historic Preservation (DAHP) letter recommended that this project be redesigned to protect the kettles, due to their historic and cultural significance. The Port Gamble S’Klallam Tribe is a living people, whose cultural practices and ties to the land remain today, and the cultural connection to the kettles is a matter of both historic preservation and current cultural practice. The letter is included as an attachment. • The Port Gamble S’Klallam Tribe has not agreed that partial elk-proof fencing was sufficient. The developer provided the information regarding partial fencing, which is not best wildlife management practice. The Tribe’s position is that full, elk-exclusion fencing of at least eight feet is necessary to prevent negative human-wildlife contact and the habituation of wild elk herds. • The Port Gamble S’Klallam Tribe has received an Inadvertent Discovery Plan with the Preliminary Plat Application, but this does not replace an outdated Cultural Resources Management Plan. The CMMP is over ten years old and has not been updated. It is important to note that tree harvesting and vegetation removal are ground disturbing activities, which are conditioned under the Forest Practice Application to provide notice to Tribes prior to these activities occurring. However, the Inadvertent Discovery Plan in the Forest Practice Application is not the same as the CMMP update, which is still necessary for accuracy. PORT GAMBLE S’KLALLAM TRIBE NATURAL RESOURCES DEPARTMENT 31912 Little Boston Rd. NE – Kingston, WA 98346 Page 2 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; Chloe Donaldson, Environmental Program Manager; Juanita C. Holtyn, THPO; George Terry, Associate Planner, Jefferson County Attachment: 2018 DAHP Letter State of Washington • Department of Archaeology & Historic Preservation P.O. Box 48343 • Olympia, Washington 98504-8343 • (360) 586-3065 www.dahp.wa.gov April 9, 2018 Ms. Kate Dean County Commissioner Jefferson County PO Box 1220 Port Townsend, WA98368 In future correspondence please refer to: Project Tracking Code: 081106-13-JE Property: Statesman Group Master Planned Resort in Brinnon's Black Point and Pleasant Harbor Marina, Jefferson Co. Re: Archaeology-DAHP Comments for Public Hearing for Pleasant Harbor MPR Development Dear Ms. Dean: The Washington State Department of Archaeology and Historic Preservation (DAHP) has been involved in the review of the proposed development since 2006. While we have some information regarding archaeological materials within the project, there is no information regarding consultation or review undertaken for cultural values. New information has been presented regarding the geological and cultural value of the project area within the past months.  RCW 43.21C.020 recognizes the responsibility to “Preserve important historic, cultural, and natural aspects of our national heritage.” Further, RCW 43.21.030 (b) Guidelines for state agencies, local governments—Statements—Reports—Advice—Information 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 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 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 (NRHP). 2 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@dahp.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