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December 9, 2007
Point No Point Treaty Council
Port Gamble S'Klallam • Jamestown S'Klallam
7999 N.E. Salish Lane • Kingston, WA 98346 • 360-297-3422
Jefferson County Board of Commissioners
Jefferson County Courthouse
PO Box 1220
1820 Jefferson St.
Port Townsend, WA 98368
Dear Sirs:
The Point No Point Treaty Council (PNPTC) is writing to express our concerns about the
potential impacts of the proposed Brinnon Master Planned Resort on culturally important elk
herds in the Duckabush and Dosewallips River Valleys. The PNPTC is a natural resource
management organization formed in 1974 to serve the Port Gamble S'Klallam, Jamestown
S'Klallam and Lower Elwha Klallam Tribes to fulfill the requirements placed upon them by the
U.S. Supreme Court in U.S. v. Washington (the "Boldt Decision"). The Treaty Council confirms
the reserved rights established in the 1855 Treaty of Point No Point and implements goals set by
member Tribes for resource conservation, management, and the protection of treaty rights.
It is our opinion that the Final Environmental Impact Statement (FEIS) contains errors, and does
not adequately address the potential adverse impacts that the planned Pleasant Harbor Marina
and Golf Resort will have on our elk herds. Consequently, we cannot support your proposed site-
specific Comprehensive Plan amendment. Our concerns are twofold. First, we believe the FEIS
vastly underestimates the potential for increased loss of elk by vehicle collisions resulting from
increased traffic on U.S. Highway 101. Second, the FEIS fails to address the potential conflicts
that will occur if and when foraging elk damage high-value landscaping (such as a golf course).
Our fear is that this will lead to increased demands to control elk damage by lethal removal of
animals from the population.
The FEIS (p. 5-21) cites a conversation with Greg Shirato of the Washington Department of Fish
and Wildlife, who stated there are no tracking data indicating elk use of the Black Point area. Mr.
Shirato is correct, but the consultant asked him the wrong question. A more appropriate question
would have been: Will the elk cross the highway and use the project area as development
proceeds?
It cannot be assumed that the current level of elk use of Black Point is a reliable indicator of
future use. Our experience suggests that elk use of Black Point is currently low because most of
the site is occupied by second -growth closed -canopy coniferous forest, a habitat type that
characteristically produces low quality and quantity elk forage. As the habitat changes due to the
construction of the golf course and the development of lawns and other open areas, the site will
become more attractive to elk. Elk are opportunistic feeders, and are particularly fond of open
areas with rich, abundant grass, particularly in the spring when the grassy areas are greening up.
The FEIS suggests that there will be an ample supply of such areas east of the highway. If it can
be assumed that the "pervious" areas referred to in Figure 1-6 will be mostly lawns and other
non -forested areas, it appears that more than 100 acres of new areas with suitable elk forage will
result from the golf course and resort development.
We also know that elk occasionally wander outside their established home ranges in search of
new feeding areas. This is documented by radio -telemetry studies of elk herds on the Olympic
Peninsula. Our most recent telemetry data, obtained in the year 2000, show at least eight
occurrences of radio -tagged elk in T25N, R2W, S16, immediately adjacent to Black Point. On
October 30 of this year, we counted 27 elk from the Duckabush herd in this section, less than 0.6
miles from Black Point. On several occasions in the past, we have observed elk in the extreme
southeast corner of Section 16, east of U.S. 101. Given these circumstances, there is a high
probability that the Duckabush herd will easily make the transition to foraging east of U.S. 101
on the project site.
Section 3.7.3 of the FEIS appears to suggest that the low level of elk use of Black Point is due to
the presence of the highway. This is erroneous. It is highly unlikely that the highway or the
topography act as barriers to elk movement. Our experience with the Dungeness elk herd near
Sequim has shown that elk will readily cross a major highway to gain access to good foraging
habitat, even if that habitat is in a densely populated residential area. As noted above, it is much
more likely that the current low quality of the foraging habitat on Black Point is responsible for
the currently low level of elk use in that area.
The new resort will generate 4,100 new vehicle trips per day, at least doubling the current traffic
volume. This, in conjunction with the increased probability of elk crossing the highway, will
vastly increase the risk of vehicle collisions. Elk are an important food and ceremonial resource
for the S'Klallam Tribes. Every elk removed from the population by vehicle collisions is an elk
that cannot serve the ceremonial and subsistence needs of tribal members. We believe that
Jefferson County and the resort developer must do a better job in assessing and mitigating the
increased risk to elk resulting from the planned resort development before the Comprehensive
Plan amendment is adopted.
Likewise, we feel that the failure to address the potential conflicts between elk foraging and golf
course/residential landscape management also puts the elk herd at risk. We do not support, and
cannot accept, lethal control to reduce property damage caused by elk. If your amendment is to
be adopted, and the MPR approved, Jefferson County should adopt safeguards to ensure the
S'Klallam people that their wildlife resources will not be diminished to accommodate golf
course management.
Respectfully,
Tim Cullinan
Wildlife Program Coordinator
cc: Randy Harder, Scott Chitwood, Paul McCollum