HomeMy WebLinkAbout026® PORT GAMBLE S'KLALLAM TRIBE
® 31912 Little Boston Road NE Kingston, WA 98346
RECEIVED
December 6, 2007
Board of'County Commissioners DEC 0 7 2007
Jefferson County JEFFERSON
P.O. Box 1220GOUN'
Port Townsend, WA 98368 COMMISSIONERS
To Whom It May Concern:
Comments regarding the Master Planned Resort (MPR) in Brinnon, WA (MLA06-87)
Comprehensive Plan Amendment
The S'Klallam Tribes and the Lower Elwha Klallam Tribe maintain a special interest in
the Brinnon area as the Tribes depend on local fish, shellfish, and wildlife resources for
their cultural and economic well-being. Tidelands harbor commercially -significant
shellfish populations, and the Dosewallips and Duckabush rivers and their deltas serve as
critical habitat for threatened salmon, and the entire area hosts a diversity of other
important fish and wildlife populations valued by the Tribe and local residents.
It is the Tribes position that the Final Environmental Impact Statement produced by the
Jefferson County Department of Community Development does not accurately address
concerns regarding shellfish resource impacts, transportation impacts, fish and wildlife
impacts, nor impacts to the rural character of the Brinnon area. The FEIS document
commonly asserts the notion that environmental impacts outside of the project's physical
borders are somehow not necessarily connected to the MPR and are therefore given little
or no weight in the text of this document. The narrow scope of this document is more
suited towards a project specific action as opposed to a request for a comprehensive plan
amendment.
It is the Tribes request that the Board of County commissioners ask staff at DCD to
revisit the environmental impacts associated with redesignation of lands within the
Brinnon area from rural to urban (i.e. dramatically increasing the human population
density) this fundamental question is lacking in the current FEIS.
The tribe is particularly concerned about what effects urbanization_ will have on the
following natural resources within the Brennan area.
The Duckabush shellfish bed which is the most productive shellfish bed in east
Jefferson County: approximately 95,000 pounds of allowable annual harvest
(state and tribal share)
(360) 297-2646 (360) 478-4583 (206) 464-7281 (360) 297-7097
Kingston Bremerton Seattle Fax
® PORT GAMBLE S'KLALLAM TRIBE
31912 Little Boston Road NE • Kingston, WA 98346
The two Elk herds of approximately 100 animals each: (see letter from Point No
Point Treaty Council, wildlife biologist)
The presence of three listed salmon species (Puget Sound Chinook Salmon, Hood
Canal Summer Chum Salmon, and Puget Sound Steelhead) as well as strong
populations of Coho Salmon and Fall Chum Salmon. (The impacts that the
proposed comprehensive plan amendment may have on these listed species should
not be taken lightly.)
The Geoduck Tract: number 22700: name Duckabush: Estimated Population
92,000
Finally the Port Gamble S'Klallam Tribe strongly contends (based on the lack of
information provided in the FEIS) that the proposed comprehensive plan amendment /
MPR is fundamentally incompatible with the continued viability of the vast natural
resources found within the project's vicinity.
Attached are documents that support the Tribes Position.
Attached documents included:
Technical document assessing the impacts of urbanization on shellfish growing
areas in the Puget Sound.
Coastal Atlas Map showing the commercial shellfish closure caused by the Port
Ludlow MPR in Jefferson County
Coastal Atlas Map showing the Approved commercial shellfish beds around the
proposed MPR and area closed by current development of Pleasant Harbor.
Recent article describing the impacts of copper from automobiles on juvenile
salmon
Selected pages from the state of Washington 2002 Geoduck Atlas
Thank you for your consideration.
Since5ely
Hans Daubenberg
Habitat Biologist
360-297-6289
(360) 297-2646 (360) 478-4583 (206) 464-7281 (360) 297-7097
Kingston Bremerton Seattle Fax