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HomeMy WebLinkAbout055Port Gamble S'Klallam Tribe Point No Point Council Jamestown S'Klallam Tribe November 24 ,2009 David Wayne Johnson Jefferson County Dept. of Community Development 621 Sheridan Street Port Townsend, WA 98368 / )l) )lI Brinnon MPR Scoping Comments Dear David Johnson, The Port Gamble S'Klallam and Jamestown S'Klallam Tribes, and the Point no Point Treaty Council appreciate this opportunity to provide scoping comments on the Supplemental EIS (SEIS) for the Brinnon Master Planned Resort (MPR). However, the S'Klallam Tribes have not been involved in the planning process since we participated in developing the 30 ordinances adopted by the Jefferson County Board of Commissioners in 2008. We fully expected the project proponent would be required to work with us. It seems only one Tribe, out ofthe four that have interest in the project, has been approached and included in the planning activities. This is not acceptable. The MPR is located within the S'Klallam Usual and Accustomed Area (U&A) and there will be impacts to our treaty resources as well as disturbances to potential cultural resources. Not only are the surrounding waters and land historically important to the S'Klallam Tribes, but the Hood Canal and the fertile beaches of the Duckabush River estuary remain crucial to our tribal members for finfish and shellfish harvesting. Currently we do not support any of the plan alternatives. We strongly suggest the project proponent adhere to provisions of the new SMP, including shoreline buffer protections, and wetland protections under the County's current (2008) critical area ordinance (CAO). It is well known that the project location is near, and in some cases incorporates, important habitat types. The protection of such critical areas should be a top priority. For example, the kettle ponds and their riparian areas are unique ecological features necessary to support species diversity for amphibians and birds, and serve as natural aquifer recharge and storage. These wetlands should not be filled, lined and used as engineered re-circulating systems, but rather they could serve as amenities to the project primarily for passive recreational purposes. The native riparian vegetated buffers surrounding these kettle ponds should be protected in accordance with the current County CAO. Native vegetated buffers should also be retained along the marine shoreline feeder bluffs along the south shore of Black Point. These bluffs naturally erode over time and vegetated buffers and setbacks must accommodate long-term rates of erosion to protect their function as sources of natural sediment and small and large woody debris to the adjacent Duckabush estuary and beaches. While we are I ffrtff$0ll t0uiiTY0[0 aware of Statesmans' efforts to build a "green" project, the overall footprint of this development is large for the small island-like area of Black Point. Pre-existing roads and disturbed areas from previous activities should be utilized as opposed to creating new disturbances to native vegetation and soils. In general, we also favor a plan that maintains larger and contiguous forested patches over a plan that results in small fragments of forest patches. The 30 ordinances adopted by the Jefferson County Board of Commissioners show that various management and monitoring plans are to be developed, and scientific reports conducted as conditions for this proposed development. In some instances, the ordinances state or allude to management plans being created for cultural resources, wildlife, stormwater and mitigation. These actions are necessary and reports should be released to the affected tribes, the public and other agencies for review. For example, it is still unclear where the source of domestic water will come from for this proposed development. The tribes must be involved in discussions of mitigation for project impacts. In general, the tribes support mitigation focused on protection and restoration of watershed and habitat- forming processes, and water quality and species protection and restoration. We do not consider leaving buffers around bluffs and wetlands (which are already requirements of existing code) as mitigation. As suggested in the ordinances, runoff projections and analysis on impacts to the Hood Canal need to be developed, the latter focusing on shellfish, finfish, water quality and habitat impacts. The ordinances call for a County-based comprehensive water quality monitoring plan for Pleasant Harbor. The tribes must review the monitoring plans that are developed as a part of this project. A component of this plan needs to include water quality monitoring of the surrounding beaches including the Duckabush estuary. Overall, the S'Klallam tribes and PNPTC feel there has been a lack of information provided to us on technical reports as well as monitoring and management plans. The tribes often review alltechnical documents related to large scale developments located in our U&A. It is our shared responsibility to protect the Duckabush river corridor and estuary which are critical habitats for ESA summer Chum, Chinook salmon, and Steelhead populations, as well as the surrounding vicinity which is home to an important elk herd for the tribes and the State. We hope that in future planning efforts, all affected tribes are invited to participate in resource management related issues. Sincerely, Paul McCollum, Natural Resources Director Port Gamble S'Klallam Tribe Scott Chitwood, Natural Resources Director Jamestown S'Klallam Tribe f*pru- Kft,fu^ Randy Harder, Executive Director Point no Point Treaty Council 2 Cc: Byron Rot; Habitat Program Manager, Jamestown S'Klallam Tribe Steve Todd; Habitat Biologist, Point No Point Treaty Council Rick Mraz; Wetland Specialist Southwest Region, Dept. of Ecology Alison O'Sullivan; Biologist, Suquamish Tribe Randy Lumper; Environmental Planner, Skokomish Tribe Michael Blanton;Area Watershed Steward, WDFW Margie Bigelow Schirato; Area Habitat Biologist, WDFW J