HomeMy WebLinkAbout90_APPLICANT SUB2023-00025 Applicant Response to Open Record Comments (002)October 27, 2025
Via Email
Jefferson County Hearing Examiner
c/o Carolyn Gallaway
Community Development Director
Jefferson County
RE: Pleasant Harbor Master Planned Resort—Application for Preliminary Plat
Approval Case No. SUB2023-00025
Applicant Response to Comments
Dear Hearing Examiner McLean:
Thank you for your time during the open record hearing on October 15th. This letter
responds to public comments received or referenced during the open public hearing. As noted
during the hearing, the Applicant accepts the Findings and Conditions set forth in the Staff Report
with minor additions and revisions as outlined in its letter identified as Exhibit 77. We believe
many of the comments have been addressed in those findings and the materials provided by the
Applicant.
Response to Comments:
Many comments are directed towards perceived impacts the project may have on the
environment like traffic, water quality and safety. As noted, in the Staff Report, the planned resort
development has been reviewed through two environmental impact statements: (1) a non-project
FEIS was prepared to support the County’s amendment of its comprehensive plan to designate the
property as a master planned resort; and (2) a project-specific FSEIS that reviewed the impacts of
the planned build out as outlined in the Development Agreement and development regulations.
Mitigating conditions derived from these processes are incorporated in the approved Development
Agreement between the Applicant and County.
The preliminary plan of land division does not authorize any development activity that is
inconsistent with the scope of the project reviewed in the FEIS and FSEIS. We are not aware of
any comment that raised issues that were not assessed in the FEIS or FSEIS or that otherwise raises
a significant impact requiring further evaluation.
RECEIVED 10/27/25
EXHIBIT 90
2 | Page
A. Responses to Comments Received from Representatives of the Jamestown
S’Klallam Tribe, the Port Gamble S’Klallam Tribe and the Point No Point
Treaty Council
1. History of Communications with the Tribes
The County included a letter at Exhibit 69 that outlines efforts to engage with local tribes
and respond to comments. Included in that Exhibit is a letter from the Applicant dated April 13,
2018 that outlined its efforts to reach out to local tribes.1 Rather than repeat that history here, the
Applicant directs the Hearing Examiner to that Exhibit to the extent the Hearing Examiner desires
to understand the engagement with the tribes during the entitlement process to date.
2. Water Quality (General)
A number of comments from tribes referenced concern that the MPR will generate
contaminated stormwater runoff that will impact tribal treaty resources in Hood Canal including
fisheries and shellfish. See e.g. Ex 66C at 2; 66E at 2; and 66F at 2. From the outset, the Applicant
has committed to retain all stormwater generated within the preliminary plat on-site. See e.g. Final
Environmental Impact Statement (November 27, 2007) at 3-30 (included as link in Exhibit 3). The
obligation to retain all stormwater from development within the preliminary subdivision is ongoing
and is incorporated into the Development Agreement.2 The preliminary plan of subdivision has
reserved sufficient area to allow for stormwater retention on-site to full-fill the Applicant’s
commitment to zero-discharge of stormwater (and wastewater) to Hood Canal from development
in the preliminary plat property). See e.g. Ex 26 (Drainage Report).
The Applicant has also agreed to a number of other measures to protect water quality
including, but not limited to: (1) recorded a conservation easement for the 200’ of the property
landward of the ordinary high water marks along hood canal ensuring development is at least 200’
feet from ordinary high water3; (2) service sewage through a waste water treatment plant (as
opposed to septic systems) that treats wastewater to Class A standards for reuse; and (3) design
and operated the golf course in accordance with King County Best Management Practices for Golf
Course Development and Operation.4
Additionally, and as described more fully below, the Applicant has been and will continue
to sample water quality as outlined in the water quality monitoring plans included in the
Development Agreement. We are not aware of any other development on Hood Canal or Puget
Sound in general that requires the same level of monitoring for water quality and adaptive
management strategies.
1 The Applicant’s letter starts at pdf page 342 of Exhibit 69.
2 Section 9.2.3 requires that development substantially comply with express mitigation measures in the EISs.
3 The Conservation Easement is located at Exhibit 44.
4 JCC 17.80.020(4).
RECEIVED 10/27/25
EXHIBIT 90
3 | Page
3. Preservation of Wetlands and Kettles
Tribal comments request that all kettles and their associated wetlands be preserved. Only
Kettle B has a wetland. Kettle C does not.
All wetlands and their buffers within the preliminary plat are preserved. The Applicant has
placed wetland and their buffer in tracts in the preliminary plan of subdivision. The Applicant
prepared a conservation easement for the wetlands (Exhibit 47) and agrees to Staff Condition 66
which requires the conservation easement be recorded as part of final plat including the wetland
and its buffers.
It should be noted that the original design reviewed through the FSEIS would have resulted
in a loss of the naturally occurring wetland in Kettle B. The Applicant, at significant cost and
expense, reassessed the ability to use Kettle C (which does not have a wetland) and other facilities
to meet its on-site stormwater retention requirements. That analysis demonstrated that the
Applicant could meet its commitment to zero-discharge without using Kettle B. Avoiding Kettle
B further minimizes impacts to the environment, increases wildlife protection and avoids having
to create a mitigation wetland in Kettle C.
The Applicant’s commitment to retain Kettle B exceeds its legal obligations under the
Development Agreement.5 Pursuant to the Development Agreement the Applicant is only required
to preserve Kettle B or Kettle C if the Port Gamble S’Klallam Tribe (“PGST”) applied for and
received a recommendation from the State Advisory Council on Historic Preservation that the
kettles were eligible for listing in the Nation Register of Historic Places prior to the application of
the first grading permit.6 The Applicant has not been presented with a recommendation from the
State Advisory Council on Historic Preservation that the kettles were eligible for listing in the
Nation Register of Historic Places. Even though it is not obligated to preserve any kettles, the
Applicant has made a considerable effort to preserve the largest kettle on site and the only kettle
with a naturally occurring wetland at its bottom to address, in good faith, comments received from
the tribes.7 Kettle B is the largest kettle on site and the only Kettle with a naturally occurring
wetland at the bottom.
5 The Applicant also refers the Hearing Examiner to the County’s August 15, 2024 letter to the Point No Point
Treaty Council at Exhibit 69. The letter outlines the efforts made to engage with and address concerns raised by
tribes over the course of project entitlement. It notes disagreement over the claim that kettles are unique geologic
features. (Page 53-54). It also includes an extensive recitation of the efforts to coordinate with all tribes early on in
the planning process and the lack of meaningful involvement until late in the FSEIS process. For example, the
PGST never commented on the Cultural Resources Management Plan submitted by the Applicant to DAHP (Page
53).
7 Specifically, the Port Gamble S’Klallam Tribe commented in 2016 that one of the reasons the kettles were
significant was because they held freshwater. See Exhibit 66H at pdf page 32. Kettle B was the only kettle that had
wetland characteristics.
RECEIVED 10/27/25
EXHIBIT 90
4 | Page
The Applicant’s preliminary plan of subdivision preserves all wetlands and preserves the
largest kettle on site, Kettle B. This exceeds its obligations under Development Agreement and
applicable regulations.
4. Tribal Contacts in the Event of an Inadvertent Discovery
The Applicant has no objection to and is committed to notifying the current historic
preservation officers if a notification event is triggered under the inadvertent discovery protocols.
We would propose the tribes notify the County and the Applicant of the current officers and their
contact information and update those contacts as they change. The Applicant has no objection to
a condition on permits for land disturbing activities that includes the most recent contact
information for current preservation officers identified by the tribes for notification.
In addition to coordinating with tribes as required under the Development Agreement, the
Applicant is open to meeting with the tribes to discuss project updates and respond to questions.
The tribes can request a meeting by contacting Ryan Hodges via email:
ryanh@statesmangroup.com.
We were surprised by the email from Ms. Aikman that the PGST’s concerns were not
addressed through the FPA process. We understand the PGST does not believe the kettles were
adequately evaluated in the Cultural Resources Management Plan. While we disagree on that
issue, we did make an effort in good faith to address the other concerns raised by the PGST during
landowner meetings for the Forest Practices Permit—namely training of employees on inadvertent
discovery protocols, updating TPHO contacts in the event of an inadvertent discovery, updating
the GIS maps for high probability areas, and offering tribes root wads from the site for habitat
restoration efforts. It was our understanding that we had agreement on those specific issues per
the email attached as Appendix A.
5. Elk Protection Measures
During the FSEIS process the Applicant retained a qualified biologist to prepare a Wildlife
Management Plan to assess impacts to wildlife including elk. The original Wildlife Management
Plan proposed an iterative approach to managing Elk herds by starting with scare tactics before
resulting to structural management techniques like fencing. Based on comments, including those
from various tribes and specifically the Point No Point Treaty Council, the Applicant revised the
Wildlife Management Plan to require construction of an 8’ tall exclusion fence before construction
of the golf course:
Developer shall construct an exclusion fence along the western
border of the MPR South of Black Point Road, to exclude elk from
the MPR. The Developer will be responsible for determining the
precise location of the exclusion fence, but will consult with WDFW
RECEIVED 10/27/25
EXHIBIT 90
5 | Page
and the Point No Point Treaty Council before constructing the
exclusion fence. The exclusion fence shall be visible to elk . . and
shall be at least 8 feet in height. Fencing shall either be woven-wire
or electric. Fencing shall be constructed before or concurrent with
clearing the forest and developing greens, fairways and lawns the
MPR.
(Development Agreement, Appendix P). The Applicant intends to coordinate with the WDFW
and the Point No Point Treat Council during design of the fence as required under the DA.
The Applicant has agreed to Staff’s condition 15 which requires the fence be installed as
condition to final plat approval. The preliminary plat includes sufficient space along the western
boundary to install the fence as required.
6. Water Quality Monitoring
A number of commentators including Mrrs. Scagliotti and Powers expressed concern over
perceived inconsistencies with the water quality monitoring plans developed during the FSEIS and
incorporated into the Development Agreement. The approved Development Agreement with the
County includes two water monitoring plans at Appendixes N and O. There are no inconsistencies
between these two plans. They are intended to monitor two different concerns identified during
the FEIS and FSEIS reviews: sea water instruction to the aquifer, and introduction of contaminants
into Pleasant Harbor and groundwater.
Appendix N (Water Qualify Monitoring Plan) addresses monitoring requirements to assess
whether the project is introducing contaminants to the groundwater or surface water adjacent to
the marina. The Applicant has been gathering surface water samples from Pleasant Harbor for
over two years and has been gathering groundwater samples for two years exceeding its
responsibilities under the plan. In the event post construction sampling shows three consecutive
increases in concentrations for any sampled parameter the Applicant must assess the cause of the
increase and, if related to resort operations, address the cause. This requirement applies regardless
of whether water quality criteria are exceeded.
Appendix O (Neighborhood Water Supply Plan) addresses the monitoring requirements to
assess saltwater intrusion into the aquifer. Even though Ecology determined that the risk of
saltwater intrusion was low, the Applicant agreed to monitor for saltwater intrusion out of an
abundance of caution. The wells and data loggers have already been installed on site and Pleasant
Harbor has gather over two years of baseline data that has been submitted to the County. The
NWSP establishes a threshold “Baseline Threat” that if triggered requires consultation with
relevant agencies to determine the cause and implementation of mitigation measures including
installation of recharge wells (areas have been reserved in the plat to account for this potential
need) or altering points of withdrawal.
RECEIVED 10/27/25
EXHIBIT 90
6 | Page
7. Shellfish Protections
The Applicant has designed its project and agreed to conditions to minimize impacts to
shellfish resources:
(1) As noted above, the Applicant agreed to retain all stormwater generated from
development areas within the preliminary plat on site.
(2) The Applicant has agreed to install a wastewater treatment plant to address sewage
which provides better treatment than the series of septic systems that serviced the old
RV site on the property. The Applicant has further agreed to treat wastewater to Class
A standards and will use that water for irrigation and fire control—further avoiding
discharge to the canal.
(3) The Applicant agreed to a 200’ buffer from the ordinary high water mark along the
portion of the plat fronting Hood Canal and adjacent to the Duckabush shellfish beds.
The Applicant recorded a conservation easement (Exhibit 44) in favor of the County
protecting the 200’ buffer area. The Development Agreement further restricts public
access from the resort to the beach areas. DA at .
(4) The Applicant has extensive water quality monitoring obligations and must take actions
to address any increase in contaminant levels from resort operation.
(5) The Applicant has agreed to implement best management practices including, but not
limited to, designing and operating the golf course consistent with King County’s Best
Management Practices for Golf Course Development and Operation.
(6) The Applicant agreed as mitigation condition to provide educational and licensing
information regarding shellfish harvesting rules and regulations at the resort. (Exhibit
3, FEIS at 5-2).
B. Response to Ms. Schanfald (North Olympic Group of Sierra Club)
Ms. Darlene Schanfald commented on behalf of the North Olympic Group of Sierra Club
regarding concern that sewage solids will be applied as fertilizer to the grounds in the MPR. The
approved Pleasant Harbor General Sewer System Plan proposes to hold biosolids (sludge) in a
sludge holding tank. The sludge is then pumped to a screw press for dewatering. The residual
sludge cakes will be hauled off site for disposal at a licensed facility. Ex. 22, General Sewer Plan
at pdf page 64, Section 5.2.5.
C. Response to Comments from Mr. Rick Aramburu on Behalf of the Brinnon
Group
The Brinnon Group has submitted over a half-dozen separate comment letters. See
Exhibits 65A, 65B, 65G-I, 65W, 75 and 89. These letters raise a panoply of issues and claims
most of which have no bearing on preliminary plat approval. For example, and without limitation,
RECEIVED 10/27/25
EXHIBIT 90
7 | Page
a hallmark of the Brinnon Group’s objections to the master planned resort over the last two decades
has been that the Applicant lacks the financial and managerial capability to construct and/or
operate the project. Courts and growth boards have rejected this claim as grounds for reversal over
various decisions through the years. See e.g. The Brinnon Group v. Jefferson County, WWGMHA
No. 18-2-0005 Final Decision and Order at 23 (“The GMA does not impose any requirement on
local jurisdictions to assess the financial capacity of managerial experience of MPR Proponents.”).
The Brinnon Group continues to raise this claim and similar claims that have no bearing on
application under review.
1. Motion for Recusal
The Brinnon Group sought to have the Hearing Examiner, and all hearing examiners,
recuse themselves from considering this application due to a statement made by the County
Council regarding the project. As the Hearing Examiner noted on the record, this is not grounds
for recusal and does not create a conflict of interest within the independent Office of the Hearing
Examiner.
In addition to the points already made by the Hearing Examiner, one of the reasons for
designating authority to hearing examiners to make decisions in lieu of elected representatives,
like the Council, is to permit the County’s elected representatives to converse freely with their
constituents about applications in their jurisdiction and to allow them to freely opine on their views
of development projects without violating appearance of fairness principles. These types of
communications, while not barred, become more problematic if the Council is also the deciding
authority and can undermine the public’s faith in the fairness of quasi-judicial processes.
2. Phasing Under the Development Agreement
A common theme running through the comments from the Brinnon Group relates to the
preliminary subdivisions perceived lack of compliance with the phasing requirements in the
Development Agreement. The preliminary subdivision fully complies with the phasing
requirements contained in the Development Agreement. First, the phasing requirements are
established in the Development Agreement recorded against and binding on the property. Any
future final plat or development application must comply with its terms. Indeed, for the avoidance
of doubt, the preliminary subdivision expressly incorporates the phasing requirements in Section
10 and Exhibit 4 of the Development Agreement, as amended on the face of the plat. Staff
Condition 6, which Applicant has not objection to, further requires that phased final plats comply
with the Development Agreement.
While not germane to the preliminary subdivision application, the Applicant notes that the
Brinnon Group misconstrues the phasing requirements under the Development Agreement. The
Phasing Plan in the Development Agreement does not require construction of the minimum
recreational amenities before all residential units are constructed. For example, many of the
minimum recreational amenities, like pools and sports courts, will likely be constructed in the
RECEIVED 10/27/25
EXHIBIT 90
8 | Page
Community Recreation Center. That building also includes over 200 residential units. Thus,
residential unit construction can occur while the recreational amenities are being constructed. The
phasing plan, consistent with the Kitsap County Superior Court’s Order, requires that the minimum
recreational amenities be completed before the Applicant can construct the balance of residential
units identified in Phases 2 and 3.
3. Designing Recreational Amenities or Buildings is not Required for Preliminary
Plat Approval and Cannot be Completed Until the County Approves the
General Layout of the Lots and Tracts.
The Brinnon Group and other commentators8 site to the lack of perceived progress over
the last six years towards designing recreational amenities or other building or improvements as
grounds for denying the preliminary plat application. The comments misunderstand the
development process and the Development Agreement. There is no requirement in the DA,
County Code or elsewhere that the Applicant must pre-design the recreational amenities or
proposed structures to secure preliminary plat approval. Any such requirement would be
nonsensical. The creation of lots and tracts is a necessary pre-requisite to any design work for the
recreational amenities and buildings.
The preliminary plat creates sufficient tracts and lots to accommodate the minimum
recreation amenities required by the Development Agreement: 9-hole golf course, spa services,
sports courts, pool and waterslides. DA at 10.3. It also sets aside adequate spaces for
ingress/egress, open spaces and preserves and protects critical areas like wetland and steep slopes
as required by the DA.
4. Appropriate Provision for Utilities
The Brinnon Group asserts that chapter 58.17 requires the application make “adequate
provisions” for utilities. Adequacy is not the standard for preliminary plat. A demonstration of
“adequacy” is the standard for other entitlements like building permits. See e.g. RCW 19.27.097
(requiring evidence of an “adequate” water supply for building permit approval). The standard for
subdivisions does not require the same level of proof as building permits. Rather, it requires an
applicant demonstrate that “appropriate provisions” for utilities to service the subdivision have
been made or can be made:
The purpose of a preliminary plat is to secure approval of the general
‘design’ of a proposed subdivision and to determine whether the
public use and interest will be served by the platting. Although the
planning department must determine ... whether water supplies {
and} sanitary waste disposal ... are currently available or whether
provisions must be made for the addition of such services , see RCW
8 See eg. Comments from Jan Wold at Ex. 88.
RECEIVED 10/27/25
EXHIBIT 90
9 | Page
58.17.110, compliance with specific health regulations applicable to
a completed development is not required for approval of a
preliminary plat.
Topping v. Pierce County Bd. Of Comm’rs., 29 Wn.App. 781, 783, 630 P.2d 1385 (1981).
The preliminary plat shall be the basis for the approval or disapproval of the general layout
of a subdivision. Whether “appropriate provisions’ have been made is judged against the general
layout of the plat, the application materials, and the conditions imposed to final plat approval. The
Applicant’s burden is met if demonstrates that it is taking adequate steps towards providing
appropriate provisions for utilities. See e.g. Haas v. Clark County, 93 Wn.App. 1066 (1999)
(unreported) (finding it was sufficient for preliminary plat approval that applicant showed it was
“taking steps to establish public water and that it would likely be available . . . particularly with a
condition that potable water be in place before final plat approval”). Here, as outlined in the
County Staff Report, the Applicant has made appropriate provisions for utilities. It has sufficient
water rights to service the proposed subdivisions, it has a water system plan that is under review
by Ecology, it has an Ecology-approved sewer plan, adequate spaces for stormwater treatment and
retention have been set aside in the plat layout, and adequate space has been reserved for a road
network appropriate for access to the lots and tracts.
Likewise, the Brinnon Group’s claim that “appropriate provisions” have not been made
ignores the conditions recommended by County Staff and agreed to by the Applicant. Whether
appropriate provisions have been made is judged against the application materials and staff
conditions. See e.g. Knight v. City of Yelm, 173 Wn.2d 325 (2011) (affirming demonstration of
adequate water availability as a condition to final plat approval); Snider v. Board of County Com’rs
of Walla Walla County, 85 Wn.App 371 (1987) (affirming the imposition of a condition on
preliminary plat approval because it was necessary to assure subdivision made appropriate
provision for public health, safety, and welfare). County Staff’s proposed conditions, that
Applicant does not object to, ensure that the necessary utilities be in place to service the final plat
under review. See e.g. Staff Report Conditions 36 (“Improvements for potable water and sanitary
sewer serving each phase shall be installed or bonded prior to final plat approval for the phase.”),
43 (“Prior to Jefferson County issuing construction permits that include electrical infrastructure
for phase, PHMPR shall provide documentation form [the PUD] to demonstrate the project can be
sufficient served with electricity for that phase.”).
The Brinnon Group further suggests that state law and County standards for approving
preliminary plats differ based on the size of the project. See Exhibit 75 (“For garden-variety
subdivisions, local government reviewers ensure they are consistent with utilities concerns,
assuring connection with the local water and sewer district and sufficient access to arterial streets.
However, this subdivision is far beyond the typical residential subdivision.”). The Brinnon Group
offers on support of this contention. State law and the County Code do not establish different
standards of proof based on project size.
RECEIVED 10/27/25
EXHIBIT 90
10 | Page
Sincerely,
John (JT) Cooke
Attorneys for Pleasant Harbor Marina &
Golf Resort LLP
Cc: Client (via email)
Phil Hunsucker (via email)
RECEIVED 10/27/25
EXHIBIT 90
Subject: Re: FPA 2618551 - PGST and JST 11-1-24 Pleasant Harbor Landowner-Tribal Meeting Update
From: Ryan Hodges <ryanh@statesmangroup.com>
Date: 2/25/25, 12:19 PM
To: Nikki Aikman <nikkia@pgst.nsn.us>
CC: "Misty A. Ives" <mives@pgst.nsn.us>, Allie Taylor <ataylor@jamestowntribe.org>, Hilton Turnbull
<hturnbull@jamestowntribe.org>, Tami Clark <tamic@statesmangroup.com>, "Puksta, Levi (DNR)"
<Levi.Puksta@dnr.wa.gov>, "Pagel, Krista (DNR)" <Krista.Pagel@dnr.wa.gov>, Roma Call <romac@pgst.nsn.us>, Issac
Purser <ipurser@pgst.nsn.us>, Glenda Breiler <glenda.breiler@dnr.wa.gov>
Dear Nikki,
We are following the IDP and in the event of a discovery all work in the discovery area will stop and all Tribes listed in the
IDP will be notified in accordance with the approved IDP plan.
The IDP was agreed to by the listed tribes before us and it only calls for the Archaeologist to be present during excavation
in the listed High Probability Areas. We must be inclusive of all tribes and saying one tribe can be present on site, is not
inclusive of all listed tribes.
To my understanding Ms Haworth has misunderstood what Mr Holbert said, as that comment was made for in the event of a
discovery.
The RCW you provided is in reference to discovered objects. As to date we have not discovered any objects. In the event
of a discovery we will follow the IDP and state RCW's
This is a sensitive issue with more than just your tribe, it affects 5 other tribes and we must honor the rights of all tribes
and the potential for discovery of there remains or artifacts as well.
We understand that this might not be what you want to hear, however, we must follow the IDP as agreed by the elders past
as they intended.
Please feel free to call as I am happy to talk anytime,
Ryan Hodges
Asst Project Manager
Pleasant Harbor MPR
907-538-1394
On 2/24/25 07:58, Nikki Aikman wrote:
Hi Ryan,
I've copied the email from Cristina Haworth at Jefferson County DCD and pasted below.
Further, I'm attaching the RCW for disturbing an archeological site with the reminder that this site has known, documented cultural
resources and these are on record at the Wa Department of Archeology and Historic Preservation as well as DNR. DNR, as well as
landowners/developers are legally obligated to protect such resources.
https://app.leg.wa.gov/RCW/default.aspx?cite=27.53.060&pdf=true
Good afternoon,
I followed up with the developer about the site visit issue you mentioned. John told me that an archaeologist or THPO representing PNPTC, PGST, and/or
JST would be welcome on the site to monitor work near potential culturally significant areas. He warned me that it is an active construction site, so the
number of people that could attend should be limited for safety. He also told me that the work will be monitored by PHMPR’s archaeologist.
Sincerely,
Cristina
Cristina Haworth, AICP | Senior Planner/Project Manager
11241 Willows Road NE, Suite 200 | Redmond, WA 98052
Direct: 425.250.5381 | Main: 425.822.4446
www.otak.com
Nikki Aikman,
Forest and Conservation Program Manager,
Port Gamble S’Klallam Tribe
360-865-2678
APPENDIX A RECEIVED 10/27/25
EXHIBIT 90
From: Ryan Hodges <ryanh@statesmangroup.com>
Sent: Monday, February 24, 2025 5:34:26 AM
To: Nikki Aikman <nikkia@pgst.nsn.us>
Cc: Misty A. Ives <mives@pgst.nsn.us>; Allie Taylor <ataylor@jamestowntribe.org>; Hilton Turnbull
<hturnbull@jamestowntribe.org>; Tami Clark <tamic@statesmangroup.com>; Puksta, Levi (DNR) <Levi.Puksta@dnr.wa.gov>;
Pagel, Krista (DNR) <Krista.Pagel@dnr.wa.gov>; Roma Call <romac@pgst.nsn.us>
Subject: Re: FPA 2618551 - PGST and JST 11-1-24 Pleasant Harbor Landowner-Tribal Meeting Update
Dear Nikki and Rest of Team,
I am writing to inform you that there was some last minute availability with our archaeologist. We will be doing some
ground disturbing activity in non forested land later today with them present following the Monitoring Plan Protocol.
Please provide the information that you received from DCD in regards to being present during excavation?
Thanks,
Ryan Hodges
Assistant Project Manager
Pleasant Harbor MPR
907-538-1394
Sent from my iPhone
On Feb 7, 2025, at 12:33 PM, Nikki Aikman <nikkia@pgst.nsn.us> wrote:
Ryan,
Thank you for the update. Jefferson county DCD let us know you have agreed to allowing access on site. When
operations begin, our PGST THPO will be contacting you to coordinate monitoring efforts around the culturally sensitive
areas during ground disturbing operations.
We appreciate your cooperation in ensuring the protection of significant cultural resources.
Nikki Aikman,
Forest and Conservation Program Manager,
Port Gamble S’Klallam Tribe
360-865-2678
From: Ryan Hodges <ryanh@statesmangroup.com>
Sent: Friday, February 7, 2025 12:23 PM
To: Nikki Aikman <nikkia@pgst.nsn.us>; Misty A. Ives <mives@pgst.nsn.us>; Allie Taylor
<ataylor@jamestowntribe.org>
Cc: Hilton Turnbull <hturnbull@jamestowntribe.org>; Tami Clark <tamic@statesmangroup.com>; Puksta, Levi (DNR)
<Levi.Puksta@dnr.wa.gov>; Pagel, Krista (DNR) <Krista.Pagel@dnr.wa.gov>; Roma Call <romac@pgst.nsn.us>
Subject: Re: FPA 2618551 - PGST and JST 11-1-24 Pleasant Harbor Landowner-Tribal Meeting Update
Dear Nikki,
On Jan 29, 2025, we walked the High Probability Areas with the Arch Firm. They are looking over the documentation,
updating the GIS maps and then we should have some kind of tentative schedule to provide you.
Since our last meeting we have not progressed on any cutting or ground disturbing activities associated with FPA
2618551.
We have updated the contact info for PGST and JST in accordance with the county requirements. In the event of IDP
findings we will notify the updated contacts.
Have a good weekend,
Ryan Hodges
Pleasant Harbor MPR
Assistant Project Manager
907-538-1394
On 2/5/25 12:21, Nikki Aikman wrote:
RECEIVED 10/27/25
EXHIBIT 90
Hi Ryan,
I wanted to follow up on our additional concerns. We haven't heard from you since the selection of the archeological firm that was confirmed. Do
you have an update for us on our additional requests?
In addition, it was stated in our meeting notes that there are no ground disturbing activities as part of this FPA. For clarification purposes, tree
harvesting and vegetation removal ARE ground disturbing activities. The FPA is conditioned in Question 28 to state that we will be notified before
ground disturbing activities occur. Can you let me know if the FPA work has begun yet?
Nikki Aikman,
Forest and Conservation Program Manager,
Port Gamble S’Klallam Tribe
360-865-2678
From: Ryan Hodges <ryanh@statesmangroup.com>
Sent: Thursday, December 5, 2024 4:10 PM
To: Nikki Aikman <nikkia@pgst.nsn.us>; Misty A. Ives <mives@pgst.nsn.us>; Allie Taylor <ataylor@jamestowntribe.org>
Cc: Hilton Turnbull <hturnbull@jamestowntribe.org>; Tami Clark <tamic@statesmangroup.com>; Puksta, Levi (DNR)
<Levi.Puksta@dnr.wa.gov>; Pagel, Krista (DNR) <Krista.Pagel@dnr.wa.gov>
Subject: FPA 2618551 - PGST and JST 11-1-24 Pleasant Harbor Landowner-Tribal Meeting Update
Dear FPA Team,
Please see attached Archaeological Firm Notice as per FPA 2618551 - PGST
and JST 11-1-24 Pleasant Harbor Landowner-Tribal Meeting.
We look forward to working with this experienced firm.
Thank you for your time,
Ryan Hodges
Pleasant Harbor MPR
Assistant Project Manager
907-538-1394
cc: Levi Puksta WA DNR
Krista Pagel WA DNR
RECEIVED 10/27/25
EXHIBIT 90