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HomeMy WebLinkAbout005I r cc:DcD elpba-) . March 12,2002 ECEIVE llAR 1? zoaz IE) tnl Testimony of Tcd Labbe, Habitat Biologis$ Port Gamble S'Klalh*fid[fi C,UNI'Before the Jefrerson County Board of Coun8 Commffi"f.t' C6MMlSSt.liERS Good evening, and thank you for the opportunity to comment on the Brinnon Subarea Plan. My name is Ted Labbe and I aln a biologist with the Port Gamble S'Klallam Tribe's Natural Resources Department. The S'Klallam and Skokomish tribes maintain a long-standing interest in the health of Jefferson County's landscape and shorelines as they provide critical habitat for a host of plant and animal species on which the Tribes depend for their cultural and economic well-being. We are very concerned about policies set forth under the BSAP and have drafted detailed comments to both the local Brinnon planning group and the County on the Plan. Though minor improvements to the Plan have been made over recent months, serious flaws remain and I would like to qpeak to those flaws today. First among the Tribe's concerns is the unconditional recommendation for a golf course-resort development at Black Point. Under the County's outdated shoreline and stormwater control standards, such a development would jeopardize Hood Canal's precious wat€r qualrty as well as the rich and productive Duckabush shellfish tidelands. The Dosewallips and Duckabush estuaries support commercially- and culturally-signifi cant tidelands, threatened salmon habitat, as well as critical habitats for a host of other fish and wildlife species valued by the Tribe and local residents. There was no review of developmelt imp?cq to these resources in the Plan, or in the County's environmental checklist and threshold determination letter. Nor, was there any consideration of water supplies, which are likely limited since Black Point is virnrally surrounded by saltrvater. The Western Washington E) r.a Grourth Management Hearings Bohrdis recint ruling indicating that Jefferson County il not dotne "n:.q+ 1: p1,3..v:* salllvater intrusion and protect domestic water supplies has immediate bearing on this case. Second, the Tribe has concems aboiit the process of Pian development,,: rcview, and adoption. There were inadequate opportunities for the Tribe's and state agencies' involvement, though the PIan will have large impacts to Treaty resources. In public hearings, Brinnon pianning'group members admitted their failure to consult with knowledgeable state/federal agency staffand stated that this was intentional. The County's limited two-week SEPA review fell during the busy Holiday season, was not conducive'to ' adequate review by state or federal agency staff, and a fo.mallrequest to ; extend the review period was flatly denied with no justification piovided. Throughout the process, Jefferson County staffmaintained that the DEIS/TEIS developed for the County Comprehensive Plan would also serye +ltfolBrinnon Plan. But new conditions have arisen since adoption of the Comprbhensive Plan: salmon stocks have bben tistea under ESA, we have new science on the harrrftl effects of stormwatei'runoffand inappropriate shoreline development, and the Corurty has relaxed its rules governing new resort developrient and locdil zoning. All ihese.n-g", require devblopmdnt of a supplemehtal environmental impact analysis to futly address and :' mitigate impaits to sensitive' environdintal featurei:" the Tribe provided detailed mitigation opportunities for County staffio'use to condition any devetopifient r..o*ii6rrdation at elaik plint in'ttre'Ptan; these included' information on Black Point'wetlahii;, potentiat st#dm'i6sfd#ti5n' rr oppii.tiiniiiis, iird landstiiG tiazard areas.'we ricdmfienadO that these'' '' ' miiigatiriri'odr*;rn ititi"i bd fifrkdd to dnfrESSiUiit+'ilop#Aiii' .' ';i 'r';i"i! ;i*iti !t-ej recornmendation to ensure there is adequate environmental protection above and beyond the minimum and inadequate safeguards of the UDC; however, our necommendations were apparently ignored. Once ado,pted, the BSAP formally becomes part of the County's comprehensive plan, which directs day-to-day permitting and planning of County staff. The recommendation for a resort development at Black Point is panicularly inappropriate because it conditions County staff to look favorably on fonhcoming project-level proposals though no analysis of cumulative effects to water quality or fish and wildlife populations has yet been completed. Please remand the Plan to Community Development with the requirement that DCD complete a strpplernental environmental impact analysis. A full EIS would allow area residents, the Tribes, as well as state and federal agencies more opportunity to weigh in on proposed land use proposals and recommend mitigation opportunities. Many of the mitigation opportunities kanscend what is possible or achievable at the individual, project review phase - this includes tools like transferable development rights, which are better implemented at the scale of the Subarea. The seriousness of this matter warrants a serious approach to resolving these problems. Legal challenges have beerr mounted and the issue may have to be resolved in the courts. The Tribe is currently evaluating its optionr#" drafted a letter to the County Commissioners requesting a formal government-to-government meeting on this matter. We want to work through these issues with the County together, in the spirit of cooperation. Please do not ignore us. Thank you.