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Skokomish Indian gibe
TIribal Center (364) 426-4232
N. 80 Tribal Center Road FAX (360) 877-5943 Skokomish Nation, WA 98584
October 23, 2007
Stacie Hoskins, Planning Manager
Jefferson County Community Development
621 Sheridan Street
Port Townsend WA 98368
RE: Comments on the DEIS for the Pleasant Harbor Marina and Golf Course
Resort Project Proposed at Black Point Near Brinnon by the Statesman
Group, Inc.
Ms. Hoskins,
The Skokomish Department of Natural Resources has reviewed the Draft Environmental
Impact Statement developed for this project and would like to provide the following
comments. Staff also attended a recent site visit with the Statesman Group, Inc., their
consultant and members of the WRIA 16 and 17 Planning Units. During this site visit the
applicant outlined the concepts and development plans for the residential, commercial
aspects of the project.
Early in the planning stages of this proposed development,_Statesman Group, Inc.
officials inet. with Skokomish 'Tribal officials including, Planning, Cultural Resources• and
Natural Resources staff. Concerns for cultural issues were expressed during those
meetings as being significant. Restricted or lack of access to traditional use areas as well
as modifications to wetland kettles were of particular concern. The wetland kettles are
thought to be of great cultural significance as identified by tribal Cultural Resources staff.
Comments on the DEIS from the Skokomish Tribe's Cultural Resources Department are
not included in this letter.
Treaty Resources
The primary concern of the Skokomish Natural Resource Department apart from the
obvious cultural resource issues are the potential impacts to the environmental elements
and impacts resulting to treaty resources. Impacts to important environmental; elements
will occur due to the project converting the current land cover and land use within the
project footprint, Current conditions of a low intensity use, rural, sparsely to heavily
wooded coniferous and mixed forest will be replaced by an urban, high to moderate
intensity use, residential and commercial development. Structures on the site built for
human, habitation and recreation as well as the transportation network and landscaping
features will replace much of the current land cover. The current baseline conditions
although modified by previous logging and campground development, still provide
mixed forest habitat with low noise disturbance and are used by wildlife including large
ungulates such as deer and potentially elk. Although Highway 101 at this site does act as
a barrier to frequent migrations of these larger animals, elk in the Dosewallips floodplain
at Brinnon regularly pass across the road on both sides of Highway 101.
Midlife exclusion will be encouraged by the development. Larger mammals such as
deer, elk, will be discouraged of using areas east of Highway 101 and may assist in
predator conflicts with potentially dangerous wildlife such as cougars. Cougar and other
predators will be discouraged as well but they are likely to still utilize habitat within the
proposed development because of other prey species including but limited to
domesticated pets.
The applicant has expressed a willingness to leave as much native forest land cover as
possible, excluding areas needed for building structures, fire suppression and the
transportation system. Especially important is the riparian forest located above Hood
Canal on the steep bluff on the southern portion of the parcel. Riparian buffer setbacks in
this area were expressed during the site visit with the applicant to be a minimum of 200
feet horizontal distance. This portion of the parcel still retains forest and bluff features
and likely providing necessary functions to the marine ecosystem and nearshore areas of
the Duckabush River delta and Hood Canal.
Green development techniques including water conservation measures and energy
efficient building and design features proposed for the development are commendable.
Given the southern exposure of much of the property the applicant may give some
thought to incorporating solar designs into the development plans to reduce and offset
energy costs further.
Another positive aspect of the proposal is that the stormwater management plan for.
clearing and grading assures that the goal of no discharge of contaminates to the waters
of Hood Canal or Pleasant Harbor is achieved. In addition the proposal proposes to use
an onsite wastewater treatment reuse and recycling program with no discharge to Hood
Canal for storm and treated waters.
Archeological and Cultural Resources
Tribal access should be maintained to allow traditional uses to continue of the areas
wetlands and natural environments. During earlier meetings within the last year or more
with Statesman Group, Inc. James Mazak and the Skokomish Tribe's Cultural Resources
and Natural Resources Department, discussions centered Tribal concerns. of the proposed
development. Primarily these consisted of loss of traditional tribal access to cultural
properties and activities, impacts to kettle wetlands with high cultural resource values,
and increased land use intensity potentially affected tribal resources of fish, shellfish and
wildlife.
During those meetings, there appeared to be a commitment on behalf of the applicant to
include Tribal cultural resource monitoring plans, access agreements, etc into the overall
l [Manning Process. The Skokomish Department of Natural Resourcesisunaware if any of
AI
these issues have been discussed more recently with the Cultural Resources Department
or other Tribal officials. Similar discussions between the Tribe and the Statesman Group,
Inc, need to take place to consider Tribal concerns raised during those earlier meetings.
The Cultural Resources Assessment by the consulting firm Western Shore Heritage
Services, Inc, was primarily a literature review and no actual field investigations were
conducted as part of the assessment. The consultants recommended that the applicant
engage in consultation with the affected Tribe (Skokomish) and the Washington State
Department of Archaeology and Historic Preservation early in the process, which did
occur to some extent. They recommended archeological investigations and systematic
monitoring of the subject property prior to construction. Discussions and action plans
need to occur prior to construction plans so that adequate time for surveying, monitoring
and assessment can take place.
Additional issues- At the site visit sponsored by the applicant, there appeared to be some
hesitancy on behalf of the PUD staff about what role or services they will be providing
relating to this development.
The size and scope of the Statesman Group, Inc. and the Brinnon MPR proposals are both
of great concern, We understand that an immense amount of effort has gone into the
planning and designing of this MPR to incorporate green building standards, energy and
water use efficiencies and innovated stormwater and sewage facilities. Goals and
objectives of no discharge to critical areas of stormwater and sewage are admirable.
Some of these designs are innovative but they still need to be tested. A strong adaptive
management component needs to include the ability to adapt to results of a well -
structured monitoring plan if it shows that changes are needed,
In closing, we thank you for the opportunity to provide comments on the DEIS,
Comments from our Cultural Resources Department may also be forthcoming. The Tribe
intends to remain engaged with local planning staff, county commissioners and the
applicants and their consultants as this process moves forward. If you have any questions
related to these comments please call me at (360) 877-2110 x504 or email me at
martyO),skokomish.om.
Sincerely,
Marty Ereth
Habitat Biologist
Cc: Denese Laclair - Skokomish Tribal Council Chair
Dave Herrera — Skokomish Fish & Wildlife Policy Representative
Lori Nies- Skokomish Tribal Attorney
Kris Miller-Skokomish Historic Preservation Officer
Jon Wolf — Skokomish Fisheries Manager