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HomeMy WebLinkAbout011JEFFERSON COUNTY DEPARTMENT OF COMMUNITY DEVELOPMENT 621 Sheridan Street • Port Townsend • Washington 98368 360/379-4450 • 360/379-4451 Fax www.co.jefferson.wa.us/commdevelopment Garth Mann, President June 13, 2006 Statesman Group, Inc. 7370 Sierra Morena Blvd. Southwest Calgary, Alberta T3H 4H9 CANADA Dear Mr. Mann: Re: Overview of Comments on the Scope of MLA06-87, Master Planned Resort in Pleasant Harbor and Black Point. As lead agency for the Environmental Impact Statement (EIS), Jefferson County received comments from residents, property owners, tribes, government agencies and non-profit organizations to narrow the scope of the EIS to the probable significant adverse impacts and reasonable alternatives, including mitigation measures. Public comment and interagency cooperation was sought through legal notice, a public workshop in accordance with Jefferson County Code (JCC) 18.45.060 (2) and optional expanded scoping as outlined in Washington Administrative Code (WAC) 197-11-410. The county website was updated regularly with information about the Master Planned Resort, MLA06-87, and included a videotape of the March 15, 2006 public workshop where the project proponents addressed the Board of County Commissioners and the Planning Commission as well as answered questions from the public. Fliers were distributed throughout the county and feature articles were written in advance of a public hearing on May 8, 2006 where, in accordance with (WAC) 197-11-410 (b) (f), agencies, tribes and the public were invited to review and comment on the scope of the MPR designation and related project environmental impact of three proposed alternatives, as follows: (1) NO ACTION - no government action, the proposal does not occur; (2) ALTERNATIVE 1 - The proposal from Statesman Group of Companies; and (3) ALTERNATIVE 2- The conceptual MPR as described in the 2002 Brinnon Sub Area Plan. While the majority of the comments were specific to `Elements of the Environment' as outlined in WAC 197-11-444, many public comments were also received about the project's impact on income and wages in Brinnon and Jefferson County. In accordance with WAC 197-11-448, these latter elements, hereinafter referred to as `social policy analysis,' are expressly excluded from this EIS, as the State Environmental Policy Act (SEPA) contemplates that these general welfare, social, economic, and other requirements will be taken into account in weighing and balancing alternatives. In making final decisions, the EIS shall not be the sole decision making document. Jefferson County has determined that the proposal has potential for probable significant adverse impacts (PSAI) to `Elements of the Environment' in nine (9) areas, as follows: (1) Shellfish, (2) Water, (3) Transportation, (4) Public Services, (5) Shorelines, (6) Fish and Wildlife, (7) Rural Character/Population, (8) Archeological and Cultural Resources, and (9) Critical Areas. A significant adverse impact could result from an impact whose magnitude would be severe, even if its likelihood is not great, from the cumulative effect of several marginal impacts and other threshold determinants. Each `Element of the Environment' where the potential for significant impacts exists is further divided into subcategories that were identified by a review of the comment letters, the `best available science' and other similar projects. With respect to PSAI (1), shellfish, Jefferson County has received agency, tribe and public comment indicating that (3) three subcategories need further investigation. First, the Department of Health indicates that increased vessel operation in Pleasant Harbor could result in an increased closure to shellfish harvesting in the immediate surrounding area. Additionally, if an expanded closure surrounding Black Point impacts the shellfish industry, these impacts need to be quantified within a range of values and mitigation of this expanded closure addressed. Second, a newly found invasive species, truncates, could be spread by increased vessel traffic. To reduce the potential that Pleasant Harbor will be the catalyst for a rapid bloom of trunicates on site, having specific, localized impacts on the shellfish in Black Point and Pleasant Harbor, analysis must be done to determine mitigation measures. Finally, since impacts to shellfish due to declining water quality, as outlined below in PSAI (2), could have direct, indirect and cumulative impacts leading or contributing to a condition known as hypoxia, the flow of nutrients into the canal and harbor need further analysis. With respect to PSAI (2), water, (7) subcategories need to be analyzed in the environmental impact statement, including (a) sewer service, (b) rainwater harvesting, (c) water quality, (d) groundwater, including saltwater intrusion, (e) water rights and (f) surface water. There is a concern that water used on the golf course and stored within natural depressions, hereinafter referred to as kettles, may adversely impact natural resources through overland and/or sub -surface movement of nutrients into Pleasant Harbor and/or the Hood Canal. Sufficient analysis will need to be performed to determine the extent of impacts, if any, and the direct, indirect and cumulative impact of nutrient loading in Pleasant Harbor and Hood Canal whether by seeps, stormwater or any other terrestrial and/or sub -surface, cross -gradient flow. (a) The sewer treatment facility of the existing Recreation Vehicle (RV) facility does not appear to have been permitted and would likely need to be replaced. An attached video prepared by public works illustrates a sewer system feasibility approach for small communities such as the Irondale and Port Hadlock area. Any sewer system must employ the `best available science' as demonstrated therein. With respect to PSAI (3), transportation, (5) five subcategories need to be analyzed, including (a) Highway 101 and the county road(s), (b) internal circulation, (c) access to and movement within the marina, (d) pedestrian circulation, and (e) bike movement. A Traffic Impact Analysis and investigations must be completed, as outlined by the Jefferson County Department of Public Works in accordance with the standards of the Washington State Department of Transportation. With respect to PSAI (4), public services, (3) three subcategories need further review, as follows: (a) fire, (b) police, and (c) schools. Included in these areas are concerns related to rescue services, tax burden, and health services. With respect to PSAI (5), shorelines, (4) four subcategories were discussed within the comment letters, including; (a) stormwater, (b) shellfish, (c) surface water, and (d) public access. Not mentioned in any other PSIA is subcategory (d) access, which includes access to and from the shorelines for the general public and the residents of the Master Planned Resort. In accordance with the Shoreline Management Act, key areas to investigate include not only how access to the shorelines will be impacted for use by MPR guests, users and 2 owners, but also the general public. Direct, indirect and cumulative impacts on access to the shorelines, with particular emphasis upon the shorelines and estuaries of the Hood Canal, shall be fully explored in accordance with the Shoreline Management Act. In accordance with the May 16, 2005 designation of watersheds draining into Hood Canal as within an `aquatic rehabilitation zone' and codified by law in Washington State as Senate House Bill 2081, the Hood Canal's shorelines are especially significant. The interplay between this project and PSAI (1), shellfish, including but not limited to the economic health of the shellfish industry and PSAI (5), shorelines, shall be investigated. Although subcategories (a), stormwater and (c) surface water have already been listed as subcategories within PSAI (2), water, the direct, indirect and cumulative impact of all waters, including but not limited to storm and surface water, on shorelines needs extensive investigation through modeling, geotechnical rendering and any other tools designated as the `best available science'. With respect to PSIA (6), Fish and Wildlife, the EIS shall investigate impact on species listed in accordance with the Endangered Species Act (ESA). To protect the values and functions of fish and wildlife, critical habitat for species, including but not limited to ESA listed endangered or threatened species, shall be investigated through updated stream typing, migratory and resident corridors analysis and evaluation of the conversion of land to a non -forestry use through a Construction Stormwater Pollution Prevention Plan (CSWPPP). Additional emphasis shall be placed upon land clearing techniques that impact species of the region, including but not limited to rare plants and insects, seals, stickleback bull frogs, dahl's porpoise eagles, elk, osprey, bears, shrimp, geoduck, clams, oysters, deer, salmon, and orcas. With respect to PSIA (7), Rural Character/Population, comments were received within (3) three principal subcategories, as follows: (a) the scope and intensity of the proposal, and (b) the potential for rural to urban conversion, and (c) Housing. Conversion from rural to urban shall be investigated within the local area, Brinnon and the region, with specific emphasis upon the Duckabush and Dosewallips river valleys. In accordance with the potential for increased growth within the region, the project shall investigate the direct, indirect and cumulative impacts of the proposed alternatives on population, the rural character, and housing density, mix (retail, professional, auto, maritime, etc.) and rental affordability. This is particularly important given the general incomes within the region and the current availability of affordable housing within the Brinnon Sub Area for the larger region. As the most current census data available is from 2000, the EIS shall include supplemental information from other sources to develop more accurate tools of analysis, including but not limited to the Washington State Department of Transportation count data, National and State park visitation records compiled in anticipation of a new National Forest Plan and job employment data. With respect to PSIA (8), Archeological and Cultural Resources, the draft EIS shall explore the potential for significant adverse impacts on local historic resources, including tribal artifacts, through closely associated planning with the tribes and site analysis. With respect to PSIA (9), Critical Areas, the draft EIS shall review the potential of significant adverse impact of the proposed alternatives on critical areas as defined in RCW 36.70A.030. "Critical areas" include the following areas and ecosystems: (a) Wetlands; (b) areas with a critical recharging effect on aquifers used for potable water; (c) fish and wildlife habitat conservation areas; (d) frequently flooded areas; and (e) geologically hazardous areas. 3 MITIGATION Mitigation for impacts to `Elements of the Environment' in each of the nine PSIA (9) areas shall outline measures that will reduce or eliminate the adverse environmental impacts of the proposed alternative. The mitigation measure shall include a discussion of the uncertainties, if technical feasibility, economic practicality or the science is uncertain. Mandatory mitigation is expected for impacts to all of the areas identified, including; (1) Shellfish, (2) Water, (3) Transportation, (4) Public Services, (5) Shorelines, (6) Fish and Wildlife, (7) Rural Character/Population, (8) Archeological and Cultural Resources, and (9) Critical Areas Very truly yours, Brent Butler, Lead Planner, Pleasant Harbor MPR Cep_ Stacie Hoskins, SEPA Responsible Official Attachment: Computer Disc of Sewer Planning Video cc: Al Scalf, Director of Community Development Frank Gifford, Director of Public Works m