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Home My WebLink About009PORT GAMBLE S'KL_ALLAM TRME 31912 Litrlo Basion Road NE K�gsYnn,- WA 98346 (360) 20--2646 FAX (360) 297-7097 May 19, 2006 3'effesson County Dept, of Community Development ATTN:' Brent Butler ' 621 Sheridan Street Part Townsend, WA 9835$ RE: 2006 Camp Plan •Amendmeiat MLA06,00087 MAsfer Plsr"a Resort: m Srinnon Dear W. Butler.. . Y .rd .t�ik'i Thank you for the opportunity to comment on the scope of aa EIS for a proposed master planned resort (AMR) at Black PobOkasant Harbor in Brinnon. The Port Gamble S'1 TWIM Tn'bir, MaWains a special. Wero,ia the Mmaon area as the Tribe depends on local fish, shellfish, and wildlife mources for its cultural and economic well beiag. Tidelands limbar. cvam =ialiy signifCWA shefth populations, and the Dosewallxps and Duch rivers and their deltas' serve as aftM habitat for tlnmt=d salmon, and the entire aroma hostsa, &mrssity of afhex imaportaW fish and wildlife populations valued by the Tribe and i=a residents. Past hahritai Ioss and degradown stemming from poor. development standards and dmructive W use praactices has rwcxlted in closure of sshoMh harvest amus and dmeAc salmon population declines, thaeby jeopardizing our Tn�be's courtaffirmed peaty rights to fish and hunt This scoping Pirie is an important opportwity' for the project proparmm and Jefferson County DCD staff tO_ hear about issues of cmern by acted paw, in order to ensure the scope of the M is comprcheuszvc: Tho Port Cxamble SMaam Tribe steres coRcerns outlinW by WDFW biolo'gist Ted Davis in his leiter dated may 17, 2006, which we incorporate by reference, la addition, we detail our concerns with: the development Size and scope, hydrogeology and water demand int motion mss, golf course managemeW, wastewater and stormwater trent, incomplete LSA maps, and wildlife habitat conserya tion seeds. _ Finally, we highlight mitiga&n vpporiunWes tlurt slavuld be caasidercd as part of the MPR desigmtion process. Development Size and Scope -- We are concemed with the size and scope ofthe development proposed by the Statesman Co oration at Black Point/Pl xP . easant �Tsxbar. This issue is iMPIDAOnt to the Tribes and others since increased traffic and isi3:v,�•.��,�� moi`=r_:. land use will have delOerious'impacts on the areas fish, shellfrslr, and wildlife resources. 'The Stern Corporations pre&ared •alterrratme goes beyond what was envisioxted by the 2002 nrmnon• Subwta Plan,. As a result, the Tn-be expects a more thmugh and detailed as=umnt of impam under the Ems. .Hydrogeolo_ gy k1wag4tion — Given that Black Poid is a vn"al island, azo .l.9 -hale golf course and 1090 -unit rondo writ are pr+opased, and the site includes a susceptible aquifer rmharge area, the poteDUW impacts to locW groundwater, AM= flows,- and Wetland geology are veay significant. We are encouraged W the Sa Corporation is proposing mkmwcr harvesting, waxer conservation de sign measures, and mimimkl, irrigadzon, . HOwever, these efforts do hoot. •eliminate the need for u cOreU hydmgeological clysis as part of the HIS. to assm certain•watear nmoff changes and its acct an sensitive on~ sod off -side resources. We request tW the pro ed proponent assemble WDDE and Jefferson County Depa�&'ofEumomeaW Health midential well log -Mfbnjon to characterize the area's hydrogeology. This information could then lie used as inputs fear ai three- d mOnsional groundwater #vw model to ams= impacts from water extraction sand . grotmdwater c OgUmI ud inn OfOrn golf course management practices) on sin and wWaW hydrology, water quality, and seawater intrusion We expect that Black Point neighip rs might also be h7Wre ged in such an analysis, given the rntmber oftesidemial Wells fringing the proposed development, and Je$kson CaMty's existing designation of Black Point as vulnerable for s aneawater iniruszintrusion.'This analysis should be completed as part of the EIS. Water Demartd'Cakudata'arts •-- Mom information is needed on water demand.ofthe Proposed development, a W on contingencies if and when water fromthe three wells is deemod insufficient.- We expect the IIS will detail these calculations in manmer that can be easily evaluated by non-technical, reviewer. Please also detad the Yoe W6n of these •wells and'how any hydrology impacts from the dvwlGPnX-Vt could toms romise filen long -team viability. GoY"Cow* ManagemeW and `Cerdtflcation' -- State== Corpoxation'Proposes to certify their golf cow under the Audubon WematQmal's (,Ai) cexifficatinn proems, However, it is iWpori w t to note that this group is not mociated with. the National Audubon Society,'anzd is widely -perceived as an Wdustry► led certficativA garoup, Thme is IitIle intimmation publicly' available about the kation prod, and what standards or benchmarks aro 1vHawa The ETS should-deteil the -specific manage ant gra &,m the State sin n Corparadon ProPoWS to foltow, rather than, make assaremm about Al certificatiom 'Several c oMnMa qes have required new golf courge caonsftuetion follow Ax's Signem Golf MAY 23 7 . program, which may be an optioir for Black Point. It is not clear fromtine SU-esman Acmiornbon's proicet.lfterafiare if this specifc,progma velli W followed, or if they v seek certification after coon _ "J:.: 1.1 . W"tewater T-eatrtte4 StarrrrwaW, and WaAT Qudd&y Protection - Cif arming the Tribe's cOneerns with a Black Poin$ MPR are potential -water quality impacts, which could have deleterious impacts to nearby shellfish beds or could worsen ephaphiration problems in Hood Canal. R&crse.osmosis waAewerter itealmenf has been rTmentioned by tice Statesman Corporation add We' agree �thaf this te&nalogy offers much promise due to the technology's ability for blanket removal of horrnon�, p�utic�ls, and othtr nutrier is and contam� in addition to dissolved phrogen. However, the technology Also results in the creation ofa concentrated brine., of w ants and nutrients.tbid must be PjropearXy disposed o£ Tbe,EIS needs to detail.where'acrd how this byproduct ,will be disposed of to ensure -it does not reach the waters of Hood CAwI. The Sta#esmau Cakpcirtion prcipcass lining theproject site's natural kettle ponds to receive and store stormwater xmmoff as pari oftheir water conservation and reuse scheme. However; it is unknown if'this practice would be allowable under state law since -'to my knowledge - none of these ponds have ever had biological inventories to determine if tboy harbor ram, threawned, or endangered species. 'These rare, steep-szded keitle.ponds represent a regionally unusual biole al community tyke and ere important habitat; for naWe amps PoPulaftons, since they are completely isolated from f>sb-bearwg' mss. As part ofthe proponent's wetland inventory, these ponds should be surveyed ' for amphibian species under the EIS development process. Details on measures to protect wetland hyortropmod add water quality sbould also be onilined in the EIS. Black POi& ESA his 7rtwmplete -- The environmentally sensitive area (ESA) nWs posted nn Jefferson. Courcy DCWs website (accessed May 18, 2006) enfWed-w4ter" (deporting streaans, wetlands, floodplains, and Nuifer recharge areas) and "Geology" (depicting landslide, erosion, and sei snnze haza *) are i ncor ect. In previous - con wuuications to Je#Tcrwn County, the Port Gamble S'KWh m Tribe has asked the County to correct and update this khrmation. It is unfortunate the Cauttty has now chosen to post this incozrect information on their website which only serves to confuse and mislead the public about the environmental suitability of Bla+ek Point for MPR development. In a December 21, 2001 joint SEPA comment letter from Point No Point Treaty Council, Jamestown S'KhMam, Port Gamble SXlallam, and Skokomish t r bes, we highli&ed the preseaoe of numerous sensitive environmental feahm that would be degmded by resort development including unique kettle ponds and mis-typed streams. This miudes stream incorrectly ravPed as non-R&bmring, which are &cus%swd in the May 17, 2005 WDFW letter. In separate Sriaaon Saba= Plan meetings, we have also requested that the County update itis landslide hazmrd mappiimtg to include new maps available from the Stam (httpJlwww.dnr.wa gowld rnedtnaps�. The WDNR fandslidc hazard zone maps depict steep, unstable slopes fringing the Black Point kettle ponds, which me missed in TefT son County's landslide hazard zone map. MAY 23 2W, We now formally request'that the Germy update- its ESA maps to r6f[eath*otrqeg#mt of sensitive resources at Blmek Point, before developrra c>at of the MPR ELS. A -sit ` with WDFW and Trmal. would likely help � �ohrtion ofthes� issues. These issues are important to the scope ofthe EIS and relevemt-to the proposed development, since they affect the type and intensity of development allowed under the County's development Code. Fish'and W7Y 4 t fe Habitat Conwvatinn and TDR — At Maeeh 15, 2006 mfarmational. M&CS09, J6%rspn Court+DDCD staf ..ioned the County's now Transfer of Development Rijbis (TDR) program as a potential. mechanism, for use, wg* h the MSR. designation. However, the TDR program will not be adopted in#il at lit DecenAwr . 2006 when MPR approval is expealed. How does the County reasonably expect to implement an infant TDR program at Black Paint to mitigato for wildlife habitat loss? A .fra.nactional TDR program Gould leverage the additionaz residential density awarded ate. Black Point MPR site, fez More effective.wildlifie habiw conservationoff--site. For examale, the forested uphMJ4 to the nom of Black Point represent an Opoxtanx elk: migration corridor between the Dosewallips and Duckabush rya valleys: , In addition, tyre are numerous undeveloped rural residential properties in tbo.posowddi s and Da&abush river bottvmlamds with high habitat conservation value. - With resort development at Black Point, the will be ivareas:rng pressure to develop !wiry view homes close by, and these important areas will be put at Wised risk-of'habM lossldegradatiom However, a f nctional TDR program does not eA94 and will not eidg* before MPR approval. Therefore the County and proponent need to consider alternative. measures to protcCt these important aeac'by elk migration corridors and river. bott6mfland environments the# w,iil be indirectly threatened by development of the MPR :Groom zoning on,d= lands include a mix afrural residential (I du15 ac, and 1 du/20 ac) and commercial forestlauds on which pmmwment conservation casements should be secured.. We ask that you consider and outline these options under the EIS: We acknowledge tat. only easements from'willimg se}m could be semavd. HowevCr, rrevent cooperative efforts between the County, Jefferson Land Trust, and properly owners on the lower.' Dosewallips River demonstrate that such willing landowners exist in the area. Mtigation apportwdeiu — Even a well-planned MPR development at Black' PoWPleasant Harbor will lead to certain umvoidablo harmful impacts to regionally - significant fish and wildlife populations. Ackno,w'ledgmg this tact, the Trine would like to outImo habitat mitigatiOn oppo-r AM ics at Black Point d* could be linked to any formal approval for resort development. We have already detaited one option, pe-mamnt conservation casements on adjacent rural residential leads TWO dreams at Slack Point have fish -blocking culverts which should be, repaired as part Of Mit�igativn for an MPR development. This include two culverts en the ummmed, mis- Wed stream dreGining to the southwest Comer of PlmquA Harbor (referenced in the May d 7�0� . Wim. Ju additiop, a Im V, pie W tkm compdax (fed by sftms $ from thp south) is. bixrod by read- fill adjacent to the Inge ke gond on the side of BIaek Point (With n � wart Connection to flood Caziai}.; Thome crossiMr are off the subject pmpertp glateci fir development battbeir would sego as an, excellent mitipgon opporhmrty. x'bank you for your consideration of these mfrs. - MAY Ted Labbe .;r:,s: : .,:,�., • mac $loIo 30.297-6299 - t.��stnsr<.us Chervi Halvorson From., Tad LAbbe (t6abbe ugpgst.nsn.usj { •Sent: Sunday, May 21; 2006 7:36 PM - To: #Planning Department) Doug Peters (E-mail); Jeff Davis; gh m48'i aey.wa gav; John Carn0allk (E-rno; Aatnufmp0dfW.wa.gov; bymecjb@dfw-wa.gov; many skofcomisi�.org; Byron. Rot; Mike McHenry; sharon purser, Marie Hebert; LaudO Mattson .� Subject: PGST Black Point BIS scaping commerrfs 5-19-M awk ° Pt-Pleaswt •Hatb... Brent: -Attached are our Comments on the Black Paint/Pleasant Harbor BIS.:, .Written comments were mailed on Friday.' Sorryjor the delay. -Teti Ted Labbe' Habitat Biola gist Port . Gamble S' K]:allam Tribe Natural Resources Dept. 31912 Little Boston Rd Kingston, YEA 983+16 PH:' 360-297-6289 FAX: 360-297-9791 "Dei5nders of the short-sighted men who in their greed and selfishness will, if permitted, rob our country of half its charm by their' reokless extermination of all useful and beautiful wild things aMetia►es seek to champion them by saying that 'the game belongs to the people.' so it does; and not mare -1,Y to the, people now alive, but to the unborn people, The 'greatest good for the greatest ndiaber' applies to the number within the womb 'of time, compared to -which those now alive form but an Insignificant fraction. Our duty to, the zvhols,-including.the unborn.generations, bids us restrain an unprincipled present-day min6rity.from wasting the heritage of these unborn generations. The movement for the conservation of wild, life and the larger•movement for the conservation of all our natural resources are essentially democratic tri spirit, purpose, and method." Theodore Roosevelt, 1916 i i