HomeMy WebLinkAbout91_JC FINAL Jefferson County Response to PHMPR Hearing Testimony and Comments
RESPONSE TO COMMENTS SUBMITTED AT THE
OCTOBER 15, 2025, PUBLIC HEARING
Jefferson County
Preliminary Plat Application
Case No. SUB2023-00025
Issue Date: October 27, 2025
Pleasant Harbor Master Planned Resort
RECEIVED
EXHIBIT 91
Jefferson County Response to Comments Submitted at the October 15, 2025, Public Hearing
Pleasant Harbor Master Planned Resort (SUB2023-00025)
Issued October 27, 2025
Page 2 of 68
Contents
Contents .............................................................................................................................. 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. Response to Public Comments .............................................................................. 5
A. Public Comments Received .................................................................................. 5
B. Response to Public Comments ........................................................................... 13
1. Procedural Issues ............................................................................................... 13
2. Phasing ............................................................................................................... 17
3. Decision Criteria .................................................................................................. 18
4. Residential Subdivisions Not Allowed .................................................................. 18
5. Incompatibility with Rural Character .................................................................... 18
6. Traffic Impacts ..................................................................................................... 18
7. Appropriate Provision of Infrastructure ................................................................ 19
8. Cultural Resources Management ........................................................................ 22
10. Water Quality Monitoring and Management ........................................................ 27
11. Compliance and Enforcement ............................................................................. 29
12. Other Comments ................................................................................................. 30
Attachment A: Professional Qualifications of Contract Planner .................................................. 31
Attachment B: Professional Qualifications of Jefferson County Building Official/Fire
Marshal ............................................................................................................... 48
Attachment C: Jefferson County’s Response to DAHP’s April 9, 2018, Comments for
Public Hearing for Pleasant Harbor MPR, dated June 7, 2018 ............................ 51
Attachment D: DAHP’s Response to Jefferson County BOCC Letter of June 7, 2018,
dated June 20, 2018 ........................................................................................... 66
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 17, 2025.
RECEIVED
EXHIBIT 91
Jefferson County Response to Comments Submitted at the October 15, 2025, Public Hearing
Pleasant Harbor Master Planned Resort (SUB2023-00025)
Issued October 27, 2025
Page 3 of 68
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
RECEIVED
EXHIBIT 91
Jefferson County Response to Comments Submitted at the October 15, 2025, Public Hearing
Pleasant Harbor Master Planned Resort (SUB2023-00025)
Issued October 27, 2025
Page 4 of 68
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
CRMP Cultural Resources Management Plan
DAHP Department of Archaeology and Historic Preservation, Washington
DCD Department of Community Development, Jefferson County
DNR Department of Natural Resources, Washington
DOE Department of Ecology, Washington
DOH Department of Health, Washington
FEIS Final Environmental Impact Statement
FS&CA Future Staffing & Consultant Agreement
FSEIS Final Supplemental Environmental Impact Statement
IBC International Building Code, as adopted by Chapter 51-50 and
JCC 15.05.030. Per WAC 51-50-003, the 2021 edition of the IBC
has been adopted.
IDP Inadvertent Discovery Protocol
JCC Jefferson County Code
JST Jamestown S’Klallam Tribe
LOSS Large Onsite Septic System
Master Plan The master plan defined in Development Agreement Section 3.2
and JCC 17.60.040
ODW Office of Drinking Water, Washington Department of Health
PGST Port Gamble S’Klallam Tribe
PHMPR Pleasant Harbor Master Planned Resort
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.
RECEIVED
EXHIBIT 91
Jefferson County Response to Comments Submitted at the October 15, 2025, Public Hearing
Pleasant Harbor Master Planned Resort (SUB2023-00025)
Issued October 27, 2025
Page 5 of 68
Acronym Meaning
PNPTC Point No Point Treaty Council
Property The property described in Section 5 of this Staff Report
PUD Public Utility District
THPO Tribal Historic Preservation Officer
RCW Revised Code of Washington
WAC Washington Administrative Code
WSDOT Washington State Department of Transportation
SECTION 3. Response to Public Comments
Additional oral testimony and written comments were submitted after the publication of the
Addendum to Staff Report on October 10, 2025. Prior to the close of the public hearing on
October 15, 2025, the Jefferson County Hearing Examiner consented to allow Jefferson County
and the project applicant an opportunity to respond in writing to public comments. The deadlines
set by the Hearing Examiner are:
1. Public comments may be submitted until 4:30PM on Wednesday, October 15, 2025.
Comments must be submitted to the Office of the Hearing Examiner.
2. The Exhibit Log shall be updated by October 17, 2025.
3. Jefferson County and the Applicant shall submit written responses to comments by
October 27, 2025.
A. Public Comments Received
As described in Section 3, written and oral testimony were submitted between the publication of
the Addendum to the Staff Report (Exhibit 74) on October 10, 2025, and the close of the public
hearing on October 15, 2025. Comments are briefly summarized below and can be found in full
in Exhibits 75-89.
Name Summary of Comments and County Action
Rick Aramburu
The Brinnon Group
October 14, 2025
See Exhibit 75
Summary of Comments:
Preliminary plat is inconsistent with phasing plan
and does not include detailed information about
required infrastructure and resort amenities.
Request for Hearing Examiner’s recusal based on
improper influence of Jefferson County
Commissioners.
Adequate provision of water, sewer, electricity, and
transportation utilities and infrastructure has not
been made.
Permit for Agra-Center building should not be
accepted or considered until final plat approval, and
additional environmental review should be
performed.
RECEIVED
EXHIBIT 91
Jefferson County Response to Comments Submitted at the October 15, 2025, Public Hearing
Pleasant Harbor Master Planned Resort (SUB2023-00025)
Issued October 27, 2025
Page 6 of 68
Name Summary of Comments and County Action
County Action:
Analysis provided in Staff Report (Exhibit 1),
Addendum to Staff Report (Exhibit 74), and
Sections B.1, B.2, and B.8 of this Written Response.
Marla Powers
Port Gamble S’Klallam Tribe
October 14, 2025
See Exhibit 78
Summary of Comments:
Concerns about cultural resources and natural
resources. Primary concerns are:
• Cultural resources management through
preservation of Kettles B and C, and
conducting the traditional cultural property
study recommended in the cultural
resources study.
• Incorrect tribal contact information and other
information in the Archaeological Monitoring
and Inadvertent Discovery Protocol
(Appendix Q). Requests update to Appendix
Q.
• Collaborate with the Tribes to prepare a
Kettle Management Plan.
• Water quality requirements are
unconsolidated and conflicting. Requests
one clear, concise water quality document.
• Prepare a water quality monitoring plan for
the stormwater retention pond.
• Mature tree stands should be preserved.
Requests a tree retention report.
• Exclusion of elk. A fence should extend
around the entire perimeter of the property
and PHMPR should work with the tribes to
update the Wildlife Management Plan
(Appendix P).
• Shellfish beds at the Duckabush and
Dosewallips Rivers may be impacted,
potentially leading to closures. PHMPR,
Jefferson County, and the State of
Washington should work together to monitor
shellfish beaches and manage shellfish
harvesting. Requests that signage, public
education, and shellfish harvest best
management practices be provided.
• Increased traffic may lead to more
stormwater runoff. Requests a stormwater
management plan for roads leading to
PHMPR.
• Increased boaters may cause congestion in
Pleasant Harbor. Requests a monitoring
plan and solutions for overflow parking.
RECEIVED
EXHIBIT 91
Jefferson County Response to Comments Submitted at the October 15, 2025, Public Hearing
Pleasant Harbor Master Planned Resort (SUB2023-00025)
Issued October 27, 2025
Page 7 of 68
Name Summary of Comments and County Action
• Increased population may increase light
pollution. Requests enforcement of Dark Sky
standards.
• Compliance and enforcement are not clear
for PHMPR. Requests that Jefferson County
work with the tribes and others to agree on
standards for resource management and a
plan for exceedances.
• Requests regular meetings between the
tribes and the developer/site manager during
and after construction.
• Requests a notification to tribes for any
unintended, unplanned, or emergency
discharge from the wastewater treatment
plant.
County Action:
Analysis provided in Staff Report (Exhibit 1),
Addendum to Staff Report (Exhibit 74), and
Sections B.8, B.9, B.10, and B.11 of this Written
Response.
Allie Taylor
Jamestown S’Klallam Tribe
October 14, 2025
See Exhibit 79
Summary of Comments:
Concerns about cultural resources and natural
resources. Primary cultural resources concerns are:
• Incorrect tribal contact information and
illegible maps in the Archaeological
Monitoring and Inadvertent Discovery
Protocol (Appendix Q). Requests update
and/or addendum to Appendix Q, preferably
in consultation with affected tribes.
• Destruction of critical aspects of traditional
cultural property. Kettles B and C and
adjacent wetlands should be preserved, and
the Development Agreement should be
corrected.
• Tribes should be recognized as having
special expertise in assessing the eligibility
of historic properties that may possess
religious and cultural significance to them.
Primary natural resources concerns are:
• Water quality requirements are
unconsolidated and conflicting. Requests a
summary document and reference list that
consolidates all water quality requirements.
• Exclusion of elk. A fence should extend
around the entire perimeter of the property
and cattle guards should be installed at each
RECEIVED
EXHIBIT 91
Jefferson County Response to Comments Submitted at the October 15, 2025, Public Hearing
Pleasant Harbor Master Planned Resort (SUB2023-00025)
Issued October 27, 2025
Page 8 of 68
Name Summary of Comments and County Action
entrance. Or adaptive management should
be required.
County Action:
Analysis provided in Staff Report (Exhibit 1),
Addendum to Staff Report (Exhibit 74), and Section
B.8 of this Written Response.
Sierra Club North Olympic Group
Darlene Schanfald, Ph.D.
October 15, 2025
Oral Testimony
Summary of Comments:
Sierra Club North Olympic Group has been tracking
this project since 2009. Written comments were
submitted (see Exhibit 65P). Primary concerns are:
• Spreading treated sewage solids on land
• Treatment of unknown and/or unregulated
contaminants in sewage
• Loss of land for use by wildlife
County Action:
Information about sewage treatment was included in
the Addendum to Staff Report, Section 3.C.8.
Additional information provided in Sections B.7 and
B.9 of this Written Response.
Rick Aramburu
The Brinnon Group
October 15, 2025
Oral Testimony
Summary of Comments:
Request for procedural clarifications.
Adequate provision has not been made for utilities,
transportation infrastructure, and other factors to be
considered. A finding that the preliminary plat is
consistent with the Development Agreement is not
possible.
A building permit related to the subdivision is being
processed with an unknown use inconsistent with
the PHMPR.
County Action:
Analysis provided in Staff Report (Exhibit 1),
Addendum to Staff Report (Exhibit 74), and
Sections B.1, B.2, and B.8 of this Written Response.
Allie Taylor
Jamestown S’Klallam Tribe
October 15, 2025
Oral Testimony
Summary of Comments:
Concerns about traditional cultural properties,
particularly Kettles B and C and wetlands. Assertion
that it is Jefferson County and the Washington
Department of Archaeology and Historic
Preservation (DAHP) responsibility to ensure
protection of sacred sites under local and state
laws.
RECEIVED
EXHIBIT 91
Jefferson County Response to Comments Submitted at the October 15, 2025, Public Hearing
Pleasant Harbor Master Planned Resort (SUB2023-00025)
Issued October 27, 2025
Page 9 of 68
Name Summary of Comments and County Action
Requested an update to the Archaeological
Monitoring and Inadvertent Discovery Protocol
(Appendix Q) to use current standards, corrected
contact information, and a current site plan.
County Action:
Analysis provided in Staff Report (Exhibit 1),
Addendum to Staff Report (Exhibit 74), and Section
B.8 of this Written Response.
Alex Scagliotti
Jamestown S’Klallam Tribe
October 15, 2025
Oral Testimony
Summary of Comments:
Jamestown S’Klallam Tribe is not opposing the
project, but is trying to improve it. See prior
submitted written comments (Exhibit 79). Primary
concerns are:
• Water quality requirements are unclear and
conflicting. Requests a single summary table
that lists all water quality standards,
document location, and pathway to conflict
resolution.
• Elk exclusion fence should extend around
entire property, and adaptive management
should be required if fence does not work.
County Action:
Analysis provided in Staff Report (Exhibit 1),
Addendum to Staff Report (Exhibit 74), and
Sections B.9 and B.10 of this Written Response.
Marla Powers
Port Gamble S’Klallam Tribe
October 15, 2025
Oral Testimony
Summary of Comments:
Port Gamble S’Klallam Tribe is not opposing the
project. See prior submitted written comments
(Exhibit 78). Primary concerns are:
• Appreciate Dark Skies requirements,
requests monitoring.
• Requests pathway for notification to Tribes
for exceedance of monitored environmental
benchmarks.
• Requests monthly meetings between Owner
and Tribes during construction and quarterly
meetings during operation.
• Requests notification of Tribes with usual
and accustomed rights of any unplanned or
emergency discharge from the wastewater
treatment plant.
RECEIVED
EXHIBIT 91
Jefferson County Response to Comments Submitted at the October 15, 2025, Public Hearing
Pleasant Harbor Master Planned Resort (SUB2023-00025)
Issued October 27, 2025
Page 10 of 68
Name Summary of Comments and County Action
County Action:
Analysis provided in Staff Report (Exhibit 1),
Addendum to Staff Report (Exhibit 74), and
Sections B.9 and B.10 of this Written Response.
Chloe Donaldson
Port Gamble S’Klallam Tribe
October 15, 2025
Oral Testimony
Summary of Comments:
See prior submitted written comments (Exhibit 78).
Primary concerns are:
• Agrees with and affirms Jamestown
S’Klallam Tribe comments related to:
updated Archaeological Monitoring and
Inadvertent Discovery Protocol (Appendix
Q); water quality requirements summary
table; preservation of Kettles B and C and
wetlands; and elk exclusion.
• Requests a kettle management plan.
• Requests a human and environmental
health monitoring plan.
• Requests protection of shellfish beds at
Dosewallips and Duckabush Rivers,
including monitoring beaches and adding
public education and signs.
• Tree retention is unclear. Requests a current
tree retention report and future reports as
development activity continues.
County Action:
Analysis provided in Staff Report (Exhibit 1),
Addendum to Staff Report (Exhibit 74), and
Sections B.8, B.9, and B.10 of this Written
Response.
Shelly Yarnell
October 15, 2025
Oral Testimony
See Also: Exhibit 85
Summary of Comments:
Read letter from Suzy Ames, Ed.D., President of
Peninsula College. In support of this project, which
will create sustainable economic development and
more recreational and childcare opportunities for
children and youth in the Brinnon community.
County Action:
None. Oral testimony incorporated into the record.
Jean Ball
October 15, 2025
Oral Testimony
Summary of Comments:
Strongly in support of this project, which will bring
positive economic development to the Brinnon
community. Project is supported by the silent
majority of Brinnon residents.
RECEIVED
EXHIBIT 91
Jefferson County Response to Comments Submitted at the October 15, 2025, Public Hearing
Pleasant Harbor Master Planned Resort (SUB2023-00025)
Issued October 27, 2025
Page 11 of 68
Name Summary of Comments and County Action
County Action:
None. Oral testimony incorporated into the record.
Melissa Chittenden
October 15, 2025
See Exhibit 80
Summary of Comments:
Full support of the project. Disappointment in delays
and request to move project forward.
County Action:
None. Comments incorporated into the record.
Melissa Chittenden
October 15, 2025
See Exhibit 81
Summary of Comments:
Explanation of meeting attendance and request to
incorporate prior comments (see Exhibit 80) into the
record.
County Action:
Comments incorporated into the record (see Exhibit
81).
Marla Powers
Port Gamble S’Klallam Tribe
October 15, 2025
See Exhibit 82
Summary of Comments:
Clarifies that Port Gamble S’Klallam Tribe is not
unopposed and prefers project not move forward,
but will collaborate with Jefferson County on
conditions of approval.
Other clarifications are:
• DAHP letter recommended preservation of
Kettles B and C. The PGST is a living people
with cultural connection to the kettles as a
matter of historic preservation and current
cultural practice.
• Full perimeter fencing is necessary to
exclude elk from the property.
• An Inadvertent Discovery Plan is separate
from the outdated Cultural Resources
Management Plan (CRMP). The CRMP
should be updated to reflect current
practices.
County Action:
Analysis provided in Staff Report (Exhibit 1),
Addendum to Staff Report (Exhibit 74), and
Sections B.8 and B.9 of this Written Response.
Miriam Murdoch
October 15, 2025
See Exhibit 83
Summary of Comments:
Opposed based on incompatibility with rural
character; financial feasibility; timing of resort
amenity construction vs. residential lots/housing
RECEIVED
EXHIBIT 91
Jefferson County Response to Comments Submitted at the October 15, 2025, Public Hearing
Pleasant Harbor Master Planned Resort (SUB2023-00025)
Issued October 27, 2025
Page 12 of 68
Name Summary of Comments and County Action
construction; scale of project; natural resources;
traffic on US Highway 101.
County Action:
Analysis provided in Staff Report (Exhibit 1),
Addendum to Staff Report (Exhibit 74), and
Sections B.2, B.5, B.6, B.9, and B.12 of this Written
Response.
Suzy Ames, Ed.D.
Submitted by Shellie Yarnell
October 15, 2025
Original date October 6, 2025
See Exhibit 85
Summary of Comments:
Read letter from Suzy Ames, Ed.D., President of
Peninsula College. In support of this project, which
will create sustainable economic development and
more recreational and childcare opportunities for
children and youth in the Brinnon community.
County Action:
None. Comments incorporated into the record.
Patty Schmucker
PNW Business Resource Collective
October 15, 2025
See Exhibit 86
Summary of Comments:
Strong in support of this project, which will
strengthen and revitalize the local economy. The
PHPMR is a catalyst for community renewal.
County Action:
None. Comments incorporated into the record.
Nikki Aikman
Port Gamble S’Klallam Tribe
October 15, 2025
See Exhibit 87
Summary of Comments:
Includes Ryan Hodges response to Forest Practices
Application (FPA) comments. PGST’s cultural
resources concerns were not addressed in the FPA
process and there is no mutual agreement for
protection of natural resources.
County Action:
Analysis provided in Staff Report (Exhibit 1),
Addendum to Staff Report (Exhibit 74), and Section
B.8 of this Written Response.
Jan Wold
October 15, 2025
See Exhibit 88
Summary of Comments:
Project located in very environmentally sensitive
area. Primary concerns are:
• Strict adherence to phasing plan in
Amendment 2 to Development Agreement.
• Lack of progress and plans for amenities.
• Inadequate water rights.
• Jefferson PUD paying for water and sewer
improvements.
RECEIVED
EXHIBIT 91
Jefferson County Response to Comments Submitted at the October 15, 2025, Public Hearing
Pleasant Harbor Master Planned Resort (SUB2023-00025)
Issued October 27, 2025
Page 13 of 68
Name Summary of Comments and County Action
• Environmental damage from development
activities.
County Action:
Analysis provided in Staff Report (Exhibit 1),
Addendum to Staff Report (Exhibit 74), and
Sections B.2, B.4, B.7, B.9, and B.12 of this Written
Response.
Rick Aramburu
The Brinnon Group
October 15, 2025
See Exhibit 89
Summary of Comments:
The Brinnon Group is opposed to the project and
requests denial of the application. Primary concerns
are:
• Request for recusal based on BoCC
“Values” statement creating appearance of
unfairness.
• Application of recusal argument applying to
any Hearing Examiner is irrelevant and
BoCC should not issue directives on
applications they don’t retain decision-
making authority on.
• The building permit application should not be
processed while a plat is in review.
• Economic development is not a criterion for
preliminary plat review.
County Action:
Analysis provided in Staff Report (Exhibit 1),
Addendum to Staff Report (Exhibit 74), and Section
B.1 of this Written Response.
B. Response to Public Comments
Public comments and oral testimony identified several areas of concern:
1. Procedural Issues
Jefferson County’s Review Staff
Several of Rick Aramburu’s comments (Exhibit 75, Exhibit 89, and oral testimony) imply that
Jefferson County’s reviewer is overlooking certain review requirements or improperly processing
this and other applications. Jefferson County contracted with Otak, Inc., to serve as the Contract
Planner defined in the Future Staffing & Consultant Agreement (FS&CA). Otak is a firm
composed of qualified professionals that provided planning and civil engineering expertise for
preliminary plat review. Jefferson County’s Building Official and Fire Marshal (a single individual
holds both offices) has relevant qualifications and the necessary expertise to provide building
code and fire code interpretation and review services related to this project. Jefferson County’s
Contract Planner and Building Official/Fire Marshal are qualified to review the application and
RECEIVED
EXHIBIT 91
Jefferson County Response to Comments Submitted at the October 15, 2025, Public Hearing
Pleasant Harbor Master Planned Resort (SUB2023-00025)
Issued October 27, 2025
Page 14 of 68
make professional recommendations and determinations related to consistency with the master
plan. Qualifications for Otak’s assigned staff are included in Attachment A to this response letter
and qualifications for Jefferson County’s Building Official/Fire Marshal are included in
Attachment B to this response letter.
Considering All Public Comments
Rick Aramburu, representing The Brinnon Group, states that “The Brinnon Group’s most recent
comment letter, dated September 16, 2025, is not an Exhibit in the record…. This letter was
delivered based upon the comment deadline provided by the county, which was a day before
the issuance of the Staff Report, and accordingly does not address its contents,” (Exhibit 75).
Pursuant to JCC 18.40.280(2), “the staff report shall include and consider all written public
comments on the application,” (emphasis added). Jefferson County included and considered
public comments on the application received between September 6, 2023, and September 15,
2025, in the Staff Report (Exhibit 1). Written public comments on the application received
between September 15, 2025, and October 10, 2025, were included and considered in the
Addendum to the Staff Report (Exhibit 74) issued on October 10, 2025. The Hearing Examiner
Rules of Procedure require a “record of a hearing conducted by the examiner” to include the
“Departmental report,” which is the staff report referenced in JCC 18.40.280(2) (see Rule
4.1(a)). Departmental reports “shall be made publicly available at least 14 days prior to a
Hearing” (see Rule 4.2) and the record must be submitted to the Hearing Examiner’s office at
least five days in advance of the scheduled hearing (see Rule 4.3).
To ensure adequate time for interested parties to review the staff report and recommendation,
Jefferson County published the report on its website on September 15, 2025, 30 days prior to
the public hearing. This exceeds the minimum requirement for publication of the staff report at
least 14 days before the public hearing per Rule 4.2, an important consideration for Jefferson
County Department of Community Development (DCD) staff for such a complex project.
Because the staff report was issued so far in advance of the public hearing, however, DCD staff
continued to receive comments and issued an addendum five days prior to the public hearing in
compliance with Rule 4.3. The purpose of the addendum was to include and consider all written
public comments on the application pursuant to JCC 18.40.280(2) (Section 3, Exhibit 74).
Additional public comments were submitted on October 14, 2025,. These were not included and
considered in the staff report or addendum because they were submitted just one day prior to
the scheduled public hearing. Issues raised in these and other oral and written testimony
provided at the hearing are addressed in this written response.
Site Visit
The Hearing Examiner disclosed a site visit conducted prior to the public hearing. As an active
construction site, the Hearing Examiner was admitted to the site and escorted in a separate
vehicle by the Pleasant Harbor Master Planned Resort’s (PHMPR) employee. To avoid any
appearance of unfairness, Jefferson County notes that site visits are permissible pursuant to
Hearing Examiner Rules of Procedure 1.9. This rule requires that the Hearing Examiner obtain
consent to enter private property, which was granted by PHMPR’s employee.
The Request for Hearing Examiner’s Recusal was Correctly Decided
RECEIVED
EXHIBIT 91
Jefferson County Response to Comments Submitted at the October 15, 2025, Public Hearing
Pleasant Harbor Master Planned Resort (SUB2023-00025)
Issued October 27, 2025
Page 15 of 68
In a last minute motion made just prior to taking testimony by the Hearing Examiner, The
Brinnon Group requested that the Hearing Examiner recuse himself based on a claim of unfair
influence by the Jefferson County Board of Commissioners. This alleged influence is related to
the Board of County Commissioners’ (BoCC) “Pleasant Harbor Master Planned Resort and
Values of the Jefferson County Board of Commissioners” document dated May 27, 2025, and
posted on the project website. The motion was not properly filed with the Office of the Hearing
Examiner or served on counsel for the parties.
The Hearing Examiner correctly denied the request for recusal. The Brinnon Group suggested
the BoCC’s Values Statement dated May 27, 2025, creates an appearance of unfairness.
However, “The appearance of fairness doctrine does not apply to legislative actions.” King
County v. Cent. Puget Sound Bd., 91 Wn. App. 1, 35, 951 P.2d 1151, 1169 (1998), reversed in
part on other grounds, 138 Wn.2d 161, 979 P.2d 374 (1999). The values statement was a
legislative action. The BoCC went to great length to expressly distinguish its legislative action
from approval of the permit. In the Values Statement, page 2, the BoCC also explicitly says: “As
required by county code and state law, DCD’s role in the process is to serve as a neutral
reviewer of development and building applications.” (Emphasis added.)
There are four factors courts must consider when determining whether an action is quasi-judicial
or legislative in nature:
(1) whether the court could have been charged with the duty at issue in the
first instance; (2) whether the courts have historically performed such
duties; (3) whether the action of the municipal corporation involves
application of existing law to past or present facts for the purpose of
declaring or enforcing liability rather than a response to changing
conditions through the enactment of a new general law of prosecutive
application; and (4) whether the action more clearly resembles the ordinary
business of courts, as opposed to those of legislators or administrators.
City of Seattle v. Kaseburg, 13 Wn. App. 2d 322, 335-36, 467 P.3d 115, 123 (2018) (citing Harris
v. Pierce County, 84 Wn. App. 222, 228, 928 P.2d 1111 (1996)). Application of these factors
results in the conclusion the adopting the Values Statement was not a quasi-judicial action—it
was legislative. The Brinnon Group has proffered no evidence that the Values Statement was
directed at the Hearing Examiner and cannot be considered an ex party communication.
The Jefferson County Hearing Examiner Rules of Procedure (dated October 15, 2019) set forth
Appearance of Fairness Considerations in Rule 1.3, which provides the standard for
disqualification of a hearing examiner: “The examiner shall be disqualified from a hearing in
which the examiner's impartially is reasonably questioned.” At the hearing, the Hearing
Examiner made clear that he would not consider the Values Statement in making his decision.
In addition, the Hearing Examiner stated he would not be influenced by the threat of non-
renewal of his contract because he has plenty of other hearing examiner clients. As the Hearing
Examiner noted, the claim of appearance of unfairness resulting in recusal would apply to any
Hearing Examiner the County might appoint.
None of the evidence provided asserting the appearance of fairness doctrine precludes the
hearing examiner from hearing the matter. The appearance of fairness doctrine does not apply,
and even if it did, The Brinnon Group has not satisfied the requirements for recusal of the
Hearing Examiner.
RECEIVED
EXHIBIT 91
Jefferson County Response to Comments Submitted at the October 15, 2025, Public Hearing
Pleasant Harbor Master Planned Resort (SUB2023-00025)
Issued October 27, 2025
Page 16 of 68
Building Permit for AgraCenter Building
Rick Aramburu, representing The Brinnon Group, argued that a building permit is improperly
being reviewed and processed by Jefferson County (Exhibit 75). The building permit in question
is for a steel structure at the AgraCenter location, case no. CBLD2024-00028. Jefferson County
believes this is irrelevant to any decision on the preliminary plat application but offers this
additional explanation for clarification.
As Mr. Aramburu noted, the permit application is incomplete, but Jefferson County understands
that the structure will be used for temporary secure construction storage. Secure storage for
equipment and materials is necessary due to a history of trespass, vandalism, and theft on the
site. The building may be converted in the future to a permanent use. Any new uses in existing
structures require a new building permit to confirm that applicable building code requirements
for that use or occupancy are met.
JCC 18.35.440 governs the issuance of building permits with respect to plat approvals, stating:
(1) No building permit for a structure other than a temporary contractor’s office or temporary
storage building shall be issued for a lot or parcel within an approved long subdivision
prior to a determination by the relevant fire district chief or designee that adequate fire
protection and access for construction needs exist.
(2) No building permit for a structure other than a temporary contractor’s office or temporary
storage building shall be issued for a lot or parcel within an approved long subdivision
until the applicant complies with the improvement method report, all requirements of the
department of public works certificate of improvements, and all requirements of the final
plat approval.
(3) No occupancy permit for a structure other than a temporary contractor’s office or other
approved temporary building shall be issued for a structure on a lot or parcel within an
approved long subdivision prior to final inspection and approval of all required
improvements which will serve such lot or parcel to the satisfaction of the director of the
department of public works and county building official.
The requirements all allow temporary storage buildings, which are typical of large construction
projects. As proposed, the building is a prefabricated structure that will be assembled in the
location of the future AgraCenter. “Temporary” is not defined in the 2021 International Building
Code (IBC) adopted in WAC 51-50 and JCC 15.05.030, and therefore the term takes its usual
meaning as lasting for a limited time. The building can be disassembled and removed, and this
will be a condition of building permit approval to ensure compliance with JCC 18.35.440. As
noted above, if PHMPR chooses to convert the building to a permanent structure in the future or
change the use in the building, a new building permit will be required to verify compliance with
applicable IBC standards for the new use or occupancy. There is no blanket approval for the
AgraCenter for use as permanent storage, factory-assembled structure facility, maintenance, or
any other use.
Mr. Aramburu also argued that the building cannot be adequately screened by landscaping, that
adequate stormwater management cannot be provided, and that utilities and infrastructure are
not available for the building. Detailed landscaping information is not appropriately reviewed
with a preliminary plat and will instead be reviewed with construction permits. To ensure
RECEIVED
EXHIBIT 91
Jefferson County Response to Comments Submitted at the October 15, 2025, Public Hearing
Pleasant Harbor Master Planned Resort (SUB2023-00025)
Issued October 27, 2025
Page 17 of 68
compliance with landscaping requirements, staff recommended Condition 14. Stormwater
management is addressed in the Drainage Report (Exhibit 26) and will be reviewed in detail with
construction permits. Utilities are not required for a temporary storage facility; if the building
converts to a permanent use in the future and PHMPR wishes to connect to a water and sewer
system, capacity and connections will be reviewed with the new building permit required for this
change in use.
Proposed Uses
Mr. Aramburu also expressed concern about the proposed uses in Tract X-7 (Exhibit 75).
Proposed uses, including modular construction, are addressed in the Addendum to the Staff
Report (Section 3.C.12, Exhibit 74)
2. Phasing
Rick Aramburu, representing The Brinnon Group, alleges that “this Applicant does not really
intend, nor have the organizational or financial capacity, to develop a major destination master
planned resort at this location,” based on a lack of detailed drawings, renderings, or plans for
the central features of the PHMPR and a departure from the phasing plan adopted in
Amendment 2 to the Development Agreement (Exhibit 75). Jan Wold also comments on the
need for strict adherence to the adopted phasing plan (Exhibit 88).
Phasing is discussed in the Staff Report (see Section 7.G, Exhibit 1) and the Addendum to the
Staff Report (see Section 3.C.2, Exhibit 74).
State law (in RCW 58.17.020) defines a preliminary plat as “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 the requirements of this chapter. The preliminary plat
shall be the basis for the approval or disapproval of the general layout of a subdivision.” It is
typical for a developer to seek preliminary plat approval prior to the installation of infrastructure
and amenities required by local codes; requirements related to the location or design of
infrastructure and amenities are commonly included in conditions of the preliminary plat
approval by local jurisdictions. It would be unnecessarily wasteful in terms of design costs borne
by the developer, staff time, construction costs borne by the developer, and environmental
impacts from construction or site design choices to install infrastructure or amenities that may
be changed by a preliminary plat decision. Jefferson County’s code does not require detailed
drawings, renderings, or plans for infrastructure, facilities, or amenities as part of any
preliminary plat application pursuant to JCC 18.35.280-300. See also: Section 3.C.3 of the Staff
Report Addendum, which clarifies Jefferson County’s position on the appropriate level of review
for a preliminary plat; Section 3.C.12 of the Staff Report Addendum, Amenity and Golf Course
Design subsection, which discusses construction-level design information for resort amenities
(Exhibit 74).
Mr. Aramburu also claims there was departure from phasing requirements in Amendment 2 to
the Development Agreement, arguing that “Though the Amended Development Agreement from
2019 requires phasing of development,” the Applicant instead discusses construction
sequencing that appears to be inconsistent with the phasing plan. As discussed in the Staff
Report (Paragraph 169, Section 7.G, Exhibit 1), phasing is not mandatory; if the Applicant
chooses to phase the project, it must follow the phasing plan as adopted in Amendment 2 to the
Development Agreement. This is reflected in the Plat Notes, which state “Delineation of Phases:
RECEIVED
EXHIBIT 91
Jefferson County Response to Comments Submitted at the October 15, 2025, Public Hearing
Pleasant Harbor Master Planned Resort (SUB2023-00025)
Issued October 27, 2025
Page 18 of 68
Section 10 of the Development Agreement and Exhibit 4 delineate the required components for
phased final plat approval of the subdivision,” (Exhibit 33) and in staff-recommended Condition
6.
Regardless of any statement in application materials, the PHMPR must comply with the phasing
plan. This is mandatory within the development agreement as amended (which incorporates the
phasing plan), in JCC 17.60.040, and in staff-recommended Conditions 6, 11, and 12 for the
preliminary plat. The phasing plan allows the applicant to proceed to final plat in one or more
phases. Noncompliance with the phasing plan will result in either rejection or denial of permits
or enforcement action pursuant to Title 19 JCC.
3. Decision Criteria
Rick Aramburu, representing The Brinnon Group, notes that economic development is not a
criterion for preliminary plat review, a comment that stems from the BoCC’s “Values” statement
(Exhibit 75). Jefferson County agrees. Decision criteria are found in JCC 18.35.310, JCC
18.40.280(5), and RCW 58.17.110. These criteria are analyzed in the Staff Report, and staff’s
proposed findings and conclusions for the applicable criteria are included in Section 8 of that
document (Exhibit 1).
4. Residential Subdivisions Not Allowed
A central theme in several comments is an objection to the preliminary plat on the grounds that
residential subdivisions are not allowed in this part of Jefferson County (Exhibit 83, Exhibit 88).
The proposal is for a mixed-use project consistent with the uses and development thresholds
established in the master plan (see Development Agreement section 3.2 and JCC 17.60.040); in
includes residential uses as well as nonresidential (resort amenities and commercial) uses. It is
not a residential-only subdivision.
Additionally, PHMPR is required to include all components of the project in a preliminary plat.
Pursuant to JCC 18.35.330, if phasing is utilized, “preliminary plat approval must be granted for
the entire subdivision.” PHMPR cannot proceed with a preliminary plat without including the
residential lots.
5. Incompatibility with Rural Character
Miriam Murdoch claims that the project design and scale is incompatible with the rural character
in the Brinnon area (Exhibit 83). Rural compatibility was addressed in the Addendum to the Staff
Report (Section 3.C.7).
6. Traffic Impacts
Miriam Murdoch expresses concern about traffic on US Highway 101 and the impacts this
project will have during periods of higher congestion (Exhibit 83). Traffic impacts are discussed
in Section 7.D of the Staff Report (Exhibit 1) and Section 3.C.5 of the Staff Report Addendum
(Exhibit 74). Traffic was analyzed in the 2007 Final Environmental Impact Statement (FEIS) and
2015 Final Supplemental Environmental Impact Statement (FSEIS) and mitigation measures
were identified to reduce or avoid impacts to US Highway 101.
RECEIVED
EXHIBIT 91
Jefferson County Response to Comments Submitted at the October 15, 2025, Public Hearing
Pleasant Harbor Master Planned Resort (SUB2023-00025)
Issued October 27, 2025
Page 19 of 68
7. Appropriate Provision of Infrastructure
Rick Aramburu, representing The Brinnon Group, claims that adequate provision has not been
made for water, sewer or electric utilities or transportation infrastructure (Exhibit 75). For
preliminary plats, Washington state law requires not “adequate” provision, but “appropriate”
provision. RCW 58.17.110(1) states, in relevant part:
A proposed subdivision and dedication shall not be approved unless the city, town,
or county legislative body makes written findings that: (a) Appropriate provisions
are made for the public health, safety, and general welfare and for such 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 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) the public use and interest will be served by the
platting of such subdivision and dedication.
(Emphasis added.) Pursuant to JCC 18.40.040, including Tables 8-1 and 8-2, a preliminary plat
is a Type III decision, where the hearing examiner makes a final determination of whether a
preliminary plat should be approved. Accordingly, the Hearing Examiner makes the findings
required by RCW 58.17.110(2). The preliminary plat application before the Hearing Examiner is
for a master planned resort, where there is a “master plan” that addresses all of the findings
required by RCW 58.17.110(2). See JCC 17.60.040 and Development Agreement, Section 3.2.
Section 3.2 of the Development Agreement states: “For the purposes of this Agreement, the
Master Plan for future development of the Pleasant Harbor MPR consists of the development
regulations adopted by the Board of County Commissioners, the conditions and requirements of
Ordinance 01-0128-08, the Final Environmental Impact Statement, the Final Supplemental
Impact Statement, and this Agreement, inclusive of a Phasing Plan and Master Plan Map of the
Property.” The “master plan” requires compliance with the 21 appendices in the Development
Agreement, the 68 conditions in the 2008 comprehensive plan amendment ordinance (Ord. No.
01-0128-08, also included as Appendix K to the Development Agreement), and the mitigation
conditions in the 2007 FEIS and the 2015 FSEIS.
The standard of review is substantial evidence for fact findings under RCW 58.17.110. Lanzce
G. Douglass, Inc. v. City of Spokane Valley, 154 Wn. App. 408, 421, 225 P.3d 448, 455 (2010).
This standard requires that reviewing courts to accept the fact finder’s determination of the
credibility of the witnesses and of the weight given to reasonable but competing inferences. Id.
(citing Hilltop Terrace, 126 Wn.2d 126 Wn.2d 22, 34, 891 P.2d 29, 36 (1995)). Here, substantial
evidence exists to support the required findings. In fact, the weight of the evidence in support of
the findings required by RCW 58.17.110(2) is overwhelming.
According to Mr. Aramburu, a “basic and fundamental requirement of the subdivision process is
to assure there will be basic utilities available to the new lots approved in the preliminary
subdivision,” (Exhibit 75). Jefferson County agrees, has analyzed information related to water,
sewer, and electric utilities and transportation infrastructure, and has determined that there is no
requirement that basic utilities must be installed before preliminary plat approval. Jefferson
County has also consulted with the Washington Department of Ecology (DOE), the Office of
Drinking Water (ODW) within the Washington Department of Health (DOH), Mason Public Utility
RECEIVED
EXHIBIT 91
Jefferson County Response to Comments Submitted at the October 15, 2025, Public Hearing
Pleasant Harbor Master Planned Resort (SUB2023-00025)
Issued October 27, 2025
Page 20 of 68
District (PUD) No. 1, and the Washington State Department of Transportation (WSDOT) about
their respective areas of regulatory control.
Jefferson County does not believe that utilities and infrastructure must exist for the proposed
subdivision to meet the “appropriate provisions” standard, but rather that the subdivision can be
appropriately provided with various utilities and infrastructure necessary to meet its needs as
laid out in the master plan. Requirements for construction of the various infrastructure and
utilities are subject to multi-jurisdictional review:
• Water System. The water system and plan must be approved by ODW in consultation
with DOE. Following water system plan and design approval, Jefferson County will issue
construction permits for land disturbance that includes installation of the water system.
To meet the standards of the master plan, permits for the water system cannot be issued
until State approvals and authorizations are provided. PHMPR submitted a draft water
system plan and staff-recommended Condition 38 requires this plan to be approved prior
to issuing construction permits that include water system infrastructure.
• Sewer System. The sewer (wastewater treatment) system and plan must be approved
by DOE. The wastewater treatment plan (Exhibit 22) was approved by DOE (Exhibit 23),
but further review will occur with system design. Following wastewater system approval,
Jefferson County will issue development permits for land disturbance that includes
wastewater/sewer infrastructure. A building permit is required for the wastewater
treatment plant. To meet the standards of the master plan, permits for the wastewater
treatment plant and underground infrastructure cannot be issued until State approvals
and authorizations are provided. Staff-recommended Condition 42 requires construction
and operation permits from DOE to be provided prior to Jefferson County issuing any
construction permits for structures or buildings to be served by the wastewater treatment
system.
• Electricity. Electricity will be provided by Mason PUD No. 1. According to Mason County
PUD No. 1, PHMPR must enter into a Large Load Agreement to determine the
necessary system improvements (Exhibit 67B). Mason County PUD No. 1 confirmed the
availability of two megawatts of power to serve the PHMPR project (Exhibit 67J), which
is approximately two-thirds of projected power needs. Statesman has paid a deposit to
Mason County PUD No. 1 to create a reimbursement agreement for the engineering,
design, and construction work to upgrade facilities and Mason County PUD No. 1
estimates that the agreement will be executed by the end of 2025 (Exhibit 67J). Staff-
recommended Condition 43 requires documentation from Mason County PUD No. 1
demonstrating that each phase can be adequately served with electricity, and verification
of adequate electric supply must be provided prior to final plat approval for each phase.
• Transportation. Mr. Aramburu’s transportation comments focus on the intersection
improvements at US Highway 101 and Black Point Road (Exhibit 75), citing a lack of
progress to apply for or construct the required improvements. Alterations to State-
managed roadways and work in WSDOT-owned right-of-way requires approval from
WSDOT. This intersection is a preliminary facility pursuant to section 10.2 of the
Development Agreement (as amended), and staff-recommended Condition 16 requires
construction of this intersection improvement prior to final plat approval.
RECEIVED
EXHIBIT 91
Jefferson County Response to Comments Submitted at the October 15, 2025, Public Hearing
Pleasant Harbor Master Planned Resort (SUB2023-00025)
Issued October 27, 2025
Page 21 of 68
The Application has demonstrated consideration of all necessary facilities and determined they
can feasibly be installed to serve the development. Rational, actionable pathways to construct
the necessary utilities and infrastructure are identified. Pursuant to staff-recommended
conditions, a final plat cannot and will not be granted until infrastructure plans are approved and
infrastructure is installed and verified to be in compliance with the master plan. As conditioned,
the project makes “appropriate provisions” for utilities and infrastructure.
Water Rights
Jan Wold comments on inadequate water rights to serve the development (Exhibit 88). Water
rights are discussed in Section 7.D of the Staff Report (Exhibit 1) and Section 3.C.6 of the
Addendum to the Staff Report (Exhibit 74).
Formation of Water and Sewer District
Rick Aramburu, representing The Brinnon Group, claims that failure to form a water and sewer
district is a failure to make “adequate provision” for water and sewer utilities (Exhibit 75). As
described above, however, the correct standard for a preliminary plat is “appropriate provision,”
and formation of a water and sewer district is not a requirement for making appropriate provision
for water and sewer service to the proposed development.
Formation of the water and sewer district is a component of Phase 1b, described in Section
10.1.3 of Amendment 2 to the Development Agreement:
10. 1. 3 Phase 1.
Phase 1 a consists of site clearing, grading and construction of the golf course,
road network, building footprints, and stormwater storage. Complete Highway
101 and Black Point intersection improvements. Build waste water treatment
plant, commence road construction with services and begin implementation of
the vegetation management plan. Create construction materials processing
location. Phase lb consists of construction of the LOSS drainfield ( wastewater
treatment plant back up system), water storage tank with distribution piping at
Tee 5, transit stop, construct sanitary sewer pump stations, Sea View Villas ,
Golf Vistas , construction of the Golf Terrace Community/Recreation Center (
See Appendix S to FSEIS) and Conference center/ spa ( including 208 units,
spa services, pool, water slides, commercial space and sports courts),
construct maintenance building and 52 units for staff quarters and formation of
a water and sewer district.
(Emphasis added.) The phasing plan does not require the formation of a water and sewer
district prior to a preliminary plat, nor are there any state regulations related to the timing of
formation of a water and sewer district with respect to preliminary plat approval.
Jefferson PUD
Jan Wold’s comments indicate that Statesman “wants to have the Jefferson Public Utility District
(PUD) either pay for the water and sewer systems or pay for them if the developer is unable to
complete them,” (Exhibit 88). The project is not within Jefferson PUD’s water, sewer, or electric
service areas; Jefferson PUD would need to accept PHMPR into its service area to pay for or
operate any water or sewer systems. Further, Statesman’s funding sources are not a matter of
RECEIVED
EXHIBIT 91
Jefferson County Response to Comments Submitted at the October 15, 2025, Public Hearing
Pleasant Harbor Master Planned Resort (SUB2023-00025)
Issued October 27, 2025
Page 22 of 68
public record; it seems unlikely, however, that Jefferson PUD would agree to pay for the water
and sewer improvements for a property outside its service areas.
Wastewater Treatment – Unregulated Contaminants and Reuse of Biosolids/Sludge
Darlene Schanfeld, Ph.D., of Sierra Club North Olympic Group, gave oral testimony describing
concerns about spreading biosolids/sludge (treated sewage solids) as fertilizer on the project
site and inadequate treatment of unregulated contaminants in sewage influent. Wastewater
treatment is analyzed in Section 7.D of the Staff Report (Exhibit 1) and Section 3.C.8 of the
Addendum to the Staff Report (Exhibit 74).
The Applicant submitted a wastewater system plan (the Pleasant Harbor Sewer System General
Plan, Exhibit 22) describing the proposed membrane bioreactor wastewater treatment plan,
which will be used to treat influent wastewater to Class A reclaimed water standards. Reclaimed
water will be used for irrigation on site. Minimum treatment and water quality requirements for
Class A reclaimed water are set forth in the 1997 Washington State Standards for Water
Reclamation and Reuse. DOE is responsible for ensuring planned facilities can successfully
meet treatment standards. DOE approved the wastewater system plan on October 6, 2022, and
requires that plans and specifications for facilities meeting the plan standards be submitted and
approved by DOE prior to construction (Exhibit 23). Jefferson County has no further authority to
require treatment in excess of that approved by DOE.
The wastewater treatment plan describes “residuals treatment and disposal” in section 2.2.5 of
the Pleasant Harbor Reclaimed Water Facility Engineering Report (Appendix 1, Exhibit 22).
Sludge will be held in a holding tank until it is dewatered, then hauled offsite to a disposal
facility. Biosolids disposal is regulated under WAC 173-308, including both for disposal at an
approved landfill facility. DOE is responsible for reviewing the disposal of biosolids.
8. Cultural Resources Management
Cultural Resources Concerns Not Addressed
Nikki Aikman for the PGST made comments, supported by attachments, that the PGST’s
cultural resources concerns were not addressed in the Forest Practices Application (FPA)
process and there is no mutual agreement for protection of natural resources (Exhibit 87). The
Washington State Department of Natural Resources (DNR) is responsible for reviewing and
issuing FPAs and Jefferson County is not a party to discussions between DNR, PHMPR, and
the Tribes.
Jefferson County does, however, offer some additional information about project history with
respect to cultural resources concerns. Tribes have been consulted with each major project-
related decision regarding cultural resources and Jefferson County understands PHMPR will
continue to consult with tribes. See Appendix Q of the Development Agreement, Proposed Plan
for Archeological Monitoring and Inadvertent Discovery Protocol, DAHP Response to Cultural
Resources Plan, and Skokomish Tribe Response to Cultural Resources Plan, addressing
cultural resources concerns. See also Exhibit 42. PHMPR shall implement the Cultural
Resources Management Plan (CRMP) attached in Appendix Q. Development Agreement,
section 8.8.3. Consultations with area tribes and with other local and state agencies helped
refine many of the development agreement’s management plans. The County has consulted
with area tribes on tribal treaty rights and other topics of interest throughout the PHMPR project
history. There is a long history of tribal engagement with this project.
RECEIVED
EXHIBIT 91
Jefferson County Response to Comments Submitted at the October 15, 2025, Public Hearing
Pleasant Harbor Master Planned Resort (SUB2023-00025)
Issued October 27, 2025
Page 23 of 68
Updating the Plan for Archaeological Monitoring and Inadvertent Discovery Protocol
The Port Gamble S’Klallam Tribe (PGST) and the Jamestown S’Klallam Tribe (JST) have asked
for an update to the Plan for Archaeological Monitoring and Inadvertent Discovery Protocol
(Exhibit 78, Exhibit 79, and oral testimony of Allie Taylor and Chloe Donaldson). Jefferson
County is aware that contact information in the Plan for Archaeological Monitoring and
Inadvertent Discovery Protocol (Appendix Q to the Development Agreement) is out of date.
Appendix Q is incorporated by reference into the Development Agreement and, because it lacks
adaptive management provisions, updating Appendix Q requires an amendment to the
Development Agreement. An amendment to the Development Agreement requires mutual
agreement by Jefferson County and PHMPR. Jefferson County does not have legal authority to
compel PHMPR to update the Development Agreement.
Jefferson County recommends adding a condition to each issued development permit that
requires PHMPR to incorporate current Tribal Historic Preservation Officer contact information in
coordination with the tribes. Jefferson County understands that the Development Agreement
already requires coordination with the Tribes through the required CRMP. Jefferson County
proposes the following condition for the Hearing Examiner’s consideration:
Jefferson County shall annually confirm current contact information for Tribal
Historic Preservation Officers (THPO) and shall immediately update contact
information if Tribes notify Jefferson County of THPO staffing changes. With
each issued development permit that involves land-disturbing activity,
Jefferson County shall provide current THPO contact information and shall
require PHMPR to incorporate it into the Inadvertent Discovery Protocol kept
on site. Development permits that involve land-disturbing activity shall include
the following condition of approval: PHMPR shall append to the site copy of
the Inadvertent Discovery Protocol (IDP) a list of current Tribal Historic
Preservation Officer contact information provided by Jefferson County and
shall use such contact information in case of inadvertent discovery or any other
notification required by the IDP.
Preserving Kettles B and C and Adjacent Wetlands
Jefferson County’s understanding is that the adjacent wetlands will be protected consistent with
requirements in the FEIS and FSEIS. Although easements are not shown on the preliminary plat
drawings (Exhibit 33), the drawings demonstrate that all wetlands will be placed in open space-
oriented tracts. The civil drawings (Exhibit 34) further indicate that no improvements are
proposed within the wetlands or their buffers. PHMPR submitted a draft of the wetland
conservation easement language (Exhibit 47).
With respect to the preservation of Kettles B and C, Jefferson County provided a
comprehensive response to the Point No Point Treaty Council’s (PNPTC) August 15, 2024,
comment letter on November 13, 2024 (Exhibit 69), which included a similar request to preserve
both geologic kettles. The County’s letter includes several appendices related to prior
documents, decisions, and correspondence. The County’s response letter provides detailed
information about Jefferson County’s position with respect to each comment made by the
PNPTC, environmental analysis conducted, regulations in place, and other commentary. In
particular, significant improvements have been made to the project proposal, development
RECEIVED
EXHIBIT 91
Jefferson County Response to Comments Submitted at the October 15, 2025, Public Hearing
Pleasant Harbor Master Planned Resort (SUB2023-00025)
Issued October 27, 2025
Page 24 of 68
regulations, and Development Agreement as a result of Tribal participation. This includes
reducing the golf course from 18 holes to nine holes, increasing protections for the kettles in the
Development Agreement compared to the underlying comprehensive plan amendment approval
in Ord. No. 01-0128-08, and improving water quality monitoring and best management practices
requirements, among others.
The Tribes have provided a letter from DAHP dated April 9, 2018, (see Attachment D in Exhibit
79) as one basis for this request. Jefferson County provided a detailed response to this letter on
June 7, 2018 (Attachment C) and DAHP sent a follow-up letter dated June 20, 2018, confirming
they were not expecting to impose any regulatory requirements on this project,” (see Attachment
D to this Written Response).
Requested Studies and Plans
Several representatives of the JST and PGST requested additional studies and plans, including:
• Traditional cultural property study
• Kettle management plan
• Human and environmental health monitoring plan
Cultural resources analysis was completed for the 2007 FEIS and the 2015 FSEIS. The
Development Agreement requires adherence to the CRMP adopted in Appendix Q (called the
Plan for Archaeological Monitoring and Inadvertent Discovery Protocol). Jefferson County has
no authority to require a traditional cultural property study.
A kettle management plan is considered in section 5 of the Development Agreement, which
states:
The PGST has applied for including of any Traditional Cultural Properties on the National
Register of Historic Places as of the date of this 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 educational signs that explain the significance of the kettles to native people.
This provision does not restrict or otherwise prevent Developer from exercising its right
to object to any application that kettles are culturally significant.
The Applicant has applied for and received a stormwater permit for land disturbing activity (case
no. ZONS2024-00008). To date, no information about the Traditional Cultural Properties
application has been provided and Jefferson County is not aware of any eligibility determination
having been made for either Kettle B or Kettle C. A kettle management plan cannot be required.
RECEIVED
EXHIBIT 91
Jefferson County Response to Comments Submitted at the October 15, 2025, Public Hearing
Pleasant Harbor Master Planned Resort (SUB2023-00025)
Issued October 27, 2025
Page 25 of 68
There are numerous requirements for benchmarking and monitoring various environmental
health factors, including water quality, wildlife management, vegetation management, tunicates,
saltwater intrusion, and archaeology. Water quality standards and monitoring requirements are
particularly stringent (see Section B.10 of this Response), and PHMPR must comply with State
standards for exceeding emissions in ground or surface water. Jefferson County believes an
additional human and environmental health monitoring plan is not warranted.
Jefferson County does, however, recognize and acknowledge the cultural resources concerns
communicated by the PGST and JST. Within the framework of the master plan, Jefferson
County recommends the following condition for the Hearing Examiner’s consideration:
PHMPR shall follow the approved Plan for Archaeological Monitoring and
Inadvertent Discovery Protocol (Appendix Q to the Development Agreement) and
shall provide a final report to affected Tribes at the completion of excavation in
each high-probability area shown in Appendix Q. These Parties shall keep reports
and maps confidential to respect the concerns of the Tribes.
Recognition of Tribes’ Expertise in Assessing Cultural Resources
Allie Taylor for the JST commented that Jefferson County should recognize the expertise of
Tribes in assessing cultural resources (Exhibit 79). Jefferson County supports recognizing tribes
as having special expertise in assessing the eligibility of historic properties that may possess
religious and cultural resources to them. Jefferson County has encouraged and maintained
tribal engagement throughout the history of the PHMPR project. It is Jefferson County’s
understanding that tribal comments have been substantially addressed through previous County
responses, including but not limited to a comprehensive response to the PNPTC’s comment
letter on November 13, 2024 (Exhibit 69). Furthermore, Jefferson County substantially
addressed the Kettle Management Plan through its Development Agreement, Section 5,
Recognition of Areas with Cultural Significance, where PHMPR agreed to preserving one of the
Kettles, based on certain conditions. This required PGST to apply for and receive a
recommendation from the State Advisory Council on Historical Preservation that either Kettle B
or C is eligible for listing in the National Register of Historical Places. If, prior to PHMPR
applying for a grading or building permit for the PHMPR, the PGST received the designation,
then PHMPR agreed to: “(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.” However, to date, Jefferson County is not aware that this designation has been
provided.
9. Natural Resources Management
Elk Habituation
Allie Taylor for the JST raised additional concerns around natural resources and wildlife
management (Exhibit 79). Jefferson County’s understanding is that the Wildlife Management
Plan (Appendix P to Development Agreement) and Revised Wildlife Plan at Exhibit 28,
sufficiently address elk concerns along with balancing the needs of other wildlife. The Wildlife
Management Plan requires adaptative management practices for the elk in particular (see
RECEIVED
EXHIBIT 91
Jefferson County Response to Comments Submitted at the October 15, 2025, Public Hearing
Pleasant Harbor Master Planned Resort (SUB2023-00025)
Issued October 27, 2025
Page 26 of 68
discussion under Roosevelt Elk, starting on page 7 of Exhibit 28). The Wildlife Management
Plan is intended to ensure all animals and wildlife can thrive.
Based on Jefferson County’s review, there is no legal basis to require an updated Wildlife
Management Plan or require complete fencing around the full perimeter of the property at this
time. Adaptive management will be implemented, with PHMPR being required to provide
additional fencing or another exclusion mechanism if groups of four or more elk are found on the
site. A complete fence around the perimeter of the property will fragment habitat for other wildlife
that are already present on the Black Point peninsula, in direct conflict with the goals of the
Wildlife Management Plan. Jefferson County does not object to a condition requiring installation
of cattle guards at each entrance.
Shellfish Protection
Marla Powers for the PGST identified concerns about shellfish beds at Dosewallips and
Duckabush Rivers (Exhibit 78). Jefferson County has previously addressed shellfish in the Staff
Report. See references to Shellfish Resource Protection and Management and Water Quality
Protection and Management at pages 86 and 87. Jefferson County respectfully reiterates its
position here that shellfish is already heavily monitored and regulated by state and federal laws.
See Appendix N to the Development Agreement (Water Quality Monitoring Plan) and
FEIS/FSEIS mitigation measures. See also Jefferson County provided a comprehensive
response to the PNPTC’s comment letter on November 13, 2024 (Exhibit 69), specifically as
part of the Development Agreement, the project is required to conduct periodic surface water
and groundwater quality monitoring, and to follow best management practices and an adaptive
management program to ensure no violation of water quality criteria occurs (Appendix N to the
Development Agreement and Appendix 1 to Amendment 1 to the Future Staffing & Consultant
Agreement [FS&CA]).
Further, both the Development Agreement and the mitigation measures in the 2007 FEIS and
2015 FSEIS prohibit public access to the beach on the south side of the resort (the only beach
frontage on the upland golf resort portion of the master plan). A conservation easement (Exhibit
44) was recorded to close public access to beach and prevent establishment of new trails.
Further, the 2007 FEIS and the 2015 FSEIS mitigation measures require recreational shellfish
harvest information to be posted at the upland golf resort.
Tree Removal
Jefferson County refers to the Vegetation Management Plan in Appendix L and its Attachment 1,
Forest Report. (See also Exhibit 41). It is Jefferson County’s understanding that the Vegetation
Management Plan and Forest report already preserve healthy trees by prioritizing mature,
healthy stands. This is supported by best management practices to retain mature significant
trees, preferably in groups, where possible. As shown in the Staff Report (Exhibit 1), the project
has been substantially designed to avoid the high-priority stands of trees.
DarkSky Standards
Jefferson County understands PHMPR is already committed to using the International Dark Sky
Association’s standards. See Staff Report page 25, Development Agreement Appendix S Dark
Sky-Lighting Standards, and Development Agreement section 8.8.10. Light fixture cut sheets
are reviewed with construction permits and installed fixtures are inspected during construction.
RECEIVED
EXHIBIT 91
Jefferson County Response to Comments Submitted at the October 15, 2025, Public Hearing
Pleasant Harbor Master Planned Resort (SUB2023-00025)
Issued October 27, 2025
Page 27 of 68
10. Water Quality Monitoring and Management
Confusing Water Quality Requirements
The JST and the PGST made repeated requests for clarification of water quality requirements
(Exhibit 78, Exhibit 79, and oral testimony of Alex Scagliotti and Chloe Donaldson). The
comments indicate that the water quality requirements are unclear and conflicting because they
are spread out in five different documents. JST and PGST staff requested and recommended a
single clear, concise summary table that lists all applicable water quality standards, the
document in which the standard is located, and clarification of which standard(s) control in the
case of conflict.
Allie Taylor for the JST provides several examples (Exhibit 79):
• “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.
• “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.
• 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 [Jefferson County Environmental Public Health – Water Quality
Division], to achieve compliance with water quality criteria.” (Appendix N p. 5)
• “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)
• “For any violation of water quality criteria, PHMPR shall:
o Take immediate steps to correct the violation and shall remedy any impact to
water quality caused by the MPR; and
o Modify existing best management practices or apply further water pollution
control measures, selected or approved by the Washington Department of
Ecology or [Jefferson County Environmental Public Health – Water Quality
Division], to achieve compliance with water quality criteria.” (p. 7-8 of the First
Amendment to Future Staffing and Consultant Agreement)
Jefferson County is aware that water quality requirements are present in many documents. This
is due to the ongoing project review process, in which each decision has responded to prior
decisions. As JST and PGST staff note, water quality requirements are located in:
1. 2007 FEIS water quality mitigation measures. Required mitigating conditions are listed in
Chapter 5.
2. Ord. No. 01-0128-08, adopted in 2008.
3. 2015 FSEIS water quality mitigation measures.
RECEIVED
EXHIBIT 91
Jefferson County Response to Comments Submitted at the October 15, 2025, Public Hearing
Pleasant Harbor Master Planned Resort (SUB2023-00025)
Issued October 27, 2025
Page 28 of 68
4. Development Agreement and Appendix N (as amended), adopted 2018.
5. “June 11, 2024 Best Management Practices for the Pleasant Harbor Master Planned
Resort (Including the Pleasant Harbor Marina),” Appendix 1 to the First Amendment to
Future Staffing and Consultant Agreement for the Pleasant Harbor Master Planned
Resort
Jefferson County disagrees that the standards are conflicting, however. The standards build on
requirements made in each prior decision, culminating in the “Best Management Practices”
document, and each succeeding document was written to ensure it was harmonious with all
prior decisions and requirements. An example of this is easily seen by comparing the third and
fifth requirements cited in the JST letter (Exhibit 79), which are nearly identical. The “Best
Management Practices” document was intentionally written to collect prior standards and
requirements that still apply (note that some requirements have been completed); the origin of
each best management practice is cited in the “Best Management Practices” document. This
document must also be reviewed annually and requires adaptive management pursuant to
Appendix N to the Development Agreement. The “Best Management Practices” document does
not replace any of the other water quality documents; all water quality requirements for
monitoring, permits, construction and operational standards, etc. continue to apply.
Jefferson County is not opposed to creating a summary table in the next annual review and
update of the “Best Management Practices” document. Jefferson County believes the “Best
Management Practices” annual review and update is procedurally a more pertinent time to
address this concern. Jefferson County proposes the following condition for the Hearing
Examiner’s consideration:
Jefferson County shall, at the next annual review and update of the “Best
Management Practices for the Pleasant Harbor Master Planned Resort (Including
the Pleasant Harbor Marina),” provide a summary table that documents all
applicable water quality standards, the document in which the standard is located,
and clarification of which standard(s) control in the case of conflict.
US Highway 101 Stormwater Management Plan
Marla Powers for the PGST identified a concern about increased traffic contributing to more
stormwater runoff and requested a stormwater management plan for roads leading to PHMPR
(Exhibit 78). Jefferson County disagrees that there will be a significant increase in stormwater
runoff from roadways that will cause a greater amount of stormwater runoff. Except for a limited
area of expansion to accommodate the required US Highway 101/Black Point Road intersection
improvements, there are no planned expansions of US Highway 101 leading to or from the
PHMPR and therefore no additional increases in pollution-generating impervious surface that
would cause an increase in stormwater runoff beyond what was analyzed in the FEIS and
FSEIS.
Additional traffic may cause an increase in pollutants deposited on roadways from vehicles. The
intersection improvement will be designed to meet stormwater standards in place when permits
are applied for. There are no other construction triggers to require stormwater improvements
along US Highway 101 beyond what is necessary to treat the expanded roadway at the
RECEIVED
EXHIBIT 91
Jefferson County Response to Comments Submitted at the October 15, 2025, Public Hearing
Pleasant Harbor Master Planned Resort (SUB2023-00025)
Issued October 27, 2025
Page 29 of 68
intersection. WSDOT is responsible for the maintenance of US Highway 101 within their right-of-
way, including monitoring and mitigating stormwater impacts.
Water Quality Monitoring in Stormwater Retention Pond
Marla Powers for the PGST requested preparation of a water quality monitoring plan for the
stormwater retention pond (Kettle C) (Exhibit 78). Water quality impacts have been analyzed in
the 2007 FEIS and 2015 FSEIS. Kettle C will be converted to a stormwater facility, and there is
no basis to require additional monitoring of water quality in stormwater facilities. Water in the
pond will be used for irrigation of on-site landscaping and golf course fairways. Any irrigation
water will infiltrate through the ground, which is DOE’s preferred method to address stormwater.
PHMPR is required to monitor the surface water quality in Pleasant Harbor and groundwater
pursuant to the Water Quality Monitoring Plan adopted in Appendix N to the Development
Agreement. Additional water quality monitoring is not required.
Congestion in Pleasant Harbor and Pleasant Harbor Marina
Marla Powers for the PGST indicated that an increase in boaters may cause congestion in
Pleasant Harbor and requests a monitoring plan with solutions for overflow parking. The
Pleasant Harbor marina is not part of the land area included in the preliminary plat application.
Jefferson County believes there is not a nexus to require monitoring of marina activity with the
preliminary plat for the upland golf resort.
Notification of Tribes for Unplanned Discharge from Wastewater Treatment Plant
Marla Powers for the PGST requested a pathway to notify tribes with usual and accustomed
areas (U&A) on the Black Point peninsula and the surrounding Hood Canal of any unplanned or
emergency discharge from the wastewater treatment plant (Exhibit 78 and oral testimony).
PHMPR is required to notify Jefferson County and applicable State agencies if there are any
emergency or unplanned discharges from the wastewater treatment plant. It is incumbent upon
those agencies to pass notifications along to the Tribes. If the Hearing Examiner determines
additional notification or the Tribes’ requested regular meetings is appropriate, Jefferson County
has no objection.
11. Compliance and Enforcement
Marla Powers for the PGST commented that compliance and enforcement are not clear for the
PHMPR. Jefferson County disagrees; as described in Section 6.A of the Staff Report (Exhibit 1),
compliance with the master plan is enforceable through Title 19 JCC pursuant to JCC
17.60.110. The “Best Management Practices” document is part of the FS&CA. While the FS&CA
is not enforceable through Title 19 JCC, the “Best Management Practices” document is a
requirement of Appendix N and is therefore enforceable through Title 19 JCC. All standards
identified and established in the master plan, including environmental benchmarks, are
enforceable through Title 19 JCC.
Under Jefferson County’s enforcement program, in the event of a violation, enforcement action
is taken under Title 19 JCC. PHMPR has reporting requirements for water quality, among other
environmental benchmarks, and reports are proactively reviewed because of requirements in
the master plan. Enforcement will follow Jefferson County’s Enforcement Rules of Procedure.
RECEIVED
EXHIBIT 91
Jefferson County Response to Comments Submitted at the October 15, 2025, Public Hearing
Pleasant Harbor Master Planned Resort (SUB2023-00025)
Issued October 27, 2025
Page 30 of 68
12. Other Comments
Some comments were made that cannot be considered in the preliminary plat decision,
including:
• Financial feasibility and Statesman’s performance on other projects.
• Lack of progress on the PHMPR project.
• Lack of detailed drawings of amenities and infrastructure.
These topics are addressed in Section 3.C.12 of the Addendum to the Staff Report (Exhibit 74).
Attachments:
A. Professional Qualifications of Contract Planner
B. Professional Qualifications of Jefferson County Building Official/Fire Marshal
C. Jefferson County’s Response to DAHP’s April 9, 2018, Comments for Public Hearing for
Pleasant Harbor MPR, dated June 7, 2018
D. DAHP’s Response to Jefferson County BOCC Letter of June 7, 2018, dated June 20,
2018
RECEIVED
EXHIBIT 91
Jefferson County Response to Comments Submitted at the October 15, 2025, Public Hearing
Pleasant Harbor Master Planned Resort (SUB2023-00025)
Issued October 27, 2025
Page 31 of 68
Attachment A: Professional Qualifications of Contract Planner
RECEIVED
EXHIBIT 91
At Otak, we imagine, plan, and create exceptional
places that add to the greater good of the
communities where we enjoy life. Our planning,
design, engineering, architecture, and construction
management professionals take their responsibility
to future generations seriously.
In 1981, Otak’s founders set out to create a premier
interdisciplinary planning, design, and engineering firm.
Since it’s inception, Otak has grown into a company with
a strong reputation for excellence in smart growth
planning, sustainable design and development, and
innovative transportation solutions.
With a team of interdisciplinary experts, Otak brings
diverse experience and a forward-thinking approach to
every project. Creativity, integrity, and skill have guided
Otak’s efforts as an award-winning firm.
For more information, visit: www.otak.com
IMAGES OF OTAK PROJECTS PICTURED ABOVE Row 1: Swift BRT Orange
Line | Moshier Park | UW-Bothell Husky Village Housing Row 2: Tolt Avenue
(SR 203) Central Business District | Trilogy at Redmond Ridge
Planning. Design. Engineering. Project Management.
CONTACT
Mandi Roberts, AICP, Otak, (206) 949-2741
RECEIVED
EXHIBIT 91
Architecture
PM/CM and
Owner Representation
Civil and Structural
Engineering
Survey and
Mapping
Landscape
Architecture
Transportation
Planning and
Urban Design
Water and
Natural Resources
Our Team Our people are passionate and committed
to the pursuit of practice excellence—
through continuous growth, development,
and improvement we reach for innovative
yet practical solutions. We are a design-
focused company with the ability
to deliver our clients’ projects from
conception through construction.
Our firm’s diverse set of skills and
collaborative atmosphere support a wide
range of specializations, including:
•Current and Long Range Planning
•Permitting and Development Support
•Long Range Planning: Cities, Subareas,
Planned Communities, and Corridors
•Infrastructure Planning and Engineering
•Parks, Open Space, and Recreational
Facilities Planning and Design
•Mixed-Use, Residential, and Commercial
Development
Our Services
RECEIVED
EXHIBIT 91
Resumes
RECEIVED
EXHIBIT 91
Mandi Roberts AICP, PLA
Senior Vice President, Principal Planner, and Landscape Architect
Over the course of over 35 years in planning and landscape architecture, Mandi has
gained extensive experience in project management, public involvement,
environmental analysis, integrated land use and transportation planning, long range
and urban planning, master planning, design of various public and private projects,
and development review support. She is an excellent communicator and facilitator,
and her strong expertise in coordinating with multiple governmental agencies at the
federal, state, regional, and local levels, as well as with tribes, technical experts,
regulatory decision makers, and other diverse project stakeholders has benefited the
many planning and design projects she has been involved in. She is also an advocate
for integrated design, involving interdisciplinary teams and has worked cohesively
with other planners, designers, architects, engineers, and a variety of design
professionals on sustainable planning and design projects.
EDUCATION
Master of Landscape
Architecture (University of
Idaho)
BS, Landscape
Architecture (University of
Idaho)
REGISTRATIONS &
CERTIFICATIONS
Professional Landscape
Architect, WA, #639
Professional Landscape
Architect, ID, #16807
Certificate, Low Impact
Development (Washington
State University)
American Institute of
Certified Planners
Selected Project Experience
Pleasant Harbor Master Planned Resort, Consultant Planner;
Jefferson County, WA
Principal Planner/Advisor—Mandi is leading Otak’s role as the consultant planner identified in
the Future Staffing and Consultant Agreement for the Pleasant Harbor Master Planned Resort
(PHMPR) project, working on behalf of the County to review and process applications to
implement the PHMPR. She has been working with the team to determine compliance with the
development agreement and other governing documents and codes, tracking of conditions of
approval, and coordinating reviews by other staff, departments, and consultants. Mandi also
works closely with County staff and the developer to proactively coordinate on the permit review
process.
On-Call Development Review for Town Center Projects; Sammamish, WA
Principal Planner/Contract Manager—As part of an on-call contract with the City of
Sammamish, Otak provided support for Town Center development projects, including pre-
application reviews and comment letters; consistency reviews for the Town Center Plan and
Town Center Infrastructure Plan; and meetings with project applicants.
On-Call Development Review and Planning Services; Mountlake Terrace, WA
Principal Planner—Otak provided on-call development review and planning services to the City,
which included review of a variety of land use applications, SEPA compliance review,
preparation of staff reports and presentation materials, and frequent coordination and
interactions with City staff and applicants. We provided services on an on-going basis and
coordinated bi-weekly with the City team on upcoming applications, as well as work in process.
Holmes Point Drive Street Standards and Corridor Plan; Kirkland, WA
Project Manager—Otak worked with the City to develop recommendations for the Holmes Point
Drive corridor and to create specific street standards for the corridor and surrounding
neighborhood that are contextual and cohesive with the neighborhood character. The
standards differ in certain ways from the City’s street standards for the rest of the City and will
be implemented primarily through in-fill development. For the Holmes Point Drive corridor
analysis, the City sought to identify safety, preservation, and functional improvements that
should be made with recommendations for how those issues should be addressed. Otak also
supported public and stakeholder engagement for the project, helping prepare materials and
facilitate discussions in online public meetings.
RECEIVED
EXHIBIT 91
Mandi Roberts, AICP, PLA
Senior VP, Principal Planner, and Landscape Architect
2
148th Avenue NE Urban Boulevard Concept Plan; Bellevue, WA
Project Manager—Otak worked with City staff to develop an urban boulevard concept plan for
148th Avenue NE from I-90 to Bel-Red Road. The corridor streetscape was being designed to
enhance Bellevue’s Northwest character and vision as a City in a Park. The project follows the
City’s guiding principles for urban boulevard enhancements, calling for exceptional landscape
and community design. Otak developed an illustrative planting palette for use throughout the
corridor, which includes coding of trees, shrubs, and ground covers to coincide with distinctive
neighborhood character areas. The project also focused on methods for mitigating installation
of power transmission lines proposed along the boulevard and recommendations of trees and
landscaping appropriate for under and adjacent to the lines.
Comprehensive Plan Update/Middle Housing; Mill Creek, WA
Project Manager—Otak assisted the City in collaboratively engaging residents, the business
community, and affected property owners in preparation of a subarea plan that identifies the
highest and best future land uses for the area. The plan will be the basis for amendments to the
Mill Creek Comprehensive Plan and Municipal Code, which will facilitate future redevelopment
within the subarea. It will evolve through a collaborative interdisciplinary approach that includes
considerations related to land use, multi-modal transportation, stormwater management, utilities
and other infrastructure, placemaking, and civic campus enhancements.
City Center/Airport District Subarea Plan; SeaTac, WA
Project Manager—The subarea plan will expand on the recently updated community vision and
findings from the City Center Plan Update Phase 1 Vision Report. The planning process will
include a robust, inclusive public engagement process, consideration of opportunities and
constraints related to the achievement of the District’s potential for community and economic
development, and creation of a well-supported subarea plan and recommendations for code
updates to guide the revitalization of the area into the envisioned urban, airport-serving
business district and multifamily residential community.
Comprehensive Plan Update; Shoreline, WA
Project Manager—Otak was hired to assist the city in developing a comprehensive plan
through a vigorous stakeholder engagement process. The plan will anticipate 20 years of
growth, through 2044. Consistent with regional and county growth projections, Shoreline will
need to provide capacity for 13,330 new housing units and 10,000 new jobs by 2044. The
comprehensive plan will provide a strong vision and thoughtful approach for managing that
growth in a way that retains the character of the community and the qualities that make it a
desirable place to live. Otak is developing the updated plan, goals, policies, and other content
and related analysis for land use, housing and middle housing, climate change and adaptation,
environmentally critical areas, utilities, and to support capital facilities planning. Our team is
integrating content by others (transportation; parks, recreation, open space, and arts; public
participation outcomes) into the plan, reviewing the city’s development regulations, and
preparing draft amendments to be consistent with and implement the updated comprehensive
plan. Our team is supporting economic development, market, housing, and employment
analysis to support the plan.
Mill Creek Boulevard Corridor Subarea Plan; Mill Creek, WA
Project Manager—Mill Creek Boulevard is an important north-south transportation corridor
located in the heart of Mill Creek. The parcels along the corridor were developed in the 1980s
and include numerous two-story walk-up office buildings occupied by smaller office-based
businesses and single-story shopping centers. Otak helped the City to collaborate with its
residents, the business community, and affected property owners to create a subarea plan that
identifies the highest and best future land uses for the area. The plan addresses land use,
multi-modal transportation, stormwater management, utilities, and other infrastructure,
placemaking, and civic campus enhancements.
RECEIVED
EXHIBIT 91
Mandi Roberts, AICP, PLA
Senior VP, Principal Planner, and Landscape Architect
3
City Center + Alderwood Subarea Plan and Citywide Comprehensive Plan
Update; Lynnwood, WA
Project Manager—Our team is helping the City complete its 2024 Comprehensive Plan update
and, concurrently, preparing a subarea plan for the Regional Growth Center. Otak led a
detailed policy-by-policy audit of the existing comprehensive plan to understand gaps, conflicts,
and inconsistencies that need to be addressed in the update. The subarea plan covers 764
acres of the City center and includes two light rail stations as part of the Lynnwood Link and
Everett Link extensions. Lynnwood has a dynamic planning environment, with Sound Transit’s
Everett Link extension still in development and the Lynnwood Link extension planning only
recently completed; a citywide Housing Action Plan; and multiple other subarea or
neighborhood-scale plans in progress or recently completed. Lynnwood’s current
comprehensive plan lacks cohesion, a challenge City staff is eager to address. Otak’s audit
identified gaps, conflicts, inconsistencies, duplications, unnecessarily detailed provisions,
provisions that cannot be effectively implemented, and similar issues. The audit results will be
used to create a streamlined, cohesive, and easy-to-read plan that provides a greater range of
implementation strategies. Lynnwood has, historically, had difficulty reaching underserved and
underrepresented groups in planning efforts. Otak’s public engagement strategy relies on
innovative methods and partnerships with community liaisons to effectively engage with these
groups, providing a key opportunity to build trust and integrate new and unique perspectives
into the Comprehensive Plan and Regional Growth Center Subarea Plan. Work for both plans
include development of related, but project-specific logos and branding, work plans,
presentations, and similar efforts. A consolidated public engagement strategy ensures
resources are used efficiently and participants are spending their time effectively. A central goal
for each planning effort is to ensure diversity, equity, and inclusion are the foundation of the
outreach efforts.
Town Center Subarea Plan; Lake Forest Park, WA
Project Manager—Otak worked with the City and community to develop a vision and policy
framework for the town center from 2017 through 2018. Our contract was amended to add
Phase II services, which includes development of design standards and supporting code
revisions, analysis and development of a non-project environmental impact statement, and
other related services. The town center is the heart of the community and its commercial and
employment hub. Sound Transit is planning to extend BRT through the SR 522 corridor and the
town center will be an important BRT station with a new parking structure. The vision calls for
integrating the BRT facilities with future redevelopment planning of the town center that will
include intensifying mixed-use employment, commercial use, and multifamily housing
opportunities within walking and bicycling distance to the BRT station.
Regional Growth Center Subarea Plan; University Place, WA
Project Manager—Otak helped the City develop a subarea plan for its town center and
commercial core in response to the Puget Sound Regional Council’s designation of the area as
a regional growth center. Regional centers are relatively small areas of compact development
where housing, employment, shopping, and other activities are in close proximity. The
University Place Growth Center is a 465-acre area that includes a mix of commercial, civic,
single and multifamily residential, and light industrial uses. It will be divided into three districts—
the Northeast Business District, the 27th Street Business District, and the Town Center District.
Otak’s work involved community visioning, goal identification, policy and action strategy
development, capital facility planning, architectural design, and conceptual plan drawing.
Evergreen Corridor Management Plan; Vancouver, WA
Project Manager—Otak developed a comprehensive improvement and implementation plan to
direct future decisions and actions along seven miles of this highway corridor. Our team
performed an existing conditions analysis and technical traffic analysis and managed an
extensive public process. The final Corridor Management Plan incorporated the corridor history,
existing conditions analysis, concept level plans, specialized road design standards,
operational design parameters, cost estimates, and funding strategies.
RECEIVED
EXHIBIT 91
Mandi Roberts, AICP, PLA
Senior VP, Principal Planner, and Landscape Architect
4
185th and 145th Street Light Rail Station Subarea Plans and SEPA Analysis;
Shoreline, WA
Project Manager—The goals of these planning efforts include defining future development
around a new light rail station to provide greater access to the region's transit system and
creating vibrant transit-oriented neighborhoods. The subarea planning processes for both
station areas are engaging stakeholders and the community in shaping the future plans for the
neighborhoods. The plans will maximize short- and long-term land use opportunities presented
by the light rail stations, including a mix of residential, employment, and commercial uses;
maximize pedestrian and bicycle access between uses that develop in the area; establish a
comfortable, attractive, and vibrant public realm; create effective transitions between the newly
planning transit-oriented community and adjacent uses; maximize opportunities for housing for
a range of income levels; and enhance the ridership base for the expanded transit system.
Work includes project management, Sound Transit coordination; environmental analysis and
documentation preparation; public participation and community outreach; existing conditions
data collection and analysis; market research and analysis (including analysis of property
values and fiscal conditions); potential land use changes around the station and major
corridors; opportunities, challenges, and alternatives analysis; preferred alternative
development; and preparation of the station area plan. Otak is managing the preparation of
planned-action environmental impact statements (EISs) to support implementation of the
station subarea plans. The EISs include analysis of land use, neighborhood character and
cohesion, population and employment, transportation, parks and recreation, utilities, and public
services and facilities.
Growing Transit Communities—East Corridor Implementation Support;
Bellevue and Redmond, WA
Project Manager—Mandi was the project manager, responsible for a large interdisciplinary
team’s work in providing pivotal opportunities to transform Eastside bus rapid transit and light
rail station areas into more vibrant, economically healthy neighborhoods that offer equitable
housing choices, more convenient access to jobs and jobs-to-housing balance, and better
connectivity to goods and services. Smart growth that encourages transit use will lead to a
more sustainable future for the Puget Sound region, preserving the unique character and
natural resources that make this area an attractive place to live, work, learn, and play.
Implementation issues to address include affordable housing, business retention and attraction,
partnerships, and transportation access and connectivity.
EPA Building Blocks for Sustainable Communities, Technical Assistance to
Smart Growth America; Nationwide
Project Manager—Otak is providing on-call services to Smart Growth America with technical
assistance to communities across the nation in a new program being funded by a grant from
the EPA. Otak assists selected local communities to help them grow in ways that benefit
families and businesses while protecting the environment and preserving a sense of place. Our
focus is on regional and smart growth planning assignments and helping communities develop
policies and strategies to address climate change. Specific community development, land use,
and transportation planning techniques can enable communities to reduce their carbon
footprints and are covered in depth in these workshops. The workshops draw on a technical
assistance team that has facilitated hundreds of smart growth and sustainable community
development presentations, programs, and workshops in communities across the US and
abroad. Interactive exercises are integrated into the program to engage participants and get
them thinking about how they can get involved. Publications and resources available to help
communities are referenced. Available tools that can be used to monitor a community’s
progress are presented, including walkability index/scoring tools, surveys, focus groups and
interviews, audits, and other methods/indicators.
RECEIVED
EXHIBIT 91
Cristina Haworth AICP
Senior Planner
Cristina is a land use planner with more than 15 years of experience helping clients
manage growth and make better use of their land and public spaces. She has
supported development review and compliance for a variety of complex project
applications. She also has worked on integrated planning and zoning plans and
amendments at citywide, subarea, district, and neighborhood scales and is familiar
with land use and development law, including Washington’s GMA and SEPA, and
regional planning frameworks such as PSRC’s Vision 2050. She specializes in
development services support at scales ranging from minor additions to single-family
residences to regionally significant transportation projects and regularly supports
code audits and amendments in partnership with city staff. Cristina is also proficient in
virtual and in-person outreach techniques that foster inclusion and engage
underserved and underrepresented communities.
EDUCATION
MCP, Planning (University
of Pennsylvania)
Certificate, GIS and Spatial
Analytics (University of
Pennsylvania)
BA, Community,
Environment, and Planning
(University of Washington)
REGISTRATIONS &
CERTIFICATIONS
American Institute of
Certified Planners, State
abbreviation, #027848
Selected Project Experience
Pleasant Harbor Master Planned Resort, Senior Planner;
Jefferson County, WA
Project Manager/Senior Planner—Cristina serves as a senior planner pertinent to the
consultant planner role identified in the Future Staffing and Consultant Agreement for the
Pleasant Harbor Master Planned Resort (PHMPR) project, working on behalf of the County to
review and process applications to implement the PHMPR. Cristina supports land use and
development compliance with the development agreement and other governing documents and
codes, tracks conditions of approval, and coordinates reviews by other staff, departments, and
consultants.
On-Call Development Services; Issaquah, WA
Project Manager/Senior Planner—Otak provides on-call planning and development review
services for a new collocated high school and elementary school project in Issaquah. Cristina
and the Otak team provide code interpretation guidance, coordination and support for required
community meetings, technical review of the proposed project, legal notices and processing,
reviewing and analyzing public comments, developing staff reports and recommendations,
communication with the applicant and with members of the public, and supporting the City as
needed in hearings.
On-Call Development Review and Planning Services; Mountlake Terrace, WA
Senior Planner—Otak provides on-call planning and development review services for the City
for land use entitlements such as site plans, shoreline permits, subdivisions/short subdivisions,
conditional use permits, variances, and state environmental compliance (SEPA) review.
Cristina and the Otak team provide technical review of projects to evaluate compliance with City
code, standards, regulations, and procedures, and support the City as needed during public
hearings or related services as needed.
On-Call Planning Services; Medina, WA
Project Manager/Senior Planner—Cristina reviewed development applications such as building
permits, construction mitigation plans, shoreline substantial development permits, variances,
conditional uses, special uses, and site plan reviews. She supported the City’s SEPA official in
reviewing environmental documentation and permit applications. Cristina acted as City staff
during permit review, coordinating directly with the applicant’s project manager, reviewing the
project’s site and construction mitigation plans, and representing the City during associated
hearings.
RECEIVED
EXHIBIT 91
Cristina Haworth, AICP
Senior Planner
2
On-Call Development Review; Sammamish, WA
Senior Planner—Cristina reviewed development applications for code compliance, represented
staff during public hearings, and attended pre-application meetings for major mixed-use
development projects on an on-call basis to the City. During a period of staff turnover, Cristina
addressed several subdivision files that had been waiting for final written decisions or staff
reports. Task needs ranged from initial review, to issuing correction letters, to reviewing
revisions, and writing the final report/decisions.
On-Call Planning and Development Review; Federal Way, WA
Project Manager/Senior Planner—Otak provided on-call planning and development review
services for a unique development project on the former Weyerhaeuser campus in Federal
Way. Cristina and the Otak team provided technical review of proposed development; drafting
comment letters, legal notices, and land use decisions; reviewed and analyzed public
comments; and supported the City as needed in meetings with the applicant.
On-Call Planning Services; Bothell, WA
Senior Planner—Otak provided on-call planning services support for development projects in
the City of Bothell. Cristina reviewed land use and building permit applications, prepared
comment letters and worked with applicants to address comments, prepared staff reports, and
supported City staff at hearings.
On-Call Planning Services; Shoreline, WA
Project Manager/Senior Planner—Otak provided on-call planning and development services
support for single-family development review in the City of Shoreline. Cristina reviewed building
permit applications for zoning, critical areas, and tree protection requirements; prepared
comment letters; and signed off on approved plans.
On-Call Planning; Woodinville, WA
Project Manager/Planner—Otak provided a range of on-call services to the City, including long-
range planning efforts and current planning tasks. Cristina acted as supporting staff with permit
review for land use permits, design review, subdivisions, SEPA compliance, critical areas
review, and construction permit review. Long-range planning projects include parking studies,
subarea plans, comprehensive planning, sustainable development planning, and corridor plans.
Comprehensive Plan Update; Lake Forest Park, WA
Project Manager/Senior Planner—Cristina led a detailed policy and code audit of the existing
plan and development regulations, then facilitated Planning Commission review and discussion
on an element-by-element basis to prepare a recommended draft for adoption. Her work
includes education on recent legislative changes (especially related to housing), the importance
of equity and inclusion, and readiness for climate planning. Cristina also supported grant
applications for middle housing funding and climate funding to support additional planning work.
Comprehensive Plan Update; Lynnwood, WA
Project Manager/Senior Planner—Cristina was the project manager and senior planner helping
the City prepare for its 2024 Comprehensive Plan update. She led a detailed policy-by-policy
audit of the existing comprehensive plan and development of best practices for modern
comprehensive plans. This project also included development of updated project logos and
branding for presentations, working documents, outreach materials, and the final
Comprehensive Plan. Future work on this project includes developing a detailed work plan for
execution by City staff and public engagement plan that prioritizes equity and inclusion.
Comprehensive Plan Update and Climate Resilience Element; Snoqualmie, WA
Senior Planner—Otak is leading a team of city staff and consultants who are working on a
regular update of the comprehensive plan for Snoqualmie, a historic railroad center and fast-
growing suburb of Seattle. Otak is reviewing, editing, and assembling proposed goals and
policies, technical studies, and community context to create an updated Comprehensive Plan
that meets the standards of the Washington State Growth Management Act and is consistent
with locally adopted goals and the regional planning framework. In 2024, Otak began work on
the second phase of the project, creating a Comprehensive Plan element addressing the
RECEIVED
EXHIBIT 91
Cristina Haworth, AICP
Senior Planner
3
climate resilience and greenhouse gas (GHG) emissions reduction objectives, including an
analysis of community assets, potential risks, climate justice, and an inventory of GHGs from
both municipal and community sources.
Mill Creek Boulevard Subarea Plan; Mill Creek, WA
Senior Planner—Mill Creek Boulevard is an important north-south transportation corridor
located in the heart of Mill Creek. The parcels along the corridor were developed in the 1980s
and include numerous two-story walk-up office buildings occupied by smaller office-based
businesses and single-story shopping centers. Otak helped the City to collaborate with its
residents, the business community, and affected property owners to create a subarea plan that
identifies the highest and best future land uses for the area. The plan addresses land use,
multi-modal transportation, stormwater management, utilities, and other infrastructure,
placemaking, and civic campus enhancements. Cristina reviewed permitting documents and
supported community engagement efforts, including interactive workshops with diverse groups
to gather input and data as well as with facilitating visioning exercises with the City’s community
focus groups, project advisory committee, and the Planning Commission.
Code Updates; Medina, WA
Project Manager/Senior Planner—In support of Medina’s NPDES Phase II MS4 permit, Cristina
led Otak’s effort to update the City’s municipal codes as needed, including incorporating LID
standards and practices, authorizing, and establishing a standard and a review process for
rooftop play areas on school buildings, and updating the City’s tree code. She performed code
audits and gap analyses to identify barriers to adoption, supported public engagement, and led
project teams comprised of Otak staff, City staff, and the City attorney in making
recommendations for updates, writing, and drafting revisions to City code and design manuals,
with presentations to the planning commission and public hearings. Cristina also prepared and
submitted the required GMA filing and SEPA notices as needed.
Housing Code Amendments; Bothell, WA
Project Manager/Senior Planner—Otak supported the City in implementation of its Department
of Commerce housing grants to improve housing choice and affordability options. This effort
updated City codes, plans, policies, and design and construction standards to provide middle
housing and affordable housing. In Phase 1, Otak updated City codes and standards to
increase the division or redivision of land to the maximum number of lots through the short
subdivision process and authorize a duplex on each corner lot in single-family residential
zones. In Phase 2, Otak explored additional middle housing options in all single-family
residential zones. Cristina managed research and audit efforts, developed amendment
language, and supported City staff through the code, plan, and standards review and adoption
processes, including SEPA review.
Light Rail Consulting; Mountlake Terrace, WA
Senior Planner—During design of Sound Transit’s North Link light rail extension, the City
agreed to expedite and prioritize design submittal reviews, over-the-shoulder reviews for 30, 60
and 90 percent submittals, issuance of permits, and possible future expedited construction
inspections related to the final design and pre-construction phase. Our team provided civil,
traffic, roadway, utilities, drainage, rights-of-way, structural (including elevated station, light rail
transit systems), geotechnical, environmental, mechanical, electrical, and architectural design
expertise. Otak assisted the City in coordinating the design review, permitting, code
compliance, and inspection of the project. Cristina completed technical review and processing
of the land use applications on behalf of City staff.
RECEIVED
EXHIBIT 91
Touta Phengsavath PE
Senior Civil Engineer
Touta is a senior project engineer with 26 years of experience. This includes
engineering for public and private clients related to transportation and roadways,
trails, sanitary sewers, watermains, surface water management, hydraulic design
projects, site development, and other utilities and infrastructure components. His work
has included design, design and permit review, preparation of plans, specifications
and cost estimates, utility and agency coordination, and construction observation for
federally and non-federally funded projects. He is familiar with storm drainage
analysis and has been responsible for plan review and permit issuance for several
municipalities.
EDUCATION
BS, Civil Engineering
(University of Washington)
REGISTRATIONS &
CERTIFICATIONS
Professional Engineer,
WA, #38374
Selected Project Experience
Pleasant Harbor Master Planned Resort, Consultant Planner;
Jefferson County, WA
Civil Engineering Review—Touta is supporting the Otak team and Jefferson County with the
engineering review for the Pleasant Harbor Master Planned Resort (PHMPR) project. He is
reviewing the proposed infrastructure (roadway, utilities) components of the preliminary plat
application and has been working with the team to determine compliance with the development
agreement and other governing documents and codes, tracking of conditions of approval, and
coordinating reviews by other staff, departments, and consultants.
On-Call Engineering and Development Plan Review; Kent, WA
Senior Engineer—Otak performed plan review of submitted development applications for the
City for several years. The City experienced an increase in their backlog of development
applications and contracted with us to assist in expediting development reviews and helping
meet the City’s obligations on submitted applications. Services included review of civil and
structural design elements. Each task consisted of reviewing the applicant-submitted plans and
calculations for compliances with City codes, design standards, and conditions of approval;
preparation of review comments relative to submitted documents; and meeting with City staff to
present and discuss the findings.
On-Call Consulting Services; Woodinville, WA
Senior Engineer—For multiple years, Otak provided on-call services to the City. Services
included supporting planning and permitting staff by participating in the project review and
evaluation process with timely response pursuant to and consistent with current City codes.
Work involved review of development applications including land use, shoreline, and building
permits; subdivision reviews; arborist reviews; third party environmental reviews; and land use
coordination and data support roles with on-going transportation planning efforts; downtown
planning studies; and on-going sustainable development efforts.
Husky Village Redevelopment; Bothell, WA
Senior Engineer—This project involved redeveloping the 4.4-acre Husky Village student
housing site to provide three new multi-story buildings combined with office and commercial
uses, together with a new on-site campus dining facility. Work involved widening 950 feet of
Beardslee Boulevard to provide one additional eastbound travel lane and eliminating the
eastbound on-street bicycle lane and constructing a new 13-foot-wide shared-use
nonmotorized trail. The trail is separated from the new curb and gutter by landscaping.
Additional work included coordination with Sound Transit regarding future transit stops,
overlaying existing eastbound travel lane, pedestrian and traffic signal modifications and
roadway and trail illumination, a new storm drain collection, conveyance, detention, and water
RECEIVED
EXHIBIT 91
Touta Phengsavath, PE
Senior Civil Engineer
2
quality treatment system, utility undergrounding, and construction engineering support. Touta
provided engineering expertise and design guidance and QA/QC of construction documents.
Woodside; King County, WA
Senior Engineer—Touta assisted with grading and drainage for this development. Woodside
was developed under a County program that allowed urban residential density on one-fifth of
the total site acreage in exchange for dedicating the remaining four-fifths of the site as open
space. Otak provided master planning and engineering for development of 475 single-family
homes. Work also involved streetscape and recreation area design and included many off-site
improvements including a neighborhood collector road for access to the site.
Arbors at Pine Lake; Sammamish, WA
Senior Engineer—Touta assisted with the water and sewer design for this residential
development. The City contracted with the private development client to take charge of the
water and sewer design needs. Otak provided development services for the nine-acre parcel
known as Arbors at Pine Lake, located within the City of Sammamish. Otak provided surveying,
planning, civil engineering, and landscape architecture support for the development of 26
residential lots, including design of roadway improvements, stormwater conveyance and
treatment facilities, water and sewer systems, and a neighborhood park. The developer
extended our design and permit support contract to include construction services.
Trilogy at Redmond Ridge; King County, WA
Senior Engineer—As part of this large 1,050-acre development, Touta provided engineering
design on several phases. He assisted in storm bypass design by an unnamed creek in the
development and provided drainage improvement and layout design for the NE 133rd Street
widening.
Springfield Meadows; Vancouver, WA
Senior Engineer—Springfield Meadows is a 275-unit multifamily development located on 9.9
acres. The project included 13,000 SF of onsite community and learning center facilities
providing daycare, classrooms, and recreation. Site improvements included grading; storm
drainage collection, conveyance, and water quality treatment; water and sanitary sewer utility
main extensions and services; and asphalt pavement, pedestrian, and hardscape facilities.
Stormwater treatment and discharge for the site is facilitated by two biofiltration swales and on-
site infiltration vaults. Offsite roadway, storm drainage, water, and sewer main improvements
were also required. Otak provided engineering design, permitting, survey, and support services
during construction for off-site roadway improvements, public water and sewer mains, storm
drainage collection and conveyance system, and other specialized grading features and
drainage facilities. Touta provided water and sewer design.
Little Boston Road Pedestrian Trail; Kingston, WA
Senior Engineer—Otak is leading this project that includes design and construction of 0.75
miles of trail adjacent to Little Boston Road. Project elements consist of a ten-foot-wide paved
trail including retaining walls, pedestrian bridges, wetland mitigation, five stream crossings, and
frontage impact improvements associated with 14 homes. Otak’s team provides civil and
structural engineering, landscape design, construction document preparation, community
outreach, environmental mitigation design, permitting, and construction assistance. Touta is
leading the design effort and coordinating between disciplines and is providing preliminary
layout design options and cost estimates, construction documents, and utilities coordination.
Harper Estuary Bridge; Kitsap County, WA
Senior Engineer—Otak is designing a bridge to replace an undersized culvert at the inlet of
Harper Estuary to restore tidal influences and natural habitat. Otak is working with WDFW, who
led the design of the estuary restoration, which consisted primarily of the removal of historic fill
and reconnection of tidelands and cleanup of contaminated soil. The first phase of the project
included evaluation of alternatives for the new structure including different lengths and locations
for the proposed bridge. The evaluation used 2D modeling to evaluate hydraulic connectivity
RECEIVED
EXHIBIT 91
Touta Phengsavath, PE
Senior Civil Engineer
3
and geomorphic and ecologic processes, as well as habitat benefits for multiple salmonid
species and adjacent wetlands. Touta provided roadway and utility design oversight.
Bucklin Hill Bridge; Kitsap County, WA
Senior Engineer—This project replaced twin culverts with a 240-foot-long bridge, widened the
road to five lanes, traffic signals, roadway and pedestrian lighting, storm drainage
improvements and amenities for pedestrians and bicyclists. Otak provided utility coordination
for relocation of utilities including watermain, sanitary sewer force main, several
communications providers, gas, underground and overhead power. Touta prepared plans,
specifications, and cost estimates, coordinated with the County and subconsultants, and led
utility coordination.
Elliott Road Culvert Replacement; Snohomish County, WA
Senior Engineer—Otak designed and is currently providing construction engineering services
for road improvements and a culvert replacement to reduce flooding along Elliott Road from
Anderson Creek. Improvements include raising the roadway, installing a fish passable culvert,
and performing upstream and downstream channel grading. Otak performed 2D hydraulic
modeling of the creek and wetlands to identify the preferred alternative for the roadway and
culvert. Otak prepared preliminary and final design PS&E for the preferred alternative.
Additional work included a technical (zero-rise and compensatory flood storage analysis) cost
and permitting feasibility study and alternatives analysis on backwater channel alignments,
culvert or bridge use, extents of levee breach, and re-vegetation schemes. Touta provided
roadway and utility design oversight.
180th Street SE Improvements; Snohomish County, WA
Senior Engineer—The 180th Street SE corridor is one of the primary east/west corridors in
Snohomish County. Otak designed the reconstruction of 180th Street SE from SR 527 to 35th
Avenue SE, approximately 1.25 miles in length. This project provided an opportunity to deliver
improved mobility, safety improvements, pedestrian/bicycle improvements, and neighborhood
access. The project widens the existing roadway section from two/three lanes to five with
bicycle lanes, curb, gutter, sidewalks, and planter strips. The project also included culvert
upgrades, a stream relocation, retaining walls, signal improvements, and utility relocation.
Touta led the preliminary layout design, prepared construction plans, specifications, and cost
estimates, and provided utilities coordination. He also coordinated the design effort between
disciplines and subconsultants.
West Side Trail; Fall City, WA
Senior Engineer—The goal of this project is to increase public safety and community
connectivity. By developing this one-mile trail along SR 202, it will create a more walkable
community and enhance the character of the western gateway into Fall City. The new ten-foot-
wide paved trail will be separated from the roadway and will include hardscape and landscape
elements, drainage facilities, pavement markings; wayfinding and signage, public art, an
information kiosk, and other trail amenities. Otak is providing surveying and base mapping,
utility coordination, community outreach, evaluation and recommendations on alignment and
features, environmental permitting, easement acquisition, preliminary design plans and report,
and assistance in securing additional funding.
Anderson/Laventure Road Improvements; Skagit County, WA
Senior Engineer—Otak worked with Skagit County to design a 1.25-mile-long new arterial
roadway within the City of Mount Vernon’s southeastern Urban Growth Area. The project
involved extending Laventure Road southerly and connecting it with the existing I-5 interchange
at Anderson Road. The project included three- and five-lane roadway improvements with curb,
gutter, drainage, and sidewalks; two creek crossing structures; over 2,500 LF of a 4-foot to 16-
foot-high retaining wall; three stormwater detention and water quality facilities; stream
modifications; wetland mitigation; landscaping; and utility relocation. Touta provided roadway
design, utility coordination and design, preparation of construction documents, cost estimates,
and construction design support.
RECEIVED
EXHIBIT 91
Megan Vance
Engineering Designer and Water Resource Analyst
Megan is an engineering designer and water resource analyst with over two years of
experience. She performs hydrologic and hydraulic analyses to support stream and
stormwater improvements. Her analyses have included 2D simulations of complex
streams within the Thornton Creek basin. Megan has performed stormwater planning
for several local cities and counties and assists with drainage project design.
EDUCATION
MS, Environmental
Engineering (University of
Washington, 2023)
BS, Biology (Western
Washington University,
2011)
REGISTRATIONS &
CERTIFICATIONS
Engineer-in-Training
Selected Project Experience
Pleasant Harbor Master Planned Resort, Development Review;
Jefferson County, WA
Development Review Support for Surface Water Management—Megan has been part of the
development review team from Otak, involved in reviewing the technical compliance of the
surface water management approach outlined in the preliminary plat application. Megan has
reviewed proposed plans and assessed alignment with technical requirements at the state and
county levels. She has been working with the team to prepare findings, recommendations, and
conditions of approval for the staff report and addendum.
Elliott Road Culvert Replacement; Snohomish County, WA
Engineering Designer—Otak designed and is currently providing construction engineering
services for road improvements and a culvert replacement to reduce flooding along Elliott Road
from Anderson Creek. Improvements include raising the roadway, installing a fish passable
culvert, and performing upstream and downstream channel grading. Otak performed 2D
hydraulic modeling of the creek and wetlands to identify the preferred alternative for the
roadway and culvert. Otak prepared preliminary and final design PS&E for the preferred
alternative. Additional work included a technical (zero-rise and compensatory flood storage
analysis) cost and permitting feasibility study and alternatives analysis on backwater channel
alignments, culvert or bridge use, extents of levee breach, and re-vegetation schemes. Megan
assisted with proposed stream design and grading, in addition to preparing the JARPA
permitting plan set for this project.
Monroe Avenue NE Infiltration Facility; Renton, WA
Engineering Designer—Otak completed the design of a regional stormwater infiltration facility to
manage stormwater runoff from a 250-acre closed depression in the City of Renton. This flood
reduction project includes providing enhanced water quality treatment and stormwater
infiltration facility to prevent historic flooding along Monroe Avenue. Otak provided alternative
analysis, hydrologic and hydraulic modeling of the subbasin in order to estimate existing flows,
assess the capacity of the existing infiltration system, and size the proposed improvements.
Otak also developed stormwater flow control and water quality solutions for the highly
urbanized contributing subbasin in the Renton Highlands area. The existing stormwater
conveyance system will convey the runoff from the contributing subbasin to the new facility for
treatment and infiltration, which is sized to provide enhanced water quality treatment and will
provide infiltration for up through the 100-year event. Megan is providing construction support
to the City of Renton via site visits and submittal review. She is also preparing the operations
and maintenance manual for the facility.
Redmond Central Connector, Phase III; Redmond; WA
Engineering Designer—Otak’s team is completing design of Phase III of the Connector, which
consists of 1.6 miles of regional trail that completes the connection to the City of Kirkland Cross
Kirkland Trail and King County Eastrail at NE 124th Street. The Phase III segment of the trail
connects the City’s downtown to the Willows business district. Otak’s team also completed
design and provided construction management services for Phase II of the Connector, which
consisted of 1.3 miles of a natural trail section and an urban zone where the trail is edged by
RECEIVED
EXHIBIT 91
Megan Vance
Engineering Designer and Water Resource Analyst
2
Willows Road to the west and warehouses and offices to the east. While Phase I runs through
a densely populated downtown as a linear park, justified by its intensive surrounding, Phase II
is more removed from urban influence creating a more traditional extruded profile active with
cyclists, pedestrians, and equestrians. Megan drafted the Stormwater Pollution Prevention Plan
(SWPPP) for Phase III. This document provides guidance to reduce or eliminate erosion and
stormwater pollution during construction.
Gilliam Creek and Green River Fish Barrier Removal; Tukwila, WA
Engineering Designer—Otak is leading this project to remove fish barriers and restore fish
access to Gilliam Creek while improving existing flood protection along the Green River levee
system. It will restore access and shoreline habitat as part of a watershed-wide effort to restore
ESA-listed Chinook salmon and will be designed to allow juvenile fish access between the
creek and the river, which are tidally influenced. Options are being evaluated for replacing the
tidegate at a different location and opening up the confluence with the Green River with a
pedestrian bridge for the Green River Trail. Habitat enhancements including log structures and
revegetation will occur within the stream and riverbank. The project will also address
recreational, aesthetic, and educational opportunities and constraints associated with the
adjacent Green River Trail and trailside park area. Megan is providing large woody material and
flood plain assessment in the vicinity of the project site, helping to inform proposed design.
Additionally, she has performed an assessment of existing culvert infrastructure, evaluating
remaining service life.
Sweetwater Ranch Stormwater Main Replacement; Mill Creek, WA
Engineering Designer—The goal of this project is to replace an existing damaged stormwater
main with a conveyance with adequate flow capacity while not disturbing adjacent residential
structures and utilities. The project is complicated by a narrow easement, 14-foot-deep pipe,
existing abandoned storm pipe and sanitary sewer, potential groundwater seepage, and
adjacent residential home foundations. Our team provided site investigation and
characterization including geotechnical investigation (by subconsultant) structural assessment
of the adjacent residential structures, surveying including settlement monitoring, hydrologic and
hydraulic capacity analysis, alternatives analysis in coordination with geotechnical and
structural engineering, type, size and location for the stormwater main, utility coordination, and
preliminary design. Megan has performed GIS analysis to determine hydrologic and hydraulic
model inputs. She has also participated site visits to better understand stormwater conveyance
issues near the site.
SE Petrovitsky Road Culvert Replacements; King County, WA
Engineering Designer—This project includes analysis and design for four culverts along SE
Petrovitsky Road, a heavily used five-lane arterial. Work included BOD studies to support a
feasibility study of the project and an alternatives analysis for various solution elements. These
special investigations and studies included an HSPF basin hydrologic model, HEC-RAS
hydraulic modeling, geomorphic and biological assessments, channel stability, a wetland
hydroperiod, and traffic detour analyses. The project resulted in designs of two fish passage
culverts and culvert slip-lining of two non-fish bearing culverts along Petrovitsky Road. Megan
assisted in the final stages of design and prepared the permitting plan set. She also worked on
the specifications and summary of quantities for the project.
Nathan Hale High School Thornton Creek Reach and Buffer Study: Data
Collection, Assessment, and Concept Plan Development; Seattle, WA
Engineering Designer—Seattle Public Schools is addressing flooding of Thornton Creek on the
Nathan Hale High School site. Otak is first identifying the cause and impacts of the flooding and
then will be identifying remediation measures including permitting, phasing, and cost estimates.
Megan evaluated existing conditions at the site via data collection, GIS analysis, and review of
reports and as-builts. She also performed HEC-RAS modelling of the stream and prepared a
proposed alternatives matrix for client review.
RECEIVED
EXHIBIT 91
CITY OF LYNNWOOD GENERAL TRANSPORTATION ON-CALL SERVICES | 5
otak.com
11241 Willows Road NE, Suite 200
Redmond, WA 98052 | 425.822.4446
RECEIVED
EXHIBIT 91
Jefferson County Response to Comments Submitted at the October 15, 2025, Public Hearing
Pleasant Harbor Master Planned Resort (SUB2023-00025)
Issued October 27, 2025
Page 48 of 68
Attachment B: Professional Qualifications of Jefferson County
Building Official/Fire Marshal
RECEIVED
EXHIBIT 91
Phillip Cecere 2011 Old Gardiner Rd. Sequim, WA. 98382
(360) 477-1122
Career overview
As my career has progressed, I have earned many credentials and experience, and as a Building Official
and Fire Marshal, my area of interest has grown to include all phases and facets of construction. In my
18-year career managing a small equipment rental business. My most pertinent experience builds on my
construction background at Jefferson County Community Development. In this position, I supervise 5 full
time staff members and occasional interns. One of my duties was to constantly look out for training
opportunities, such as CESCL, FEMA, ICC and WABO for my and staff’s career development. As the
inaugural Fire Marshal in the newly established Office of the Fire Marshal, I coordinated with
neighboring jurisdictions on meet and greet and exercises to develop consistency within our local area,
while working with elected officials to refine and establish ordinances and resolutions to establish new
county programs. I was heavily involved in a project to provide housing for the unhoused while
maintaining a minimum level of life safety and public approval. I have served as the County Floodplain
Administrator and the County CESCL for civil review and stormwater inspection. In addition, I am
currently pursuing a Master Code Professional Certification through ICC. I have trained staff and have
honed many skills on coworker interactions from dispute resolution to disciplinary action.
Certifications
• ICC Certified Building Official Credential
• ICC Certified Fire Marshal Credential
• ICC Certified B5 Residential/Commercial Inspector
• ICC Certified M1 Inspector
• ICC Certified R3 Residential Plan Review
• ICC Certified B3 Commercial Plan Review
• ICC Certified F3 Fire Plan Review
• ICC Certified Fire inspector I & II
• ICC Certified Accessibility
• IAPMO Certified Plumbing Inspector
• WABO WASAFE Level 2 Responder
• BIAW CESCL Certification
• Multiple FEMA evaluation Certificates
• Washington State licensed Notary Public
• General contractor and Equipment operator
• Proficiency with Bluebeam, Energov, Smartgov, Tidemark and Microsoft products
Skills
Staff Management: Engage and monitor staff performance as well as ensuring quality work product is
produced and recorded.
Public Interaction: Handle complex permit inquiries, accurately providing information to ensure
resolution of product/service complaints and ensure client satisfaction. I have lots of face time
experience presenting to the public and elected officials, speaking respectfully in plain language to
communicate complex technical ideas.
Efficient Organization: Delivering solutions to inefficient processes as they relate to LEAN practices and
time management. Set up inspection priorities and routing to maximize efficiency and decrease road
time. Filling in on the inspection roster and running periodic reports to ensure inspection and review
recording.
RECEIVED
EXHIBIT 91
Work Experience
D&K Rentals 52 River Rd Sequim,
WA. 98382 May 2002-August 2020
Managed a crew as large as 7 coworkers, trained several new hires as well as seasonal workers, and
strove to deliver the best customer service possible in the form of prompt, courteous responses in store
or by phone. Interfaced with homeowners and contractors daily. Daily responsibilities included
numerous phone interactions, safety instruction, coupling trailers and rental agreement paperwork.
Jefferson County Community Development 621 Sheridan St. Port Townsend WA. 98368
August 2020- February 2021
As a building inspector visiting several jobsites a day, verifying that construction is built to code, from
setback inspections to all aspects of construction phases. Duties also include facilitating permit
verification, follow up paperwork, correction notices, inspection requests, and customer emails and
calls. Lack of permanent full-time work led to needing a job with a full-time schedule.
Kitsap County Community Development 615 Division St. Port Orchard, WA 98366
February 2021- May 2021
Reviewed Residential plans, assisted with the 2018 code cycle transition. Created workbooks to be
completed by new hires and mentors in the fields of plumbing and mechanical. I have assisted and led
several group projects for the creation of protocols and policy.
May2021-Current
Jefferson County Community Development 621 Sheridan St. Port Townsend WA 98368
May 2021- Current
Progressing to the Building Official, Fire Marshal, Floodplain Administrator, CESCL and a notary for
Jefferson County, I served as a plans reviewer for the county reviewing residential and commercial
projects as well as performing field inspections and managing staff. On occasion, I have served as the
acting department director in times of director leave. I have worked closely with local community
partners, FEMA, Ecology, DEM and have served on state legislative committees.
Education
Sequim High School 504 Sequim Ave
Sequim, WA. 98382
Graduated with diploma class of 2003 cumulative GPA 3.6
In addition to the standard curriculum, I excelled at several hands-on courses in welding, auto repair,
and CAD. Some of my extra-curricular activities included concert, pep, and marching bands as well as
sports and clubs.
RECEIVED
EXHIBIT 91
Jefferson County Response to Comments Submitted at the October 15, 2025, Public Hearing
Pleasant Harbor Master Planned Resort (SUB2023-00025)
Issued October 27, 2025
Page 51 of 68
Attachment C: Jefferson County’s Response to DAHP’s April 9, 2018,
Comments for Public Hearing for Pleasant Harbor MPR, dated June 7,
2018
RECEIVED
EXHIBIT 91
RECEIVED
EXHIBIT 91
RECEIVED
EXHIBIT 91
RECEIVED
EXHIBIT 91
RECEIVED
EXHIBIT 91
RECEIVED
EXHIBIT 91
RECEIVED
EXHIBIT 91
RECEIVED
EXHIBIT 91
RECEIVED
EXHIBIT 91
RECEIVED
EXHIBIT 91
RECEIVED
EXHIBIT 91
RECEIVED
EXHIBIT 91
RECEIVED
EXHIBIT 91
RECEIVED
EXHIBIT 91
RECEIVED
EXHIBIT 91
Jefferson County Response to Comments Submitted at the October 15, 2025, Public Hearing
Pleasant Harbor Master Planned Resort (SUB2023-00025)
Issued October 27, 2025
Page 66 of 68
Attachment D: DAHP’s Response to Jefferson County BOCC Letter of
June 7, 2018, dated June 20, 2018
RECEIVED
EXHIBIT 91
RECEIVED
EXHIBIT 91
RECEIVED
EXHIBIT 91